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A Comparison of EU Immigration by Investment Options

Author: Harvey Law Group

The purpose of this article is to compare some of the most popular immigration by investment programs within the European Union (EU).


Migration for a better future has driven civilisations from the beginning of time.

Within the last 15 years, investment immigration programs have proliferated around the world, offering residence or citizenship in exchange for local investments modelled to fuel local economies.

These programs can also be used by investors as powerful financial planning and wealth management tools. Also, they are no longer reserved for the super high net worth individuals, which can be explained by a number of factors, notably a wider base of wealthy individuals worldwide, increased investment in education and family planning, climate change concerns, political turmoil, and more recently health security concerns.


Requests for immigration options to EU countries are in high demand, largely due to the quality of life that they inspire, as well as strong reputation for education and health care.

Freedom of movement and residence in the EU is the cornerstone of EU citizenship, which was established by the Treaty of Maastricht in 1992. EU citizens can establish themselves to live and work in other EU countries in search of a better future. Nowadays, it is common to meet Spanish students in Paris, French bankers in Frankfurt, or German retirees in the Algarve in Portugal, in search of better education, work opportunities, or higher standard of living. All of this is possible for one primary reason: the passport they hold.

The Schengen area (comprised of 27 countries2 that have abolished passport control at their mutual borders) guarantees free movement to over 400 million EU citizens and non-EU nationals legally present in EU, according to the State of Schengen report 2023. The European Council estimates that every day around 3.5 million people cross internal borders for work, study, visits to families and friends, and almost 1.7 million people reside in one Schengen country while working in another. Only 4 out of these 27 countries are not EU members (i.e. Iceland, Norway, Switzerland, and Liechtenstein).


Distinction needs to be drawn between “residency” and “citizenship” programs (although residency programs can lead to citizenship in time). All but one EU immigration options available are for residency, though the duration of minimum physical residency required can drastically vary from one program to another.

1. EU countries: Austria; Belgium; Bulgaria; Croatia; Cyprus; the Czech Republic; Denmark; Estonia; Finland; France; Germany; Greece; Hungary; Ireland; Italy; Latvia; Lithuania; Luxembourg;   Malta; the Netherlands; Poland; Portugal; Romania; Slovakia; Slovenia; Spain; Sweden.
2. Schengen countries list: Austria; Belgium; Croatia; the Czech Republic; Denmark; Estonia; Finland; France; Germany; Greece; Hungary, Iceland; Italy; Latvia; Liechtenstein; Lithuania;     Luxembourg; Malta; the Netherlands; Norway; Poland; Portugal; Slovakia; Slovenia; Spain; Sweden and Switzerland.

As of today, Malta is the only EU Member State that still operates a Citizenship by Investment (CBI) program. This is however the subject of serious controversy, and its future is less than certain. We recall that on 29 September 2022, the European Commission referred Malta to the Court of Justice of the European Union for this[Commission refers MALTA to the Court of Justice (]. Malta CBI program offers citizenship against (i) real property purchase investment of at least EUR 700,000 (or annual lease of at least EUR 16,000) for at least 5 years; (ii) minimum government contribution of EUR 600,000 (or EUR 750,000 to accelerate the process from 3 years down to 1 year) and (iii) donation of at least EUR 10,000 to a local non-governmental organization (NGO).

Cyprus and Bulgaria previously also offered CBI programs, which were withdrawn in 2020 and 2022 respectively, after receiving mounting pressure from the European institutions.

The European Parliament and the European Commission have been voicing concerns about Member States offering CBI programs for years. Commission President von der Leyen, in her State of the Union address on 16 September 2020 stated: “Be it about the primacy of European law, the freedom of the press, the independence of the judiciary or the sale of golden passports, European values are not for sale.” Further, the first proposal approved by the European Parliament and reported in its resolution of 9 March 2022 is a phasing-out of CBI schemes reaching zero by 2025. The European institutions have stressed on numerous occasions that although awarding citizenship is a prerogative of the Member States, it must be exercised having due regard to EU law. Citizens of a Member State enjoy the rights of EU citizenship, including that of mobility and free movement across all Member States. As such, the determination of citizenship by one Member State implies a responsibility to all others.

In light of this, some investors have been looking at acquiring passports from non-EU countries, effectively betting on their later accession to the EU. For instance:

Turkey applied to accede to the EU in 1987. It is hard to tell how much longer it will take for Turkey to become an EU member, though Turkey CBI presents other advantages as Turkey is an E2 Treaty country and requires the investors merely to purchase property of at least USD 400,000.

North Macedonia applied for EU membership in 2004, and the EU held its first intergovernmental conference with North Macedonia on 19 July 2022. To make progress, however, the country must change its constitution, notably to recognise local Bulgarians as a minority, and needs to overcome the latent opposition of neighbouring Bulgaria. The goal is for accession in 2030. In spite of recent news about an interesting CBI program, we have not seen this program as having proved itself at a time when the government is clearly preoccupied with more urgent internal matters.

As a result, investors looking at EU countries would generally be well advised to consider an EU residency program, rather than citizenship. This still gives investors a wide selection to choose from to meet their needs.


Different European programs are not equal and will need to be carefully considered by the investor together with an experienced lawyer for a successful result.

Changes happen fast, notably because those programs are tailored to respond to economical goals, and may be suddenly withdrawn once their purpose has been fulfilled or otherwise due to social or political constraints. This means that investors need to be well accompanied by professionals to act quickly and seize current opportunities.

We recall that in 2023 alone: (i) the Ireland Immigrant Investor Program offering permanent residency was terminated after 10 years of successful operations; (ii) Greece Golden Visa minimum real estate investment amount was doubled to reach EUR 500,000 if investing in certain locations; (iii) Portugal Golden Visa is being revamped to exclude real estate investment; and (iv) the United Kingdom closed its Tier 1 (Investor) visa route to favour programs that would create local jobs to boost the local economy instead of basing itself solely on the investors’ financial standing and contributions (for instance, the Innovator Founder visa and the Expansion Worker visa).

There is not one best EU immigration path that fits all. It will be an individual decision to be made after receiving advice from an experienced lawyer, depending on the investor’s goals, family structure, professional background, and ability to spend time physically in the selected country, desired citizenship timeline, nationality and much more.

For illustration

Family of 4 (2 parents; 2 children under the age of 18) holding Filipino passports and looking at acquiring EU citizenship as soon as possible to secure their children’s right to study in Europe: the Spanish Golden Visa program may be recommended, since their nationality means that they can gain fast track access to apply for Spanish citizenship after two years of physical residency under the Spanish Golden Visa. The minor children could be included in the application at no additional investment. There would be no need to renounce Filipino citizenship.

Couple of 2 (in their 50s) holding US passports wanting to enjoy the European lifestyle a third or half of the year: the Malta permanent residency program and the Spanish, Greece or Italy Golden Visas may be recommended. Those countries are all part of the Schengen area, which would permit them to reside in the country where they hold the Golden Visa, and travel in other countries within the Schengen area for 3 months in every 6-month period. Under the Greece, Spain or Italy Golden Visa programs, there are no minimum residency requirements to maintain their status whilst the Portugal Golden Visa program only requires a minimum stay of 7 days per year or 14 days every 2 years. Out of these programs, the Greece Golden Visa can be obtained for the lowest investment amount at EUR 250,000 depending on the location of the property invested in. If interested in a faster route to obtaining permanent residency, the Malta permanent residency program may be able to help them achieve this at a minimum investment of a real estate purchase of EUR 300,000 or a property rental value of EUR 10,000 per annum.

Family of 6 (2 parents, 1 child under the age of 18, 1 child 21 years old, 2 grandparents who are 70 years old) holding Chinese passports looking to secure an alternative residency option but with no immediate desire to spend any time overseas: The Malta permanent residency program might be recommended the most, although trusted advisors will also look at whether some of the Golden Visas for instance might also suit the family.

Family of 3 (main applicant investor/businessperson, spouse and young child), holding Vietnamese passports and looking at combining main applicant’s business experience and spouse’s desire to live in Europe and in time obtain a European passport: The France program could be recommended as the main applicant could invest a minimum EUR 300,000 in a new or existing entity in France to implement a genuine business plan that involves creating or maintaining jobs for French workers. A path towards citizenship by naturalization would be accessible after 5 years of residing in France, subject to meeting certain conditions.

Please see below a comparative table highlighting some of the salient features of various programs that can help select most suitable options. This does not replace the need for solid legal advice.

At the end of the day, we understand that often immigration can be an overwhelming and daunting experience. Whether you are retiring abroad, starting a business, or looking to obtain a second citizenship. Harvey Law Group (HLG)’s European residency programs offer a wide range of benefits that may suit your needs. You may find a full list of European residency programs offered by HLG here. If you are interested in learning more, please contact your local HLG office here for more details. Founded in 1992, HLG is a leading multinational law firm with offices across Asia, North and South America, Europe, Africa, and the Middle East to cater to your specific needs for immigration and beyond.


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