In April 2025, the European Court of Justice finally declared ‘golden passport‘ programme in Malta illegal, ruling that selling citizenship for investment was contrary to EU law.
Following this judicial victory for the European Commission, Malta is forced to abandon the nationality-by-investment scheme and reconsider its approach to acquired citizenship.
Why the EU Intervened?
The European Commission argued that the Maltese scheme violated treaty obligations: granting citizenship to people without a stable link to Malta undermined trust between EU countries and commercialised the status of EU citizens.
The court agreed, stating that “the acquisition of EU citizenship cannot be the result of a commercial transaction.” Malta, the only EU country to allow the practice until recently, has raised more than €1.4bn through the schemes since 2015.
New Model: Contribution, Not Investment
The established scheme now excludes direct commercial investment in real estate or business, leaving only a fixed non-refundable contribution, around €750,000, without a stable link to property or investment in the island’s economy.
This allows compliance with the court’s decision and avoids the commercialisation of citizenship. The final parameters of the new program are under discussion at the national level.
Reactions and Accompanying Dynamics in Europe
- Cyprus and Bulgaria
Even earlier, Cyprus (2020) and Bulgaria (2022) stopped similar schemes, which put Malta in last place in the EU to provide citizenship for money.
- Türkiye and the UAE
Meanwhile, Türkeye and the UAE actively continue to attract investors through their own investor citizenship programs.
Despite differences in status, both states are not members of the EU. Therefore, the models work as a mechanism for attracting investment and capital, although they have attracted criticism from Europeans for transparency and ethical practises.
Context: Security and Cross-Border Risks
Since the outbreak of war in Ukraine and the introduction of sanctions against Russia, scrutiny of schemes allowing sanctioned individuals to access the EU has increased. The European Parliament and the European Commission have condemned such schemes as a way to circumvent restrictions and increase the risks of money laundering and corruption.
Transparency International and journalist Matthew Caruana Galizia welcomed the court’s decision, calling the program a “forge of corruption” that allows “criminals to be imported into the EU.”
Economic Implications for Malta
Before the program was closed, the Maltese budget was receiving hundreds of millions of euros annually: about €620 million in the first ten years and up to €1.4 billion by 2025. The scheme also financed social projects: infrastructure, housing, healthcare through the National Development Fund.
However, between 2022-2024, there was a sharp drop in the number of applications for investor visas.
According to reports, investor revenues fell from hundreds to dozens of annual applications because of tightening conditions and a sharp increase in legal uncertainty.
Next Steps for Malta
The ECHR ordered Malta to review its legal framework and “bring its legislation into line with the principles set out in the judgment.”
However, the program, according to the authorities, will remain in force until changes are made and previously granted citizenships will be considered legitimate.
Experts warn that the absence of the CBIs program could increase the ‘national debt: GDP’ ratio by 3% and reduce contributions to social funds, especially given the growth of public debt and social spending
Malta is ending the era of “selling” citizenship, moving to a model where only a fixed contribution is allowed instead of an investment package. This decision coincides with the eradication of similar schemes in Cyprus and Bulgaria, reflecting the EU’s strategy to strengthen the integrity and trust between member states.
Meanwhile, Türkeye and the UAE continue to promote alternative schemes, and Malta is falling victim to both economic and legal challenges.
The future of investor migration schemes in Europe is at least likely to be tied to is residence systems or at the most limited to non-member states outside the EU.
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