Guide to Citizenship By Investment In Europe

The Changing Landscape of Investment Migration in Europe

The world of investment migration in Europe has undergone a dramatic transformation. What was once a thriving marketplace of "golden passports" and "golden visas" has evolved into a more complex, restricted, and carefully regulated environment.

As someone considering these pathways to European residence or citizenship, you're entering the conversation at a fascinating inflection point.

Investment migration programs have long offered a straightforward premise: make a significant financial contribution to a country's economy, and in return, receive residence rights or even citizenship. These programs have attracted thousands of wealthy individuals seeking mobility, security, or new business opportunities.

But the European landscape has shifted dramatically. The European Union has taken an increasingly firm stance against "selling citizenship," while individual countries have reassessed their programs in light of housing affordability concerns, security considerations, and changing economic needs.

In this comprehensive guide, we'll navigate the current state of citizenship and residency by investment in Europe as of May 2025. We'll explore which doors remain open, which have closed, and what you need to know to make informed decisions about your global mobility strategy.

Understanding the Terminology: CBI vs. RBI Programs

Before diving into specific countries, let's clarify the two main types of investment migration programs:

Citizenship by Investment (CBI) programs offer a direct path to acquiring a new passport through financial contribution. These programs grant full citizenship rights, including the ability to live, work, and travel freely, often with minimal or no physical residence requirements. In the European context, CBI programs have become increasingly rare, with most shut down or facing legal challenges.

Residency by Investment (RBI) programs (often called "golden visas") provide residence permits in exchange for investment. While these don't automatically confer citizenship, they allow legal residence in the country and often provide a pathway to citizenship after a period of residence. Most European investment migration opportunities today are RBI programs.

The key difference lies in the immediacy and depth of rights granted. Citizenship gives you permanent, irrevocable status (barring exceptional circumstances), while residency must typically be maintained through continued investment and periodic renewals.

Now, let's examine the current state of CBI programs in Europe.

Citizenship by Investment in Europe: A Disappearing Option

The sobering reality for those seeking instant European citizenship through investment is that these programs have largely disappeared from the European landscape. Where once several EU member states offered direct routes to an EU passport through investment, intense pressure from the European Commission and changing domestic priorities have resulted in most of these programs being terminated.

Malta: The Last EU Citizenship Program Under Legal Fire

As of early 2025, Malta operates the only remaining citizenship-by-investment program in the European Union, officially called the Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment (MEIN). However, even this program faces an existential threat.

In a landmark ruling on April 29, 2025, the European Court of Justice determined that Malta's program violates EU law and undermines the principle of "sincere cooperation" among member states. The court explicitly stated that "EU citizenship is not for sale," dealing what may be a fatal blow to Europe's last CBI program.

For those still considering this route, Malta's program requires:

• A non-refundable contribution of €600,000 (standard 36-month residence route) or €750,000 (expedited 12-month route)
• Purchase of property worth at least €700,000 or rental of property for at least €16,000 annually
• A €10,000 donation to a registered Maltese charitable organization
• Significant due diligence fees and a requirement to establish genuine links to Malta

It's important to note that Malta has already suspended applications from Russian and Belarusian nationals since March 2022. Given the ECJ ruling, the program's future is highly uncertain, and Malta will likely need to terminate or fundamentally restructure its CBI offering.

Closed CBI Programs in Europe

Several European countries that previously offered citizenship by investment have shut down their programs:

Cyprus terminated its Cyprus Investment Programme (CIP) in October 2020 following scandals and EU pressure. The program had required a €2 million investment, primarily in real estate, plus €150,000 in government contributions.

Bulgaria abolished its investor citizenship scheme in March 2022. The program had offered a fast-track to citizenship for those investing BGN 1 million (approximately €512,000) and holding permanent residence for two years.

Montenegro, while not an EU member, ran a CBI program from 2019 to December 2022. It required a €100,000 government contribution plus investments of €250,000-€450,000 in approved development projects. The program was closed as part of Montenegro's preparation for EU accession.

Other countries like North Macedonia have explored CBI programs but either never fully launched them or have put such initiatives on indefinite hold due to EU pressure.

The clear trend is that citizenship-by-investment is becoming an increasingly rare option in Europe, with the EU taking a strong stance against the practice of granting citizenship without meaningful connections to the country.

Residency by Investment: The Remaining Pathways

While citizenship programs have largely disappeared, many European countries still maintain residency by investment programs. These "golden visas" grant temporary or permanent residence rights in exchange for investment, with the possibility of citizenship after meeting additional requirements.

However, even these programs are evolving, with higher investment thresholds, stricter requirements, and in some cases, outright closure. Let's explore the current landscape:

Greece: Europe's Most Accessible Golden Visa

Greece currently offers one of Europe's most straightforward and affordable residency programs, making it increasingly popular as other countries tighten restrictions. The Greek Golden Visa grants a five-year renewable residence permit with no minimum stay requirement.

Until recently, investors could qualify by purchasing real estate worth €250,000 anywhere in Greece. However, in response to housing affordability concerns, Greece has implemented a tiered system with higher thresholds in prime locations:

• Zone A (top-tier locations like central Athens, Thessaloniki, Mykonos, and Santorini): €800,000
• Zone B (other high-demand areas): €500,000
• Zone C (rest of Greece): €250,000 (unchanged)

Alternative qualifying investments include a €400,000 capital investment in Greek government bonds, company shares, or mutual funds, or a 10-year lease of tourism accommodations with at least €250,000 in prepaid rent.

The program remains active and attractive, particularly because it:

• Requires no minimum stay to maintain residency
• Includes family members (spouse, children up to 21, and parents)
• Offers a renewable 5-year permit from the outset
• Grants Schengen travel privileges

For citizenship, you would need to reside in Greece for 7 years and demonstrate integration (including Greek language proficiency), so this is best viewed as a residency solution rather than a fast track to citizenship.

Portugal: Reformed Golden Visa Without Real Estate

Portugal's famous Golden Residence Permit Program (ARI) underwent a dramatic transformation in October 2023. For years, the program was among Europe's most popular, primarily through its real estate investment option. However, citing housing affordability concerns, Portugal eliminated the real estate pathway entirely.

The program remains active only for these investment routes:

• €500,000 investment in a Portuguese business that creates at least 5 full-time jobs
• €500,000 subscription to Portuguese investment funds
• €500,000 contribution to scientific research
• €250,000 donation to support Portuguese arts, culture, or heritage

The program's main advantage remains its minimal physical presence requirement—just 7 days in the first year and 14 days in each subsequent two-year period. After five years, investors can apply for permanent residency or citizenship, provided they pass a basic Portuguese language test.

It's worth noting that existing real estate investors who received approval before the October 2023 changes can continue to renew their permits under the previous rules.

Cyprus: Fast-Track Permanent Residence

Cyprus offers one of Europe's quickest routes to permanent residence through its Permanent Residency by Investment program. Following the closure of its CBI program in 2020, Cyprus continues to welcome investment-based residents.

The program requires:

• €300,000 investment in real estate (new residential property from a developer, other commercial real estate, or shares in a Cyprus company employing at least 5 people)
• Proof of secure annual income of at least €50,000 from abroad, plus €15,000 for a spouse and €10,000 per child

This program is notable for its speed—applications are typically processed within 2-3 months—and for granting permanent residence status immediately rather than temporary permits. There's minimal stay requirement (visit at least once every two years), and the investment must be maintained for the duration of the permit.

While Cyprus requires 7 years of residence for citizenship (with language requirements), the permanent residence program provides a stable, long-term solution for those seeking a European base without needing to relocate full-time.

Malta: Permanent Residence Programme (MPRP)

While Malta's citizenship program faces legal challenges, its residency program remains firmly established. The Malta Permanent Residence Programme (MPRP) offers immediate permanent residence status through a combination of contributions and investments:

• Government contribution: €60,000 (if leasing property) or €30,000 (if purchasing property)
• Property investment: Purchase property valued at €375,000 or rent for at least €14,000 annually
• Administrative fee: €50,000
• €2,000 donation to a Maltese charitable organization
• Proof of €500,000 in capital assets (including €150,000 in financial assets)

The MPRP grants permanent residence from day one, with no minimum stay requirement (though the resident must not be absent from Malta for more than 2 consecutive years and must visit at least once every 5 years).

This program remains active and popular for those seeking secure, permanent status in an EU member state, particularly as other programs face restrictions or closure.

Italy: Investor Visa Program

Italy offers the "Investor Visa for Italy" (Visto per Investitori), which provides a two-year residency visa, renewable for three additional years. The program maintains relatively high investment thresholds:

• €2,000,000 in Italian government bonds, held for at least 2 years
• €500,000 in shares of an Italian company
• €250,000 in an Italian innovative startup
• €1,000,000 donation to a project in Italian cultural heritage, education, or research

Italy's visa doesn't require a minimum stay to maintain status, making it suitable for those who don't plan to live in Italy full-time. However, if you're interested in permanent residence (after 5 years) or citizenship (after 10 years), you would need to establish actual residence in Italy.

A notable advantage of Italy's program is the potential to combine it with Italy's "Flat Tax for New Residents" regime, which allows eligible individuals to pay a fixed €100,000 annual tax on worldwide income—an attractive option for ultra-high-net-worth individuals.

Spain: Golden Visa Closure

Until recently, Spain offered a popular golden visa through its Law of Entrepreneurs (Ley de Emprendedores). However, in a significant shift, Spain officially ended its golden visa program for real estate investments in April 2025.

For over a decade, Spain's program had allowed investors to obtain residence by purchasing property worth at least €500,000, investing €1-2 million in Spanish companies, or developing qualified business projects. The real estate option was by far the most popular, accounting for approximately 95% of cases.

The Spanish government cited housing affordability concerns as the primary reason for closing the program, similar to Portugal's justification. Existing permit holders can continue to renew their status, but no new applications are being accepted.

With Spain's closure, another major European golden visa destination has effectively exited the investment migration market.

Recently Closed Residency Programs

Several other European countries have recently terminated their residency by investment programs:

United Kingdom

The UK's Tier 1 (Investor) visa was abruptly closed in February 2022 due to security concerns about illicit finance. The program had required a minimum investment of £2 million in UK companies or government bonds, with accelerated settlement options for higher investments (£5 million or £10 million).

Currently, the UK offers no direct investor visa. Wealthy individuals looking to move to the UK now typically use the Innovator visa (for entrepreneurs) or other immigration routes.

Ireland

Ireland's Immigrant Investor Programme (IIP) closed on February 15, 2023, after more than a decade of operation. The program had offered residency in exchange for investments of €1 million in Irish businesses or approved funds, €2 million in Real Estate Investment Trusts (REITs), or a €500,000 charitable donation.

The Irish government stated that the program had "fulfilled its purpose" and was no longer needed in the current economic context.

Bulgaria's Investor Residence

While Bulgaria abolished its fast-track citizenship program, it technically still offers Permanent Residence through investment of BGN 1 million (approximately €512,000) in government bonds or a Bulgarian business. However, without the citizenship incentive, demand has plummeted, and the program's future remains uncertain.

European Microstates: Alternative Opportunities

Beyond the EU member states, several European microstates offer residence programs for investors, though these don't provide EU citizenship or the same level of mobility within Europe.

Andorra

Andorra offers a "Passive Residency" program that requires:

• €400,000 investment in Andorran assets (property, shares of companies, or government bonds)
• €50,000 deposit with Andorra's central bank (plus €10,000 per dependent)
• Spending at least 90 days per year in Andorra

Andorra's program is particularly attractive for its tax benefits—residents enjoy a 10% flat income tax rate, which can be even lower through special regimes. Citizenship is possible after 20 years of residency, though Andorra requires renouncing original citizenship.

Monaco

Monaco doesn't have a formal investment program, but wealthy individuals can obtain residence by demonstrating sufficient financial resources and securing accommodation in Monaco. In practice, this typically means:

• Depositing at least €500,000-€1,000,000 in a Monaco bank
• Purchasing or renting property in Monaco (where real estate is among the world's most expensive)
• Passing rigorous background and financial checks

Monaco residents enjoy a zero income tax environment, making it attractive for ultra-high-net-worth individuals despite the high cost of living. Citizenship is possible after 10 years but is granted very selectively.

Liechtenstein and San Marino

Liechtenstein has extremely limited residency opportunities for non-EEA nationals, with just four permits granted annually. San Marino introduced a residency option requiring a €500,000 investment plus a €75,000 bank deposit, but uptake has been minimal.

Due Diligence and Compliance: Critical Considerations

Investment migration programs have significantly strengthened their due diligence procedures in recent years, responding to concerns about money laundering, tax evasion, and security risks.

What to Expect During Application

Modern investment migration applications involve rigorous background checks, including:

• Criminal background verification through international databases
• Source of funds verification (typically going back at least 3-5 years)
• Professional due diligence reports by specialized firms
• Health insurance requirements
• Documentation of personal wealth beyond the investment amount

Be prepared to provide extensive documentation, including bank statements, tax returns, business ownership records, and detailed explanations of your wealth sources. Many programs also require a "clean criminal record" certificate from your home country and countries of residence.

Maintaining Your Status

All investment programs require maintaining your qualifying investment for a minimum period—typically 3-5 years, but in some cases indefinitely. Selling or liquidating investments prematurely can result in residence permit cancellation or even citizenship revocation.

Some programs also conduct periodic compliance reviews to verify that:

• The investment remains active and complies with program requirements
• You continue to meet any minimum stay obligations
• You haven't engaged in activities that would make you ineligible (e.g., criminal convictions)
• You maintain required health insurance and other conditions

Remember that non-compliance can have serious consequences—in recent years, countries like Bulgaria and Cyprus have actively revoked citizenships granted through investment when requirements weren't met or misrepresentation was discovered.

Understanding the Paths to Citizenship

For many investors, residency is just the first step toward the ultimate goal of citizenship. It's important to understand how residency by investment can—and cannot—lead to a European passport.

Realistic Citizenship Timelines

Even with residency by investment, European citizenship typically requires:

• Actual residence in the country for several years (ranging from 5 years in Portugal to 10 years in Italy)
• Language proficiency in the national language (with varying difficulty levels—Portuguese A2 is considered achievable, while Greek or Italian tests are more challenging)
• Integration into the local society, often demonstrated through community ties, cultural knowledge, or civic participation
• Clean criminal record maintained throughout the residence period

The key point here is that most golden visas do not automatically lead to citizenship without actually living in the country. The main exceptions were the now-closed direct CBI programs.

Programs with Minimal Stay Requirements

If citizenship is your long-term goal while maintaining your current lifestyle, Portugal's program remains noteworthy despite recent changes. Its 7-day annual minimum stay requirement is the lowest among programs that can lead to citizenship after 5 years.

Greece, Cyprus, and Malta require more substantial residence for citizenship eligibility, even if their residence permits can be maintained with minimal presence.

The Future of Investment Migration in Europe

The investment migration landscape in Europe continues to evolve rapidly, driven by political pressures, housing concerns, and shifting economic priorities. Several clear trends have emerged:

Rising Investment Thresholds

Programs that remain active are generally increasing their minimum investment requirements. Greece's zone-based approach, with prices up to €800,000 in prime areas, exemplifies this trend. Expect other programs to follow suit, particularly for real estate investments in high-demand areas.

Shift Away from Real Estate

The closure of real estate options in Portugal and Spain signals a broader trend away from passive property investment. Future programs are likely to favor active investments that create jobs, fund innovation, or support specific economic sectors rather than potentially inflating housing markets.

Stricter Due Diligence

All remaining programs are implementing increasingly rigorous background checks and financial verification procedures. This trend will continue, with more sophisticated investigative methods and ongoing monitoring of compliance.

Preference for Productive Investment

The EU has made it clear that member states should prioritize investments with tangible economic benefits—creating jobs, fostering innovation, or supporting underdeveloped regions—rather than simply collecting fees or driving real estate speculation.

Potential EU Harmonization

The European Commission continues to push for coordinated approaches to investment migration. While not calling for a complete ban on residency programs, it advocates for standardized due diligence procedures, security checks, and minimum actual residence requirements.

Choosing the Right Investment Migration Path

With fewer options available and each program having distinct advantages and limitations, how should prospective investors approach this decision? Here are some key considerations:

Clarify Your Objectives

Different programs are best suited for different goals:

• If you want passive income while gaining residence, Greece's golden visa with property investment in emerging areas might be attractive.
• If you seek a tax-efficient structure, consider Andorra's passive residency or Italy's investor visa combined with its flat tax regime.
• If your goal is eventually gaining citizenship with minimal residence, Portugal's remaining non-real estate options might be worth considering, despite the higher investment requirements.
• If you want immediate permanent residence without relocation, Malta's MPRP or Cyprus's fast-track permanent residence offer strong options.

Consider Timeline and Flexibility

Some key questions to ask yourself:

• How quickly do you need to obtain status?
• Are you planning to actually relocate, or do you need a "Plan B" residence?
• Is your investment timeframe 5 years, 10 years, or indefinite?
• Do you ultimately want citizenship, or is long-term residence sufficient?

Evaluate Investment Security and Returns

Beyond immigration benefits, the investment itself matters:

• Property investments in established European markets like Greece may offer appreciation potential and rental income
• Fund investments in Portugal or Italy involve market risk but potential financial returns
• Government contributions (as in Malta) are non-recoverable but involve no market risk
• Business investments require more active management but might generate higher returns

Factor in Total Costs and Family Needs

Remember to consider:

• Application and due diligence fees (which can exceed €50,000 for a family in some programs)
• Ongoing renewal costs
• Tax implications in both your current country and the new jurisdiction
• Education options if your children will relocate
• Healthcare access and quality

Navigating the New Reality

The golden era of European citizenship by investment is largely behind us. The EU has made its position clear: citizenship should reflect genuine connections to a country, not merely financial transactions. Even residency programs are becoming more selective, focused on quality over quantity, and designed to serve specific economic goals rather than simply attracting wealth.

For investors, this changing landscape requires adaptation:

• Be realistic about citizenship prospects—most paths now require actual residence and integration
• Consider combining strategies (like obtaining residence in one country while pursuing citizenship in another where you have personal ties)
• Engage specialized legal counsel with current expertise in the rapidly changing rules
• Be prepared for enhanced due diligence and ongoing compliance obligations
• Look beyond Europe to citizenship programs in the Caribbean, Turkey, or other regions if immediate citizenship is the priority

Despite these changes, legitimate opportunities remain for those willing to engage meaningfully with the countries they choose. Investment migration continues to offer valuable mobility options, business opportunities, and quality of life enhancements for those navigating the new, more restrictive reality with clear objectives and proper guidance.

The key to success in today's investment migration landscape isn't just financial capacity, but understanding the nuanced requirements, genuine willingness to establish connections with your chosen country, and strategic long-term planning based on your family's unique needs and goals.

For those willing to adapt to these new realities, investment migration remains a powerful tool for global mobility and opportunity—even in a Europe that has become more selective about who it welcomes and how.