The European Parliament has initiated critical legislative updates to EU Regulation 2018/1806, targeting visa-free travel privileges extended to certain third countries under Citizenship by Investment (CBI) programs. The proposal, passed on March 19 by the Committee on Civil Liberties, Justice and Home Affairs (LIBE) with 41 votes in favor, 10 against, and 21 abstentions, now advances through the EU’s legislative framework. If implemented, the revised regulation would revoke visa-free Schengen Area access for citizens of Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and St. Lucia.
Background and Justification
The move is a direct response to growing concerns over the integrity and security risks associated with investor citizenship schemes, often referred to as “golden passport” programs. These schemes allow individuals to obtain citizenship without a meaningful connection to the issuing country, solely based on financial investment. EU lawmakers have emphasized that such programs can be exploited for purposes including tax evasion, money laundering, and illicit travel, thereby undermining the Union’s border security and common visa policy.
While the European Union respects the sovereign rights of countries to set their own naturalization policies, it opposes the practice of leveraging visa-free EU access as an incentive to attract foreign capital. The EU previously acted in a similar manner in 2022 by suspending visa-waiver privileges for Vanuatu following transparency and security concerns surrounding its investor citizenship model.
Impact on Investment Migration and RCBI Markets
The proposed changes mark a pivotal shift in EU policy toward third-country investor citizenship programs. They may also signal increased regulatory scrutiny on residence-based investment migration programs (commonly known as “Golden Visas”) across Europe. Notably, while the proposed regulation targets CBI schemes, its implications may reverberate through the broader Residency and Citizenship by Investment (RCBI) ecosystem.
For instance, Greece’s popular Golden Visa program—which grants residency in exchange for real estate or capital investment—could come under greater review. Although Greek residency does not confer immediate citizenship, the visa-free access it provides to the Schengen Zone may place it under the lens of EU compliance and regulatory audits. Similar programs in Portugal, Spain, and Malta have already faced calls for reform amid geopolitical and economic recalibrations across Europe.
Strategic Opportunities for Program Reform
Amidst tightening regulations, countries operating investment migration schemes have a strategic opportunity to reinforce transparency, due diligence, and alignment with EU values. Greece, in particular, can leverage this momentum to further enhance its Golden Visa program by integrating robust vetting procedures and redefining its investment criteria to attract long-term, value-driven investors.
Moreover, a shift in policy focus—from transactional citizenship models to holistic residency frameworks that support local economies—could bolster the legitimacy and resilience of such programs. Enhanced compliance mechanisms, cooperation with EU institutions, and the establishment of unified standards across member states could also pave the way for a harmonized European approach to investment migration.
Conclusion
The European Parliament’s initiative is not just a regulatory shift—it is a clear signal of the EU’s commitment to preserving the integrity of its common travel area. As the global RCBI industry continues to evolve, proactive adaptation and alignment with international standards will be key to ensuring the continued viability and credibility of investment migration programs.
