Citizenship by Investment 2026: Programmes, Requirements & Process

uk citizenship by investment

SECTION GUIDE

Citizenship by investment has become an increasingly prominent topic among high-net-worth individuals seeking greater global mobility, long-term security and personal or family optionality. In simple terms, citizenship by investment refers to a legal process under which a sovereign state grants nationality to a foreign national in return for a qualifying economic contribution. This contribution may take the form of a non-refundable donation, a real estate investment, a government bond purchase or, in limited cases, exceptional services rendered to the state.

Despite its growing visibility, citizenship by investment is widely misunderstood. It is often portrayed in marketing materials as a transactional purchase of a passport, when in reality it operates within the framework of national citizenship laws, constitutional powers and discretionary naturalisation regimes. Each programme reflects the political priorities, economic strategy and legal architecture of the issuing state, and the rights conferred by citizenship vary significantly depending on jurisdiction.

What this article is about
This article provides a detailed, legally grounded explanation of citizenship by investment for individuals who are evaluating second or alternative citizenship options. It explains how citizenship by investment programmes work in practice, which countries operate credible programmes, the costs involved, the benefits that citizenship confers and the legal, political and reputational risks that must be considered before proceeding. The focus is on clarity, legal substance and long-term consequences, rather than promotional claims or headline figures.

The article also addresses common misconceptions, including the assumption that citizenship by investment automatically grants unrestricted global rights or guarantees permanent security. In practice, citizenship obtained through investment is subject to revocation powers, international scrutiny and shifting geopolitical attitudes. Understanding these factors is essential for individuals who are making decisions that affect not only their own status but that of their family and future generations.

This is not an advocacy piece for or against citizenship by investment. Instead, it is intended to equip readers with a precise understanding of what citizenship by investment is, how it is granted, where it is available and what it does — and does not — achieve in legal terms.

 

Section A: What Is Citizenship by Investment?

 

Citizenship by investment is a legal mechanism by which a state grants its nationality to a foreign national on the basis of a qualifying economic contribution. The power to grant citizenship rests exclusively with the sovereign state, and citizenship by investment programmes operate as specialised forms of discretionary naturalisation under domestic nationality law. They are not private transactions and do not exist independently of a country’s constitutional and legislative framework.

At its core, citizenship by investment is an exchange between an individual and a state: the individual makes a defined contribution that supports national objectives, and the state exercises its discretion to confer citizenship. The contribution is not a payment for citizenship in a commercial sense. Instead, it is one of several eligibility criteria assessed alongside background checks, character requirements and, in some jurisdictions, residence or cultural integration considerations.

Different states structure their programmes in different ways, reflecting their economic needs and policy priorities. Some programmes are based on non-refundable donations to national development funds, infrastructure projects or public interest initiatives. Others require investment in approved real estate developments, government bonds or strategic sectors of the economy. A small number of jurisdictions provide for citizenship on the basis of exceptional merit, where an applicant’s contribution is judged to be of outstanding national interest rather than purely financial.

A defining feature of citizenship by investment is that it results in full legal citizenship, not a temporary status. Successful applicants typically acquire the same nationality rights as citizens by birth or descent, including the right to reside indefinitely in the country, obtain a passport and transmit citizenship to future generations, subject to local law. However, the route by which citizenship is acquired can carry ongoing legal and political significance, particularly in relation to revocation powers and international recognition.

Citizenship by investment must be distinguished from residence by investment, which grants a right to live in a country without conferring nationality. Residence programmes are usually conditional, time-limited and subject to renewal or physical presence requirements. Citizenship by investment, by contrast, confers a permanent legal status once granted, even if the individual never becomes a resident of the country in question.

Section summary
Citizenship by investment is a form of discretionary naturalisation grounded in national law. It involves a qualifying economic contribution but remains a sovereign legal act, not a commercial purchase, and it results in full citizenship rather than a temporary or conditional immigration status.

 

Section B: How Citizenship by Investment Programmes Work in Practice

 

Although citizenship by investment programmes differ in structure and cost, they tend to follow a broadly similar legal and administrative process. This process reflects the fact that states are conferring nationality, which is one of the most significant powers of sovereignty, and therefore apply scrutiny that goes well beyond a financial transaction.

The process typically begins with a preliminary eligibility assessment. At this stage, the applicant’s nationality, personal background and proposed investment route are reviewed to ensure that there are no obvious legal or policy barriers. Many programmes restrict applications from nationals of certain countries or individuals subject to sanctions, international arrest warrants or heightened geopolitical risk. This initial screening is designed to prevent applications that would be unlikely to succeed or that could expose the state to reputational or diplomatic harm.

Once eligibility is confirmed, the applicant submits a formal application to the relevant government authority, often through a licensed agent or approved intermediary. Direct applications are frequently prohibited, with states requiring the use of regulated representatives to maintain oversight and quality control. The application will include extensive personal documentation, including identity records, civil status documents and a detailed account of the source of funds used for the investment or donation.

A central feature of all credible citizenship by investment programmes is multi-layered due diligence. Governments engage specialist due diligence providers to conduct background checks on applicants and, in many cases, their family members. These checks typically cover criminal history, financial conduct, political exposure, sanctions compliance and adverse media. The depth of scrutiny reflects increasing international pressure on states to ensure that citizenship is not granted to individuals who pose security, financial crime or reputational risks.

Only once due diligence is completed and approved does the applicant proceed to make the qualifying investment or contribution. In some jurisdictions, funds must be placed in escrow pending final approval, while in others the contribution is made after a positive decision in principle. The sequencing is deliberate, ensuring that financial contributions do not influence the outcome of the legal assessment.

Following approval, the state issues a certificate of naturalisation or equivalent legal instrument confirming the grant of citizenship. The applicant may then apply for a passport and, where applicable, complete any remaining formalities such as an oath of allegiance. In some jurisdictions, enhanced checks may continue after approval in principle and before final document issuance. Processing times vary significantly between programmes, ranging from several months to over a year, depending on the complexity of the case and the level of due diligence involved.

Section summary
Citizenship by investment programmes operate through structured, government-controlled processes that prioritise due diligence and legal approval before financial contribution. The grant of citizenship is a sovereign act, supported by rigorous screening rather than speed or transactional certainty.

 

Section C: Which Countries Offer Citizenship by Investment in 2026?

 

Citizenship by investment is not a global norm. Only a limited number of states operate formal programmes that allow foreign nationals to acquire citizenship primarily on the basis of economic contribution. Even among those that do, the structure, stability and credibility of programmes vary considerably. For individuals considering this route, understanding which programmes are active, well-established and internationally recognised is critical.

The most prominent citizenship by investment programmes are found in the Caribbean. Countries such as Antigua and Barbuda, St Kitts and Nevis, Dominica, Grenada and St Lucia have operated programmes for many years and have developed mature administrative frameworks. These programmes typically involve a choice between a non-refundable contribution to a national development fund and an investment in approved real estate projects. Caribbean programmes are often favoured for their relative efficiency, established track record and the level of visa-free travel their passports provide.

In Europe, citizenship by investment options are significantly more limited. Malta operates a highly regulated route to citizenship based on exceptional services by direct investment. This is not an open investment-for-passport programme and involves stringent residence, due diligence and contribution requirements. Other European programmes that previously offered citizenship by investment, such as Montenegro, have been formally closed following political and regulatory pressure.

Beyond Europe and the Caribbean, a small number of states operate or have introduced citizenship by investment frameworks with varying levels of international visibility. These include jurisdictions such as Egypt, Jordan, Türkiye, Nauru, North Macedonia and São Tomé and Príncipe. The legal foundations and policy objectives of these programmes differ, with some designed to attract foreign direct investment and others focused on development funding or geopolitical positioning.

It is also important to distinguish between programmes that are currently open and those that have been suspended or terminated. Citizenship by investment schemes are particularly sensitive to international scrutiny, and states may amend, restrict or close programmes with limited notice. Historical availability does not guarantee ongoing access, and reliance on outdated information is a common source of error.

Section summary
As of 2026, citizenship by investment is offered by a small group of jurisdictions, most notably in the Caribbean, with limited and highly controlled options elsewhere. Programme availability is subject to change, and credibility depends on legal structure, governance and international acceptance.

 

Section D: How Much Does Citizenship by Investment Cost?

 

The cost of acquiring citizenship by investment is often summarised in headline figures, but the true financial commitment is more complex. While minimum investment thresholds are an important starting point, they rarely reflect the total cost of a successful application. For individuals considering this route, understanding the full cost structure is essential to informed decision-making.

Most citizenship by investment programmes offer a choice between different qualifying contributions. The lowest-cost option is typically a non-refundable donation to a government-approved fund, such as a national development or sustainability fund. These donation-based routes often have clearly defined minimum amounts, which may increase depending on the number of family members included in the application. While donations do not provide a recoverable asset, they are usually the simplest and fastest option.

Investment-based routes generally involve higher headline figures. Real estate options require the purchase of government-approved property, often subject to minimum holding periods before resale. In some jurisdictions, applicants may also access bond or business investment routes, though these are less common and often carry additional conditions. Although investment routes may allow for partial capital recovery, they expose applicants to market risk, liquidity constraints and regulatory conditions that can affect exit timing.

In addition to the core investment or donation, applicants must account for mandatory government fees. These can include application fees, due diligence fees, processing fees and passport issuance charges. Due diligence fees are often charged per applicant and may increase significantly where enhanced checks are required or where adult dependants are included.

Professional costs form another substantial component of the overall expenditure. Most programmes require the use of licensed agents or authorised representatives, whose fees reflect the complexity of the process and the level of compliance involved. Applicants may also incur legal, tax and advisory costs, particularly where citizenship planning forms part of a broader international structuring strategy.

When all elements are taken into account, the total cost of citizenship by investment frequently exceeds the advertised minimum by a considerable margin. Variations between programmes, family composition and investment route mean that accurate cost comparisons require careful, programme-specific analysis rather than reliance on headline figures.

Section summary
Citizenship by investment involves more than a single payment. In addition to the core contribution, applicants must budget for government fees, due diligence costs and professional expenses, all of which can materially increase the overall financial commitment.

 

Section E: What Rights and Benefits Does Citizenship by Investment Provide?

 

The primary benefit of citizenship by investment is the acquisition of full legal citizenship of the issuing state. This status carries a defined set of rights and entitlements under national law, which are distinct from those associated with residence permits or temporary immigration statuses. However, the practical value of these rights varies significantly depending on the jurisdiction granting citizenship and the individual’s personal objectives.

One of the most commonly cited benefits is enhanced global mobility. Many citizenship by investment programmes are offered by countries whose passports provide visa-free or visa-on-arrival access to a large number of destinations. This can reduce travel friction, simplify business travel and provide flexibility in personal and commercial planning. The scope of visa-free access is determined by bilateral agreements and international arrangements, and it can change over time as diplomatic relationships evolve.

Citizenship also confers an unconditional right of abode in the issuing country. Unlike residence permits, which are often time-limited and subject to renewal conditions, citizenship allows an individual to enter, reside and remain in the country indefinitely. This can provide a secure fallback option in times of political, economic or personal uncertainty, even if the individual has no intention of relocating immediately.

For many applicants, intergenerational planning is a key consideration. Citizenship acquired through investment is typically transmissible to future generations, subject to local nationality laws. This can create long-term security for children and descendants, offering them access to rights and opportunities that may not be available through their country of birth or primary nationality.

Citizenship may also facilitate access to financial and commercial systems. In some cases, holding citizenship of a particular country can ease interactions with banks, investment institutions or international counterparties. However, this benefit should not be overstated. Enhanced due diligence requirements and global financial compliance standards mean that citizenship alone does not eliminate scrutiny or guarantee access to financial services.

It is important to recognise the limits of the rights conferred. Citizenship of one state does not create automatic rights in other jurisdictions beyond those provided through visa-free travel arrangements. It does not override the immigration laws of third countries, nor does it guarantee favourable tax treatment or regulatory outcomes. The benefits of citizenship by investment are therefore specific, legally defined and subject to external constraints.

Section summary
Citizenship by investment grants full nationality of the issuing state, including the right of abode and passport privileges. While it can enhance mobility and long-term security, its benefits are jurisdiction-specific and should not be assumed to extend beyond what the law expressly provides.

 

Section F: Legal, Political and Reputational Risks of Citizenship by Investment

 

While citizenship by investment can offer significant advantages, it is not without risk. These risks are not limited to the individual applicant but extend to the durability of the citizenship itself and the international perception of the programme under which it was granted. Understanding these factors is essential for assessing whether citizenship by investment aligns with long-term personal and strategic objectives.

One of the principal legal risks is the potential for revocation. Many states that operate citizenship by investment programmes reserve the right to revoke citizenship if it was obtained through misrepresentation, fraud or concealment of material facts. In some jurisdictions, revocation powers extend further, allowing citizenship to be withdrawn where the individual later becomes involved in criminal activity or conduct deemed contrary to the national interest. The existence and scope of these powers are set out in domestic nationality legislation and should be examined carefully.

Citizenship by investment programmes are also subject to political risk. Changes in government, public opinion or international pressure can lead to programme reform, suspension or termination. Several jurisdictions have amended or closed programmes following concerns raised by international organisations or partner states. While changes to a programme do not usually affect citizenship already granted, shifts in political attitudes can influence how existing citizens are treated or perceived.

Reputational considerations have become increasingly important. Citizenship by investment programmes are closely scrutinised by international bodies concerned with financial crime, sanctions evasion and security risks. Applicants may find that holding citizenship acquired through investment attracts additional scrutiny from banks, regulators or counterparties, particularly where the programme has been the subject of criticism or heightened monitoring.

There is also a risk associated with over-reliance on intermediaries or promotional claims. Marketing narratives often emphasise speed, discretion and guaranteed outcomes, which can obscure the reality of discretionary decision-making and the possibility of refusal. Applications can and do fail at the due diligence stage, sometimes without detailed explanation, and investments may be delayed or complicated as a result.

Section summary
Citizenship by investment carries legal, political and reputational risks that extend beyond the application process. Revocation powers, policy change and international scrutiny mean that citizenship obtained through investment should be evaluated as a long-term legal status, not a risk-free asset.

 

Section G: Citizenship by Investment vs Residence by Investment

 

Citizenship by investment is often considered alongside residence by investment, but the two routes serve different legal and strategic purposes. Understanding the distinction is critical, as each carries different rights, obligations and levels of permanence. Choosing between them requires clarity on the outcome sought rather than a focus on speed or cost alone.

Residence by investment programmes grant foreign nationals the right to live in a country, usually on a temporary or renewable basis, in return for a qualifying investment. These programmes may lead to permanent residence or citizenship over time, but progression is not automatic. Applicants are typically required to meet physical presence requirements, maintain the qualifying investment and demonstrate ongoing compliance with local immigration rules.

Citizenship by investment, by contrast, results in the immediate acquisition of nationality once approved. There is usually no requirement to reside in the country either before or after naturalisation, and the status is not dependent on continued investment once any mandatory holding period has expired. This permanence is one of the key attractions of citizenship by investment but also one of its most significant legal consequences.

From a risk perspective, residence by investment offers greater flexibility. Residence permits can often be surrendered or allowed to lapse without lasting legal effect, whereas citizenship, once acquired, creates a permanent legal relationship between the individual and the state. This relationship may carry obligations as well as rights, depending on the jurisdiction, including potential tax, military or civic duties.

Residence programmes also tend to attract less international scrutiny than citizenship programmes. Because they do not confer nationality, they are generally viewed as less sensitive from a security and sovereignty standpoint. For some individuals, residence by investment may therefore represent a lower-profile or more adaptable option, particularly where eventual citizenship is not the primary objective.

Section summary
Citizenship by investment offers permanence and immediate nationality, while residence by investment provides conditional rights that may lead to citizenship over time. The choice between them depends on the individual’s objectives, risk tolerance and long-term planning horizon.

 

Frequently Asked Questions

 

Can you legally buy citizenship?
Citizenship cannot be bought in a commercial sense. Citizenship by investment operates through lawful nationality frameworks in which a state exercises its discretion to grant citizenship to eligible applicants who meet defined criteria, including an economic contribution. The grant of citizenship remains a sovereign legal act, not a private transaction.

Is citizenship by investment recognised internationally?
Citizenship granted under a lawful citizenship by investment programme is generally recognised internationally in the same way as any other nationality. However, the treatment of such citizenship in practice may vary, particularly where enhanced due diligence or additional scrutiny is applied by third states or institutions.

Which countries offer the most established citizenship by investment programmes?
Long-standing programmes are primarily found in the Caribbean, including Antigua and Barbuda, St Kitts and Nevis, Dominica, Grenada and St Lucia. Malta operates a highly regulated and selective citizenship route based on exceptional merit and contribution. Other programmes exist in a limited number of jurisdictions outside these regions.

Can citizenship obtained through investment be revoked?
Yes. Most jurisdictions reserve the right to revoke citizenship if it was obtained through fraud, misrepresentation or concealment of material facts. Some states also allow revocation in cases of serious criminal conduct or where citizenship is deemed contrary to the national interest, subject to domestic law.

Does citizenship by investment guarantee visa-free travel indefinitely?
No. Visa-free travel rights depend on bilateral agreements between states and can change over time. While a particular passport may offer extensive travel access at the time it is granted, future changes in diplomatic relationships or security policies can alter those arrangements.

 

Conclusion

 

Citizenship by investment is a lawful and increasingly prominent feature of global nationality planning for individuals of considerable means. It offers a route to full legal citizenship in a limited number of jurisdictions, grounded in sovereign discretion and supported by defined legislative frameworks. When properly understood, it can provide enhanced mobility, long-term security and intergenerational benefits.

At the same time, citizenship by investment is often mischaracterised. It is not a guaranteed transaction, nor is it insulated from legal, political or reputational risk. States retain wide powers over naturalisation, including the ability to amend programmes, apply stringent due diligence and, in defined circumstances, revoke citizenship after it has been granted. The benefits associated with a second passport are also jurisdiction-specific and subject to change as international relationships evolve.

For individuals considering citizenship by investment, the critical issue is not speed or headline cost but durability. Assessing the legal basis of the programme, the stability of the issuing state, the scope of revocation powers and the level of international acceptance is essential. Citizenship, once granted, establishes a permanent legal relationship between an individual and a state, and decisions taken in pursuit of it should reflect that significance.

Citizenship by investment should therefore be approached as a long-term legal status with strategic implications, rather than as a short-term mobility tool or financial product. A clear understanding of its limits, risks and consequences is fundamental to making a decision that will endure beyond immediate personal or geopolitical considerations.

 

Glossary

 

TermMeaning
Citizenship by InvestmentA legal process under which a sovereign state grants citizenship to a foreign national following a qualifying economic contribution and successful due diligence, exercised as a form of discretionary naturalisation.
Discretionary NaturalisationA form of citizenship acquisition where the state retains discretion to approve or refuse an application, even where statutory criteria are met.
Residence by InvestmentAn immigration status granted in return for an investment that allows an individual to live in a country without acquiring citizenship, usually subject to conditions and renewal requirements.
Due DiligenceMulti-layered background checks conducted by governments and specialist providers to assess an applicant’s criminal history, financial conduct, political exposure and reputational risk.
RevocationThe legal power of a state to withdraw citizenship after it has been granted, typically in cases of fraud, misrepresentation or conduct contrary to the national interest.
Naturalisation CertificateThe formal legal instrument issued by a state confirming that citizenship has been granted to an individual.
Right of AbodeThe unconditional right of a citizen to enter, reside in and remain in their country of nationality without immigration restriction.

 

Useful Links

 

ResourceLink
Henley & Partners – Citizenship by Investment Programmeshttps://www.henleyglobal.com/citizenship-investment
OECD – Global Forum on Transparency and Exchange of Informationhttps://www.oecd.org/tax/transparency/
European Commission – Investor Citizenship and Residence Schemeshttps://commission.europa.eu
Transparency International – Citizenship and Residence by Investmenthttps://www.transparency.org

 

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About our Expert

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Anne Morris

Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.She is recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals.
Picture of Anne Morris

Anne Morris

Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.She is recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals.

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The matters contained in this article are intended to be for general information purposes only. This article does not constitute legal advice, nor is it a complete or authoritative statement of the law, and should not be treated as such. Whilst every effort is made to ensure that the information is correct at the time of writing, no warranty, express or implied, is given as to its accuracy and no liability is accepted for any error or omission. Before acting on any of the information contained herein, expert legal advice should be sought.