Within the last year, the EU Court of Justice has finally put a stop to citizenship by investment (CBI). The decision, which effectively ruled that Malta’s “golden passport” program was illegal, ended the last remaining CBI scheme in the European Union. Prior to that, Cyprus also took part in CBI, before abolishing its program on November 1, 2020.
The main issue opposers had with these schemes was that they essentially commodified citizenship in the EU and promoted corruption.
The End of Malta’s “Golden Passports”
The citizenship by investment scheme in Malta began in 2015 under the leadership of then-PM Joseph Muscat. Historically, Malta has tried to defend the exchanges by pointing to the $1.6 billion in revenue generated for the country. By 2020, The European Commission was after both Malta and Cyprus for infringing upon the laws of the European Union.
By 2022, Malta suspended its CBI scheme for Belarusian and Russian nationals until further notice, but continued its scheme for citizens of other third countries. On March 28, 2022, the European Commission adopted a recommendation that stated that investor citizenship schemes are not compatible with EU law and called on Member States that used them to repeal them.
By April 6 of the same year, the European Commission sent a reasoned opinion to Malta confirming its position that the citizenship by investment scheme violated Article 20 TEFU and Article 4(3) TEU, calling for Member States to comply and end their CBI schemes. Malta expressed disagreement with this position in response, but by April 2025, the European Court of Justice held a ruling to completely end citizenship by investment in Malta, on the basis that it was contrary to EU law.
How Did Citizenship by Investment in Malta Work?
Before the April decision, the CBI schemes in Malta awarded nationality to people in exchange for payment or investment. For the past decade, Malta had allowed individuals who contributed up to €750k and, in theory, spent 12 months in Malta to gain Maltese citizenship, as well as the right to live anywhere within the EU.
But the program had actually been allowing people who only spent a month or less in Malta to obtain citizenship through this route. They would rent property short-term and then leave, which raised red flags regarding the commodification nature of the scheme.
The End of CBI in Cyprus
Cyprus’ interior and finance ministries made the 2020 decision to do away with the country’s citizenship by investment scheme following Al Jazeera’s intense investigation into the already controversial program.
The EU had long held the CBI program under scrutiny, believing it allowed criminals to launder money and exploit the Cypriot citizenship pathways. And the Al Jazeera investigation, which resulted in the release of The Cyprus Papers, showed that the nation had given passports to criminals convicted of crimes in their home countries for years.
The Push for Ancestry Based Pathways to EU Citizenship
In the absence of citizenship by investment, one of the only remaining pathways for gaining citizenship in countries across the EU is citizenship by descent.
Each country has specific and nuanced legislation regarding the pathway to ancestral citizenship, sometimes based on reparations efforts like in Germany, and sometimes based on historical displacement of citizens in times of political strife.
How Does Lineage Citizenship Work?
Ancestry-based citizenship, also known as lineage citizenship or citizenship by descent, is growing in accessibility in countries across the EU. Countries including Lithuania, Germany, Greece, and the Czech Republic, among others, have pathways to citizenship for people looking to reclaim their status, gain citizenship through birthright, and become dual citizens while living abroad.
How to Apply for Citizenship by Descent in the EU
For those interested in applying for citizenship by descent in the EU, the important first step is to determine eligibility. Distinct stipulations factor in when applying for citizenship in each country, including required documentation for descendants and ancestors, ways of proving direct descent, and more.
And beyond proving lineage, some countries allow dual citizenship in their legislation, while others don’t. There are even laws related to past and current residency status for applicants and their ancestors that you need to be aware of.
This is where we come into the picture. Citizenship.eu provides expertise when it comes to dealing with these complex citizenship laws in European countries. We have assisted more than 3,000 people in obtaining dual citizenship, and we’re expanding our efforts. Now, we offer eligibility assessments and reports for individuals pursuing ancestral citizenship in Europe.
What are the key differences between Citizenship by Investment (CBI) and Citizenship by Descent (Cbd)?
CBI was a financial transaction where you could buy citizenship with a large investment. It was criticized for promoting corruption. CBD is based on your family’s ancestry. It’s a legitimate way to claim citizenship based on your lineage, and it’s recognized legally in many European countries.
Why did the European Court of Justice rule against Malta’s “golden passport” program?
The EU Court of Justice ruled against the program because it was against EU law. They argued that selling citizenship without a genuine connection to the country undermined EU citizenship and could create security risks. The program was seen as a violation of fundamental EU principles.
Are there other similar options to gain EU citizenship now that CBI schemes are gone?
No, there are no other similar programs. The main remaining pathway for non-EU citizens to get citizenship in many EU countries is through Citizenship by Descent (CBD). This requires an ancestral link to the country. There is no other way to get a passport and full EU rights through a financial contribution alone.
Next Steps
If you’d like to determine your citizenship eligibility for an EU country or just want to keep up to date with the latest news and laws passed regarding EU citizenship, we can help. Our blog is home to citizenship by descent guides for different countries, FAQs, dual citizenship updates, and more.
Contact us to learn more!