State of Play: European Citizenship & Residency in 2025

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European Citizenship and Residency in 2025: Investment, Merit, Ancestry, Long-term Residence Options & the Principle of 'Contributive Belonging'

This Thought Leadership publication explores the shifting landscape of citizenship and residency in Europe, offering a strategic 2025 perspective for HNW and UHNW families. Country-specific updates highlight the spectrum of remaining options, some reformed: golden (temporary) visas, true Permanent Residence permits, Citizenship-by-Investment, Ancestry-based Citizenship, and Merit-driven recognition. We examine the impact of EU and national reforms, geopolitical pressures reshaping mobility rights, and the re-framing of citizenship and residency as alternative long-term asset classes in family wealth strategies. Strategic analysis explains what these developments mean for investors, entrepreneurs, and families in practice, and why host states - and the European Union - now expect a level of demonstrable belonging and contributions that tangibly benefit their economies and communities, a principle of 'Contributive Belonging' coined by the author in response to this industry evolution. This publication provides actionable insights for families, investors, and advisors navigating a complex and evolving legal and policy environment.

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Copyright © 2025 Chetcuti Cauchi. This document is for informational purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking any action based on the contents of this document. Chetcuti Cauchi disclaims any liability for actions taken based on the information provided. Reproduction of reasonable portions of the content is permitted for non-commercial purposes, provided proper attribution is given and the content is not altered or presented in a false light.

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jpc@ccmalta.com +356 22056111

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Dr. Jean-Philippe Chetcuti

Managing Partner

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Dr. Priscilla Mifsud Parker

Senior Partner

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Dr. Antoine Saliba Haig

Partner, Immigration & Global Mobility

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Marina Magri

Director, Immigration & Global Mobility.

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European Citizenship and Residency in 2025: Investment, Merit, Ancestry, Long-term Residence Options & the Principle of 'Contributive Belonging'

Key Legal Points

European citizenship and residency remain under national competence, but are increasingly shaped by EU policy and court rulings.‍
2025 reforms in Malta, Portugal, and other jurisdictions show a shift from transactional pathways to contribution-driven models.
Geopolitical dynamics - from US-EU relations to security concerns - are redefining mobility frameworks.
The framing of residency and citizenship as long-term asset classes is consolidating among HNW families and their advisors.
The newly coined principle of Contributive Belonging captures a future-oriented vision of integration and reciprocity.

The Evolution of Citizenship & Residency in Europe

European citizenship and residency rights have always sat at the intersection of national sovereignty and supranational oversight. While nationality remains a prerogative of Member States, EU jurisprudence — most recently the European Commission v. Malta judgment — demonstrates growing scrutiny of how Member States exercise this competence.

Historically, investment migration options across Europe flourished under a market-driven model. Malta, Cyprus, Portugal, and others created frameworks that appealed to globally mobile families. Yet, the last five years have seen these models tested by political challenges, media scrutiny, and supranational intervention.

2025 represents a turning point: national legislators are reframing access not merely as a matter of individual choice or fiscal benefit but as an opportunity to strengthen societal, cultural, and economic ties.

Geopolitical Pressures Reshaping Mobility and Citizenship

The 2020s have been defined by instability: war on Europe’s borders, sanctions regimes dividing East and West, and renewed strategic competition among global powers. These developments are reshaping mobility planning. Families are securing European residencies as a geopolitical hedge, ensuring access to safe jurisdictions, quality education, healthcare, and predictable legal systems.

Global families now face a mobility environment shaped by:

Security concerns: EU policymaking reflects heightened scrutiny of external actors, dual nationals, and applicants from sensitive jurisdictions.
US-EU dynamics: For American families seeking residence in Europe, policy shifts — including tax reforms in both blocs — are reshaping mobility strategies.
Demographic needs: Ageing populations in Europe drive states to balance restrictions with incentives to attract entrepreneurial and talent-based migrants.

These pressures point towards tighter alignment between immigration frameworks and long-term state interests.

Mobility is no longer about convenience but about resilience. In this climate, residence permits and citizenships are insurance policies against volatility. This explains why investors are prepared for longer timelines and stricter criteria if it means securing a base in Europe.

Citizenship & Residency as Asset Classes

Global families and their advisors increasingly approach citizenship and residency as asset classes, akin to trust structures or real estate portfolios. This shift reflects:

Risk diversification: Multiple residencies mitigate political, economic, and security risks.
Wealth and succession planning: Inter-generational transfer of status parallels inheritance planning.
Portfolio balancing: Families structure holdings of passports and residencies alongside tangible assets.

As mobility frameworks evolve, families are advised to view these rights not as one-off acquisitions but as ongoing, managed assets requiring compliance, governance, and stewardship.

The Principle of 'Contributive Belonging'

Contributive Belonging is the principle that the grant of long-term residency or citizenship should rest not only on formal criteria but on demonstrable integration and contributions — economic, social, cultural, or civic — that create reciprocal value for the host state.

This concept bridges the debate between sovereignty and supranationalism, offering a visionary framework for balancing individual aspirations with state interests. By embedding ties and contributions as core criteria, Contributive Belonging reframes mobility not as a privilege exchanged for payment, but as a mutually reinforcing bond between individuals and host nations.

While many frameworks focus narrowly on national integration, Contributive Belonging recognises the reality of globalisation and the lifestyle of financially free families. These individuals are often global citizens, maintaining professional, cultural, and business ties across multiple jurisdictions, sometimes spending no more than one to three months per year in any single country, including their country of origin.

The principle therefore calls for a balanced understanding of belonging: while meaningful ties to the host state remain essential, these must be seen in harmony with a broader global sense of belonging shaped by globalisation, mobility, and interconnectedness. Contributions can thus extend beyond the purely local to include:

Economic investment and entrepreneurial activity that strengthen the host economy.
Cultural and educational exchanges that enrich communities.
Professional and philanthropic engagement with global impact that still aligns with host-state values.

By embracing this duality, Contributive Belonging avoids the parochialism of traditional integration models and instead provides a standard suited for globally mobile, high-impact individuals and families. It acknowledges that residency and citizenship law must evolve alongside the reality of international mobility and interconnected lives whilst adhering to this year's European law precedent.

Merit-Based And Ancestry Routes On The Rise

Merit-based naturalisation remains highly selective. Austria recognises extraordinary contributions in science, art, or business, but requires a demonstrable record and parliamentary approval, failing mostly in the area of offering legal certainty expected by global investors. Malta’s reform direction points toward recognising innovators, global leaders, and cultural contributors, balancing discretion with investor attractiveness, whilst preserving Malta's hallmark due diligence. These routes illustrate a shift from transactional entry to recognition of meaningful impact.

Ancestry-based citizenship is expanding as families rediscover European roots. Italy, Ireland, and Poland allow descent-based citizenship in certain cases. This not only reconnects families with heritage but also underscores the principle that citizenship reflects long-standing ties to a community.

Both merit and ancestry routes highlight a central principle: citizenship is no longer a commodity but a recognition of belonging.

National Developments in 2025

European states continue to recalibrate their residency and citizenship frameworks in response to EU oversight, political pressures, and evolving mobility demands. Some have closed or restricted pathways, while others have reframed or improved their offerings to align with broader contribution-based models.

Malta

Malta has transitioned to a citizenship by merit framework, phasing out its previous investment-based route. The focus is now on measurable contributions and ties, such as philanthropy, entrepreneurship, and innovation projects, consistent with the emerging principle of Contributive Belonging. In residency, the MPRP framework remains robust, recently enhanced to clarify dependency rules and streamline contribution requirements.

Portugal

Portugal has closed its golden visa property investment route, reflecting concerns over housing pressures. However, it continues to attract global families through entrepreneurship, research, and cultural contribution channels. The D7 visa (for passive income earners) and the tech visa (for entrepreneurs and professionals) remain important pathways.

Greece

Greece has introduced higher minimum investment thresholds for its golden visa programme, aimed at curbing speculative real estate pressure. At the same time, it continues to position itself as a Mediterranean hub for investors and retirees, balancing accessibility with greater focus on economic and cultural integration.

Spain

Spain has confirmed plans to phase out its golden visa programme, citing housing affordability. Alternative pathways — including entrepreneurial visas, talent-based residencies, and family reunification options — remain central, though subject to greater scrutiny regarding applicants’ contributions.

Cyprus

Cyprus maintains a long-term residence regime but has permanently closed its citizenship by investment framework following EU pressure. Its residency by investment route remains available, though tightened, with greater oversight on financial sources and compliance.

Italy

Italy continues to expand its elective residency and investor visa options, especially for UHNW families seeking lifestyle relocation and succession planning benefits. Tax reforms, including the lump-sum regime, enhance its attractiveness, though applicants are increasingly expected to demonstrate active contributions to the Italian economy and cultural landscape.

United Kingdom

Post-Brexit, the UK has fully closed its Tier 1 Investor visa, replacing it with innovator and talent-based visas. Permanent residency and citizenship remain obtainable but subject to stringent presence requirements. The UK increasingly links residency to business creation and high-value contributions.

Switzerland

Switzerland continues to offer residency through lump-sum taxation agreements, though negotiations with EU and domestic political debates introduce uncertainty. Its highly structured approach appeals to HNW families seeking stability and predictable tax treatment.

What This Means For You

For globally mobile families, 2025 marks a shift from transactional acquisition towards substantive ties and meaningful contributions. Applicants must demonstrate how their presence benefits the host country, whether through economic participation, cultural engagement, or civic involvement.

Advisors must therefore guide families not just in structuring applications, but in designing integration strategies that align with the principle of Contributive Belonging.

How Our Global Citizenship & European Residency Lawyers Can Help You

At Chetcuti Cauchi Advocates, we have over 25 years of experience advising international families on residency and citizenship solutions in Malta and across Europe. Our lawyers bring expertise in immigration, private client tax, corporate structuring, and family governance.

We assist families in:

Designing multi-jurisdictional residency portfolios.
Navigating EU policy developments and national reforms.
Structuring contribution and integration strategies aligned with state expectations.
Ensuring compliance, governance, and inter-generational continuity of citizenship and residency rights.

FAQs – European Citizenship & Residency In 2025

[question]How is European citizenship different from permanent residency? [/question]

[answer]European citizenship confers EU-wide rights, while permanent residency offers long-term settlement in a single Member State, often with pathways to citizenship.[/answer]

[question]What is changing in 2025? [/question]

[answer]Reforms in Malta, Portugal, and other jurisdictions reflect a pivot towards contribution-based models, embedding ties as a central criterion.[/answer]

[question]What does Contributive Belonging mean in practice? [/question]

[answer]Applicants are expected to demonstrate integration and contributions that benefit the host state — economically, socially, culturally, or civically.[/answer]

[question]Can American families still access European residencies? [/question]

[answer]Yes, though tax and geopolitical considerations require careful structuring. Our firm regularly advises on US-EU cross-border planning.[/answer]

Key contacts

jpc@ccmalta.com +356 22056111

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