Malta, a small island nation between Sicily and North Africa with a population of just over 550,000, has become an unlikely hub for the world’s ultra-wealthy. Its allure? One of the most sought-after “golden passport” programs in the world—offering a shortcut to European Union citizenship through financial investment.
For a minimum of €600,000 (about $660,000), wealthy individuals can obtain Maltese citizenship, which grants them the right to live and work anywhere in the EU. Buyers have included Russian oligarchs, Chinese nationals, and international celebrities. Unlike most EU golden visa schemes, which offer only residency, Malta’s program goes a step further, offering full citizenship.
However, the program is now facing a major legal challenge. The European Commission, which represents the EU’s executive branch, took Malta to court in 2022, arguing that citizenship should be based on a “genuine link” to the country—not merely on financial investment. The outcome, currently under review by the European Court of Justice, could reshape or even eliminate such schemes across the EU.
Golden visa and passport programs began popping up across Europe following the 2012 debt crisis, as countries sought new sources of foreign investment. While popular with investors, these programs have sparked concerns over ethics, security, and economic consequences.
“We’ve had momentum against these programs in the EU for several years now,” says Eka Rostomashvili of Transparency International, an anti-corruption watchdog. She warns that the ease with which wealthy individuals can buy EU citizenship poses serious risks—particularly the potential for criminals to bypass traditional immigration checks and engage in illicit activities like money laundering.
The European Commission argues that EU citizenship must reflect a real, personal connection to the granting country. Without a standard definition of this “genuine link,” however, the legal case is murky. A recent non-binding opinion from EU Advocate General Anthony Michael Collins suggests that the court may side with Malta. Collins stated that EU law does not currently require a “genuine link” for national citizenship, and that each country retains the right to define its own rules.
Critics like Rostomashvili argue that, regardless of the court’s decision, these schemes threaten to erode integrity within the EU. She notes that Malta’s program could inspire a “race to the bottom,” where other countries adopt increasingly lax requirements in a bid to attract wealthy investors. “What worries us the most,” she says, “is that it facilitates cross-border corruption and allows individuals to evade scrutiny and accountability.”
Transparency International began investigating these programs in 2018, uncovering widespread abuse. In a joint investigation with Al Jazeera, the organization found that Cyprus had granted citizenship to convicted criminals and fugitives. The scandal led to the revocation of at least 233 Cypriot passports and increased pressure on other countries to reconsider their golden passport policies.
In response to mounting concerns, several countries have already scaled back their investor visa schemes. Ireland, Portugal, and Spain have either restricted or eliminated parts of their programs. Bulgaria and Cyprus scrapped their citizenship-by-investment offerings entirely.
Yet problems persist. Real estate is a common investment route for these visas, which has fueled housing inflation in countries like Portugal and Spain, pricing out local residents. Residency requirements are also minimal in many cases—investors sometimes only need to be physically present in the country for a few days to qualify.
“These features are particularly attractive to corrupt individuals,” Rostomashvili warns. “If applicants had to live in the country and integrate into society, the risks would be significantly lower.”
The EU has responded with tighter anti-money laundering measures, including requiring intermediaries who market the visas to report suspicious activity. Still, experts argue that more robust vetting and standardized criteria across member states are needed to prevent abuse.
As the European Court of Justice prepares to issue its ruling, the future of golden passport programs hangs in the balance. If the court sides with Malta, the door could remain open for similar schemes to flourish across Europe. But if the Commission prevails, it could signal the end of citizenship-for-sale in the EU.
Regardless of the outcome, the debate underscores a growing tension between national sovereignty, economic strategy, and collective European values. At its core lies a fundamental question: should citizenship be bought—or earned?
