Citizenship by investment in 2026: programs, costs, EU pressure

What this covers

Citizenship by investment, often called a golden passport, is a route where a state grants its nationality to a foreign national mainly because they pay into a government fund or make a qualifying investment, such as approved real estate. It differs from naturalization after years of residence and from citizenship by descent. It is also different from a golden visa, which gives a residence permit rather than citizenship. Each program is set by national law and run by a government unit, and the rules, amounts and legal risks change often.

Understand what citizenship by investment is

Citizenship by investment programs grant nationality in return for a payment or investment that the law fixes in advance. The applicant usually does not need years of residence first. That is the main difference from ordinary naturalization, which normally follows a period of lawful residence.

Most programs have a long legal history. The St Kitts and Nevis unit says its program was established in 1984 and now operates under the Citizenship Unit Act 2024. Dominica's unit says its program was introduced in 1993 and rests on Section 101 of the Constitution, Sections 8 and 9 of the Citizenship Act of 1978, and Citizenship by Investment Regulations gazetted on 28 June 2024 as SRO No. 8 of 2024. Grenada's Investment Migration Agency says it was set up in 2014 under the Grenada Citizenship by Investment Act 2013.

Türkiye works differently. Its official investment agency says foreigners who meet one of several investment criteria may acquire citizenship subject to the decision of the President of the Republic, under regulations published in the Official Gazette on 18 September 2018. See Türkiye.

Citizenship by investment is not the same as a residence permit for investors. See golden visas in Europe and the golden visa entry for residence-only routes, the citizenship by investment entry for a short definition, and second citizenship basics and the citizenship flag for the wider picture.

Compare the programs official units list

The table shows the lowest contribution or investment figure each official page listed when checked. Government fees, due diligence fees and amounts for extra family members are charged on top, and they differ by program. The European Commission's December 2025 report says the five Eastern Caribbean countries have harmonized their minimum investment threshold at US$200,000. Programs in other countries exist, but this table covers only the ones checked on their official pages.

Check how due diligence and approval work

Every program says it screens applicants, but the checks differ. The St Kitts and Nevis unit says main applicants and dependants aged 16 or over may need to attend an interview. It also says that from 14 April 2026 people who obtained citizenship through the program, including dependants and children, must enroll in its national biometric and passport program by 31 July 2027. Saint Lucia's unit links its applicant interview and identity verification process to 4 September 2023.

Dominica's 2024 regulations, according to its unit, set minimum investment amounts, the grounds for denial and revocation, and the roles of authorized agents and licensed promoters. Revocation matters. A citizenship granted under a program can come with conditions that allow it to be withdrawn later.

The five Eastern Caribbean states have also agreed to a regional regulator. A Dominica government release dated 2 October 2025 says the Eastern Caribbean Citizenship by Investment Regulatory Authority is meant to set and enforce common standards, oversee agents, developers, promoters and due diligence providers, and support a regional applicant database. Grenada's agency published a release on 22 September 2026 saying it had commissioned an independent review of its program.

The European Commission remains critical. Its December 2025 report gives 2024 rejection rates of 1.7% in Antigua and Barbuda, 5.3% in Saint Lucia and 6.5% in Dominica, and says these raise concerns about the adequacy of security and due diligence procedures.

Know how the EU treats investor citizenship in visa-free countries

For many applicants, the value of these passports has rested on visa-free short stays in the Schengen area. That access is now under direct pressure. The European Parliament approved a revised visa suspension mechanism on 7 October 2025 that adds investor citizenship schemes as a new ground for suspending visa-free travel.

The Commission's Eighth Report under the Visa Suspension Mechanism, dated 19 December 2025, says that under the revised mechanism the operation of such programs constitutes, in itself, a ground for suspending the visa-free status of a third country. It names Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia. It estimates that about 107,000 passports have been issued through their schemes and counts 13,113 applications in 2023 and 10,573 in 2024. It asks these countries to ensure adequate security vetting pending the discontinuation of the schemes.

There is a precedent. The same report notes that Vanuatu was removed from the EU visa-free list in December 2024. The United Kingdom imposed a visa requirement on nationals of Dominica and Vanuatu from 19 July 2023, after a Home Office review found what it called clear and evident abuse of their schemes.

FlagSage did not find an EU act suspending visa-free travel for the five Eastern Caribbean countries when this page was checked. Check the Commission's current position before relying on visa-free access. See the Schengen 90/180 rule and the Schengen calculator for how short stays are counted.

Read what the EU court decided about Malta

On 29 April 2025 the Court of Justice of the EU ruled in Case C-181/23, Commission v Malta, that Malta's 2020 investor citizenship scheme infringed EU law. The court's press release says the scheme amounted to the commercialization of the grant of nationality and, by extension, of EU citizenship.

The court accepted that each member state sets its own nationality rules, but said that power must be used consistently with EU law. It described nationality as based on a specific relationship of solidarity, good faith and reciprocal rights and duties. A member state that grants nationality in direct exchange for predetermined payments or investments breaches those principles and the principle of sincere cooperation.

The Commission had already asked member states in March 2022 to end any investor citizenship schemes immediately. Its December 2025 report adds that candidate countries for EU membership must abolish such schemes. See Malta for the country record, and check current Maltese law for what applies after the judgment.

Know that a passport does not change your tax residence

A new citizenship does not by itself move your tax residence. Most countries tax people by residence, which depends on where you live, your home, your family and your economic interests. Spain's tax agency, for example, says a person can hold a residence permit in a state and still not be tax resident there, and the same logic applies even more strongly to a passport. See tax residence and the 183-day rule.

The United States is the main exception. IRS Publication 54 says the worldwide income of a US citizen is generally subject to US income tax regardless of where they live. A US citizen who buys a second citizenship stays inside the US system. Giving up US citizenship is a separate process with its own tax rules. See US citizens abroad and renouncing US citizenship.

The Commission's report lists tax evasion among the risks it links to these programs. Expect banks and tax authorities to ask where you actually live, not only which passports you hold. Where you live is a living base question, and the United States record covers US rules.

List the questions to settle before applying

Program websites describe benefits. The legal questions sit elsewhere. Work through these with a lawyer who does not earn a commission from the sale.

• Does your current country allow dual citizenship, or would you lose your existing nationality?
• On what grounds can the new citizenship be revoked, and for how long after it is granted?
• What would happen to your travel plans if the EU or another country suspended visa-free access?
• Which fees, due diligence charges and family amounts come on top of the headline contribution?
• Is the agent licensed by the government unit, and is the money paid directly to a government account?
• Where will you actually live, and which country could treat you as tax resident?
• Does the new country impose duties such as military service or passport renewal rules on citizens abroad?

Common misconceptions

Questions to take to a professional

1. Would acquiring this citizenship affect my current citizenship under my home country's law?
2. On what grounds could the new citizenship be revoked, for me or my family?
3. How would a suspension of EU or UK visa-free access affect the reasons I am considering this?
4. What is the full cost, including fees, due diligence and dependants, and is any part refundable if refused?
5. Is the agent authorized by the government unit, and how is the payment protected?
6. Which country will treat me as tax resident after I apply, given where I actually live?
7. What reporting duties would a new citizenship create for me, especially if I am a US citizen?

Questions people ask

Sources

• Citizenship by Investment Unit (St Kitts and Nevis)Official guidance
• Sustainable Island State Contribution (St Kitts and Nevis Citizenship Unit)Official guidance
• Economic Diversification Fund (Dominica Citizenship by Investment Unit)Official guidance
• Legal Basis and Relevant Legislation (Dominica Citizenship by Investment Unit)Primary law
• Becoming a Citizen: fees and costs (Investment Migration Agency Grenada)Official guidance
• Investment Migration Agency GrenadaOfficial guidance
• National Development Fund (Antigua and Barbuda Citizenship by Investment Unit)Official guidance
• Citizenship by Investment options (Saint Lucia Citizenship by Investment Unit)Official guidance
• Acquiring Property and Citizenship (Invest in Türkiye)Official guidance
• Dominica Signs Agreement to Establish Regional CBI Regulatory Authority (Office of the Prime Minister, Dominica)Official guidance
• Eighth Report under the Visa Suspension Mechanism, COM(2025) 792 final (European Commission)Official guidance
• More flexible visa suspension mechanism (European Parliament press release)Official guidance
• Court of Justice of the EU, Press Release No 52/25, Judgment in Case C-181/23 Commission v Malta (Citizenship by investment)Primary law
• Investor Citizenship Schemes (European Commission)Official guidance
• Commission urges Member States to act on golden passports and golden residence permits schemes (28 March 2022)Official guidance
• Explanatory memorandum to the statement of changes in Immigration Rules: HC 1715, 19 July 2023 (GOV.UK)Official guidance
• Agencia Tributaria: Persona física residente en EspañaOfficial guidance
• Publication 54, Tax Guide for U.S. Citizens and Resident Aliens AbroadOfficial guidance