The European Union has spent seven years tightening the screws on golden passports, the citizenship by investment (CBI) schemes that grant nationality in return for a set payment or investment. What began with reports and warnings has become binding law: a 2025 court ruling that ended Malta's program and a 2025 regulation that lets the EU suspend visa-free travel for any country that sells citizenship.
The pressure now falls mainly on countries outside the EU. In June 2026 the European Commission asked the five Eastern Caribbean CBI states to phase out their programs by June 2028. Here is how the EU got here.
Key takeaways
- The EU Court of Justice ruled on April 29, 2025 that Malta's investor citizenship scheme breached EU law. Malta repealed the program in July 2025.
- Vanuatu became the test case outside the EU. Its visa waiver was suspended from 2022, and an EU law adopted in December 2024 ended visa-free travel for its nationals.
- Since December 30, 2025, operating an investor citizenship scheme is a standalone ground for suspending visa-free access to the Schengen area.
- Golden visas, which grant residence rather than citizenship, face a separate track of tighter anti-money laundering checks from July 2027.
The timeline at a glance
| Date | Step |
|---|---|
| January 2019 | Commission report flags security, money laundering and tax risks in member states' investor schemes |
| October 2020 | Commission opens infringement procedures against Cyprus and Malta; Cyprus ends its program the same year |
| March 2022 | After Russia's invasion of Ukraine, the Commission urges member states to end investor citizenship schemes immediately; Bulgaria's parliament abolishes its program the same month |
| September 2022 | Commission refers Malta to the Court of Justice |
| March 2022 to February 2023 | EU partially, then fully, suspends its visa waiver agreement with Vanuatu |
| December 2024 | EU adopts a law ending visa-free travel for Vanuatu nationals, published in January 2025 |
| April 29, 2025 | Court of Justice rules against Malta in case C-181/23 |
| July 24, 2025 | Malta amends its Citizenship Act and repeals the investment route |
| December 30, 2025 | Revised visa suspension mechanism enters into force |
| June 25, 2026 | Commission letters ask five Caribbean states to phase out CBI by June 1, 2028 |
| July 10, 2027 | EU Anti-Money Laundering Regulation applies, with extra checks for residence-by-investment applicants |
The Malta ruling
Malta ran the EU's last major citizenship by investment program. The Commission referred Malta to the Court of Justice in 2022, and the Grand Chamber gave its judgment on April 29, 2025. According to the Court's press release, Malta's investor citizenship scheme is contrary to EU law.
The Court accepted that each member state sets its own nationality rules. But because national citizenship also confers EU citizenship, with rights that every other member state must recognize, a state cannot grant it in what amounts to a commercial transaction. The Court rested this on the special relationship of solidarity and good faith between a state and its citizens, and on the duty of sincere cooperation between member states.
Malta complied. Its government said the amendments would bring the law into line with the ruling and remove all references to the program, the transactions and its agents. Community Malta Agency confirms the Maltese Citizenship Act was amended on July 24, 2025 by Act XXI of 2025. Citizenship by merit remains, but the agency stresses that it is discretionary, case by case, and not a successor to the investment program.
With Cyprus and Bulgaria having closed their schemes earlier, the ruling effectively ended golden passports inside the EU.
Vanuatu: the first visa-free country to pay the price
Outside the EU, the Commission's tool is visa-free travel. Vanuatu was the first country to feel it. The EU partially suspended its visa waiver agreement with Vanuatu in March 2022, citing failures in the screening of investor citizenship applicants, and fully suspended it from February 2023.
The EU then went further. A regulation amending the EU visa list, adopted in December 2024 and published in January 2025 under procedure 2024/0128(COD), ended the visa exemption for Vanuatu nationals on a lasting basis. Every Vanuatu passport holder, not only investor citizens, now needs a Schengen visa.
The new visa suspension mechanism
Vanuatu's case rested on evidence of security failures. The EU has since lowered that bar. Regulation (EU) 2025/2441, in force since December 30, 2025, adds the operation of an investor citizenship scheme as a standalone ground for suspending visa-free travel. It covers citizenship granted for set payments or investments without a genuine link to the country.
It also allows an initial suspension of up to 12 months, an extension of up to 24 months, and targeted suspensions for specific categories of travelers.
This is the basis for the Commission's June 2026 letters to Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia. The letters ask for a phase-out by June 1, 2028, with interim measures such as the exclusion of people under EU sanctions. Talks continue, and our report on EU pressure on Caribbean CBI covers the latest round.
Golden visas: a separate track
Golden visas, which grant residence, have not been banned, but several EU countries have closed or narrowed them. Ireland closed its Immigrant Investor Programme to new applications in 2023, Portugal removed real estate as a qualifying investment the same year, and Spain ended its golden visa in April 2025. Others, such as Greece and Cyprus, have raised thresholds or tightened conditions.
At EU level, the Anti-Money Laundering Regulation (EU) 2024/1624 will apply from July 10, 2027. It brings investment migration firms under EU anti-money laundering rules and requires enhanced due diligence, including source of funds and source of wealth checks, for non-EU nationals applying for residence in exchange for investment. Our guide to source of funds for investment migration explains what those checks involve.
What it means now
For people who already hold a CBI passport, nothing in EU law withdraws their citizenship. Only the issuing country can do that, under its own rules, as our guide to citizenship by investment revocation risk explains. What the EU can change is how easily that passport crosses European borders.
The direction of travel is clear. The EU now treats the sale of citizenship as a problem in itself, not just a vetting failure, while residence-based routes face stricter checks but remain open. Our comparison of residency by investment and citizenship by investment sets out the trade-offs.
Frequently asked questions
Is citizenship by investment illegal in the EU?
For EU member states, effectively yes. The Court of Justice ruled in April 2025 that granting nationality in return for predetermined payments or investments breaches EU law, and Malta repealed its program in response.
Can the EU take away a Caribbean passport?
No. Citizenship is granted and revoked by the issuing country. The EU can suspend visa-free travel to the Schengen area for that country's nationals, which affects the passport's value but not the citizenship itself.
Are golden visas banned in the EU too?
No. Residence by investment programs remain legal, but several countries have closed or narrowed them, and new EU anti-money laundering rules from July 2027 will add enhanced checks for applicants.
Important: This article is general information, not tax, legal or financial advice. Rules change often and depend on your personal circumstances. Speak with a qualified professional in each relevant country before you act.