🇪🇺Caribbean CBI Under Ultimatum: the EU's 2028 Deadline and US Entry Restrictions

The idea: a passport as an asset that now has a review date

Five Caribbean citizenship-by-investment programmes — Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, St Lucia — have been sold for thirty years as a liquid asset: a contribution to a fund, a few months of waiting, a passport with visa-free access to the Schengen area and the United Kingdom. By August 2026 that asset has, for the first time, an officially stated date by which its core consumer value may cease to exist: the European Commission has demanded in writing that the programmes be wound down by 1 June 2028. In parallel, an American proclamation signed on 16 December 2025 restricted entry for nationals of two of the five states, naming the presence of "CBI without residency" as the reason.

Two questions that agents' marketing material tends to merge need separating at the outset. Citizenship already acquired under the law of the issuing state cannot be revoked by either the EU or the United States — that is the exclusive competence of the issuer. Visa-free travel, by contrast, is a bilateral privilege withdrawn by a decision of the receiving side, with no hearing for individual holders. That is what is under threat. The wider point for readers with no Caribbean interest at all: this is the first time Brussels has attached a calendar date to the proposition that a passport can be bought, and the machinery it is using — the visa suspension mechanism — applies to every visa-free third country, not just these five.

The frame of the question in one table; each row is covered in the sections below.

The European track: where it is covered

The Commission's demand that the programmes be wound down by 1 June 2028 (Commissioner Magnus Brunner's letter of 25 June 2026 and the region's reply of 10 July 2026), the legal machinery of Regulation (EU) 2025/2441 with Articles 8a(1)(e), 8e(3) and 8f and its 12- and 24-month terms, the Vanuatu precedent carried through to the end, and the figures of the eighth report COM(2025) 792 are covered in full in the EU visa suspension mechanism. The European demands alongside the American restrictions, and the procedural checklist of what to verify on the date of application, sit in the review of citizenship by investment.

Regulation 2025/2441 and the eighth report

The anchor figures the country pages refer back to are collected here. Regulation (EU) 2025/2441 was adopted on 26 November 2025 and has applied since 30 December 2025: it made the operation of an investor citizenship scheme a free-standing ground for suspension (art. 8a(1)(e)) and lowered the "substantial increase" threshold from 50 to 30 per cent. The eighth report under the mechanism, COM(2025) 792 final of 19 December 2025, puts issuance across the five at roughly 107,000 passports, records applications falling from 13,113 (2023) to 10,573 (2024), and gives 2024 refusal rates: Antigua and Barbuda 1.7 per cent, St Lucia 5.3 per cent, Dominica 6.5 per cent; no figures are given for Grenada or St Kitts.

The Commission reads a low refusal rate not as praise but as an argument about weak vetting, and asks for its measures "pending the discontinuation of those schemes" — quality of administration does not, in itself, buy relief from the deadline. One caveat about the source: the Commission never published Brunner's letter, and its content is known from the addressees' own official statements — in particular the Antigua and Barbuda government release of 7 July 2026 — rather than from an EU primary source.

The nature of the deadline and the region's reply

The legal nature of the deadline reads precisely too: 1 June 2028 is written in the Commission's letter, not in the text of Regulation (EU) 2018/1806 — the regulation contains no such date. It is a political demand backed by the threat of an already operative mechanism, not a date that arrives automatically: legally the button can be pressed earlier or later. The only "2028" in the regulation itself is 31 December 2028, and it relates to the 30 per cent threshold, not to CBI. The region's reply is the joint statement of the five states of 10 July 2026: a high-level mission to Brussels, a single negotiating position and a demand for a compensating package — development finance, climate resilience, investment partnerships; the 1 June 2028 deadline is neither accepted nor even mentioned in it.

The American track: Proclamation 10998, trimmed visas and bonds

The United States is moving on its own logic and without transitional periods. The proclamation of 16 December 2025, Proclamation 10998, "Restricting and Limiting the Entry of Foreign Nationals To Protect the Security of the United States", took effect on 1 January 2026 at 12:01 a.m. EST. Of the Caribbean CBI jurisdictions, Antigua and Barbuda and Dominica were placed on the partial-restriction list (section 5), with the express reasoning that each "has historically had CBI without residency". Grenada, St Kitts and Nevis and St Lucia are not in the proclamation.

What a partial restriction covers

The perimeter of a partial restriction: entry is suspended for nationals of those two states on immigrant visas and on the nonimmigrant categories B-1, B-2, B-1/B-2, F, M and J, while consular officers are directed to reduce validity on any other nonimmigrant visa. This restricts entry, not issuance: the proclamation does not revoke visas already granted and does not touch lawful permanent resident status. The recitals spell out the mechanism Washington is closing: a national of a restricted country "may purchase CBI in a second country, obtain a passport from that second country, and then apply for a United States visa, thereby circumventing the restrictions". That distinction matters: the American measure strikes not at the issuing state as such but at the function of a Caribbean passport as a workaround.

Reciprocity and visa bonds

The second layer is consular practice. On 28 February 2026 the State Department revised the reciprocity schedules for Antigua and Barbuda and Dominica: B-1/B-2 validity was cut from 120 months with unlimited entries to three months, single entry, with comparable reductions for F, J, L and R. As at August 2026 the reciprocity schedules for both countries still list B-1, B-2 and B-1/B-2 on those "three months, one entry" terms — that is, visas in these classes continue to be issued, on materially worse conditions, while what is closed is entry on them.

The third layer is bonds: the Visa Bond Program rule, published and effective on 3 August 2026, made the 2025 pilot permanent and lets a consular officer require a bond of $10,000, $15,000 or $20,000 on issuing a B-1/B-2, with $15,000 as the default. The country list is published on travel.state.gov on 15 days' notice and changes administratively; it must be checked on the date of application, not against last year's write-ups.

The $200,000 price floor and the real 2026 price lists

The Memorandum of Agreement was signed on 20 March 2024: four states signed at the ceremony — Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis — and St Lucia acceded afterwards, so the OECS Commission release of 22 June 2024 names all five as signatories. The memorandum does not itself impose the floor: it bound the parties to raise the minimum to at least US$200,000 "no later than June 30, 2024", and the floor acquires legal force through each programme's own national instrument. The common regional date comes from that same OECS release: "With effect from July 01, 2024, all countries have agreed that the minimum price for any CBI options shall be US$200,000", which also states in terms that discounting below the agreed minimum is illegal. The dates differ across the five.

So 30 June 2024 is the memorandum's compliance deadline, not the date the floor took effect. By the same document the signatories undertook to create a common regional body and a digital portal for exchanging applicant data built on the Joint Regional Communications Centre (JRCC) of CARICOM IMPACS — what took shape eighteen months later as ECCIRA.

Ancillary fees above the floor

That memorandum and the subsequent OECS agreement of 23 September 2025 fixed a regional minimum of $200,000 and a ban on price wars. In practice the floor holds, but the spread above it is noticeable. Ancillary fees are priced per head, and how much they add depends on the programme and the family. The base is a single one: government fees only — due diligence, processing, the interview, the certificate of naturalisation and the passport, on the official schedules of the responsible units — with no licensed agent's or lawyers' remuneration in it. On those schedules the markup runs from about 5 per cent to about 15 per cent of the contribution. The two extremes are Dominica on the CBIU price list and Antigua and Barbuda under the CIP schedule of fees.

Three things follow from reading the table across. The cheapest contribution is not the cheapest route: Dominica's $200,000 carries the lowest overhead in the region at 5 to 6.6 per cent, while Antigua's $230,000 NDF adds about 15 per cent for a family of four, which closes most of the headline gap between them. The overhead is driven by the unit of charge rather than by the price list: Dominica prices a family as a single case, St Kitts charges $7,500 for each further person, and St Lucia charges nothing for children under 16 — so the same family can be the cheapest or the most expensive case in the region depending on the children's ages at the date of filing. And the fourth column is the one that will move: all five are visa-free for Schengen today and will simply need an ETIAS authorisation once the system starts, but visa-free status is exactly what the 2028 demand puts at risk, and two of the five have already lost visa-free entry to the United Kingdom without any EU involvement at all.

The 25–40 per cent estimates that circulate in agents' materials are computed on a different base — the contribution plus agent, legal and escrow fees — and are not government tariffs. Where an agency publishes no schedule at all, as in Grenada, the figure in the table is an industry compilation and needs confirming against the IMA's own quotation before any money moves.

The five programmes in figures

The first table covers money and timing, the second the visa side of the same five programmes.

The figures for Dominica, Antigua and St Kitts come from the official schedules of Dominica's CBIU, the Antigua CIP schedule of fees and the SISC description on the St Kitts CIU site; for Grenada and St Lucia the official agencies publish the options without amounts on their public pages, so the numbers are taken from industry compilations as an indication and need confirming with a licensed agent. Processing times follow a survey of actual 2026 waiting periods; the "three to six months" promised in most brochures no longer matches practice. Fees are counted separately: in Antigua, for instance, a single applicant adds $10,000 in processing fees to the NDF contribution, $8,500 in due diligence on the principal applicant and $5,000 on a spouse. The full-cost method is set out in the total cost of investment migration.

ECCIRA: a regional regulator, biometrics and a compulsory interview

The agreement signed on 23 September 2025 in Castries, Saint Lucia established the Eastern Caribbean Citizenship by Investment Regulatory Authority — the industry's first supranational regulator. It is headquartered in Grenada; the instrument runs to 99 articles; under article 95 it enters into force, and the body comes into being, on the thirtieth day after the fifth instrument of ratification is deposited, and withdrawal from the agreement is possible on six months' notice. National implementing statutes have been enacted by all five states — Dominica first, on 14 October 2025, with completion across all five recorded by the Eastern Caribbean Central Bank on 1 December 2025 — but neither the OECS nor the authority itself has publicly confirmed deposit of the fifth instrument of ratification; the subordinate standards and enforcement practice do not exist, and there is no board. As at August 2026 ECCIRA is not functioning supervision, and the agreed 30-day presence requirement does not apply as a regional rule.

What the agreement requires

The substantive obligations in the agreement run to seven items.

• a single minimum threshold of $200,000;
• mandatory biometric capture from all new applicants at interview and from previously approved applicants on passport renewal;
• interviews for applicants and adult dependants;
• regional registers of applicants, licensees and developers, with a shared database of approved, refused and revoked files;
• enhanced vetting through the Joint Regional Communications Centre within CARICOM IMPACS;
• annual public compliance reports;
• administrative fines and licence revocation.

A separate strand concerns presence: the regional standards introduce a minimum number of days in country after approval, and St Vincent and the Grenadines says its own programme will launch in 2026 with a residency requirement built in from the start.

St Kitts biometrics: the 31 July 2027 deadline

Some of those obligations are already being delivered by national measures, without waiting for the Authority's subordinate standards. On 14 April 2026 St Kitts and Nevis launched a national biometric enrolment and passport modernisation programme: every citizen must enrol, children from the age of five included, the deadline is 31 July 2027, and from 1 August 2027 the passports of those who have not enrolled are deactivated and cannot be used to travel. For the holder of a passport obtained through the investment programme this means biometrics has ceased to be a one-off episode at filing and become a permanent tether with a deadline of its own — administered by the same unit that ran the original vetting.

What changes for the applicant

For an applicant this changes the process, not just the price. Anonymous filing "on the papers, through an agent" is going away: there is now in-person or video contact with the authorities, biometrics and a trace in a shared database. A refusal in one country of the region is visible to the other four — so the strategy of filing wherever vetting is softest stops working. What is actually checked, and which profiles draw refusals, is covered in due diligence in investment migration.

What happens to a passport already issued

The analysis has moved to the piece on status risk in investment migration, where the Caribbean case is treated as the fifth closure scenario — "devaluation without revocation" — across the three levels of the answer: citizenship, visa-free access, and visa history and reputational trail. Whether the passport itself loses its force when visa-free travel is suspended is answered in the Q&A of the EU visa suspension mechanism.

Pricing the programme as an asset with a 2028 horizon

First, separate the objectives. If the passport was bought as insurance against loss of the primary document, as a base for tax planning on a territorial basis, or as a means of access to routes outside the EU and the US, the 2028 deadline barely touches that function — the citizenship remains. If the sole purpose is visa-free Schengen, then buying now means acquiring an asset with an announced risk of impairment on its key parameter by a stated date.

Second, model scenarios rather than headlines. There are three realistic branches. The five states accept the demands and stop taking applications — visa-free travel survives, and the secondary value of passports already issued holds at its present level. The parties settle on a softer construction (a hard residency requirement, full data exchange, sanctions filters) — the programmes survive in altered form. Or the talks break down and the Commission opens the procedure: 12 months of suspension, then extensions. Even in the third branch, time passes between the decision and the actual switch-off, and the procedure itself is public and observable.

Third, watch the calendar points. September 2026 — the interim measures on sanctions filters and enhanced vetting. December 2026 — the next Commission report under the suspension mechanism, the first formal assessment of the five states' responses. 1 June 2028 — the end of the transitional period as stated by the EU. None of these dates cancels anything automatically on its own.

Fourth, alternatives if it is specifically European access that matters. The most direct are routes that confer status inside the EU rather than visa-free entry from outside: residence by investment in Greece and Portugal, and talent and entrepreneur tracks with a path to naturalisation. All the European routes are surveyed in routes to EU citizenship, and the models of investment migration are compared by the type of status granted in the models overview. Applicants holding Russian passports face an additional layer of restrictions, set out in Russian applicants in investment migration.