The End of EU Citizenship by Investment is Here – are Golden Visas Next?

A landmark court ruling means EU citizenship by investment schemes will soon be a thing of the past. Could residency by investment be next?

By Alex Schulte | 30 April 2025

Some things are priceless. And now, legally speaking, Maltese citizenship is one of them, according to the European Court of Justice (CJEU).

On 29 April, the European Union’s top court ruled that Malta must scrap its ‘golden passport’ scheme. Since 2020, this programme has allowed wealthy investors to purchase permanent citizenship of the island – and, by extension, the wider European Union.

This is a decisive judgment that almost certainly spells an end to a significant and controversial trend in European immigration law.

What is EU Citizenship by Investment?

In recent years, several EU states have allowed wealthy foreign investors to obtain national citizenship, granting citizenship rights for the European Union as a whole, in exchange for significant injections of cash.

Colloquially known as ‘golden passports’, such schemes have typically fetched a price tag of up to €2 million, with investments largely made in real estate and national development funds.

Which countries offer EU citizenship by investment?

Malta is the last EU country to offer a ‘pay-to-play’ citizenship by investment scheme.

Malta’s golden passport

Malta’s scheme, officially known as the Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment, offers naturalisation in exchange for significant economic contributions.

These entail a direct minimum investment of:

• €600,000 (after a 36-month residency) or
• €750,000 (after a 12-month residency) non-refundable contribution to the National Development and Social Fund (NDSF).

This is on top of a property commitment, where one must either:

• Purchase a residential property worth at least €700,000; or
• Rent a property with a minimum annual rent of €16,000.

And that’s not all. Applicants must donate at least €10,000 to a registered Maltese NGO.

Places are scarce, limited to just 400 applicants per year.

The CGEU’s ruling means that Malta will almost certainly end its scheme in the very near future.

In the past, both Cyprus and Bulgaria both offered fast-track citizenship to major investors in real estate. But both yielded to pressure from the European Commission and terminated their schemes in 2020 and 2022 respectively.

Austria’s special exception

Only one other EU member state still grants any citizenship rights through investment: Austria. But unlike Malta, Austria does not have a formal golden passport programme. Instead, it grants citizenship without prior residence in highly exceptional circumstances to those deemed to make significant and direct contributions to the country’s interests.

Also unlike the Maltese scheme, investments such as real estate or government bonds are not eligible. The applicant must make a substantial contribution to the Austrian economy through investments in Austrian businesses that create jobs and spur innovation.

Approval is extremely rare, with only 20-30 individuals accepted each year. The non-transactional nature of the scheme and its rarity suggests Austria is unlikely to face the censure of the EU courts, though it may come under greater scrutiny to tighten its citizenship requirements yet further.

Why is the EU Banning Golden Passports?

So how to understand the CJEU’s latest move and its implications for the future of citizenship by investment schemes in Europe as a whole? We should start by thinking about the basic principles that bind together the country’s 27 member states.

Cultural integrity and fairness

The EU isn’t just a trading bloc. It’s a community of nations tied together by history, geography and common ties that extend back thousands of years. Since its inception, the EU has been as much a cultural project as an economic one. The bloc has sought to cultivate a coherent, supranational European identity, based on shared values.

Citizenship of one EU member state grants citizenship of the EU as a whole. EU officials thus perceive golden passport schemes as a blow to the integrity of the project: a way to commodify the privileges and basic meanings of EU citizenship. The CJEU said as much in their ruling. Their judges described Malta’s investor-citizenship as “the commercialisation of the grant of the nationality of a member state and, by extension, of union citizenship”.

Privileged access for the rich is also seen as an affront to the vast majority of naturalised citizens who had to follow conventional channels without the benefits of huge wealth.

Crime, security and geopolitics

Golden passport schemes are also seen as a weak spot in Europe’s security architecture. EU officials worry they may provide backdoors for criminals, or individuals from hostile or sanctioned states, to gain access to the entire bloc. Golden passports are, in some European officials’ eyes, an open invitation for wealthy criminals to bypass regular immigration and citizenship processes. This creates channels for illicit financial flows that can circumvent anti-money laundering controls

This also has a significant geopolitical aspect. In the aftermath of Russia’s 2022 invasion of Ukraine, the EU was forced to grapple with just how many applicants for golden passports and their related ‘golden visa’ programmes were Russian nationals and suspected oligarchs. With the full rights of EU citizens to live, work and travel across the Schengen Area, they could enjoy impunity from sanctions and shelter their gains from the law.

Adverse impacts on local economies

Offering citizenship or residence as an added bonus for property investors is an invitation for real estate speculation. This has created documented distortion effects in housing markets, with negative effects on local residents.

All of these pressures have finally come to a head in the CJEU’s effective ban on citizenship by investment. But what is conspicuous is that many of these downsides also feasibly apply to the much more common routes for residence by investment, commonly known as ‘golden visas’.

What is the Difference Between a Golden Passport and a Golden Visa?

Over 100 countries, from Saudi Arabia to Montenegro, now offer residency rights in exchange for investment. By making a significant financial investment, often in real estate, business, or government bonds, foreign nationals can obtain residency rights in a country. Golden visa holders and their families gain the ability to live, work, and access essential services like healthcare and education in the host country.

However, a golden visa does not grant citizenship or a second passport outright. It may provide a pathway to permanent residency or citizenship after several years, but these are subject to additional requirements such as minimum stay periods and language tests, depending on the country.

This is a markedly different proposition to the permanent (and inheritable) rights of citizenship granted by golden passport schemes. It opens eventual routes to obtaining citizenship, but eligibility will normally depend on several years of permanent residence. However, the regulatory tide may be turning against residence by investment schemes too.

Why Europe’s Golden Visa Schemes Might Soon Be in Danger

The European Commission has been calling for tighter regulation of golden visa programs since 2019. In their opposition to residence by investment, officials and lawmakers make similar arguments to those used against golden passports.

European politicians and commentators have blamed golden visas schemes for enabling corruption, overheating housing markets and fundamental unfairness. In response, EU countries including Spain, the Netherlands and Ireland have either entirely closed their residency by investment schemes or, in the case of Portugal, removed property from the list of eligible investments.

Others, like Greece, Hungary, and, yes, Malta, are still defying the pressure from Brussels and offering residency rights in exchange for hefty investments in real estate. But the Maltese golden passport ruling may be the opening shot in an official campaign to outlaw residence by investment in the EU.

Left-wing MEPs have been advocating for a ban since 2018. And now, in response to the CJEU’s Malta ruling , campaign groups like Renew Europe are calling for ‘concrete proposals to counter the practice across the EU’, which would include:

• More stringent background checks
• Requirements for minimum physical residence
• Higher taxes on revenues generated.

The pendulum may be swinging.

What an End to EU Golden Visa Schemes Would Mean for Businesses

While wealthy individuals have always been the main market for golden visas, businesses and Global Mobility have found their uses for them too.

Golden visa schemes have provided a fast-track route for relocating top executives, investors and senior hires to Europe. This has created a windfall for local property agents, relocation specialists and immigration service firms.

But local businesses in other sectors have benefited from higher investment too. In Italy, where buying property is not an eligible route for golden visa, businesses received over €22 million from golden visa customers in 2022.

If golden visas were outlawed, we expect that the distorting effects of speculative real estate investment would be one of the primary reasons given. This may push more countries to adopt Austria and Italy’s model of only granting (rare) residence rights for those making substantial, productive investments in the ‘real economy’. Relocation specialists in target European locations would have to swiftly recalibrate their pitches to talk up the benefits of investment in other asset classes, like equity in local start-ups or government bonds.

Equally, corporate Global Mobility teams may soon no longer be able to rely on a strategic one-off investment in a luxury Cyclades condominium as a quick way to get top executives into the EU. Instead, they would have to navigate the significantly more complicated, standard immigration routes of the EU and visa-free Schengen Area.

Stay briefed on every legal change

In the aftermath of the CJEU’s ruling, it is highly possible that European golden visas will begin to to be more highly scrutinised and pared back.

Uncertainty will rein in the short-term. But whenever the law changes, we will keep you updated.

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