Citizenship by investment (CBI) is the express lane to a second passport: you make a government-approved donation or investment, pass due diligence and receive citizenship in months, not years. It’s legal, it’s regulated – and it’s under more political pressure than ever.
This guide compares the programmes that actually take applications as of September 2026. For the slower (and sturdier) routes, see second passports, citizenship by descent and fastest naturalisation.
The EU door is closed#
- Malta: on 29 April 2025 the EU Court of Justice ruled in Commission v Malta (C-181/23) that Malta’s “citizenship by naturalisation for exceptional services by direct investment” breached EU law: nationality can’t be granted in exchange for predetermined payments or investments. Malta’s Citizenship (Amendment) Act 2025 (Act XXI of 2025), in force since 24 July 2025, removed the investment route. What remains is a merit-based naturalisation for genuinely exceptional contributions – science, sport, culture and the like – not a price list. Malta still offers residence programmes.
- Cyprus closed its programme in November 2020. Cyprus sells permanent residence, not citizenship.
- Bulgaria ended its programme in 2022. Montenegro stopped accepting applications at the end of 2022.
After the Malta ruling, any EU state launching a new passport-for-cash scheme would be walking straight into the Commission’s arms. If someone sells you an “EU passport by investment” in 2026, they’re selling a naturalisation route with extra steps – or a problem.
The comparison table (as of September 2026)#
Minimum government donation for a single applicant or small family, before government, due-diligence and agent fees (which typically add tens of thousands of dollars). Visa-free counts are from the Henley Passport Index 2026 data as retrieved in September 2026; they include visa-on-arrival and eTA destinations.
| Country | Donation route (from) | Family add-on | Other routes | Visa-free (Henley 2026) | Presence required |
|---|---|---|---|---|---|
| St Kitts and Nevis | US$250,000 (up to 4 people) | +US$25,000 per child under 18, +US$50,000 per dependant 18+ | Approved real estate from US$325,000 | 157 | None; interview and biometrics |
| Antigua and Barbuda | US$230,000 National Development Fund | Spouse, children and parents over 55 without extra contribution (fees per person apply) | Real estate from US$300,000, business | 154 | 5 days within the first 5 years |
| Grenada | US$235,000 National Transformation Fund (up to 4) | Additional dependants cost extra | US$270,000 approved real estate + US$50,000 donation | 148 | Interview; 30-day rule passed, start pending |
| Dominica | US$200,000 Economic Diversification Fund (single) | US$250,000 for up to 4 people | Approved real estate from US$200,000 | 144 | Interview |
| St Lucia | US$240,000 National Economic Fund (up to 4 people) | Per-dependant amounts beyond that | Real estate or bonds from US$300,000, enterprise projects | 143 | Interview |
| Türkiye | – | Spouse and children under 18 included | US$400,000 real estate (hold 3 years), US$500,000 bank deposit, bonds or fixed capital (3 years) | 112 | None to qualify |
| Nauru | US$90,000 limited-time offer until 31 Dec 2026 + US$5,000 application fee | US$2,000 per dependant 16+, plus fees | – | 84 | None to qualify |
| São Tomé and Príncipe | From about US$90,000 (programme launched 2025) | Small family surcharge | – | 59 | Reportedly none |
| Egypt | US$250,000 non-refundable | Check programme | US$300,000 state property, US$500,000 deposit (3 years), business + donation | 49 | None to qualify |
| Jordan | – | Check programme | Investment in shares or job-creating projects; criteria amended in July 2026 | 49 | Check programme |
| Vanuatu | Check the official programme page | – | – | 86 | None to qualify |
A few notes:
- The Caribbean floor: in 2024 the five Eastern Caribbean states signed a memorandum of agreement setting a common minimum of US$200,000 and shared due-diligence standards. Dominica sits exactly on the floor; the others price above it.
- Processing: St Kitts and Nevis quotes 120–180 days, Dominica 3–4 months. Antigua and St Lucia have reportedly built up backlogs of a year or more in 2026. Türkiye takes longer because property title and valuation come first.
- Vanuatu reopened its programme in 2025, but lost visa-free Schengen access: the EU fully suspended the waiver from February 2023 and permanently repealed it with Regulation (EU) 2025/11. The UK imposed visas in 2023.
- Cambodia raised its thresholds sharply in late 2025 (reportedly around US$1 million investment or US$3 million donation). Sierra Leone launched a programme in 2025. With weak visa-free access (Henley: 47 and 63), neither makes much sense as a mobility passport.
The Caribbean five, in one paragraph each#
- St Kitts and Nevis runs the oldest programme (since 1984) and prices at the top. The Sustainable Island State Contribution is US$250,000 for up to four family members. Strongest visa-free score of the group.
- Antigua and Barbuda is the family-friendly one: US$230,000 covers up to four people. Catch: you must spend five days in the country within the first five years.
- Grenada attracted investors because Grenadians can apply for the US E-2 treaty investor visa. That route is much narrower now: under US law, investors who acquired the nationality by investment need three years’ domicile in Grenada first. Grenada also passed a bill in July 2026 requiring 30 days of presence in the first five years; its start was postponed until ECCIRA is up and running.
- Dominica is the cheapest of the five at US$200,000. The UK imposed visa requirements on Dominica nationals in 2023, and the US added Dominica (and Antigua and Barbuda) to its partial entry restrictions in December 2025.
- St Lucia offers the widest menu (fund, real estate, government bonds, enterprise projects) from US$240,000. The UK introduced a visa requirement for St Lucians in March 2026, citing asylum claims rather than CBI.
ECCIRA: the new regional regulator#
The five states signed an agreement in 2025 to create the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA), based in Grenada. It is meant to set binding standards across the programmes: harmonised due diligence, mandatory interviews, biometrics and caps on the number of grants. As of September 2026 the legislation has been passed nationally; check whether ECCIRA’s rules already apply when you file.
The political risk: visa-free access can disappear#
The value of most CBI passports is travel. And travel is exactly what other countries can take away.
- EU visa suspension mechanism: Regulation (EU) 2025/2441 entered into force on 30 December 2025. Running an investor citizenship scheme is now an explicit ground to suspend visa-free travel to the Schengen area. The Commission’s December 2025 report under the mechanism singled out the five Eastern Caribbean states, which together have issued roughly 107,000 passports through investment. In June 2026 the Commission reportedly asked the five to phase out their programmes by mid-2028; as of September 2026 no suspension has been proposed.
- Precedent: Vanuatu shows the process end to end – partial suspension (2022), full suspension (2023), permanent repeal (2024/2025).
- UK and US: the UK has imposed visas on Vanuatu and Dominica nationals; the US has restricted entry for some CBI nationalities.
If Schengen access goes, most Caribbean passports lose a large part of their appeal overnight. Your donation doesn’t come back.
Scams and traps to avoid
“Passport in 30 days.”
No legitimate programme is that fast. Due diligence alone takes weeks; anything quicker is a fake or a fraud.
Unlicensed agents.
Every Caribbean programme licenses its agents and publishes the list. Check the official unit’s website before you send a single document.
“EU passport by investment.”
Doesn’t exist in 2026. Offers for Malta, Cyprus or Bulgaria “special routes” are either naturalisation with years of residence or a scam.
Sanctions and due diligence.
If you’re on a sanctions list, have unresolved criminal cases or unexplained wealth, you will be refused – and the fees are usually non-refundable. A CBI passport doesn’t shield anyone from sanctions or extradition.
Losing your first passport.
Some countries (for example Austria, and several Asian states) strip citizenship when you voluntarily acquire another one. Check your home country’s rules first.
A passport is not a tax plan#
Nearly every country taxes by residence, not nationality. A German with a St Kitts passport who still lives in Munich is a German taxpayer. The exception is the US, which taxes its citizens wherever they live. Read the tax residency guide and, if you’re leaving Germany, leaving Germany.
The useful combination is usually: a passport for mobility and Plan B, plus a residence in a low-tax country where you actually live. The easiest residency permits and the Jurisdiction Finder help with the second half.
FAQ#
What is the cheapest citizenship by investment in 2026?
By headline price, Nauru (US$90,000 limited-time offer until the end of 2026) and São Tomé and Príncipe (from about US$90,000). Among the Caribbean programmes, Dominica at US$200,000. Cheap passports tend to have much weaker visa-free access.
Can I still buy an EU passport?
No. Malta’s programme was ruled contrary to EU law in April 2025 and repealed in July 2025. Cyprus and Bulgaria closed earlier. EU citizenship now takes descent or years of residence.
Do I have to live in the country?
Mostly not. Antigua and Barbuda requires five days within the first five years; the other Caribbean programmes require interviews but no residence. Rules are tightening under ECCIRA, so check before you apply.
Will my Caribbean passport keep visa-free Schengen access?
Nobody can promise that. Since 30 December 2025 the EU can suspend visa-free travel for countries that run investor citizenship schemes, and the Commission has named all five Eastern Caribbean states as a concern.
Does a second passport reduce my taxes?
Not by itself. Tax follows residence. You need to actually move and cut ties with your old tax home – and US citizens stay US taxpayers regardless.
How long does it take?
From a complete file, typically a few months for the Caribbean programmes, longer for Türkiye. Document collection (apostilles, bank references, police certificates) often takes longer than the government’s processing.
This guide is general information, not legal, tax or investment advice. Programme rules and prices change often – the official pages below are the final word. Want to see how a passport fits with residence and company structure? Book a strategy session.
Sources#
- Court of Justice of the EU – Judgment C-181/23, Commission v Malta (29 April 2025)
- CJEU press release 52/25 – Maltese investor citizenship scheme contrary to EU law
- European Commission – Investor citizenship schemes
- Regulation (EU) 2025/2441 – revised visa suspension mechanism
- European Commission – Eighth report under the visa suspension mechanism, COM(2025) 792
- Regulation (EU) 2025/11 – repeal of the EU–Vanuatu visa waiver
- Council of the EU – Vanuatu: Council ends visa exemption (12 December 2024)
- St Kitts and Nevis Citizenship by Investment Unit – Sustainable Island State Contribution
- Antigua and Barbuda Citizenship by Investment Unit
- Grenada Investment Migration Agency
- Dominica Citizenship by Investment Unit
- Saint Lucia Citizenship by Investment Unit
- Nauru Program Office – Contribution and fees
- Invest in Türkiye – Acquiring property and citizenship
- Henley Passport Index
