Caribbean Citizenship: EU Reforms and Safer Options for Investors

In April 2025, the Council of the European Union and the European Parliament reached a provisional agreement on a legislative amendment that revises the EU's visa suspension mechanism, originally introduced in 2013. The amended regulation is intended to strengthen the EU’s capacity to respond when visa-free travel arrangements are abused or when they conflict with the interests of the Union.

Key among the new grounds for suspension is the operation citizenship programmes which confer nationality without requiring a genuine link to the country, exchange for fixed financial contributions. The amendment empowers the EU to temporarily suspend visa-free travel for countries that maintain such schemes and, where circumstances remain unremedied, to proceed with permanent revocation.

Other grounds for suspension include:

• A third country’s failure to align its visa policy with that of the EU;
• Document security vulnerabilities and hybrid threats;
• A deterioration in bilateral relations, particularly in areas relating to human rights and the rule of law;
• An increase in asylum applications or overstays from nationals of the concerned country.

The revised mechanism will now allow an initial visa suspension period of 12 months, with a possible extension of up to 24 additional months, longer than the previous maximum duration. Notably, the EU will also have the option of applying targeted suspensions affecting only certain categories of individuals, such as government officials or those deemed responsible for breaches.

The Polish Minister for Foreign Affairs, Mr Radoslaw Sikorsi held:

“Visa-free travel to the EU benefits foreign citizens and the EU alike. But if citizens of third countries abuse this advantage, the EU must have all necessary tools in place to correct thesituation.”

For several years, Caribbean citizenship by investment programmes offered visa-free access to a number of high-demand jurisdictions, including the United Kingdom, Canada, and the Schengen Area. These benefits made Caribbean citizenship an attractive mobility tool for global investors, particularly those from regions affected by instability or visa constraints.

However, from 2023 onward, various jurisdictions began to revoke or review their visa-exemption agreements with Caribbean states. The UK and Canada led the way, citing security and due diligence concerns, including insufficient transparency in the vetting of applicants and a lack of ongoing monitoring post-naturalisation in Dominica. While Schengen access had remained intact, the new EU framework signals a firm intention to restrict such privileges where investor citizenship schemes are deemed incompatible with EU values or security interests.

This policy shift substantially reduces the utility of Caribbean passports for visa-free travel within Europe and raises questions about the long-term sustainability of CBI-based mobility strategies.

These developments present challenges for investors and global citizens who have acquired or were considering acquiring a second citizenship through citizenship by investment in the Caribbean. From a legal perspective, the loss of visa-free rights reconfigures the substantive value of such citizenships. It may also create reputational risks, especially in jurisdictions that view the acquisition of citizenship without residency as incompatible with public policy.

The broader international context is equally relevant. Increasing geopolitical tension, rising demands for international regulatory alignment, and mounting pressure from bodies such as the European Commission and the OECD have all contributed to a more restrictive environment. In such a climate, investor migration programmes that lack EU regulatory alignment may come under further pressure.

The Schengen Area is a zone of 29 European countries that have abolished internal border controls, allowing for passport-free movement between member states. Non-EU nationals who are granted permanent residence in Malta under the Malta Permanent Residence Programme (MPRP) enjoy visa-free travel within the Schengen Area for up to 90 days in any 180-day period. This facilitates seamless short-term travel across most of Europe for business or leisure, without the need for separate visas. As of 2025, the Schengen Area comprises the following 29 countries: Austria, Belgium, Bulgaria, Croatia, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden. Bulgaria and Romania officially joined the Schengen Area in 2025, expanding the zone’s reach and accessibility.

Against this background, the Malta Permanent Residence Programme (MPRP) stands out as a stable, EU-compliant pathway for acquiring permanent residence and Schengen access. Unlike CBI programmes, Malta's MPRP is a residence route that confers permanent residence rights but not citizenship.

Malta is a member of both the European Union and the Schengen Area, and has long maintained a strong rule of law, sound financial governance, and political stability. Its legal system is based on the civil law tradition, with a strong British common law influence in commercial and administrative matters. The country has a track record of regulatory compliance, including active participation in OECD and EU-level financial crime prevention frameworks.

Under the MPRP, successful applicants and their eligible family members are granted permanent residence status in Malta and visa-free access to the Schengen Area for up to 90 days within any 180-day period.

To obtain permanent residence under the MPRP, applicants must satisfy a number of cumulative legal and financial requirements:

1. Government Contribution: Applicants  must pay a one-time contribution of €110,000 if leasing a property or €80,000 if purchasing a qualifying property. An additional fee of €10,000 applies for each dependent.
2. Property Requirement: Applicants must lease a property in Malta with a minimum annual rent of €14,000 or purchase a property with a minimum value of €375,000. The property must be retained for at least five years. In order for the residence card to be renewed, the applicant must always have a property (rented or purchased) in Malta.
3. Philanthropic Donation: A mandatory contribution of €2,000 must be made to a Maltese-registered philanthropic, cultural, scientific, animal welfare, artistic, or sports NGO.
4. Wealth Threshold: Applicants must declare and prove possession of assets of at least €500,000, of which a minimum of €150,000 must be held in financial assets. Alternatively, they may declare €650,000 in total assets, with at least €75,000 held as financial assets.

Applicants must also demonstrate goodconduct, submit to rigorous due diligence checks, and show that they havestable and regular resources to support themselves and their dependents.

The MPRP reflects a model of residence by investment that emphasizes due diligence and transparency. It adheres to AML/CFT standards and ensures origin of funds verification, and disclosure of assets.

The MPRP offers a number of advantages forindividuals and families seeking long-term residency in Malta:

• Lifetime Residency for the main applicant and qualifying family members
• Single Application for the Whole Family, streamlining the process
• Inclusion of Unmarried, Financially Dependent Children up to age 28
• Inclusion of Financially Dependent Parents and Grandparents
• Retention of PR Status by Children, even if they marry or start working after approval
• Future Family Rights, allowing children who obtain PR with the main applicant to extend PR to their own spouse and children in the future
• Immediate Permanent Residence granted upon approval
• VisaFree Travel Across the Schengen Area
• No Physical Presence Requirement or Language Test
• Investment Required Only After Approval, reducing upfront financial risk

Our award-winning Immigration & Relocation Law practice is Malta’s longest-standing specialised immigration law team. Over the years, we’ve guided hundreds of clients, from expatriate retirees to high-net-worth individuals listed in the Fortune 500, on their journey to relocate to Malta.

We proudly promote Malta as a prime destination for investment and relocation, underpinned by the country’s long-standing traditions of hospitality and cultural diversity.

Our team provides comprehensive legal and tax advice tailored to the specific residence programme that best suits your circumstances. We offer clear guidance on eligibility, procedural requirements,and expected timelines. In addition to legal support, we assist with all practical aspects of relocation, including transportation, insurance, education, and healthcare.

Our Senior Partner, Dr Priscilla Mifsud Parker, a Licensed Agent under the Malta Permanent Residence Programme (MPRP), holds licence number AKM-ACCA.

Get in touch with us today.