# Caribbean CBI Under Ultimatum: the EU's 2028 Deadline and US Entry Restrictions > The EU wants Caribbean CBI programmes wound down by 1 June 2028 or Schengen goes; the US already restricts Antigua and Dominica. What issued passports face. Author: Maria Plotnikova — Lawyer, Family Office (https://wiki.private.law/en/authors/plotnikova) Last modified: 2026-08-14T13:11:00.000Z Canonical: https://wiki.private.law/en/caribbean-cbi-2028 Topics: migration Jurisdictions: dominica, eu, usa, global Product tags: permanent-residence, relocation, compliance Semantic tags: permanent-residence, relocation, compliance --- ## 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 Visa-free travel, by contrast, is a bilateral privilege withdrawn by a decision of the receiving side, with no hearing for individual holders.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 Brunner letter: 1 June 2028 and an interim deadline in September 2026 The letter was signed by Magnus Brunner, the EU Commissioner for Internal Affairs and Migration; it is dated 25 June 2026 and addressed to the heads of government of the five states. Its contents were made public by Gaston Browne, Prime Minister of Antigua and Barbuda, and reported by the trade press; the Commission has not published the text, so formally this is diplomatic correspondence rather than a legal act. The construction is as follows. The states are offered a 24-month transitional period, with applications to stop being accepted altogether by 1 June 2028. The interim milestone is September 2026, by which two measures are expected: complete exclusion from the programmes of persons subject to EU restrictive measures \(sanctions lists\), and enhanced vetting of applicants of all nationalities. The five governments answered on 10 July 2026 at a meeting in Roseau, Dominica, attended also by St Vincent and the Grenadines, which is preparing a programme of its own. The joint response mentioned neither the 1 June 2028 date nor the Schengen threat: the states agreed to dialogue and to sending a delegation to Brussels, but tied any abandonment of the programmes to compensating development finance. Browne separately stated that his government "will not be coerced" into a unilateral wind-down. The Caribbean side's bargaining position is economic, and the regulator confirms it: on the [Eastern Caribbean Central Bank's figures](https://www.eccb-centralbank.org/blogs/eccu-citizenship-by-investment-a-make-or-break-era), CBI receipts in 2025 came to 4.3 per cent of the Eastern Caribbean Currency Union's GDP and 14.5 per cent of government revenue. That is not a marginal line item but a load-bearing one — which makes a swift voluntary exit unlikely and, at the same time, explains why the EU chose a long transitional period rather than an immediate sanction. > ⚠️ **The standard mistake when reading the headlines.** The "1 June 2028 deadline" is neither the date visa-free travel ends nor a rule of law. It is a date in a Commission letter, after which what follows is not an automatic Schengen switch-off but the opening of a procedure under the regulation, with stages and timelines of its own. The opposite mistake is no less dangerous: that because it is "only a letter", nothing will happen. Vanuatu shows the procedure gets carried through to the end. ## Legal mechanics: Regulation 2025/2441 and what can actually be suspended Until the end of 2025, the mere existence of a citizenship-by-investment programme was not in itself a ground for suspending visa-free travel — the Commission had to argue its case through migration and crime statistics. [Regulation \(EU\) 2025/2441 of 26 November 2025](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ%3AL_202502441), amending Regulation \(EU\) 2018/1806, fixed that. It was published in the Official Journal on 10 December 2025 and entered into force on 30 December 2025. The operative provision is Article 8a\(1\)\(e\): a ground for suspension now arises from "the operation, by a third country listed in Annex II, of an investor citizenship scheme under which citizenship is granted to a person, in exchange for pre-determined payments or investments, without that person having any genuine link to that third country". The test is qualitative: it requires no statistics on abuse and is not tied to the 30 per cent "substantial increase" threshold the regulation introduced for migration-based grounds in place of the former 50 per cent. It is enough that the scheme operates and that a finding is made of no genuine link — a term the regulation itself does not define. Timeframes and instruments. An initial suspension is imposed by a Commission implementing act for 12 months \(Article 8e\); extension runs by delegated act for 24 months \(Article 8f\), with a further 24-month extension possible if the circumstances persist. More consequential for a private client is something else: Article 8e\(3\) allows a suspension to apply not to all nationals of a country but to specific categories, identified by reference to types of travel document. Technically, then, a scenario is possible in which visa-free access survives for citizens by birth and is withdrawn from holders of passports issued through the investment route — provided such passports are distinguishable by series or issue date. The legal backdrop was set by the Court as well: on 29 April 2025 the Grand Chamber of the Court of Justice, in [Case C-181/23 Commission v Malta](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A62023CJ0181), held the Maltese scheme incompatible with EU law. The case concerned a Member State rather than a third country, but the reasoning — that nationality cannot be a commercial transaction absent a genuine connection — has been carried into the visa regulation almost verbatim. On the now-closed Maltese route, see [Malta Citizenship by Merit](https://wiki.private.law/en/malta-citizenship-merit). ## The Vanuatu precedent: a full procedural cycle in under three years Vanuatu is the only completed case, and it shows the real tempo. The visa waiver agreement with the EU had applied from 28 May 2015. Partial suspension came in May 2022, full suspension by Council decision of 8 November 2022. The end point was [Regulation \(EU\) 2025/11 of 19 December 2024](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ%3AL_202500011): Vanuatu was moved from Annex II \(visa-exempt\) to Annex I, published on 14 January 2025 and in force on the twentieth day thereafter. That is no longer a suspension but a change of status. The reasoning in the EU's preparatory documents describes precisely the defects Brussels is now looking for in the Caribbean: applicants had no direct contact with the Vanuatu authorities and sat no in-person interview, processing ran from 14 to 30 days, and of 1,988 applications in 2022–2023 only 27 were refused — under one and a half per cent. Continued acceptance of Russian nationals after 2022 was noted separately. The practical consequences for holders: passports remained valid, no one's citizenship was revoked, but a Schengen visa became compulsory. The United Kingdom travelled the same road earlier and faster — from 19 July 2023 visas were imposed on nationals of Dominica, Vanuatu, Honduras, Namibia and Timor-Leste. On the specific programme, see [Vanuatu: citizenship by investment](https://wiki.private.law/en/cbi-vanuatu). ## 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](https://www.federalregister.gov/documents/2025/12/19/2025-23570/restricting-and-limiting-the-entry-of-foreign-nationals-to-protect-the-security-of-the-united-states), 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. The perimeter of a partial restriction: immigrant visas plus the nonimmigrant categories B-1, B-2, B-1/B-2, F, M and J. 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. 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. The third layer is bonds: the [Visa Bond Program rule](https://www.federalregister.gov/documents/2026/08/03/2026-15726/visas-visa-bond-program), 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](http://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. > ⚙️ **A procedural checklist before buying.** Verify on the date of application, not from an agent's deck: \(1\) the current Annex II to Regulation 2018/1806 in the consolidated version on EUR-Lex — is the country still on the visa-free list; \(2\) the live country list in the US proclamation and the State Department reciprocity schedule for that specific country; \(3\) the Visa Bond Program country list on [travel.state.gov](http://travel.state.gov/); \(4\) the official price schedule of the country's CIU or IMA, not an aggregator; \(5\) whether national legislation implementing the ECCIRA standards is in place. None of the five is stable over a 12-month horizon. ## What the Commission's report shows: volumes issued and refusals The most substantive primary document on the merits of the complaint is the [Commission's report COM\(2025\) 792 of 19 December 2025](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=COM%3A2025%3A792%3AFIN) on third countries' compliance with visa-free requirements. On its figures, the five Eastern Caribbean programmes have issued some 107,000 passports in total, and application flow remains high — 13,113 in 2023 and 10,573 in 2024. The Commission treats the refusal rate as an indicator of vetting quality: 1.7 per cent in Antigua and Barbuda, 5.3 per cent in St Lucia. Harmonisation of the minimum threshold at $200,000 and the strengthening of individual screening elements are recorded, but the conclusion is unchanged: the situation "continues to give rise to serious concerns". That is the bar against which delivery of the September interim measures will be judged. The next regular report under the suspension mechanism is expected in December 2026 — and that will be the first formal point at which the Commission assesses the five states' responses. No legal action against them has been announced before that date. ## The $200,000 price floor and the real 2026 price lists The 2024 memorandum of understanding and the subsequent [OECS agreement of 23 September 2025](https://pressroom.oecs.int/oecs-sets-standards-for-citizenship-by-investment-programmes-cbicip-to-safeguard-their-integrity-and-sustainability) 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, and ancillary fees often add 25 to 40 per cent to the contribution. | Programme | Minimum contribution, USD | Real estate, USD | Average processing in 2026 | US restrictions | UK visa | | --- | --- | --- | --- | --- | --- | | Dominica | 200,000 \(EDF\) | 200,000, hold 3 years | 9.3 months | Partial restriction from 01.01.2026; B-1/B-2 three months, single entry | Required from 19.07.2023 | | Antigua and Barbuda | 230,000 \(NDF\); 260,000 \(UWI fund\) | 300,000 | 14.2 months | Partial restriction from 01.01.2026; B-1/B-2 three months, single entry | — | | Grenada | around 235,000 \(NTF\) | IMA-approved projects | 7 months | — | — | | St Lucia | around 240,000 \(NEF\) | approved projects | 18 months | — | — | | St Kitts and Nevis | 250,000 \(SISC\) | from 325,000 | 5.1 months | — | — | The figures for Dominica, Antigua and St Kitts come from the official schedules of [Dominica's CBIU](https://cbiu.gov.dm/investment-options/), the [Antigua CIP schedule of fees](https://cip.gov.ag/schedule-of-fees/) and the [SISC description on the St Kitts CIU site](https://ciu.gov.kn/press-invest-in-st-kitts-and-nevis-the-sustainable-island-state-contribution/); 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](https://wiki.private.law/en/investment-migration-total-cost). ## ECCIRA: a regional regulator, biometrics and a compulsory interview The agreement of 23 September 2025 established the Eastern Caribbean Citizenship by Investment Regulatory Authority — the industry's first supranational regulator. It is headquartered in Grenada; the instrument runs to 92 articles; 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. Industry reporting has all five parliaments ratifying by mid-2026, but the body of subordinate standards and the actual enforcement practice are still taking shape — treating ECCIRA as functioning supervision as at August 2026 would be premature. The substantive obligations in the agreement: 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. 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](https://wiki.private.law/en/investment-migration-due-diligence). > 💡 **The practical takeaway.** The EU's demands and ECCIRA's logic point the same way: turning CBI into a residency programme with a verifiable connection. For a client who is prepared to spend days in the country and sit an interview anyway, the tightening is close to neutral. For a client who was buying anonymity and speed, the product has already changed — and will change further by 2028 regardless of how the talks with Brussels end. ## What happens to a passport already issued The practical answer splits into three levels, and they should not be confused. Citizenship. Neither the EU nor the United States has power to annul it. Revocation is possible only under the national law of the issuing state and, as a rule, only where status was obtained by deception — a concealed conviction, false information, forged documents. Regulators do hold those powers and do use them: Grenada's IMA is expressly empowered to revoke citizenship granted on the basis of misrepresented information. None of the five states has announced a mass review of previously issued passports. Visa-free access. This is exactly what gets withdrawn — and without any individual hearing. Vanuatu shows the mechanics: the passports remained, the Schengen visa became compulsory. More than that, Regulation 2025/2441 permits a suspension to be applied to specific categories of travel document, so a variant is theoretically possible in which investment passports are separated from "ordinary" ones. How to read visa-free rankings in that light is discussed in [the passport index](https://wiki.private.law/en/passport-index) and in the rules on [the Schengen 90/180 count](https://wiki.private.law/en/schengen-90-180). Visa history and reputational trail. The US restrictions do not cancel previously issued visas automatically, but the shortened validity in the reciprocity schedules applies on the next issuance, and a Caribbean passport as a second document now draws additional questions from consular officers and banks more often. For a bank's compliance function, a second citizenship bought without relocation is a standard trigger for source-of-funds enquiries. ## 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](https://wiki.private.law/en/greece-golden-visa) and [Portugal](https://wiki.private.law/en/portugal-golden-visa), and [talent and entrepreneur tracks](https://wiki.private.law/en/talent-routes-models) with a path to naturalisation. All the European routes are surveyed in [routes to EU citizenship](https://wiki.private.law/en/eu-citizenship-routes), and the models of investment migration are compared by the type of status granted in [the models overview](https://wiki.private.law/en/investment-migration-models). Applicants holding Russian passports face an additional layer of restrictions, set out in [Russian applicants in investment migration](https://wiki.private.law/en/russian-applicants-investment-migration). > 🍓 In short. On 25 June 2026 the European Commission demanded in writing that Antigua, Dominica, Grenada, St Kitts and St Lucia wind down their citizenship-by-investment programmes by 1 June 2028, with interim measures due by September 2026; the legal basis is Regulation \(EU\) 2025/2441, which made the operation of such a programme in itself a ground for suspending visa-free travel. The United States moved harder and faster: the proclamation of 16 December 2025 restricted entry for nationals of Antigua and Dominica from 1 January 2026, and from 28 February 2026 their B-1/B-2 visas were cut to three months, single entry. Passports already issued are not being revoked — only visa-free access is at risk, and the Vanuatu precedent shows the procedure is carried through to the end. Buying Caribbean citizenship for Schengen in 2026 means buying an asset with a published review date; buying it for insurance, mobility outside the EU and tax structuring is a decision the 2028 deadline affects only weakly. ## Questions and answers ### **Can Caribbean citizenship already granted be taken away because of the EU's demands** No. Revocation is the exclusive competence of the issuing state and, under its own law, is generally possible only where status was obtained by deception: a concealed conviction, false information, forged documents. The EU's demand is addressed to governments and concerns stopping new applications, not reviewing passports already issued. None of the five states has announced a mass review. ### **What exactly happens to visa-free travel if the states miss the 1 June 2028 deadline** There is no automatic switch-off. Under Regulation \(EU\) 2025/2441 the Commission imposes a suspension by implementing act for 12 months, may then extend it by delegated act for 24 months and once more for 24. A suspension can also be applied selectively, to particular categories of travel document. The final stage, as with Vanuatu, is moving the country from Annex II to Annex I of Regulation 2018/1806 — a permanent visa requirement. ### **Are all five countries covered by the US restrictions** No. The proclamation of 16 December 2025, effective from 1 January 2026, placed only Antigua and Barbuda and Dominica on the partial-restriction list — in both cases the reasoning refers expressly to CBI without a residency requirement. Grenada, St Kitts and Nevis and St Lucia are not included. The reduction of B-1/B-2 validity to three months from 28 February 2026 likewise affected only Antigua and Dominica. ### **Is there any point buying a Caribbean passport in 2026** It depends on the objective. For visa-free Schengen, this is the purchase of an asset with a publicly announced risk of impairment on its key parameter by a stated date. For insurance against loss of a primary document, mobility outside the EU and the US, access to a territorial tax regime or, in Grenada's case, the E-2 visa, the 2028 deadline matters moderately. The answer rests not on forecasting the talks but on which function of the passport is critical. ### **What does the genuine link requirement mean in practice** Regulation 2025/2441 uses the term genuine link but does not define it. In practice the content comes from the ECCIRA standards and national rules: an in-person interview for the applicant and adult dependants, biometrics, a minimum number of days of presence in the country after approval, a single regional register. The direction of travel is turning CBI into a residency programme; a genuine willingness to spend time in the country becomes part of the product rather than an option. ### **When will the outcome of the negotiations become clear** The first substantive point is September 2026, the deadline for the interim measures: excluding persons subject to EU restrictive measures and enhanced vetting of applicants of all nationalities. The second is December 2026, the next Commission report under the suspension mechanism, in which the five states' responses will be assessed. No formal legal action against them has been announced before December 2026. --- ## FAQ ### Can Caribbean citizenship already granted be taken away because of the EU's demands No. Revocation is the exclusive competence of the issuing state and, under its own law, is generally possible only where status was obtained by deception: a concealed conviction, false information, forged documents. The EU's demand is addressed to governments and concerns stopping new applications, not reviewing passports already issued. None of the five states has announced a mass review. ### What exactly happens to visa-free travel if the states miss the 1 June 2028 deadline There is no automatic switch-off. Under Regulation (EU) 2025/2441 the Commission imposes a suspension by implementing act for 12 months, may then extend it by delegated act for 24 months and once more for 24. A suspension can also be applied selectively, to particular categories of travel document. The final stage, as with Vanuatu, is moving the country from Annex II to Annex I of Regulation 2018/1806 — a permanent visa requirement. ### Are all five countries covered by the US restrictions No. The proclamation of 16 December 2025, effective from 1 January 2026, placed only Antigua and Barbuda and Dominica on the partial-restriction list — in both cases the reasoning refers expressly to CBI without a residency requirement. Grenada, St Kitts and Nevis and St Lucia are not included. The reduction of B-1/B-2 validity to three months from 28 February 2026 likewise affected only Antigua and Dominica. ### Is there any point buying a Caribbean passport in 2026 It depends on the objective. For visa-free Schengen, this is the purchase of an asset with a publicly announced risk of impairment on its key parameter by a stated date. For insurance against loss of a primary document, mobility outside the EU and the US, access to a territorial tax regime or, in Grenada's case, the E-2 visa, the 2028 deadline matters moderately. The answer rests not on forecasting the talks but on which function of the passport is critical. ### What does the genuine link requirement mean in practice Regulation 2025/2441 uses the term genuine link but does not define it. In practice the content comes from the ECCIRA standards and national rules: an in-person interview for the applicant and adult dependants, biometrics, a minimum number of days of presence in the country after approval, a single regional register. The direction of travel is turning CBI into a residency programme; a genuine willingness to spend time in the country becomes part of the product rather than an option. ### When will the outcome of the negotiations become clear The first substantive point is September 2026, the deadline for the interim measures: excluding persons subject to EU restrictive measures and enhanced vetting of applicants of all nationalities. The second is December 2026, the next Commission report under the suspension mechanism, in which the five states' responses will be assessed. No formal legal action against them has been announced before December 2026. --- ## Factual claims - The letter was signed by Magnus Brunner, the EU Commissioner for Internal Affairs and Migration; it is dated 25 June 2026 and addressed to the heads of government of the five states. - Until the end of 2025, the mere existence of a citizenship-by-investment programme was not in itself a ground for suspending visa-free travel — the Commission had to argue its case through migration and crime statistics. - The legal backdrop was set by the Court as well: on 29 April 2025 the Grand Chamber of the Court of Justice, in Case C-181/23 Commission v Malta, held the Maltese scheme incompatible with EU law. - The perimeter of a partial restriction: immigrant visas plus the nonimmigrant categories B-1, B-2, B-1/B-2, F, M and J. - The most substantive primary document on the merits of the complaint is the Commission's report COM(2025) 792 of 19 December 2025 on third countries' compliance with visa-free requirements. - The 2024 memorandum of understanding and the subsequent OECS agreement of 23 September 2025 fixed a regional minimum of $200,000 and a ban on price wars. - The agreement of 23 September 2025 established the Eastern Caribbean Citizenship by Investment Regulatory Authority — the industry's first supranational regulator.