The European Commission's position on Citizenship by Investment within EU member states has continued to evolve through 2025 and into 2026. The April 2025 ECJ judgment on Malta closed the period of legal uncertainty and established the boundary between EU competence and member-state sovereignty over nationality law.
The practical effect: Malta has continued its programme, restructured around the four-tier diligence framework. No other EU state currently operates an active CBI programme.
For applicants, the implications are: Malta remains the only EU CBI route, but with materially higher diligence requirements and longer residency periods. EU mobility for non-EU nationals therefore continues to flow primarily through Golden Visa programmes (Portugal, Greece, Spain) which lead to citizenship after 5–10 years.
Applicants concerned about regulatory durability should structure with two redundant pathways — Malta CBI plus a Golden Visa, or a Caribbean CBI for immediate mobility plus a Golden Visa for EU residency optionality.
