EPRSauthor By / January 15, 2014

EU Citizenship and residence permits for sale

Granting residence permits to non-EU citizens who make substantial investments seems to be a common practice for a number of…

© michaklootwijk / Fotolia

Granting residence permits to non-EU citizens who make substantial investments seems to be a common practice for a number of EU Member States (MS). Some of them, like recently Malta, go further by granting third-country investors full citizenship although mostly after first granting residence rights (e.g. Austria, Bulgaria and Cyprus). Since Article 21 of the Treaty on the Functioning of the European Union confers the right to move and reside freely within the territory of the Union directly on every EU citizen and their family members, granting full citizenship rights to third country nationals in theory enables unrestricted access to the entire EU.

© michaklootwijk / Fotolia
© michaklootwijk / Fotolia

Requirements for granting residence permits vary from one country to another. In Greece, a residence permit can be granted to a third-country national acquiring a real estate property of minimum €250.000, the United Kingdom applies a “Tier 1” investor scheme to wealthy third-country nationals if they can potentially invest at least £1.000.000. Eligibility for the Residency Bond Programme in Hungary does not require exceptional investments. A third country national can simply become a resident by paying a programme participation fee of €300.000, of which €250.000 is given back after 5 years.

Through these specific programmes, host MS intend to benefit from investments made by wealthy third country nationals, but the results of these schemes are not uncontroversial. The money laundering potential of these schemes is also a source of concern. Nevertheless, it is the factor of unwanted migration in the Schengen area which has become arguably the most controversial side-effect of such schemes. Malta recently amended its Citizenship Act to attract investors not with residence permits, but directly with full-fledged citizenship in exchange of a total investment of €650.000 (amendments raising the requirements to €1.150.000 have been announced by the Maltese government). However, despite being the most debated, the Maltese scheme is not the only one of its kind in the EU. Cyprus, for example, has recently developed a “Scheme for naturalisation of non-Cypriot investors by exception”. Its citizenship can be acquired with a minimum of €5.000.000 direct investments, though only by investors having a permanent privately-owned residence in Cyprus.

This Keysource offers legislative documents and country-specific analyses related to these schemes.


Should Citizenship be for Sale ? / Ayelet Shachar and Rainer Bauböck, EUI Working Paper RSCAS 2014/01
This paper contains comments on the topic and an overview of a debate held in November 2013 at the initiative of the EUDO Citizenship observatory.

EU citizenship: on sale now / Ana Baric, 16 November 2013, Organised Crime and Corruption Reporting Project (OCCRP)
Starting off with the Maltese example, this article then goes into defining who are the “exceptional” persons eligible for “investor citizenship”, which countries are and have historically been offering similar citizenship-awarding policies, and what are the ramifications of such schemes within and outside the European Union.

The growing trend of offering citizenship to foreign investors in European countries fuels controversy / European University Institute, Robert Schuman Centre for Advanced Studies, EUDO Citizenship, 18 November 2013

Citizenship for sale: how unique is Malta? / James Debono, MaltaToday, 12 November 2013
This article offers comparative analysis of the citizenship-selling schemes of Malta, Belgium, Portugal, Canada, Singapore, ST Kitts & Navis, Austria.

EU citizenship goes on sale, price war breaks out / Wolf Richter, Testosterone Pit, 13 November 2013
This article analyses EU trends in citizenship-selling.

European citizenship: sold to the super wealthy / Julia Mahncke and Christian Ignatzi, Deutsche Welle Act, 15 November 2013
This article reviews the citizenship-selling schemes of a number of EU countries and focuses on the inequality these programmes create among the third country nationals aspiring towards EU citizenship.

Citizenship by investment: Can money buy citizenship? / Jelena Dzankic, European University Institute, Robert Schuman Centre for Advanced Studies, EUDO Citizenship, 15 February 2012
This consists in an analysis of the criteria which have to be fullfiled (is residence mandatory ? Has a real estate to be purchased ?) in order to get an “investor citizenship” in different countries throughout the world.

Country reports

Residence permit granting schemes


Legislative framework

Residence permit in Greece by real estate acquisition or strategic investment (Law 4146/2013) / Ministry of Foreign Affairs of Greece, July 2013


For just €250,000 you can buy a home in Greece and become an EU resident / Fearguss O’Sullivan, Quartz, 3 September 2013


Legislative framework

Law amendment to Act No. 2 of 2007 on the Admission and Right of Residence of Third-Country Nationals / Parliament of Hungary, 28 December 2012


Your Safe Pass to Europe: The Hungarian Residency Bond Program has Now been Launched / PRWeb, 31 July 2013


Legislative framework

Immigration Law, Latvijas Vestnesis, 169 (2744), 20.11.2002 (in English)
Law that permits obtaining residence permits for foreigners if they purchase a real estate.


Legislative framework

Order 1661-A/2013 (amends Order 11820-A/2012) / Immigration and Borders Service of Portugal


Golden Residence Permit programme / Serviço de Estrangeiros e Fronteiras

The scheme in the media

Portugal offers golden visas to rich foreigners / Claire Gatinois, The Guardian, 10 December 2013


Legislative Framework

Proyecto de Ley de apoyo a los emprendedores y su internacionalización. (121/000052) / Congreso de los Diputados

The scheme in the media

Plans to grant investor residency could revive Spain’s real estate market / Carla Passino, Forbes, 8 June 2013

United Kingdom

Legislative framework

Tier 1 investor policy / UK Border Agency, Home Office

The scheme in the media

Want to buy citizenship? It helps if you’re one of the super-rich / Tom Meltzer, The Guardian

Citizenship granting schemes


Legislative framework

Federal law concerning the Austrian nationality (Nationality act 1985)

The scheme in the media

Österreich im Angebot / Von Christoph Zotter, Zeit, 15 March 2012


Legislative Framework

Amendments to the Investor program for residence and citizenship in Bulgaria  /  State Gazette, issue 16 [available only in Bulgarian]

Bulgaria: The new legislative amendments are now official / Arton Capital Bulgaria


Bulgarian citizenship or residency by investment / Trifonov Law Offices

Comparison Of Bulgarian Investor Program VS Other Investor Programmes With Other Program / IndiaMart


Legislative framework

Grant of the Cypriot citizenship to non–Cypriot entrepreneurs / investors through the “Scheme for Naturalization of Investors in Cyprus by exception” / Ministry of Interior of the Republic of Cyprus


Naturalisation procedures for immigrants: Cyprus / Nicoletta Charalambidou, EUDO Citizenship Observatory, January 2013


Legislative framework

Act to amend the Maltese Citizenship Act, Cap 188 

The scheme in the media

Maltese passport and life as an EU citizen for anyone with £546,000 / Colin Freeman, The Telegraph, 13 November 2013

Malta’s sale of EU passports causes controversy / Andrew Rettman, EUobserver, 7 January, 2014

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