Europe
Citizenship by Investment in Europe and Around the World: Programmes, Costs and Alternatives
Last updated: October 2026
Citizenship by investment allows eligible foreign nationals to apply for citizenship through a qualifying financial contribution, investment or other legally defined route in certain countries. However, Citizenship by Investment in Europe has changed significantly, and investors should not assume that purchasing property or investing in a European country will automatically lead to a passport.
On 29 April 2025, the Court of Justice of the European Union ruled that Malta’s investor-citizenship scheme was contrary to EU law. The judgment established that EU citizenship cannot be granted through a commercial transaction involving predetermined payments or investments without a genuine connection to the country. Investors considering Europe must therefore distinguish direct citizenship programmes from residence-by-investment routes and ordinary naturalisation.
Several countries outside Europe continue to operate citizenship-by-investment programmes, including countries in the Caribbean and Türkiye. These programmes have their own investment thresholds, eligibility requirements, background checks and government fees. The right choice depends on an applicant’s budget, family circumstances, travel needs, long-term plans and willingness to meet the conditions of the relevant country.
This guide explains how citizenship by investment works, which European alternatives investors can consider, how international programmes differ, and what to check before committing significant funds.
Citizenship by investment in Europe: Understand the latest legal developments, explore residency-by-investment alternatives, and compare eligibility requirements, investment costs, and long-term options.
What Is Citizenship by Investment?
Citizenship by investment (CBI) is a legal route through which a country allows eligible foreign nationals to apply for citizenship in return for a qualifying contribution, investment or other prescribed conditions.
Depending on the country and programme, qualifying routes may include:
- A non-refundable contribution to a government development fund.
- An investment in government-approved real estate.
- A qualifying business or capital investment.
- A prescribed job-creation commitment.
- Another investment category expressly recognised by national law.
Citizenship by investment is not simply a property purchase or an ordinary investment visa. Applicants generally have to provide identity and financial records, demonstrate the lawful source of their funds, disclose relevant personal information and pass background checks. Meeting the financial threshold does not necessarily guarantee approval.
The European Commission’s information on investor-citizenship schemes explains the distinction between investor citizenship, sometimes called a “golden passport”, and investor residence, often called a “Golden Visa”. These arrangements can carry significant security, money-laundering, tax-evasion and corruption risks, making due diligence essential.
Citizenship by Investment in Europe: What Has Changed?
Europe has historically attracted international investors through residency programmes, business investment routes and, in a small number of cases, investor-citizenship schemes. The legal landscape has changed, however, and older online lists can be misleading if they present discontinued programmes as available.
Malta: The EU’s landmark ruling
Malta operated an investor-citizenship scheme under which eligible foreign nationals could apply for naturalisation after meeting specified financial and other conditions. On 29 April 2025, the Court of Justice of the European Union ruled that the scheme was contrary to EU law.
According to the Court, a Member State cannot grant its nationality – and the associated status of EU citizenship – in exchange for predetermined payments or investments through a transactional process that lacks the necessary genuine relationship with the country.
Read the Court of Justice of the EU’s official press release on the Malta ruling or the full judgment in Case C-181/23 on EUR-Lex.
For investors, the practical lesson is clear: Malta’s former transactional investor-citizenship scheme should not be presented as an available route to an EU passport. A European residence permit, meanwhile, does not automatically confer citizenship or the full rights associated with EU nationality.
Portugal: Residence by investment, not instant citizenship
Portugal continues to offer an Authorisation of Residence for Investment, commonly known as the ARI or Golden Visa. It provides a residence route for eligible non-EU nationals who meet the programme’s legal requirements.
According to Portugal’s immigration agency, AIMA, qualifying routes include:
- Creating at least 10 jobs, subject to the applicable rules.
- Investing at least €500,000 in eligible scientific research activities.
- Contributing at least €250,000 to qualifying artistic production or the recovery and maintenance of national cultural heritage.
- Investing at least €500,000 in qualifying investment funds that meet the programme’s conditions.
- Making a qualifying capital investment in a Portuguese company linked to the required job creation or maintenance.
These options have detailed eligibility and documentation requirements. The activity cannot be directed, directly or indirectly, towards real-estate investment under the ARI framework. Applicants should check the current rules and the precise conditions for their chosen category.
Portugal’s ARI can allow eligible holders to reside and work in Portugal, travel within the Schengen area under applicable rules, and seek family reunification. AIMA also states that qualifying holders may apply for Portuguese nationality through naturalisation if they meet the separate requirements of nationality law. Approval is not automatic simply because someone holds a Golden Visa or has made the investment.
See Portugal’s official residence-by-investment requirements before making any decision.
Greece: A residence route rather than direct citizenship
Greece has offered residence permits linked to qualifying investments. The precise investment threshold and conditions can depend on the investment type and location, and the applicable rules can change.
The essential distinction is that a Greek residence permit is not Greek citizenship. Investors who later wish to become Greek citizens must meet the separate requirements for naturalisation, which may involve lawful residence, language and civic knowledge, and other statutory conditions.
Anyone considering Greece should confirm the current rules with the Greek authorities or a qualified immigration lawyer rather than relying on an old article quoting a single property-investment amount.
Spain: The former Golden Visa has ended for new applicants
Spain ended its investor-visa scheme effective 3 April 2025. The former route included residence permissions linked to certain investments, including real estate.
Consequently, investors should not rely on older articles that advertise Spain’s Golden Visa as an open route for new applications. Transitional provisions may apply to applications submitted before the change and to certain existing authorisations, so people who already hold or applied for the visa should obtain advice specific to their circumstances.
The Spanish government published its announcement in its official notice on ending the Golden Visa scheme.
Other European countries: Investment does not equal citizenship
Several European countries may offer business, entrepreneur, investor or financially independent residence routes under their own immigration laws. Italy, for example, has an investor-visa framework, but this should not be confused with direct citizenship by investment.
Austria’s nationality law may allow exceptional cases involving extraordinary services to the country, but this is not a standard, purchasable citizenship programme with a guaranteed outcome. Switzerland also has specific residence arrangements for certain financially independent foreign nationals, but these do not amount to a straightforward passport-for-investment scheme.
The important question is not simply whether a country welcomes foreign investment. It is whether its current law expressly provides a citizenship route, a residence route, or an ordinary naturalisation process – and what conditions apply to each.
Citizenship by Investment in Europe and Worldwide: A Quick Comparison
The following table summarises the main distinctions investors should understand before comparing individual programmes.
| Country or region | Route to investigate | What applicants should understand |
|---|---|---|
| Malta | Former investor-citizenship scheme | The Court of Justice of the EU ruled against the transactional scheme in April 2025. |
| Portugal | Residence by investment | Qualifying investment can support residence; citizenship requires separate naturalisation eligibility. |
| Greece | Residence by investment | A residence permit is not an immediate passport. |
| Spain | Former investor visa | New applications under the investor-visa scheme ended on 3 April 2025. |
| Türkiye | Citizenship by investment | A statutory investment-based route exists, subject to eligibility and a government decision. |
| Dominica | Citizenship by investment | Offers qualifying contribution and approved real-estate routes, subject to due diligence and fees. |
| Other Caribbean participating states | Citizenship by investment | Programme structures, thresholds, dependent rules and additional fees differ by country. |
This comparison is a starting point, not a substitute for checking each country’s current regulations. Investment amounts and eligibility conditions can change, and the same advertised minimum may not reflect the full cost of an application.
Citizenship by Investment Outside Europe
For people who want a direct citizenship route rather than residence followed by possible naturalisation, some programmes outside Europe may be worth investigating. Two examples are Türkiye and Dominica.
Türkiye: Investment-based citizenship
Türkiye offers a legal route through which eligible foreign nationals may qualify for citizenship by meeting prescribed investment conditions and obtaining the necessary approval.
Under the published rules, qualifying routes include:
- Purchasing real estate worth at least US$400,000, with the required declaration and a restriction on resale for at least three years.
- Making a qualifying fixed-capital investment of at least US$500,000.
- Depositing at least US$500,000 in an eligible Turkish bank for the prescribed holding period.
- Purchasing qualifying government bonds or eligible investment-fund shares at the required threshold and holding them for the stipulated period.
- Creating at least 50 jobs, subject to the applicable verification requirements.
- Meeting the requirements for other eligible investment categories recognised under the programme.
These are statutory investment thresholds, not a guarantee that every applicant will be approved. Applicants must satisfy the applicable legal, documentary and security requirements.
The official Invest in Türkiye guide to acquiring property and citizenship provides further details on investment categories and restrictions.
Türkiye is not an EU Member State. Turkish citizenship therefore does not confer EU citizenship or an automatic right to live and work throughout the European Union.
Dominica: A Caribbean citizenship-by-investment programme
Dominica operates a citizenship-by-investment programme with two principal routes: a contribution to the Economic Diversification Fund or an investment in government-approved real estate.
The programme’s official information lists a minimum contribution of US$200,000 for a single applicant. A qualifying family application can require a higher contribution, and approved real-estate investment also starts at US$200,000. Government, processing, due-diligence and other applicable fees may be payable in addition to the headline investment.
The contribution route is generally non-refundable. The real-estate route is subject to programme-specific requirements, including rules on approved projects and the holding period. Applicants should compare the full costs, risks and terms of each option rather than assuming that the property route is equivalent to a refundable deposit.
Consult the official Dominica Citizenship by Investment Unit’s investment options and its programme legislation and legal basis.
Dominican citizenship does not grant an automatic right to live or work in Europe, the United States or the United Kingdom. Entry permissions depend on the destination country’s current rules, the passport held and the traveller’s individual circumstances.
What about other Caribbean programmes?
Antigua and Barbuda, Grenada, Saint Kitts and Nevis, and Saint Lucia have also operated citizenship-by-investment programmes. Their qualifying contributions, real-estate options, dependent eligibility, mandatory interviews, due-diligence requirements and fees differ.
Do not rely on old online comparisons that quote historical contribution amounts. Check the official programme authority for the country in question and ask for a written breakdown of the full cost for every applicant included in the application.
Citizenship by Investment vs. Residence by Investment
The difference between these two routes is central to choosing the right programme.
Citizenship by investment
A qualifying applicant can apply for citizenship under a country’s specific programme. If approved, the person becomes a citizen of that country and may qualify for its passport, subject to the applicable law and procedures.
This does not mean every applicant is guaranteed approval, nor does it guarantee unrestricted travel to every destination.
Residence by investment
A residence-by-investment programme grants a qualifying foreign national a residence permit or similar immigration status in return for a prescribed investment or activity. The person remains a foreign national unless and until citizenship is obtained separately.
Some residence programmes may allow an eligible holder to apply for permanent residence or naturalisation later. That possibility depends on national law and conditions such as residence, language ability, criminal-record checks and other eligibility requirements.
Ordinary naturalisation
Naturalisation is the legal process through which a foreign national becomes a citizen after satisfying a country’s nationality law. Requirements can include a minimum period of lawful residence, evidence of integration, language or civic knowledge, a clean criminal record, and other conditions.
Investment may be relevant to someone’s immigration status, but it does not necessarily replace the requirements for naturalisation.
What Are the Benefits of Citizenship by Investment?
For eligible applicants, a second citizenship can provide practical advantages. The value of those advantages depends on the country, the applicant’s existing nationality and their personal circumstances.
Greater international mobility
A second passport may provide visa-free or visa-on-arrival access to destinations that are less accessible with the applicant’s current passport. However, visa arrangements can change, and travellers must check the latest entry rules before booking.
Family planning
Some programmes allow eligible spouses, children or other qualifying dependants to be included. Age limits, financial-dependency tests, documentation and extra fees vary. Applicants should obtain confirmation of who qualifies before calculating the total investment.
Business and travel flexibility
A second nationality may be useful for entrepreneurs, international business owners or frequent travellers. Its usefulness depends on the country’s legal framework and the destinations the applicant regularly visits.
Long-term planning
Some families consider a second citizenship as part of a wider plan for education, business continuity, travel or future generations. Before applying, they should check whether citizenship can be passed to children born later and whether any registration requirements apply.
Potential diversification
A second citizenship may offer another legal status and a different set of travel options. It should not, however, be treated as a guarantee of financial security, political protection, or favourable tax treatment.
Costs of Citizenship by Investment: What Should You Budget For?
The minimum investment is only one part of the total cost. A realistic budget should account for all mandatory and likely expenses.
| Cost category | What to check |
|---|---|
| Qualifying investment | Contribution, property purchase, fund subscription or other eligible investment. |
| Government charges | Application, processing, naturalisation and passport fees. |
| Due diligence | Background checks and screening fees for the main applicant and relevant dependants. |
| Professional services | Legal advice and authorised-agent fees, where applicable. |
| Family members | Additional charges or higher investment requirements for dependants. |
| Property expenses | Taxes, legal fees, maintenance, insurance and possible resale restrictions. |
| Document preparation | Certified copies, translations, apostilles and other required records. |
| Ongoing obligations | Investment holding periods, renewals, tax filings or other obligations under relevant law. |
A non-refundable government contribution should be treated differently from an investment in an asset. Real estate may carry market, liquidity and resale risks, and its purchase price does not necessarily represent the full programme cost.
Ask for a written itemised quotation that distinguishes mandatory programme costs from optional services. Do not transfer funds based solely on marketing materials or verbal assurances.
Eligibility and Due Diligence: Who Can Apply?
Eligibility varies between countries and programmes. Common requirements may include:
- A valid passport and identity documents.
- Proof of the lawful source of funds and overall wealth.
- Police-clearance certificates or other criminal-record documentation.
- Disclosure of relevant business interests and financial history.
- Medical records or examinations, where required.
- Interviews or additional verification.
- Proof that the investment meets the programme’s rules.
- Supporting records for each included family member.
A programme may refuse an application even when the applicant can afford the minimum investment. Incomplete disclosure, unexplained funds, inaccurate documentation or a history that raises security concerns can create serious obstacles.
Applicants should use the programme’s official application process and verify the credentials of any agent or adviser. They should never conceal previous visa refusals, criminal matters or financial information that the application requires them to disclose.
Does a Second Passport Provide Tax Advantages?
Not automatically. Citizenship, immigration residence, tax residence and domicile are distinct legal concepts, although their definitions and consequences vary by jurisdiction.
A second passport does not by itself guarantee exemption from tax in the applicant’s existing country of residence or nationality. Tax obligations can depend on residence, income source, assets, business activities, treaty provisions and domestic law.
Before applying, seek advice from a qualified tax professional who understands both the applicant’s current circumstances and the rules of the proposed destination. Consider reporting obligations, potential double-taxation issues, inheritance rules and any consequences of changing tax residence.
Risks to Consider Before Investing
Citizenship-by-investment and residence-by-investment arrangements can involve substantial financial and legal commitments. Consider these risks before proceeding.
Programme changes
Governments can amend investment thresholds, close routes to new applicants or change eligibility requirements. A programme advertised online may no longer be open on the same terms.
Uncertain outcomes
An investment does not eliminate the possibility of refusal. Applicants should understand when money must be paid, whether any portion is refundable, and what happens if an application is unsuccessful.
Property and investment risk
Approved real estate can still be exposed to market fluctuations, resale restrictions, maintenance expenses and limited liquidity. An investment fund or business can lose value. Citizenship approval should not be treated as a substitute for evaluating the underlying asset.
Changing travel privileges
Visa-free access is not permanent or universal. Governments can change visa rules, and a passport may not provide the travel access an applicant expects. Confirm important destination-specific requirements through official sources.
Fraudulent agents and misleading claims
Be cautious of guarantees of approval, unusually low advertised prices, pressure to transfer funds quickly, or promises of unrestricted access to the EU, United States or United Kingdom. Verify the authorised-agent list, legal basis and payment arrangements directly with the official programme authority.
How to Choose the Right Programme
A sensible decision starts with the outcome you actually need. Use the following checklist before engaging an adviser or transferring funds.
- Define your goal. Decide whether you need citizenship, residence rights, greater travel flexibility, a business base or a possible future naturalisation route.
- Identify suitable countries. Compare only programmes that are currently available and legally appropriate for your nationality and circumstances.
- Verify the legal status. Check the official government website and current legislation. Do not rely solely on an agent’s brochure or an old article.
- Calculate the total cost. Include investment, government fees, professional services, dependants and ongoing obligations.
- Review the rights granted. Confirm whether the programme provides citizenship, temporary residence, permanent residence or merely eligibility to apply for a later status.
- Check family eligibility. Obtain written confirmation of which relatives can be included and what conditions apply to them.
- Understand the investment risk. Compare non-refundable contributions with property, fund or business investments and review holding periods and exit conditions.
- Obtain independent advice. Use appropriately qualified immigration and tax professionals, and verify the credentials of any programme agent.
- Keep records. Preserve application documents, source-of-funds evidence, official receipts, contracts and all written representations made by advisers.
Frequently Asked Questions
1. Can you still buy citizenship in Europe through investment?
The legal position has changed significantly. On 29 April 2025, the Court of Justice of the European Union ruled that Malta’s transactional investor-citizenship scheme was contrary to EU law. Investors should not assume that a European investment or Golden Visa grants direct citizenship. Other lawful nationality routes may exist, but their requirements must be assessed separately.
2. Which European countries offer residence by investment?
Portugal and Greece are among the countries investors commonly investigate for residence-by-investment routes, subject to current eligibility rules. Portugal’s ARI programme has specified qualifying investment options. Spain ended its investor-visa scheme for new applications on 3 April 2025. Programme availability and conditions should always be checked with the relevant national authority.
3. Does a Golden Visa automatically lead to citizenship?
No. A Golden Visa generally refers to a residence route, not citizenship itself. A holder may be eligible to seek permanent residence or naturalisation later if the country’s laws allow it and all applicable requirements are met. Approval is not automatic.
4. Which countries offer citizenship by investment outside Europe?
Türkiye and several Caribbean countries, including Dominica, have legal investment-based citizenship routes. Other Caribbean programmes include those operated by Antigua and Barbuda, Grenada, Saint Kitts and Nevis, and Saint Lucia. Each programme has its own thresholds, application process, eligibility rules and fees.
5. Can family members be included in an application?
Some programmes permit eligible spouses, children and, in certain circumstances, other dependants to be included. The rules differ by country, including age limits, financial dependency, documentation and additional fees. Confirm the current family rules before choosing a programme.
6. Does citizenship by investment guarantee visa-free travel or tax savings?
No. Travel privileges depend on the destination’s current entry rules and may change. Citizenship also does not automatically determine tax residence or eliminate tax obligations elsewhere. Applicants should check travel access and obtain independent tax advice based on their circumstances.
Conclusion: Research the Legal Route Before Investing
Citizenship by investment remains an option in certain countries around the world, but Citizenship by Investment in Europe must be approached with particular care following the EU Court of Justice’s 2025 ruling on Malta’s scheme.
For investors interested in Europe, residence-by-investment routes and ordinary naturalisation are different legal pathways, each with its own conditions. Portugal’s ARI programme, for example, can provide a qualifying route to residence, but it does not guarantee Portuguese citizenship. Spain’s former investor-visa scheme has ended for new applications.
Outside Europe, programmes such as those in Türkiye and Dominica may provide investment-based citizenship routes to eligible applicants. They still require careful due diligence, accurate financial disclosure and a realistic assessment of the total cost, investment risk and rights actually granted.
Before committing funds, confirm the latest rules through official government sources, compare the full costs and obtain independent legal and tax advice. A well-informed decision begins with understanding the difference between citizenship, residence and eligibility to apply for naturalisation – not simply choosing the country with the lowest advertised investment threshold.
Disclaimer: This article is for general informational purposes only and does not constitute legal, immigration, investment or tax advice. Programme rules, costs and eligibility requirements can change. Confirm current requirements with the relevant government authority and a qualified professional before making a decision.
