In late 2025, Argentina’s Ministry of Economy issued an international tender to appoint a consulting firm that would design, implement, and operate the country’s first citizenship by investment program. The contract is expected to run for four years and includes responsibilities ranging from program architecture to global promotion and operational management.
The project is overseen by the newly established Agencia de Programas de Ciudadanía por Inversión (APCI), created under Decree 366/2025 and regulated by Decree 524/2025. The agency will supervise program design, coordinate government oversight, and ultimately issue recommendations on applications.
Government projections suggest the program could process up to 5,000 approved applications during the initial contract period, although investment thresholds and qualifying sectors have not yet been defined.
Six Bidders Compete for the Contract
The tender process attracted interest from multiple global investment migration firms. According to publicly released bid details, six companies ultimately submitted formal offers after an initial group of eleven participated in the procurement process.
Among the bidders were several established names in the investment migration industry, including:
- Henley & Partners
- Latitude Consultancy Malta
- Salzburg International For Law (Reach Immigration)
- Hong Kong Qian Cheng Business Co.
- Ancova Associates
- A four-firm consortium composed of Apex Capital Partners, AIM Global, Passport Legacy, and Arton Capital
The presence of well-known industry operators underscores the strategic importance of Argentina’s potential entry into the global CBI market.
The Consortium’s Pricing Strategy Stands Out
One of the most notable aspects of the tender process is the pricing structure proposed by the four-firm consortium.
The group offered to receive just $50,000 in total compensation from the government for the first 5,000 approved applications, which effectively works out to around $10 per application.
By comparison, other bidders proposed significantly higher compensation levels. Henley & Partners, for example, submitted a proposal in which government payments would range from $2,000 per approved application in the initial tranche to $8,000 per application in later stages, potentially totaling around $25 million if 5,000 applications were approved.
At first glance, the consortium’s extremely low bid may appear economically unrealistic. However, the structure of Argentina’s tender helps explain the strategy. The government allows the master agent to charge applicants directly for processing, due diligence, and administrative services, meaning government compensation represents only one part of the potential revenue model.
In practice, this suggests the consortium’s approach is focused less on payments from the government and more on managing the program’s investor pipeline and associated service fees.
How the Payment Model Works
Argentina structured the tender around five tranches of 1,000 approved applications, with the government paying the contractor a fixed amount per approved case.
However, an important clause prevents market monopolization. The contractor will receive government compensation only for applications submitted through independent certified agents, not for cases sourced directly by the master agent itself.
This model forces the operator to develop a global network of licensed intermediaries while ensuring broader market participation.
It also creates a dual-revenue framework:
- Government payments for applications submitted by certified agents
- Investor fees for processing, due diligence, and administrative services
Such structures are not uncommon in the investment migration industry but are rarely outlined so explicitly in public procurement documents.
Program Design Still Uncertain
Despite the progress in selecting a master agent, the Argentine CBI program itself remains largely undefined.
The winning consultancy will be responsible for designing many core elements of the program, including:
- Minimum investment thresholds
- Eligible investment categories
- Application procedures and due diligence frameworks
- Global marketing and distribution strategies
Government documents have not confirmed any minimum investment amount, although speculation in media reports has suggested potential thresholds around $500,000. No official figure currently exists in the legal framework.
Strategic Implications for the Industry
Argentina’s move into the investment migration sector could reshape the regional landscape.
Most Latin American countries do not offer formal citizenship by investment programs, making Argentina’s initiative potentially the first large-scale scheme of its kind in South America. If successfully implemented, the program could attract significant foreign capital while offering investors access to a passport with strong global mobility and Mercosur regional rights.
At the same time, the program will likely face scrutiny from international regulators and visa-waiver partners, especially given growing global attention to due diligence and governance standards in investor citizenship programs.
