What is the future of these investment and citizenship-by-investment schemes around the world?
Dubbed “golden
visas,” citizenship/residency-via-investment programmes in a
variety of countries have been under pressure. Some of the
opposition comes from politicians who claim these programmes push
up property prices unduly, impeding citizens’ ability to
buy a home; other policymakers have claimed that they are
weak spots in the fight against international dirty money. On
their defence, advocates say they provide small jurisdictions
with valuable sources of revenue and that in any event, they
are typically meant to be temporary. Golden visas are also
evolving to meet some of these concerns. In many cases, golden
visas are part of a wider debate about inequality, globalisation
and open capital movement.
Whatever the state of the sector, Isobel Neilson (pictured
below) of global mobility advisory firm Fragomen takes us on a tour
of the terrain. The editors are pleased to share these ideas; the
usual disclaimers apply. To comment, email tom.burroughes@wealthbriefing.com
and amanda.cheesley@clearviewpublishing.com
Isobel Neilson
Investment-based residency options, commonly known as golden
visas, have narrowed significantly in recent years, due largely
to political optics and public pressure.
Investment migration became closely associated with real estate
investment, which the public often viewed negatively,
particularly where housing costs are a defining political issue.
Governments and regulators faced criticism where programmes were
perceived to attract wealthy individuals seeking diversification,
raising concerns around money laundering, tax evasion, corruption
and inadequate due diligence. As a result, many countries have
either tightened these programmes considerably or closed them
altogether.
The era of passive investment, such as purchasing property or
maintaining a bank deposit, has given way to an emphasis on
active and meaningful contribution.
Many jurisdictions have removed real estate as a qualifying
investment entirely, steering applicants towards direct
investment in local companies, philanthropic donations or
business activity that generates local employment. At the same
time, governments have strengthened due diligence and increased
residence requirements to reduce risk and ensure greater economic
value to the host country.
Where golden visas have disappeared, applicants increasingly turn
to passive income and digital nomad routes, particularly when the
objective is lifestyle relocation rather than passive residence
rights alone. Talent-based and entrepreneurial visas are also
capturing a greater share of the market. The UK’s Global Talent
visa is a prominent example, attracting increased interest since
the closure of the Tier 1 Investor visa. France and Australia
offer similar routes that prioritise expertise, innovation and
achievement over capital investment alone.
Europe illustrates the divergence in national approaches. Spain
closed its programme in April 2025, eliminating not only property
investment but also financial investment routes such as funds and
bank deposits. Spain remains highly attractive, but those seeking
relocation are now exploring alternatives, including passive
income and digital nomad routes.
Portugal adopted a different approach. While real estate was
removed as a qualifying investment route in late 2023, the
investor visa remains available through alternative options,
including regulated fund investment and contributions to cultural
or scientific initiatives. However, forthcoming changes to
nationality law, combined with ongoing processing delays, are
expected to significantly extend the path to citizenship for
Portuguese residents to seven or 10 years, depending on the
applicant’s circumstances. Despite this, the programme remains
attractive because only minimal physical presence is required of
applicants to maintain residency and continue progressing towards
citizenship.
Ireland presents a more nuanced example. Although the Immigrant
Investor Programme formally closed to new applications in 2023,
limited opportunities remain available through previously
approved projects that continue to seek qualifying investors. In
practice, the remaining route is now largely focused on
philanthropic donations to preapproved healthcare, education and
community initiatives, rather than traditional investment
structures. Ireland continues to attract interest from high net
worth individuals seeking flexible residence rights with minimal
physical presence requirements, even as the programme gradually
winds down.
Italy is emerging as one of the EU’s more attractive investor
visa options, offering routes through government bonds,
investment in Italian companies, innovative startups and
philanthropic donations. The programme has benefited from
favourable tax regimes, relatively quick processing times and the
absence of strict physical presence requirements. Greece also
remains popular because it continues to permit real estate
investment at a time when many European countries have moved away
from property-based routes, albeit with higher thresholds and
tighter restrictions in key areas.
Beyond Europe, policy is evolving in different directions. New
Zealand has refined its investor pathway to encourage active
investment aligned with national priorities, while the UAE has
expanded its Golden Visa programme as part of a broader strategy
to attract investors, entrepreneurs and highly skilled
professionals. Costa Rica has also seen increased interest,
particularly from US nationals, because of comparatively moderate
investment thresholds and limited physical presence requirements.
In the US, the longstanding EB-5 investor programme is now
complemented by the Trump Administration’s Gold Card program,
which aims to offer additional options for high net worth
individuals.
Citizenship-by-investment programmes tell a similar story. Demand
for second citizenships remains strong as wealthy individuals
seek greater optionality during a period of geopolitical
uncertainty, but scrutiny continues to intensify.
The Caribbean remains active in this space, although the region
faces increasing pressure to strengthen due diligence standards
or risk losing visa-free access to key jurisdictions. Argentina
has announced plans to introduce a citizenship-by-investment
programme in 2026, while new offerings have emerged in countries
including El Salvador and São Tomé and Príncipe. Malta, which
closed its citizenship-by-investment programme in 2025, has
transitioned to a discretionary citizenship-by-merit framework
favouring applicants that are able to demonstrate
exceptional contribution and meaningful ties to the
country.
These developments show that investment migration is not
disappearing but is being reshaped by political and economic
realities. The focus is shifting away from purely transactional
models towards expectations of credibility, contribution and
genuine connection to the jurisdiction.
About the author
Isobel Neilson is a director in the worldwide private client
practice at global mobility advisors Fragomen LLP.
www.fragomen.com