The End of Direct EU Citizenship by Investment
By 2026, every fast-track citizenship-by-investment programme that once granted European Union nationality without prior residence had been closed. Malta's final scheme—officially titled the Granting of Citizenship for Exceptional Services by Direct Investment Regulations—stopped accepting new applications in early 2025, ending a two-decade era of passport-for-capital arrangements across the bloc.
The closure wave began in November 2020 when Cyprus terminated its €2 million citizenship programme after governance concerns raised by the European Commission. Bulgaria followed in 2022, suspending its fast-track route. Malta's programme survived until 2025, when the European Court of Justice ruled that granting EU citizenship primarily for payment—rather than on the basis of genuine connection to a member state—contravened EU treaty principles.
Between 2013 and 2020, the Cyprus Investment Programme granted citizenship to approximately 7,000 individuals, generating over €9 billion in foreign direct investment. Malta's predecessor scheme, the Individual Investor Programme (2014–2020), issued around 1,400 passports before being replaced by the 2020 regulations that ultimately closed in 2025.
What Remains: Residency-by-Investment Pathways
In 2026, the only legal route to EU citizenship for third-country nationals is through residency-by-investment programmes—commonly known as golden visas—followed by naturalisation. These schemes grant temporary or permanent residence permits in exchange for qualifying investment, then require applicants to meet residence, language, and integration criteria before applying for citizenship.
The residency-first model means a minimum timeline of five to ten years, depending on the member state. Portugal historically required five years of legal residence before citizenship applications, but legislative changes in late 2025 extended that threshold to ten years for most golden-visa holders. Greece, Cyprus, Hungary, Italy, and Latvia maintain similar long timelines, typically seven to ten years.
Because residence programmes do not automatically confer tax residency, investors must separately consider physical-presence thresholds. Most EU member states apply the 183-day rule: individuals who spend more than half the year in-country become tax residents, liable for worldwide income tax. Some jurisdictions—notably Italy with its flat-tax regime and Cyprus with its non-domicile provisions—offer concessionary regimes for new residents, provided strict conditions are met.
Comparison of Remaining EU Residency-by-Investment Programmes
The table below consolidates the current investment thresholds, citizenship timelines, and key tax features of the six main EU golden-visa routes still operating in 2026. Every threshold and timeline cited is drawn from the research briefing and legacy source materials; no Tier-1 government URLs were available at the time of writing for some jurisdictions.
| Country | Minimum investment | Citizenship eligibility | Language requirement | Corporate tax rate | Notes |
|---|---|---|---|---|---|
| Portugal | €500,000 (qualifying fund or research donation); alternative 10-job creation route | 10 years legal residence | A2 Portuguese | 21 % | 2025 reform extended residence from 5 to 10 years; real-estate route discontinued |
| Greece | €250,000 (property outside Athens/Thessaloniki/islands); €400,000 or €800,000 in high-demand zones | 7 years | B1 Greek | 22 % | 2024 legislation introduced tiered pricing by location |
| Cyprus | €300,000 (property) | 8 years | B1 Greek | 12.5 % | Direct citizenship programme closed Nov 2020; residency route remains; non-dom regime available |
| Hungary | €250,000 (registered real-estate fund, ≥40 % Hungarian residential property) | 8 years | B1 Hungarian | 9 % | Guest Investor Residence Permit launched July 2024 |
| Italy | €250,000 (innovative start-up); €500,000 (limited company); €1 million (philanthropy); €2 million (government bonds) | 10 years | B1 Italian | 24 % | Investor visa for innovators or philanthropists; separate €200,000/year flat-tax regime available to new tax residents |
| Latvia | €50,000 (equity in Latvian company); €250,000 (real estate); €280,000 (government bonds) | 10 years | B1 Latvian | 20 % | Cheapest EU entry point by equity route; property and bond routes more expensive |
Sources for figures in this table: research briefing drawn from goldenvisas.com and getgoldenvisa.com advisory summaries. Tier-1 government URLs were not returned by web search at time of publication. Readers should verify current thresholds and timelines with the relevant national immigration authority before committing capital.
Tax Residency Versus Citizenship
Holding an EU residence permit does not automatically trigger tax residency. Tax liability is governed by domestic rules—typically the 183-day threshold—and bilateral tax treaties. An investor who spends fewer than 183 days per year in Portugal, for instance, may maintain residence status without becoming a Portuguese tax resident, preserving the option to establish tax residence elsewhere, such as Dubai or Monaco.
Conversely, spending more than half the year in-country will usually bring worldwide income and capital gains into the scope of the host state's tax system. Italy's €200,000-per-year flat tax (raised from €100,000 in 2024) and Cyprus's non-domicile provisions offer partial shelter for foreign-source income, but both require careful structuring and annual filings to maintain compliance.
Once citizenship is granted, tax-residency rules remain unchanged: citizenship alone does not create a tax obligation. A naturalised Portuguese citizen living in the UAE and spending fewer than 183 days in Portugal each year will not owe Portuguese income tax, though Portugal retains the right to tax Portuguese-source income regardless of residence.
Why EU Citizenship Still Matters in 2026
Despite the closure of fast-track programmes, demand for EU citizenship through residency routes remains robust. An EU passport grants the right to live, work, study, and retire in any of the 27 member states without further permits, plus access to the European Economic Area (Iceland, Liechtenstein, Norway) and Switzerland under separate treaties.
EU citizens enjoy visa-free or visa-on-arrival access to over 180 jurisdictions worldwide, materially simplifying cross-border business and family travel. For entrepreneurs operating across multiple continents, the ability to enter the United States under the E-2 treaty (available to some EU nationalities) or Australia's Electronic Travel Authority streamlines regulatory friction.
Succession and estate planning are simplified when the entire family holds a common EU nationality. Inheritance laws across EU member states vary—forced-heirship regimes in France and Spain contrast with freedom-of-disposition rules in Cyprus and Malta—but an EU passport allows testators to elect the law of their nationality under the EU Succession Regulation (650/2012), providing certainty for cross-border estates.
Country-Specific Routes
Portugal
Portugal's residency-by-investment programme requires a minimum €500,000 contribution to a qualifying Portuguese investment or venture-capital fund, or €500,000 in support of scientific research or the arts. A third route—creating or maintaining at least ten permanent jobs in a Portuguese company—requires no monetary threshold beyond the salary and incorporation costs.
The 2025 legislative changes abolished the real-estate investment route (previously €500,000 for property outside Lisbon and Porto) and extended the mandatory residence period before citizenship application from five years to ten. Applicants must demonstrate basic proficiency in Portuguese (A2 level) and show ties to the Portuguese community, typically through tax filings, rental agreements, and utility accounts.
Portugal taxes residents on worldwide income at progressive rates up to 48 %, but does not impose a wealth tax. Non-habitual-resident (NHR) status—available to new tax residents who have not been Portuguese tax residents in the prior five years—offers a ten-year exemption on most foreign-source income, though this regime is under periodic legislative review.
Greece
Greece's golden visa requires a minimum €250,000 investment in real estate located outside Athens, Thessaloniki, Mykonos, and Santorini. Properties in those high-demand zones face higher thresholds: €400,000 for residential conversions and €800,000 for new builds, reflecting 2024 legislation intended to moderate housing-market pressure in tourist areas.
Residence permits are valid for five years, renewable indefinitely. Citizenship eligibility opens after seven years of legal residence and passing a B1-level Greek-language examination. Greece taxes worldwide income for tax residents at progressive rates up to 44 %, with a flat-rate alternative tax option at €100,000 per year for new residents who transfer tax residence to Greece and declare foreign-source income separately.
Cyprus
Cyprus offers permanent residence permits to investors who purchase property worth at least €300,000. The permit is granted for life, provided the applicant maintains the property and does not work in Cyprus (passive income and self-employment through a Cypriot company are permitted). After eight years of legal residence and passing a B1 Greek-language test, naturalisation becomes possible.
The Cypriot corporate tax rate is 12.5 %, among the lowest in the EU. Non-domiciled individuals—those who have not been Cypriot tax residents for at least 17 of the prior 20 years—are exempt from tax on dividend and interest income sourced outside Cyprus, making the jurisdiction attractive for holding companies and passive investment structures. However, Cyprus tightened residence-proof requirements in 2024, mandating at least 60 days of physical presence per year to maintain non-dom status, a shift from the previous nominal-presence rule.
Hungary
Hungary launched its Guest Investor Residence Permit in July 2024, requiring €250,000 in units of a Hungarian National Bank-registered real-estate fund that invests at least 40 % of its assets in Hungarian residential property. The permit is valid for ten years, renewable, and includes immediate family members.
Citizenship is available after eight years of legal residence, subject to passing a B1 Hungarian-language examination and a test on Hungarian constitutional order. Hungary applies a flat 9 % income tax on employment income and a 9 % corporate tax rate, both exceptionally low within the EU. However, Hungary does not offer non-dom or remittance-basis regimes; all worldwide income is taxable for Hungarian tax residents.
Italy
Italy's investor visa for innovative start-ups requires a minimum €250,000 equity investment in an Italian innovative company, certified by the Ministry of Economic Development. Alternative routes include €500,000 in shares of an Italian limited company, €1 million donated to a philanthropic initiative of public interest, or €2 million in Italian government bonds.
Residence permits are granted for two years, renewable. After ten years of legal residence and passing a B1 Italian-language test, investors may apply for citizenship. Italy taxes worldwide income for residents at progressive rates up to 43 %, plus regional and municipal surcharges.
New tax residents can elect a flat-tax regime that charges €200,000 per year (raised from €100,000 in 2024) on all foreign-source income, capped and ring-fenced from Italian progressive rates, for up to fifteen years. The regime requires the individual to transfer tax residence to Italy and file an annual election with the Agenzia delle Entrate; once the fifteen-year cap is reached, ordinary progressive taxation applies.
Latvia
Latvia's programme offers the lowest equity-investment threshold in the EU: €50,000 in share capital of a Latvian company that employs at least five people and has annual turnover of at least €50,000. Real-estate and government-bond routes require €250,000 and €280,000 respectively.
Residence permits are valid for five years, renewable. Citizenship eligibility opens after ten years of legal residence, subject to passing a B1 Latvian-language examination. Latvia taxes worldwide income for residents at a flat 20 % on most income types (31 % on annual income exceeding €78,100) and applies a 20 % corporate tax rate, with the notable feature that retained profits are tax-deferred until distribution.
Language and Integration Requirements
Every EU member state imposes language and civics testing before naturalisation. Minimum proficiency levels range from A2 (Portugal) to B1 (Greece, Cyprus, Hungary, Italy, Latvia). Applicants must typically demonstrate continuous legal residence (not just permit validity), evidenced by tax returns, rental contracts, and utility bills, to satisfy the "genuine links" standard upheld by the European Court of Justice.
Prolonged absences can reset the residence clock. Portugal, for example, disqualifies periods where the applicant spent more than six consecutive months or eight non-consecutive months outside the country in a calendar year. Greece and Cyprus allow more flexible presence requirements during the permit phase but enforce stricter timelines once citizenship applications are lodged.
Outlook: Tightening Rules and Rising Thresholds
The trend across the EU since 2020 has been toward longer waiting periods, higher investment minimums, and stricter presence requirements. Spain closed its golden visa entirely in 2025; Ireland never offered one. The European Commission continues to scrutinise remaining programmes for compliance with anti-money-laundering directives and the principle that citizenship should reflect genuine integration, not solely economic contribution.
Investors considering an EU residency-by-investment route in 2026 should anticipate further regulatory tightening. Programme closures, threshold increases, and enhanced due-diligence checks—already routine in Malta and Cyprus—are likely to spread to Portugal, Greece, and newer entrants such as Hungary. Legal and tax advice should be secured before committing capital, and applicants should verify that current published rules remain in force at the time of application, as legislative amendments can occur with limited notice.
Last verified: 2025-06-20
