A Bulgarian citizen divorces in Germany, the United Kingdom or the United States — and years later discovers that in Bulgaria she is still registered as married. A foreign court awards maintenance or a sum of money against someone whose only assets are in Sofia. In both situations the foreign decision exists, but in Bulgaria it produces effects only once it has been recognised and, where something must be collected or handed over, declared enforceable. Which procedure applies depends above all on where the decision comes from.

Why recognition matters

Until a foreign divorce is recorded in Bulgaria:

• the civil-status registers continue to show the person as married, which blocks remarriage in Bulgaria;
• the former spouse may still appear as a necessary party to property transactions, and questions arise as to whether property acquired after the foreign divorce fell into matrimonial community;
• on death, the former spouse may still be listed as an heir in the certificate of heirs;
• a change of family name after divorce cannot be reflected in Bulgarian identity documents.

Most of these problems surface at the worst possible moment — at the notary’s office or after a death. Recording the divorce promptly avoids them.

Divorces from EU member states

Divorces, legal separations and marriage annulments granted in an EU member state (other than Denmark) are recognised in Bulgaria automatically, without any special court procedure. The legal basis is the Brussels IIb Regulation (Regulation (EU) 2019/1111) for proceedings started on or after 1 August 2022, and its predecessor, Brussels IIa, for earlier ones.

In practice, updating the Bulgarian civil-status records requires:

• a copy of the decision that satisfies the conditions for establishing its authenticity;
• the standard certificate issued under the Regulation by the court that granted the divorce, confirming among other things that the decision is final;
• certified Bulgarian translations.

The documents are presented to the municipality where the marriage is registered, and the civil-status officer notes the divorce on the marriage record. No apostille is needed between member states for these documents. The Regulation also covers certain out-of-court divorces — for example those registered by a notary or a civil-status authority — where they are formally drawn up as authentic instruments or registered agreements in the member state of origin.

Recognition may be refused only on narrow grounds, such as a manifest conflict with public policy, a failure to serve a respondent who did not appear, or irreconcilability with another decision between the same parties. The Bulgarian authority may not review whether the foreign court had jurisdiction, nor re-examine the substance.

Divorces from countries outside the EU

For decisions from non-EU countries — including the United Kingdom for proceedings started after the end of the Brexit transition period, the United States, Canada, Australia, Switzerland, Turkey and others — the Bulgarian Private International Law Code applies, unless a bilateral treaty provides otherwise. A foreign judgment is recognised if:

• the foreign court had jurisdiction according to standards corresponding to Bulgarian law;
• the respondent was served with the claim and the parties were properly summoned, and fundamental principles of fair procedure were observed;
• there is no final Bulgarian judgment between the same parties on the same matter;
• no proceedings on the same matter, started earlier, are pending before a Bulgarian court;
• recognition is not contrary to Bulgarian public policy.

The procedure has two tiers. In the ordinary case, recognition is carried out by the authority before which the judgment is presented — typically the municipal civil-status officer — who checks the conditions and records the divorce. If the authority refuses, or if the conditions are disputed, the interested party brings a claim for recognition before the Sofia City Court.

The documents required are:

• a copy of the judgment certified by the court that issued it;
• a certificate from that court that the judgment has entered into force;
• an apostille on both (or consular legalisation for countries outside the Hague Apostille Convention);
• certified Bulgarian translations.

Typical obstacles

• No proof of finality. Many foreign courts do not routinely issue a separate certificate that the decision is final. It must be requested specifically — for an English divorce, for instance, the final order rather than the conditional order is what counts.
• Default judgments. If the respondent did not take part, proof that he or she was properly served becomes decisive.
• Private and religious divorces. A divorce pronounced without the involvement of a state authority is unlikely to be recognised as a judgment.
• Names. Differences between the transliteration of names in the foreign decision and in Bulgarian documents cause delays and may require additional evidence of identity.

Decisions about children

Decisions on parental responsibility from EU member states are recognised and enforced under Brussels IIb; certain decisions, such as those granting rights of access, benefit from a simplified, privileged regime. For many non-EU countries the 1996 Hague Convention on the protection of children, to which Bulgaria is a party, provides for recognition by operation of law. Because circumstances concerning a child change, the recognising state’s courts may later modify the arrangements if the child has become habitually resident there.

Maintenance

Maintenance decisions from EU member states are enforced under the Maintenance Regulation (Regulation (EC) No 4/2009); for most member states no declaration of enforceability is needed. Outside the EU, the 2007 Hague Convention on the international recovery of child support and the New York Convention of 1956 provide channels through central authorities. A parent abroad who is owed maintenance by a debtor living in Bulgaria therefore rarely needs to start a new case here.

Money judgments and other civil matters

From EU member states

Under the Brussels Ia Regulation (Regulation (EU) No 1215/2012), a judgment in civil and commercial matters given in one member state is enforceable in another without any declaration of enforceability. The creditor obtains a standard certificate from the court of origin and applies directly for enforcement in Bulgaria, where a writ of execution is issued and an enforcement agent is instructed. The debtor may apply for refusal on limited grounds.

From non-EU countries

Enforcing a non-EU money judgment requires a court procedure known as exequatur: a claim before the Sofia City Court for permission to enforce. The court verifies the same conditions as for recognition and does not re-try the dispute; the debtor may, however, raise the defence that the debt has since been extinguished. Once the claim is granted, enforcement proceeds as for a domestic judgment. For some countries the 2019 Hague Judgments Convention, by which the European Union is bound, now offers a treaty framework for civil and commercial judgments; it does not cover family matters.

The reverse case: Bulgarian decisions abroad

The same instruments work in the other direction. A Bulgarian divorce is recognised automatically in other EU member states on the basis of the certificate issued by the Bulgarian court. Outside the EU, recognition depends on the law of the country concerned, usually on presentation of the apostilled decision with a translation.

A practical checklist

• Identify the regime: EU regulation, international convention, bilateral treaty or the Private International Law Code.
• Obtain the right documents from the court of origin — the decision and proof that it is final, or the EU certificate.
• Arrange apostille or legalisation where required, then certified translation in Bulgaria.
• File with the competent municipality for civil-status matters, or with the Sofia City Court where a claim is necessary.
• After recognition, update identity documents and check that the Property Register and civil records reflect the new status.

The whole process can be handled by a lawyer under a power of attorney; the person concerned does not need to come to Bulgaria.

Last reviewed: November 2026. This article provides general information about Bulgarian law and is not legal advice. Every case depends on its own facts and documents.

Need advice on a specific situation? Contact Rositsa Astakova, Attorney-at-Law in Sofia — consultations are available in English, Spanish and Bulgarian, in person or remotely.