How the Industry Began
The "passports for investment" market is older than it looks. St Kitts & Nevis opened it with its 1984 Citizenship Act, a year after independence from Britain. A small sugar economy needed revenue, and the state offered a passport in exchange for a development contribution. The program stayed niche for decades; Henley & Partners took it to the global market in 2006, and the neighbours copied the model — Dominica, Grenada, Antigua and St Lucia.
Europe walked the same road and burned itself fastest. Cyprus launched golden passports in 2013 at a €2m+ threshold and shut them in 2020 after the Al Jazeera investigation. Malta held out until the EU Court's 2025 ruling. Meanwhile the industry reached systemic scale: the five Caribbean programs alone issued about 107,000 passports by the European Commission's estimate, the investment-migration market is valued at over $20bn a year, and roughly a dozen and a half citizenship programs operate worldwide: the Caribbean five, Vanuatu, Türkiye, Egypt, Jordan — and, since 2025, Nauru and El Salvador's Freedom Passport.
The key parameters of the Caribbean route as of August 2026.
| Regulator | ECCIRA — the five's agreement of 23 September 2025; as of August 2026 the authority is not operating |
|---|---|
| Who is covered | The applicant, spouse and children; many programs add parents, some add siblings |
| Threshold | Non-refundable contribution from US$200,000 (Dominica, EDF) |
| Timeline | From 5.1 months (St Kitts) to 18 months (St Lucia), Q4 2025 data |
| All-in cost | ~$211,000 (Dominica) – ~$275,000 (St Kitts) for a single applicant |
| Presence | 5 days within the first five years in Antigua; the agreed 30 days do not yet apply |
| Tax effect | Citizenship creates no tax residence; all five programs sit on the OECD high-risk CRS list |
| Status on the date | Malta's scheme closed by C-181/23; the Commission demands a Caribbean wind-down by 1 June 2028 |
The sections below unpack each of them and show where the programs diverge.
The Concept
Citizenship by Investment (CBI) is a second citizenship in exchange for a non-refundable contribution to a state fund or a qualifying investment (usually real estate), without a long-residence requirement. Of all the routes it is the fastest: a decision within months, usually no relocation, no language exams, no renunciation of the first passport. Citizenship changes nationality and mobility — but it does not by itself make you a tax resident of the new country. Those are different flags.
The Caribbean Five: the 2026 Map
The five have harmonised their rules under the Memorandum of Agreement of 20 March 2024, which bound them to raise the minimum non-refundable contribution to US$200,000 no later than 30 June 2024; the floor itself is imposed by each state's own national instrument. The common regional date, set by the OECS Commission release of 22 June 2024, is 1 July 2024 — but the dates differ across the five: Antigua and Barbuda took a further 30 days and applies the new thresholds from 1 August 2024, while St Kitts and Nevis had been above the floor since 2023. The era of price dumping is over. The profiles differ, and the choice follows the objective:
- St Kitts & Nevis — from $250,000 (SISC). The benchmark and the strongest passport of the group (~155 destinations, Henley 2026); after the reforms, the fastest processing in the region (5.1 months on average) and the strictest innovations: biometrics and in-person document collection from 2026.
- Grenada — from $235,000 (NTF). The only one with a US E-2 treaty and China visa-free access; outside the US restriction lists. Also the future seat of the regional regulator.
- Antigua & Barbuda — from $230,000 (NDF) for a family of up to four, the broadest family definition (children to 30, parents 55+, siblings). The 2026 minuses: a 14.2-month average wait and a US entry restriction (the B-1/B-2 is still issued, but from 28 February 2026 for three months, single entry).
- Dominica — from $200,000 (EDF), the lowest entry. The toughest clean-up in the region: dozens of revoked passports and nationality stop-lists; also on the US list.
- St Lucia — from $240,000 (NEF) plus the region's only refundable option, a $300,000 bond. Two flies in the ointment: a record queue (18 months) and the loss of UK visa-free access from 5 March 2026.
The real budget runs 5–15% above the headline, on a single base — government fees alone (due diligence, processing, the interview, the certificate and the passport), with no agent's fee in it: the floor is Dominica for a single applicant (5% on the CBIU price list), the ceiling Antigua and Barbuda for a family of four (about 15%: $34,700 of fees on the $230,000 contribution under the CIP schedule of fees). All-in, a single applicant goes from ~$211,000 (Dominica) to ~$275,000 (St Kitts), and a family of four from ~$266,500 in Dominica; the full-cost method and the per-head tariffs are in the total cost of a route.
Comparing the Programs
The first table is the money: the minimum entry on each of the two routes.
| Program | Fund contribution, from | Real estate, from |
|---|---|---|
| St Kitts & Nevis | US$250,000 (SISC) | $325,000, 7-year hold |
| Grenada | $235,000 (NTF) | $270,000 + $50,000 government fee, 5 years |
| Antigua & Barbuda | $230,000 (NDF, family of up to four) | $300,000, 5 years |
| Dominica | $200,000 (EDF) | $200,000 + $75,000–100,000 government fee, 3 years |
| St Lucia | $240,000 (NEF) | $300,000, 5 years |
The second is the real speed and what each program is actually chosen for.
| Program | Real timeline | What sets it apart |
|---|---|---|
| St Kitts & Nevis | 5.1 months | the group's strongest passport (~155 destinations); biometrics from April 2026 |
| Grenada | 7 months | US E-2 treaty and visa-free China |
| Antigua & Barbuda | 14.2 months | the broadest family scope: children to 30, parents 55+, siblings |
| Dominica | 9.3 months | the lowest entry: ~$211,000 all-in for a single applicant |
| St Lucia | 18 months | the region's only refundable option: a $300,000 bond + $50,000 fee |
Timelines are measured filing-to-passport times on Q4 2025 data; other data as of August 2026. Full conditions, fees and family pricing are on the program pages.
How It Works in Practice
The mechanics are similar everywhere. The applicant retains a licensed agent (states do not accept files directly), passes due diligence — the central question is the legality of the source of funds — and pays after approval: a non-refundable fund contribution or an approved real-estate investment with a 3–7-year hold. Applications include the spouse and children; many programs add parents, some add siblings.
The era of "zero-touch" Caribbean citizenship is ending. Interviews are mandatory in all five programs (usually by video, from age 16–17). St Kitts requires biometrics and in-person collection of the naturalisation certificate from April 2026 — on the islands or at permanent centres (UAE, China); Dominica announced in-person passport collection during 2026; the agreed 30-days-in-five-years presence requirement awaits the regional regulator's launch. Antigua already runs its own minimum: 5 days on the islands within the first five years plus an oath.
ECCIRA: the Single Regulator
The region's answer to external pressure is centralisation. Back in February 2023 the "six CBI principles" were agreed with the US: common treatment of denials (no forum shopping), mandatory interviews, annual audits, additional FIU vetting, retrieval of revoked passports, and restrictions on Russian and Belarusian applicants. The Memorandum of Agreement of 20 March 2024 added the $200,000 price floor — an undertaking to raise the minimum no later than 30 June 2024, effective from 1 July 2024 under the OECS release and from 1 August 2024 in Antigua and Barbuda. On 23 September 2025, in Castries, Saint Lucia, the five signed the agreement establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA), headquartered in Grenada: common due-diligence standards, escrow, biometrics, a shared denials database, annual quotas and the power to fine member states.
The authority, however, does not yet exist. Under article 95 of the agreement it comes into being on the thirtieth day after the fifth instrument of ratification is deposited. 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 that fifth instrument.
Malta and the EU's Pressure
The only golden-passport program inside the EU — Malta's — is closed. On 29 April 2025 the EU Court of Justice in Case C-181/23 held it contrary to Union law: EU citizenship cannot be acquired as a commodity, without a genuine link to the country. Malta wound the scheme down, keeping only naturalisation for exceptional merit — discretionary and case-by-case.
The pressure then moved to third countries: since 30 December 2025 the mere operation of a CBI program has been a ground for suspending Schengen visa-free access, and in the summer of 2026 the European Commission demanded in writing that the Caribbean five wind their programs down by 1 June 2028. The Caribbean is publicly resisting, but the risk timetable is now set in Brussels — the dates, the Commission's figures and the scenarios are in Caribbean CBI and the 2028 deadline.
The 2028 Horizon: EU Demands and US Restrictions
The European track in full — the Commission's letter, the 1 June 2028 deadline, interim measures due by September 2026 and the figures of report COM(2025) 792 — is collected in Caribbean CBI and the 2028 deadline, while the legal machinery of a suspension (Articles 8a(1)(e) and 8e(3) of Regulation (EU) 2025/2441, the 12- and 24-month terms and the Vanuatu precedent) is unpacked in the EU visa suspension mechanism. The second track, the American one, runs on its own logic and without transitional periods — and it is the one that has already produced practical consequences for Caribbean passport holders.
The American Track
Proclamation 10998, "Restricting and Limiting the Entry of Foreign Nationals To Protect the Security of the United States", was signed on 16 December 2025 and took effect on 1 January 2026 at 12:01 a.m. EST. Of the Caribbean CBI jurisdictions only Antigua & 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 & Nevis and St Lucia are not in the proclamation, though "citizenship without residency" is now named as a vetting red flag in its own right.
The perimeter of a partial restriction: entry is suspended on immigrant visas and on the nonimmigrant categories B-1, B-2, B-1/B-2, F, M and J. This restricts entry, not issuance: the proclamation revokes no visa already granted, and new visas in those classes continue to be issued.
The recitals spell out the mechanism Washington is closing: a national of a restricted country "could purchase CBI from a second country that is not subject to travel restrictions, obtain a passport in the citizenship of that second country, and subsequently apply for a United States visa". The measure therefore strikes not at the issuing state as such but at the function of a second passport as a workaround — an argument consular officers and bank compliance teams now apply to any purchased citizenship, not only a Caribbean one.
The second layer is consular practice. By 28 February 2026 the State Department had revised the reciprocity schedules for Antigua & Barbuda and Dominica: B-1/B-2 validity was cut from 120 months with unlimited entries to three months, single entry, with the same three months and single entry applied to the F, J, L and R categories. As at August 2026 the schedules for both countries list B-1, B-2 and B-1/B-2 on exactly those terms — the classes are curtailed, not closed. The reciprocity schedules for Grenada, St Kitts & Nevis and St Lucia were not revised and still show the former terms.
The third layer is bonds. The Visa Bond Program rule (22 CFR 41.11(c), 91 FR 48757) was published and took effect on 3 August 2026: it made the 2025 pilot permanent and allows a consular officer to 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 list of covered countries is published on the Department's website, and a country is added to it no less than 15 days before the programme starts for that country; from 1 October 2027 and every seven years thereafter the maximum bond is indexed to CPI-U, rounded up to the nearest $1,000. This is an administrative process with no rulemaking round: check the list on the date of application, not against last year's write-ups.
Britain and Schengen
Britain cuts its own way: visa regimes for Dominica and Vanuatu since 19 July 2023, for St Lucia since 5 March 2026 — the Home Office grounded that decision in rising asylum claims and described the local CBI practice as "inherently high-risk". The remaining Caribbean passports need the ETA electronic authorisation for the UK, and Schengen adds ETIAS from late 2026. St Kitts received the opposite signal: in February 2026 FinCEN rescinded its 2014 advisory on the programme — a rare positive from a US regulator in the industry's history.
None of the five checks below is stable over a 12-month horizon: each changes by secondary act or administratively, with no transitional period.
Revocations and Program Discipline
Purchased citizenship is no longer irrevocable. Dominica has cancelled 68 passports since June 2024 for fraud and misrepresentation — including documents issued under aliases. St Kitts gave its own investors an ultimatum: passports issued before the biometric reform stop working for travel from 1 August 2027 without re-enrolment (enrolment deadline: 31 July 2027). Nationality stop-lists are widening: Dominica suspended Iranian applicants in March 2026 (following North Korea and Sudan), similar filters run across the five, and restrictions for Russian and Belarusian citizens are locked in by the six principles.
Compliance, Banks and CRS
The main CBI filter is vetting — but compliance does not end with the passport. The OECD keeps all five Caribbean programs and Vanuatu on its list of schemes posing a high risk of CRS circumvention: banks must apply enhanced due diligence, and the standard red flag is declaring the passport's zero-tax jurisdiction as your tax residence while actually living elsewhere. Accounts remain visible through CRS; Russian citizens keep the Interior Ministry notification duty and CFC rules. A passport solves mobility — not taxes and not banking secrecy.
Why People Buy a Second Passport
A second passport solves three problems: mobility through visa-free access, a backup runway against geopolitical risk, and sometimes access to banks and deals closed to the original citizenship. As a tax instrument it barely works on its own: where you pay tax is decided by residency and treaty tie-breakers. Check a passport's real strength against the passport indices, and its place in the wider design in the second passport as Plan B.
Beyond the Caribbean the niche lives its own life:
- Vanuatu — the fastest passport, but without Schengen or the UK.
- Türkiye — real estate from $400,000 and E-2 access.
- Egypt and Jordan — budget and regional.
- Nauru (from $105,000) — the 2025 newcomer with an explosive start.
The American "Gold Card" at $1m is an immigration status, not a passport.
How to Choose a Program
Selection starts with budget and family composition. For a single applicant the price leader is Dominica at ~$211,000 all-in. A family of four does better at Antigua ($230,000 for all four plus fees), and from six members its discounted UWI fund route (from $260,000) takes over. Where capital recovery matters, there is one option — St Lucia's bond: $300,000 comes back after five years, with an effective cost of about $65,000–75,000 plus an interest-free freeze.
The second criterion is mobility, counted on 2026 facts rather than the marketing "150+ countries". St Kitts holds the maximum (~155 destinations), Grenada is the only one with E-2 and China, while St Lucia lost UK visa-free access and citizens of Antigua and Dominica face curtailed US visas. Where specific destinations are critical, the picture is checked against the passport indices on the filing date.
The third is speed. Real timelines diverge severalfold: 5.1 months at St Kitts against 18 at St Lucia. When the passport is tied to a deal, a bank or a relocation, this parameter outweighs the price difference.
The fourth is horizon and durability. Brussels demands a wind-down of the Caribbean programs by June 2028, the five are introducing biometrics and presence requirements, and purchased citizenship has proven revocable. A program is therefore chosen as a long-term asset — for discipline and reputation — with mobility insured by a second status within a broader Plan B design. How the passport route sits against the residence routes, and in what order to read the rest, is laid out in the investor cluster map.
Where CBI Is Heading
The 2026 vector is the "genuine link": from a purely donation-based model toward a real connection with the country. St Kitts announced a rebuild around presence, business and productive investment; the five agreed on 30 days of presence; interviews and biometrics became the norm. The industry is consolidating under ECCIRA and getting more expensive — while the European window closed with Malta, and Brussels is pushing for a Caribbean wind-down by 2028. CBI remains a legal, working tool for mobility and Plan B — but a program is now chosen on a multi-year horizon, with the caveat that visa-free access changes faster than the price.
This material is for reference and does not constitute individual legal advice. Thresholds, fees and visa regimes change — verify the rules in force on your filing date.
Q/A
Which countries offer citizenship by investment in 2026?
The core of the market is the Caribbean five: St Kitts & Nevis, Dominica, Grenada, Antigua & Barbuda and St Lucia. Outside the region, programs run in Vanuatu, Türkiye, Egypt, Jordan and Nauru. The only scheme inside the EU — Malta's — was closed by the EU Court of Justice in 2025.
How much does a Caribbean passport cost?
The minimum non-refundable contribution after the 2024 harmonization is US$200,000: under the Memorandum of Agreement of 20 March 2024 it had to be in place no later than 30 June 2024, the common regional effective date is 1 July 2024, and Antigua and Barbuda applies it from 1 August 2024. The five agreed a common floor, ending the discount race. The real budget exceeds the headline: all-in, a single applicant runs from ~$211,000 (Dominica) to ~$275,000 (St Kitts), and a family of four pays roughly $255,000–305,000 including due diligence and fees.
How fast is a passport issued?
Only St Kitts still delivers the advertised "3–6 months". Measured filing-to-passport times on Q4 2025 data: St Kitts & Nevis 5.1 months, Grenada 7, Dominica 9.3, Antigua & Barbuda 14.2, St Lucia 18. Plan on the real timelines, not the marketing.
What happened to Malta's citizenship-by-investment?
The EU Court of Justice in case C-181/23 (April 2025) held citizenship-for-payment incompatible with Union law: an EU passport cannot be bought as a commodity, without a genuine link to the country. Malta wound the scheme down, keeping only discretionary naturalisation for exceptional merit.
Do you have to live in the country after getting the passport?
Historically not — and that is the key difference between CBI and naturalisation. But the rules are tightening: Antigua already requires 5 days on the islands within the first five years plus an oath, St Kitts has introduced biometrics and in-person document collection, and the agreed 30-day presence requirement will switch on only once the ECCIRA regulator launches — which, as of August 2026, has not been confirmed as legally complete.