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Malta CITIZENSHIP BY INVESTMENT is to be terminated. So, where is Europe now?

29/04/2025

Following the ECJ's ruling today in Case C-181/23 "European Commission v. Republic of Malta" regarding Malta's 2020 CITIZENSHIP BY INVESTMENT PROGRAM  [CBI], which has been judged to be contrary to EU law (namely to Art. 20 TFEU and Art. 4(3) TEU), the country's CBI scheme will now have to be terminated.

Following the termination of a similar scheme in Cyprus as of 2023 (already suspended in 2020), Austria remains the only EU member state that still offers citizenship by investment to foreign nationals.

With the demise of the CBI programmes around Europe, several member states offer RESIDENCY BY INVESTMENT (RBI) programs that provide a direct pathway to citizenship. However, on April 3, Spain permanently discontinued its RBI program amid issues with the Spanish population's access to affordable housing.

SO, WHAT IS THE STATE OF PLAY IN EUROPE?

CITIZENSHIP BY INVESTMENT

  • AUSTRIA (🇦🇹) - Active financial investment of ~€ 7- 8mn (in the real economy, not passive investing), spread over min. 3 years with min. €3mn invested each year. No residency requirement.

RESIDENCY BY INVESTMENT ("RBI")

  • CYPRUS (🇨🇾) - Min. €300K invested in real estate, with evidence of foreign income of min. €50K. No min. residency requirement, but Cyprus must be visited every 2 years.
  • HUNGARY (🇭🇺) - Option 1: Min. €250K invested in a regulated investment fund with min. 40% of its net asset value in domestic real estate. Option 2: A min. €1mn educational or cultural donation. No residency requirement.
  • GREECE (🇬🇷) - Min. €800K (for the capital, large cities and larger islands) or €400K (for others) invested in real estate; min. €250K if real estate is converted for residential use or is a restored historical building. No residency requirement.
  • ITALY (🇮🇹). - Option 1: Min. €2mn invested in government bonds. Option 2: A min. €2mn philanthropic donation. Option 3: Min. €500K invested in corporate bonds or stock. Option 4: Min. €250K invested in innovative startups. Min. residency for 183 days/year to maintain eligibility for citizenship.
  • PORTUGAL (🇵🇹) - Option 1: Min. €500K into invested for min. 5 years in an investment or VC fund, with min. 60% invested in commercial companies headquartered in Portugal. Option 2: A min. €250K capital-transfer donation to support arts or the national cultural heritage. Min. residency requirement: physically in Portugal is 7 days/year or 14 days every 2 years.
  • LATVIA (🇱🇻) - Option 1: Min. €50K/100K invested in a small/large Latvian company. Option 2: Min. €250K invested in government bonds. Option 3: Min. €250K invested in real estate. Option 4: Min. €280K placed in a bank deposit. No min. Residency requirement.
  • LUXEMBOURG (🇱🇺) - Option 1: A min. €500K business investment. Option 2: Min. €3mn placed with a fund management or investment entity. Option 3: Min. €20mn placed in a bank deposit. Min. residency: 6 months/year.
EU

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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.  

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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.