Buying a passport in Europe is no longer possible, and the EU is now asking five Caribbean governments to end their own citizenship-by-investment programmes by 2028. If you are planning where to hold tax residency or a second nationality, the routes that depended on a payment alone are closing one by one, and the ones built on real relocation, time spent, tax registered, a company actually run from the country, are the ones still standing.
What actually happened
On 29 April 2025 the Court of Justice of the European Union ruled in Case C-181/23, European Commission v Malta, that Malta's investor-citizenship scheme breached Article 20 of the Treaty on the Functioning of the European Union and Article 4(3) of the Treaty on European Union. The Court's reasoning was specific: granting nationality purely for a predetermined financial contribution, with no genuine link between the applicant and the country, amounts to the commercialisation of citizenship, and because every Maltese passport also carries EU citizenship, that commercialisation extended to EU citizenship itself. Malta's scheme was the last one in the EU offering citizenship for money with no residence requirement. After that ruling, none remain.
Spain had already moved in the same direction through a different route. Disposición Final 21.1 of Ley Orgánica 1/2025, published in the Boletín Oficial del Estado on 3 January 2025, repealed the investor-visa articles of Spain's 2013 entrepreneurs law with effect from 3 April 2025. Every route under that law, including the 500,000 euro real estate option, closed to new applicants on that date. People who already held the visa kept their status; nobody new could apply after it.
Portugal had moved first, and for a different reason. Lei n.º 56/2023, the housing law known as "Mais Habitação," took effect on 7 October 2023 and removed every real-estate and passive capital-transfer route from the Portuguese Golden Visa. The law was aimed at the housing market, not at investment migration, but the effect on that route was the same: closed.
The new legal tool, and who it is aimed at now
On 7 October 2025 the European Parliament adopted a revised visa-suspension mechanism by a vote of 518 to 96, with 24 abstentions. For the first time, operating an investor-citizenship scheme is now a standalone ground for suspending a country's visa-free access to the Schengen area, regardless of how well the scheme is run. The same revision lowered the threshold for a "substantial increase" in irregular stays or serious crime linked to a country's nationals, from 50 percent to 30 percent.
In letters dated 25 June 2026, European Commissioner for Internal Affairs and Migration Magnus Brunner asked five Caribbean governments, Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and St Lucia, to phase out their citizenship-by-investment programmes by 1 June 2028, with interim vetting measures requested by September 2026. Antigua and Barbuda's Prime Minister, Gaston Browne, said his government had advance notice of the letters from 20 June 2026 and intends to keep its programme running. No programme has closed as a result of the letters, and the European Commission has not itself published them; what is public comes from the Caribbean governments' own statements.
What this does not touch
None of this closes residency-by-investment routes outside the EU's immediate reach, including the UAE Golden Visa, which we cover in detail separately. The pattern across four separate actions since 2023, a housing law, a court judgment, a budget bill, and a diplomatic letter, is specific: what is closing is the subset of routes that grant EU citizenship or EU-adjacent visa-free access for money alone, with no requirement to actually live in, work from, or pay tax in the country involved. A route that requires genuine presence has not been the target of any of these four actions.
What this means if you are planning a move
If part of your plan has relied on "buy now, decide later" access to an EU country, that plan has lost three of its four possible doors in the last three years, and the fourth group, the Caribbean programmes, is now under direct and dated EU pressure with a 2028 horizon. A plan built instead on real relocation, registering tax residency, running the company from where you actually are, meeting a real days-in-country test, has not been affected by any of these four actions, because none of them target genuine residence. ETERAX explains what each route currently requires and implements the structuring. The decision to relocate, and where, is always the client's.
- Court of Justice of the European Union, press release No. 52/25, 29 April 2025: Case C-181/23, European Commission v Malta. curia.europa.eu
- European Parliament press room, 7 October 2025: "More flexible visa suspension mechanism." europarl.europa.eu
- Jamaica Observer, 7 July 2026, on the European Commission's letters to Caribbean CBI states. jamaicaobserver.com
- KPMG GMS Flash Alert 2025-008, on Spain's repeal of its investor-visa scheme (Ley Orgánica 1/2025). kpmg.com
Common questions
Can you still buy citizenship in an EU country in 2026?
No. The Court of Justice of the European Union ruled on 29 April 2025 that Malta's investor-citizenship scheme, the last EU programme offering citizenship for a financial contribution with no residence requirement, breached EU law. No EU member state currently operates such a scheme.
Is a golden visa the same as citizenship by investment?
No. A golden visa grants residency rights, not citizenship, usually in exchange for an investment, and typically still requires years of residence before naturalisation becomes possible under the country's ordinary rules. Citizenship-by-investment schemes, like Malta's former programme, granted nationality itself, directly, for a payment.
Is Spain's golden visa still open?
No. Spain closed its investor-visa routes to new applicants from 3 April 2025, under Ley Orgánica 1/2025. Investors who held the visa before that date keep their status and renewal rights.
Why is the EU pressuring Caribbean citizenship-by-investment programmes?
Since the European Parliament's 7 October 2025 vote, operating an investor-citizenship scheme is itself a ground for suspending a country's Schengen visa-free access. In June 2026 the European Commission used that basis to ask five Caribbean states to phase out their programmes by 2028.
Does this affect the UAE Golden Visa or other non-EU residency routes?
Not directly. The four actions covered here, in Portugal, Malta, Spain and the EU's approach to the Caribbean, all concern routes into the EU or EU-adjacent visa-free travel. Routes elsewhere, including the UAE's, are not named in any of them.
What should someone planning a relocation take from this?
That routes requiring only a payment, with no genuine residence, have closed or come under formal pressure in every case examined here since 2023, while routes built on actual presence and tax residency have not. ETERAX sets out what a given route currently requires; the decision on where and how to relocate stays with the client.