What Will Happen to Caribbean Passports by Investment: Three Scenarios for 2027 After the EU Court Ruling and European Commission Letter

What is citizenship by investment and how many countries offer it

Citizenship by investment is nationality granted by a state in exchange for a predetermined payment or investment, without requiring residence in the country; in European law, such a scheme has had its own legal definition since late 2025. Before that, citizenship by investment remained a market term rather than a legal one.

How many countries offer citizenship by investment is a question without a consensus answer. The top Google result on this query lists 16 countries; the top Yandex result lists 18. The difference arises because different reviews count suspended, announced, and non-functioning programs differently.

The five Caribbean passport programs mentioned in the European Commission's requirement are named explicitly and allow no ambiguity:

A common floor of $200,000 has applied to all five passport programs since July 1, 2024, under an intergovernmental agreement; actual thresholds are higher. A detailed breakdown of thresholds, fees, and family conditions is in separate materials of this series—here we address only regulation and its timeline.

The April 29, 2025 EU Court Ruling: What Exactly Was Found Unlawful

The Grand Chamber of the Court of Justice of the European Union found that Malta violated Article 20 of the Treaty on the Functioning of the EU and Article 4(3) of the Treaty on European Union, by issuing passports by investment through a "transactional naturalization procedure in exchange for predetermined payments or investments." Case C-181/23, ruling issued April 29, 2025.

The subject was Malta's citizenship program Citizenship by Naturalisation for Exceptional Services by Direct Investment, introduced by a 2020 amendment to Article 10(9) of Malta's citizenship law. The Court called such a scheme commercialization of the grant of citizenship of a member state and, consequently, of Union citizenship and stated that mutual trust among member states rests on the assumption: citizenship reflects "a special relationship of solidarity and good faith between the state and its citizens and reciprocity of rights and obligations."

Myth-busting: "The EU Court banned citizenship by investment." The Court examined obligations of a state—a member of the EU and ruled against Malta. Caribbean states are not Union members, and the ruling does not apply directly to them. The mechanism that applies to them emerged later and in a different act.

Why the Malta ruling affects the Caribbean, though the Caribbean is not in the EU

From the Malta case to EU visa law passed not a ban on citizenship by investment, but the criterion of "genuine connection" with a state. Through this criterion, the requirement reached countries to which the Court ruling does not apply.

The logic of the transition is straightforward and unfolds in three steps. First: the Court formulates that citizenship presumes genuine connection, and payment for a passport does not create it. Second: the legislator transfers the same formula to the visa regime regulation, where it functions no longer as an obligation of a member state, but as a characteristic of a third country. Third: the Commission applies the norm to specific states.

For a holder of a Caribbean passport, the practical significance is that the subject of assessment became not his biography, but the country that issued the passport. How strictly a specific program vets applicants is irrelevant in the new framework.

Regulation (EU) 2025/2441: Citizenship by Investment as Grounds for Suspending Visa-Free Travel

Citizenship by investment issued by a third country became an independent ground for suspension of its visa-free regime with the European Union—previously suspensions had to be justified through migration risks and security threats.

Regulation (EU) 2025/2441 was adopted November 26, 2025, amends Regulation (EU) 2018/1806, published in the Official Journal December 10, 2025, and entered into force on the twentieth day after publication. The new ground is Article 8a(1)(e): "operation by a third country listed in Annex II of an investment citizenship programme whereby citizenship is granted to a person in exchange for a predetermined payment or investment without that person having any genuine connection with that third country."

The last point is what most retellings miss. The norm does not distinguish between passport programs by strictness of due diligence: the scheme as such is covered by its scope.

The European Commission Letter of June 25, 2026: What Exactly Was Demanded

The June 25, 2026 letter from the European Commission demands that Caribbean passport programs be wound down by June 1, 2028. The addressees are Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia: all five countries where passports are issued for a contribution to a state fund.

The content of the requirement, based on published reports and confirmation from Antigua and Barbuda:

• wind-down deadline—June 1, 2028;
• transition period—24 months;
• interim measures of enhanced vetting—due by September 2026;
• legal basis—the revised suspension mechanism effective December 30, 2025;
• the Commission's position statement—the program is grounds for suspension "regardless of how well it is managed";
• next checkpoint—the Commission's next report on the suspension mechanism, expected December 2026, to include state responses.

The letter itself was not published in open access: its content is known from reports in industry publications and from confirmation by the Antigua and Barbuda government. This is the only element of the timeline without a primary source in open access, and we are explicit about this.

What June 1, 2028 Means and What It Does Not

June 1, 2028 is the date by which the Commission wants cessation of passport programs, not the date of automatic suspension of visa-free travel. The difference between these two statements determines everything that will happen in 2027.

Myth-busting: "from June 1, 2028, Caribbean passports lose visa-free Schengen." No published act contains such a rule. Suspension of visa-free regime is a separate procedure under Regulation (EU) 2018/1806, launched by Commission proposal and Council decision, with its own timeline and may begin either before 2028 or not occur at all if the programs are wound down.

From this follows the key point for anyone calculating deadlines for citizenship by investment: the significant dates lie before 2028, not in it. September 2026 is the deadline for interim measures. December 2026 is the Commission report. 2027 is the period in which the Commission either records compliance or gains grounds to move toward the suspension procedure.

Calendar of Decisions: September 2026 to June 2028

Between the Commission letter and the stated wind-down deadline for passport programs, four checkpoints fit, three of them in the next 15 months.

None of these dates triggers an automatic consequence. Each is a point where a decision is made or its absence is recorded.

The Second Front: The US Acts Faster and by Its Own Rules

American restrictions on Caribbean passports were introduced without transition periods and already apply, whereas European ones exist for now only as a requirement with a deadline.

Grenada has a separate case: it holds a treaty with the US granting the right to apply for an E-2 investor visa, but since December 23, 2022, US law requires an applicant who purchased citizenship to have 3 years of continuous domicile in the treaty country. This rule is discussed in a separate material in this series.

Practical takeaway for comparing the two fronts: American measures are introduced by proclamation and rule, European ones by regulation and Council decision. The former are faster, the latter broader in consequences because they affect visa-free access to 29 Schengen zone states.

Precedent: Vanuatu—How to Count the Timeline

The Vanuatu precedent—the only completed case of applying the European mechanism to a country with an investment program—took about three years: from the first restrictive measure in March 2022 to final termination of visa waiver on December 12, 2024. This duration, not eleven months from first measure to full suspension, should be used for assessing the procedure—for Caribbean forecasts this is a more prudent estimate.

The Council listed the reasons in the decision text: over 10,500 passports issued by March 2021 with an extremely low rejection rate; grant of citizenship to individuals listed in Interpol databases; no requirements for physical presence or residence; short processing times; absence of systematic information exchange with applicants' countries of origin.

Two circumstances of the precedent matter for Caribbean forecasts. First: the partial measure applied to passports issued from May 25, 2015 onward, but the full measure applied to all citizens without exception, including those who never bought a passport. Second: Vanuatu had no 24-month transition period—dialogue lasted nine months and ended with lack of progress. Full suspension subsequently stood without review for nearly two years until the December 12, 2024 decision replaced the temporary measure with a permanent one.

Three Scenarios for 2027

None of the three scenarios is a prediction: each is tied to a specific trigger that will or will not occur on the dates in the calendar above.

Scenario A. Wind-down on schedule

Trigger: interim measures introduced by September 2026, December 2026 Commission report records progress.

What happens in 2027: programs continue operating, but applications close in advance—the state needs time to process already-submitted cases by June 1, 2028. Practical consequence: the actual closure date for submissions comes earlier than the stated deadline, and how much earlier is determined by the states themselves.

Scenario B. Rebranding

Trigger: one or more states announce program reform instead of closure—following Malta's example, which replaced its passport program with naturalization for exceptional services.

What happens in 2027: the Commission evaluates not the label, but the substance. The norm in Article 8a(1)(e) describes the scheme through two features—predetermined payment and absence of genuine connection. A reform preserving both features does not remove the basis. A reform introducing a genuine residency requirement removes it—but then this is no longer citizenship by investment, but naturalization with an investment condition, and timelines are measured in years of residence.

Scenario C. Moving toward visa suspension

Trigger: the December 2026 report records lack of progress.

What happens in 2027: the procedure under Regulation (EU) 2018/1806 launches—Commission proposal, then decision. By the Vanuatu precedent, 11 months passed between first measure and full suspension, and nearly three years until final regime termination; the longer duration is a more reliable basis for timing forecasts. The first measure may be selective—for example, by document issuance date, as was done for Vanuatu with respect to those issued from May 25, 2015 onward.

What a Passport Holder Retains in Each Scenario

None of the described mechanisms revoke already-granted citizenship: European acts govern the visa regime, not the validity of a third country's passport. Only the issuing state may revoke citizenship, and only under its own law.

Myth-busting: "if the program closes, the passport will be annulled." Program closure ends new applications—it does not revoke already-granted citizenship. Revocation of citizenship exists as a separate institution of national law and applies to a specific person on a specific basis: typically, document forgery or false information in the application.

How the Real Estate Route Differs from the Passport Program

The Turkish passport—the only one in our catalog of 23 countries accessible through real estate purchase—works differently from Caribbean fund contributions: the investment remains the applicant's property.

The Turkish program threshold of $400,000 at the Central Bank of Russia rate on September 3, 2026—86.9963 RUB per USD and 100.8287 RUB per EUR—corresponds to €345,124.

Turkey did not appear in the June 25, 2026 Commission letter: the requirement was addressed to five Caribbean states. This is no guarantee for the future—Article 8a(1)(e) is phrased as a general ground applicable to any country in Annex II—but as of September 3, 2026, Turkey was not among the addressees.

How We Verify the Data

Methodology

Dates and wording of European acts are cited from texts in the Official Journal of the European Union with issue number, date, and page references; the EU Court ruling from the text of the judicial act. American measures are from published final rule and proclamation, discussed in earlier materials in this series. The content of the June 25, 2026 European Commission letter is drawn from industry publications and confirmation by the addressed government, as the document itself was not published; this is noted in the text. Catalog numbers were retrieved by query of our database on September 3, 2026; currency conversions use the Central Bank of Russia rate for the same date. Scenarios are labeled as scenarios and tied to dated triggers; we assign no probabilities.

Sources

• Judgment of the Court of Justice of the European Union (Grand Chamber) of April 29, 2025 in Case C-181/23, Commission v. Malta.
• Regulation (EU) 2025/2441 of November 26, 2025, amending Regulation (EU) 2018/1806; Official Journal of December 10, 2025.
• Council Decision (EU) 2022/2198 of November 8, 2022, Official Journal L 292 of November 11, 2022, pp. 47–49; Council Decision (EU) 2022/366 of March 3, 2022; Implementation Regulation (EU) 2022/693 of April 27, 2022.
• Council Decision of December 12, 2024 on termination of visa waiver for Vanuatu—per Council press release of December 12, 2024; act text unavailable as of publication date.
• Final Rule on Visa Bonds, 91 FR 48757, August 3, 2026.
• Central Bank of Russia rate as of September 3, 2026.
• Homzer database of properties, snapshot September 3, 2026.

Disclaimer

Information is provided for reference and describes regulatory status as of September 3, 2026. Scenarios are not forecasts with guarantees and do not replace legal advice. Program conditions, country lists, and visa regimes change; before any decision verify current status with a lawyer in the relevant jurisdiction and from official sources. Verify terms before a transaction.

Questions and Answers

Will Caribbean programs close on June 1, 2028?

That is the date the European Commission demanded their wind-down, not the date of automatic closure. The decision rests with the states; in response the Commission may launch the suspension procedure or record compliance.

Will visa-free Schengen be revoked for already-issued Caribbean passports?

No such decision exists as of September 3, 2026. In the Vanuatu precedent, the first measure applied to passports issued from a certain date, eleven months later restrictions extended to all citizens of the country, and in December 2024 the visa-free regime was terminated permanently.

Can the European Union annul third-country citizenship?

No. European acts govern the visa regime—the right of entry without a visa. The validity of the document is determined by the law of the issuing state.

Does the European Commission requirement apply to Turkey?

Turkey was not named in the June 25, 2026 letter: the addressees were five Caribbean states. However, Article 8a(1)(e) is phrased as a general ground applicable to any country in Annex II.

What changed for Caribbean programs directly from the EU Court ruling on Malta?

Directly—nothing: the Court examined obligations of a state—a Union member. Indirectly—it formulated the genuine connection criterion, which later entered visa regulation as grounds for suspension.

Can Russian citizens currently apply for a Caribbean passport?

Applications from Russian citizens are closed in at least two of the five programs: Grenada has not accepted them since March 31, 2023, and restrictions apply in Dominica as well. The status of others must be checked on the date of application.

What is the nearest date to watch?

September 2026 is the deadline for interim enhanced screening measures, and December 2026 is when the Commission will submit its report on the suspension mechanism, which will include member states' responses.