Residency by investment (RBI), often called a golden visa, gives an investor and their family the right to live in a country in return for a qualifying investment. Citizenship by investment (CBI) goes further: it grants nationality and a passport, usually within months, in return for a contribution or investment.
The two are often discussed together, but they solve different problems. A residence permit is a right to live somewhere, renewed over time and tied to keeping the investment. Citizenship is a permanent legal status that can be passed to children, and it comes with far more political scrutiny.
This guide explains how residency by investment and citizenship by investment differ in cost, speed, obligations, family coverage, tax and long-term risk, using program rules as of October 2026.
Key takeaways
- RBI programs grant a residence permit; CBI programs grant citizenship and a passport. Only citizenship is permanent in the normal sense.
- CBI entry prices in the Caribbean start around US$200,000 as a non-refundable contribution. RBI entry prices are often higher, but the capital usually stays invested and can be recovered.
- A residence permit leads to citizenship only after years of real residence, if at all. CBI skips that step.
- Neither route makes anyone a tax resident by itself, and neither removes tax duties in another country.
- Both face growing regulatory pressure, from program closures in Europe to EU action against investor citizenship.
What residency by investment is
Residency by investment programs give a non-national the right to live in a country, and sometimes to travel within a wider zone, in exchange for an investment the government approves. The permit is usually renewable, and the investor has to keep the investment in place for a minimum period.
Some examples as of October 2026:
- Portugal. The investment residence permit (ARI) now accepts options such as at least €500,000 in qualifying Portuguese investment funds, €500,000 in company capital with job creation, or €250,000 for cultural heritage and the arts, under Law 23/2007. Real estate no longer qualifies. The permit is renewed in two-year periods.
- Greece. The golden visa is tied mainly to real estate, with higher thresholds in the most popular areas. See our Greece golden visa guide.
- UAE. The golden visa for investors lists a minimum of AED 2 million, with permits of 5 or 10 years depending on the category.
- Malta. The Malta Permanent Residence Programme grants permanent residence from the start, in exchange for a mix of contributions and property.
Programs also close. Spain ended its investor visa on April 3, 2025, when Organic Law 1/2025 emptied the investor articles of Spain's Law 14/2013.
What citizenship by investment is
Citizenship by investment programs grant nationality directly. The applicant does not need to live in the country first, and approval usually takes months rather than years. Five Caribbean countries run the best-known programs. Official figures as of October 2026 include:
| Program | Main donation option | Official minimum |
|---|---|---|
| Dominica | Economic Diversification Fund | US$200,000 single applicant |
| Antigua and Barbuda | National Development Fund | US$230,000 |
| Saint Kitts and Nevis | Sustainable Island State Contribution | US$250,000 |
Sources: the Dominica CBI Unit, the Antigua and Barbuda fee schedule and the Saint Kitts and Nevis investment options page. Real estate options exist too, usually at higher amounts, and processing and due diligence fees come on top. Grenada and Saint Lucia run similar programs, and newer entrants such as Sierra Leone have appeared. Our comparison of the best citizenship by investment programs covers the wider field.
Side-by-side comparison
| Factor | Residency by investment | Citizenship by investment |
|---|---|---|
| What you get | Residence permit | Citizenship and passport |
| Typical entry cost | €250,000 to €500,000+ or equivalent, often recoverable | From about US$200,000, usually non-refundable |
| Time to approval | Months, sometimes much longer with backlogs | Often a few months |
| Presence rules | Light to moderate; varies by country | Generally none in the Caribbean |
| Ongoing conditions | Keep the investment, renew the permit | Few, but status can be reviewed or revoked |
| Path to citizenship | Only after years of real residence, if offered | Immediate |
| Passes to children | No; children need their own status | Yes, generally by descent |
| Voting and public office | No | Usually yes, subject to local law |
| Tax residence | Not automatic | Not automatic |
Cost: donation versus capital you keep
The headline prices are not directly comparable. Most Caribbean CBI options are donations to a government fund. The money is gone once the application is approved. Real estate CBI routes recover some value, but the property usually has to be held for years and resale can be difficult.
RBI programs, by contrast, generally ask the investor to place capital in property, funds or a company and keep it there. That capital can be recovered later, subject to market risk. The real cost of a golden visa is closer to the fees, taxes, transaction costs and lost returns on the money, plus renewals over time. Families should also count per-person costs, which rise quickly with older relatives, as our guide to programs that include parents shows.
Time and obligations
CBI is the faster route to a passport. The process runs through due diligence, approval in principle, payment and the issue of a certificate of naturalization, often within a few months.
RBI is faster to a permit, but slow to citizenship. Naturalization through residence requires years of lawful residence, and most countries also look at real presence, language and integration. Time spent abroad may not count. Some popular golden visa countries, such as the UAE, do not offer a standard path from investor residence to citizenship at all. Our explainer on resident vs citizen differences covers what changes when status upgrades.
Legal and political risk
Both routes carry risk, but of different kinds.
RBI risk is mostly about program change. Governments can raise thresholds, remove investment options or close programs. Portugal removed real estate from its program in 2023, and Spain closed its scheme in 2025. Existing holders are usually protected for renewals, but the rules for families, renewals and naturalization can still shift.
CBI risk is about the status itself. On April 29, 2025, the EU Court of Justice ruled in Case C-181/23 that Malta's investor citizenship scheme was contrary to EU law, holding that EU citizenship cannot result from a commercial transaction, according to the Court's press release. The EU has also put pressure on Caribbean programs whose passports carry visa-free access to the Schengen area. Our articles on the EU crackdown on golden passports and on CBI revocation risk explain where this pressure points.
Visa-free access is not a permanent feature of any passport. It depends on agreements between governments, and those can be suspended.
Tax: neither route decides tax residence
A golden visa does not make someone a tax resident of the country that issues it, and a second passport does not change tax residence at all. Tax residence depends on each country's own tests, such as days of presence, a permanent home or the center of vital interests. Leaving a previous tax system depends on that country's rules.
Citizenship can matter for tax in a few countries. The United States taxes its citizens wherever they live, and a few other countries have similar rules. For people in that position, a second passport does not end the tax link to the first country.
How people often use the two together
Investors often use the two routes for different goals. A golden visa can provide a base in a country where a family actually wants to live, school children or hold property. A second citizenship is more often about travel, a backup nationality or the ability to pass status to children. Some families hold one of each, an approach linked to flag theory.
The right mix depends on where a family wants to live, what it wants to protect against, and its tax position in every country involved. Those questions are personal and usually need professional advice in each country.
Frequently asked questions
Is a golden visa the same as citizenship by investment?
No. A golden visa is a residence permit that allows the holder to live in a country, usually while they keep the investment. Citizenship by investment grants nationality and a passport.
Which is cheaper, residency or citizenship by investment?
It depends on how cost is measured. Caribbean CBI contributions start around US$200,000 but are not refundable. Golden visas often require more capital, but the money stays invested and can be recovered, so the real cost is fees, taxes and lost returns.
Can a golden visa lead to citizenship?
Sometimes, but only after years of lawful residence and usually real presence, language and integration requirements. Some countries, including the UAE, do not offer a standard path from investor residence to citizenship.
Does citizenship by investment make me a tax resident?
No. A passport does not decide tax residence. Tax residence depends on each country's own rules, such as days spent and where your home and main ties are.
Can citizenship by investment be taken away?
Yes, in some circumstances. Many programs allow revocation if the application involved fraud or false information, and some laws allow it on public interest grounds. The level of risk differs by country.
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.