EU citizenship by investment after the Malta ruling: what's left in 2026

No. There is no EU country where a donation, a bond purchase or a property purchase entitles you to nationality. The Court's judgment means that any Member State that created such a scheme would be in breach of Article 20 TFEU and Article 4(3) TEU^[1][2], and the Commission has pursued every scheme it identified since its January 2019 report named Bulgaria, Cyprus and Malta as the three states granting nationality to investors "under conditions which are less strict than ordinary naturalisation regimes"^[5].

What you can still buy is residence. Several EU countries issue residence permits to investors, and years spent on those permits can count toward ordinary naturalisation if you actually live in the country and pass its tests. That is a 5- to 10-year project, not a purchase. If you need a second passport within months, the realistic options are outside the EU, such as St Kitts and Nevis citizenship or Grenada's donation programme; our comparison of buying citizenship versus buying residence sets out the trade-off.

Beware of "EU passport" offers

Some agents still market Maltese "citizenship by merit" packages and Austrian "investor citizenship" with price tags. Malta's merit route has no price and its decisions need no reasons^[6][7]; Austria's route is a cabinet decision with no fixed amount^[9][10]. Treat any fixed-price promise of an EU passport as a red flag.

The case was an infringement action under Article 258 TFEU. The Commission sent Malta and Cyprus letters of formal notice on 20 October 2020, arguing that granting nationality "in return for pre-determined payments or investments without any genuine link" undermines EU citizenship^[4]. Cyprus closed its scheme; Malta replaced its Individual Investor Programme with the 2020 "MEIN" regulations, and the Commission referred it to the Court on 29 September 2022^[3].

The Court's reasoning

The Grand Chamber accepted that each Member State decides who its nationals are, but held that this competence must be exercised with due regard to EU law, because a Member State's nationals automatically become EU citizens with rights across the Union^[1]. EU citizenship rests on a special relationship of solidarity and good faith between a state and its nationals, and on mutual trust between Member States. A naturalisation procedure that is in substance a transaction, granting nationality in return for predetermined payments or investments, amounts to the commercialisation of national, and therefore EU, citizenship and is incompatible with that relationship^[1][2]. Commentators note that the Court based its decision on the transactional character of the scheme rather than on a strict "genuine link" test, which leaves residence-based naturalisation untouched^[8].

What the judgment did not do

The judgment declared a breach; it did not annul individual naturalisations. Malta's transitional rules state that citizenship acquired under the old rules remains valid, while unapproved investor files lapsed^[7]. Malta now offers only a discretionary "merit" route with no fixed contribution; see our full guide to what replaced Malta's investor citizenship.

Malta. The live route is the Malta Permanent Residence Programme (MPRP): a €60,000 administrative fee, a €37,000 contribution, a €2,000 donation, and a €375,000 property purchase or €14,000 a year in rent, plus €500,000 in assets (€150,000 financial) or €650,000 (€75,000 financial)^[33]. It gives permanent residence with no minimum stay, but MPRP time spent abroad does not build toward naturalisation, which needs residence throughout the 12 months before applying and four of the six years before that^[6].

Cyprus. Investors now use the Cyprus permanent residence permit under Regulation 6(2), typically a €300,000 investment plus a secured annual income of at least €50,000^[35]. Since the December 2023 amendment of the Civil Registry Law, naturalisation needs seven years of lawful residence in the last ten plus 12 continuous months before applying, B1 Greek and a civics test^[15]. Our page on the end of Cyprus's passport programme covers revocations in detail.

Bulgaria. A fund investment of BGN 1 million, restated as about €511,292 after Bulgaria adopted the euro on 1 January 2026, still gives permanent residence. Naturalisation then requires five years with permanent residence, good Bulgarian and, for most non-EU nationals, release from the previous citizenship^[18]. Investors who obtained permanent residence before the 2021 amendment kept a transitional right to apply if they maintained their investment for five years^[17]. See what happened to Bulgarian citizenship by investment and the live Bulgaria investor residence route.

Austria is the only EU Member State whose law still lets the government naturalise someone because of what they have done or will do for the country, including in business. Section 10(6) of the Citizenship Act 1985, a constitutional provision, says the residence period, the secured-livelihood test and the renunciation requirement fall away "if the Federal Government confirms that granting citizenship is in the special interest of the Republic because of the extraordinary achievements already made by the foreigner and still to be expected from him" (our translation)^[9]. The latest amendment to the Act, BGBl. I Nr. 39/2026 in force 12 June 2026, left this wording intact^[9].

The economic criteria

The Interior Ministry publishes criteria adopted by the Council of Ministers on 25 February 2014. For business, the applicant should own the company or hold a leading position with decisive influence (a board seat alone is not enough); make substantial investments or projects that have largely already been carried out; create and secure jobs in Austria, ideally in structurally weak regions; run an internationally recognised enterprise; and promote Austria's foreign economic relations^[10]. Mere transfers of money do not qualify^[10]. Science, sport and culture have their own criteria.

Process, fees and odds

Applicants send a reasoned request to the provincial citizenship authority, such as MA 35 in Vienna; the federal government, acting through the Council of Ministers, must confirm the special interest^[11][12]. No German test, livelihood proof or citizenship test is required, and the applicant does not have to give up their existing nationality^[11]. Vienna charges €163 for an adult application (€89 for a minor), payable even if the application is refused, and €1,918 when citizenship is granted^[11]. A Vienna law firm reports that procedures of several years are common and that the government decides on such cases irregularly^[12]. Austria publishes no breakdown of grants by field and no investment amount; figures of €3–10 million and more quoted by agents are market estimates, not law. Our guide to Austria's discretionary citizenship and the residence-only Austrian investor residence permit cover both routes.

Ranked purely by the statutory clock, Ireland (5 years in 9) and Malta (about 5 in 7) are shortest, but Ireland has no investor permit since 2023 and Malta's MPRP years count only if you actually live on the island^[26][6]. Bulgaria's five years start immediately because investors receive permanent residence on day one, but most non-EU nationals must give up their current citizenship^[18]. Greece (7 years) is the shortest route where an investor permit is itself a qualifying title for naturalisation, and its €250,000 entry point is among the lowest in the EU^[32]. Cyprus and Hungary need 8 years; Portugal, Italy, Spain and Austria need 10 for most non-EU nationals^{[15][30][29][22][27][9]}.

Speed on paper matters less than whether the country will count your years. Portugal is the classic example: its investment residence permit needs only 7 to 14 days of presence, and those years have historically counted as legal residence, but since 19 May 2026 the clock runs from the first permit issue and takes 10 years for most applicants^[29]. Our Portuguese naturalisation guide sets out the transitional rules. In Greece, the investor permit counts as a legal title, yet the PEGP exam and proof of five years' economic integration are hard to meet without living there^[32]; see the Greek naturalisation route and the Greek residence programme.

The Hungarian guest investor permit is cheap to hold and valid for up to 10 years, but naturalisation needs 8 years of continuous residence and an exam in Hungarian^[30][31]. Italy's investor visa requires 10 years and B1 Italian; a June 2025 referendum to cut the period to five years failed with turnout of 29.9%^[22][23][25]. Latvia's investor residence dropped its property and subordinated-deposit routes on 15 September 2026; the working route is now a €50,000 or €100,000 company investment plus a €10,000 state fee, while a new €150,000 state-fund route exists in law but cannot yet be used and is the target of a 3 September 2026 bill to delete it^[36][21][37]. Its naturalisation clock only starts with permanent residence^[19]. For a ranking across all regions, see our guide to residence routes with the fastest path to a passport.

Portugal, Greece, Italy, Malta, Cyprus, Hungary and Ireland allow you to keep your existing nationality when you naturalise^[15][26]. Spain, whose naturalisation rules require 10 years for most nationalities, requires a formal renunciation except for nationals of Ibero-American countries, Andorra, the Philippines, Equatorial Guinea and Portugal^[27]. Austria requires you to give up your previous citizenship unless you are naturalised under Section 10(6)^[9][11]. Latvia permits dual nationality only with EU, EFTA and NATO states, Australia, Brazil, New Zealand and treaty partners^[19], and Bulgaria generally requires release from the previous nationality for non-EU applicants^[18].

Your home country's law matters just as much: India and China, for example, end your original nationality when you naturalise elsewhere. If you already hold two passports, read our guide on holding three citizenships before applying.

The legal route for an investor is the same everywhere: residence first, citizenship later.

Under €300,000. Greece's €250,000 property routes, Hungary's €250,000 fund, Portugal's €250,000 cultural donation (€200,000 in low-density areas), Italy's €250,000 start-up investment and Latvia's €50,000–€100,000 company route (plus a €10,000 state fee and annual tax conditions) all buy residence; Latvia's €150,000 state-fund route is not operational^[36][21][37]. Of these, Greece offers the shortest naturalisation clock at 7 years. Compare them in our European residence programme comparison.

€300,000–€600,000. Cyprus permanent residence (€300,000) and Bulgaria's fund route (about €511,000) give permanent status immediately; Malta's MPRP costs about €99,000 in fees on top of property or rent^[33][35]. Spain's former investor visa and Ireland's investor programme are closed; our list of closed residence and citizenship programmes tracks them.

€5 million and more, with an operating business. Only here does Austria's Section 10(6) become a conversation, and only for an active, job-creating investment already under way^[10].

A passport in months. That means Caribbean or other non-EU programmes, which give Schengen visa-free travel but no right to live in the EU, and which now face the EU's new visa-suspension ground^[34]. Read our analysis of the EU visa-free risk for Caribbean passports, browse every live programme on the citizenship by investment hub, or see which purchasable passports travel furthest.

Citizenship itself rarely changes your tax position; residence does. Moving to qualify for naturalisation usually makes you tax resident in that country after about 183 days a year, so check the local regime first: Portugal's IFICI, Italy's flat tax for new residents, Greece's non-dom regime and Cyprus's non-domicile rules all have conditions and time limits. Also check exit-tax and inheritance rules in your current country. Our individual program pages cover each regime in detail.

The residence-to-citizenship route suits families prepared to relocate for 5–10 years, who want EU schooling, healthcare and business rights, and who can learn the local language. It suits founders who will run a real business in the country. It does not suit someone who wants a second passport for travel or contingency without moving: for them, a non-EU citizenship programme combined with an EU residence permit is the usual answer.