Member-state-level closures are likely to continue. Programme-by-programme:
• Spain (closed 2025) and Portugal real-estate (closed 2023) reflect the strongest political signal so far.
• Greece has tightened thresholds rather than closed — the political consensus is to keep the programme but make it less leveraged.
• Malta MEIN and MPRP face ongoing EU Commission infringement scrutiny (case C-181/23 was the first ruling against Malta's CBI specifically). The MPRP residency programme is more durable politically.
• Latvia, Hungary and others have already closed their schemes.
The Commission can't force a member state to close an RBI programme directly — citizenship policy is a Member-State competence under Article 9 TEU. What it can do is restrict access to the rights citizenship confers (free movement, banking) and apply political pressure. Realistic two-year horizon: expect more tightening, fewer closures, and Caribbean programmes growing in relative importance.
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