After Malta’s Golden Passport Collapse: What Investors Should Know About the Future of EU and Caribbean Programs

By Hyong-jin Kwon September 22, 2025

When the European Court of Justice (ECJ) finally slammed the door on Malta’s “golden passport” program earlier this year, it didn’t just end one country’s experiment in citizenship for cash — it signaled the twilight of an entire era in Europe’s investment migration industry.

For high-net-worth individuals and global entrepreneurs, the question is no longer whether “golden passports” can survive in the EU (they can’t), but where and how to recalibrate their global mobility and wealth strategies.

Europe: The End of Easy Citizenship

Malta’s model, which allowed citizenship in exchange for an investment of around €750,000 with minimal residence requirements, has been declared incompatible with EU law. The ECJ emphasized a principle that investors cannot ignore: EU citizenship is not a commodity. It must be earned through genuine ties — residence, integration, or contribution — not simply purchased.

The ruling comes on the heels of Spain scrapping its real estate Golden Visa, Portugal closing the property route, and Cyprus bowing out years earlier. Europe has drawn its red line: while residence-by-investment may continue in highly regulated forms, fast-track passports tied only to financial transfers are history.

For investors, the message is clear: in Europe, the game is shifting toward active participation — founding companies, creating jobs, investing in innovation, or engaging in long-term funds. The “buy and hold” property routes are disappearing, replaced by models that expect investors to contribute to the real economy.

The Caribbean: Opportunity and Risk

Contrast that with the Caribbean, where five nations still run successful Citizenship by Investment programs. For investors who need speed and certainty, the Caribbean offers what Europe has taken away: passports within months, visa-free access to dozens of countries, and relatively straightforward processes.

But the ECJ ruling still casts a long shadow. Pressure from Brussels, Washington, and London is mounting. Banks and governments worry about security, due diligence, and money flows. The Caribbean’s programs must now choose: professionalize and tighten controls — or risk reputational damage and possible erosion of visa-free privileges.

For investors, this means opportunity with caution. Caribbean passports remain a valuable mobility hedge, but buyers should weigh the long-term sustainability of these programs. A passport is only as strong as the international trust behind it.

Beyond Passports: Smarter Investment Strategies

The end of Europe’s golden passports doesn’t mean the end of investor mobility. It means that the playbook is evolving. Here are the strategies forward-thinking investors are already exploring:

1. Company Founding & Active Investment

   • Many EU countries now welcome entrepreneurs through start-up visas and innovation programs. By founding a company, employing locals, and contributing to national economies, investors can still secure residency pathways that, over time, lead to citizenship.

   • Think less “real estate lock-in” and more “venture creation.”

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2. Diversification of Domicile

   • Wealth managers are increasingly advising clients to build a portfolio of domiciles, not just one second passport. Residency in a stable EU jurisdiction, combined with citizenship in a Caribbean state and perhaps a tax-friendly domicile in the Gulf or Asia, creates resilience against political or regulatory shifts.

   • Diversification is the new diversification — not just in assets, but in sovereign ties.

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3. Digital Assets, Crypto & Stablecoins

   • For globally mobile investors, financial sovereignty is as important as physical mobility. Stablecoins and crypto can complement traditional diversification, offering cross-border liquidity and insulation from banking bottlenecks.

   • Some forward-looking jurisdictions are beginning to integrate blockchain technology into residency or e-citizenship frameworks, hinting at a future where digital identity and digital wealth interact seamlessly.

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4. Hybrid Models: Lifestyle + Citizenship

   • Investors are also reconsidering lifestyle investments: eco-resorts, wellness ventures, blue economy projects. These not only create business returns but also fit with residency/citizenship options in countries emphasizing sustainability and innovation.

The Investor’s Lens

From a purely transactional perspective, Europe’s message is a loss: one fewer shortcut. But from a strategic investor’s perspective, it’s a chance to rethink mobility. Citizenship should not just be a “plan B passport” — it can be part of a diversified, future-proof plan that combines residence, lifestyle, financial agility, and digital freedom.

In short: the golden passport era may be over in Europe, but the age of smart, diversified citizenship has just begun.

For investors willing to adapt, the opportunities are richer — and more resilient — than ever.

While “golden passports” (citizenship by investment) are effectively dead in the EU after the ECJ’s Malta ruling, several Golden Visa programs (residency by investment) still exist in Europe. These remain attractive for investors who value residency rights, Schengen access, or property diversification — even if they no longer guarantee fast-track EU citizenship.

Greece: Europe’s Star Performer

Greece continues to host one of the most popular Golden Visa schemes in Europe. For a minimum real estate investment of €250,000–€500,000 (depending on region), investors secure a five-year renewable residence permit, with family inclusion. While it doesn’t lead to immediate citizenship, Greece offers an appealing mix of lifestyle, climate, and Schengen mobility — making it a prime choice for investors seeking both utility and lifestyle benefits.

Cyprus: Residency, Not Citizenship

After shutting down its citizenship program in 2020, Cyprus restructured around permanent residency by investment. The typical entry point is a €300,000 real estate purchase, plus proof of stable income from abroad. The program provides long-term security on the island and indirect benefits of EU residence, though applicants must still live in Cyprus to eventually qualify for naturalization.

Malta: A Two-Track System

While the ECJ ended Malta’s direct sale of citizenship, the country still runs a residency by investment program. Known as the Malta Permanent Residence Programme (MPRP), it requires a property purchase or lease, plus a government contribution and donation. For investors seeking EU residency rights without the controversy of passports-for-cash, the Maltese route remains viable — though tightly monitored.

Hungary: Back in the Game

Hungary re-entered the RCBI market in 2024 with its Guest Investor Residence Permit. Investors may secure five years of renewable residency by investing in real estate or government bonds (minimum around €250,000–€500,000). While Hungary is not part of the Schengen zone’s core passport pathways, the program is gaining attention for its simplicity and relatively low thresholds.

Latvia: Affordable but Quiet

Latvia operates one of Europe’s most affordable Golden Visas, allowing residency through property purchases starting at €250,000, or business investment. While it receives less international attention than Portugal or Greece, it remains a functional entry point into the EU, particularly for investors from Eastern Europe and the CIS region.