The EU investment passport, in the sense of buying an EU citizenship outright, is no longer available. The European Court of Justice ruled Malta’s citizenship-by-investment program incompatible with EU law in May 2025, Cyprus closed its program in November 2020, and the European Commission has pressed remaining member states to shut similar schemes down. What is still available is residency by investment: permits to live in a specific EU country, obtained through a qualifying financial commitment, in Portugal, Greece, Italy, Malta, and Hungary. Those permits can lead to citizenship after several years, but only through the same naturalization rules that apply to any other resident.
Why the Citizenship Route Is Closed
Under Article 20 of the Treaty on the Functioning of the European Union, holding the nationality of any member state automatically makes a person an EU citizen, with the right to live and work in any EU country and travel visa-free throughout the bloc.1EUR-Lex. Consolidated Version of the Treaty on the Functioning of the European Union – Article 20 Because national citizenship triggers bloc-wide rights, the Commission treats the sale of it as a matter of collective concern.2European Parliament. The Citizens of the Union and Their Rights
In 2022, the Commission declared citizenship-by-investment schemes “not compatible with the principle of sincere cooperation” under EU treaties and called on member states operating them to repeal them immediately.3European Commission. Recommendation on Immediate Steps in the Context of the Russian Invasion of Ukraine – C(2022) 2028 Final The ECJ then ruled in Case C‑181/23 that Malta’s golden passport program violated EU law.4InfoCuria. Case C-181/23 – European Commission v Republic of Malta Malta replaced its old Maltese Exceptional Investor Naturalisation program with a “Citizenship by Merit” pathway that has no fixed investment threshold and looks at demonstrated contributions to national interest rather than a set payment. Ireland and the United Kingdom terminated their investor programs around the start of the Ukraine conflict. Spain ended its golden visa in April 2025.
The takeaway for anyone searching for a straight cash-for-passport route: it does not exist in the EU. Residency programs remain, and residency can eventually convert into citizenship through naturalization, but the timelines and requirements are the ones ordinary immigrants face.
What Residency by Investment Actually Gives You
A residence permit lets you live in the issuing country without a time limit, subject to renewal, and lets you travel to other Schengen-area countries for up to 90 days within any 180-day window. Longer stays in another Schengen country require following that country’s national immigration rules. Your residence permit does not make you a citizen of the issuing country, and it does not carry EU-wide rights to live and work in other member states.
That said, physical presence requirements on the residency permit itself are unusually light. Greece, Italy, Malta’s residency program, and Hungary impose no minimum stay to keep the permit active. Portugal asks for an average of seven days per year, structured as 14 days per two-year renewal period. This is why the programs appeal to investors who want a European foothold without moving.
Programs Currently Active
Thresholds and eligible investments have shifted repeatedly in the last few years. Verify the current rules with the issuing country’s immigration authority before you commit any capital.
Portugal
Portugal’s golden visa has raised more than €7 billion since 2012. Real estate was removed as a qualifying route in late 2023. The primary path now is a €500,000 minimum commitment to a venture capital or private equity fund. Qualifying funds must be regulated by Portugal’s securities market regulator (CMVM), must invest at least 60% of their capital in Portuguese-based companies, and require a minimum five-year holding period. Eligible sectors include renewable energy, tourism, healthcare, and agriculture; real-estate-focused funds no longer qualify. Applications are processed through AIMA, the Agency for Integration, Migration, and Asylum. Citizenship eligibility begins after five years of legal residency.
Greece
Greece offers the broadest set of qualifying investments, and real estate is still on the list. The property thresholds are tiered:
- €250,000 for converting commercial properties to residential use or restoring listed buildings, anywhere in the country.
- €400,000 for a single residential property of at least 120 square meters outside the highest-demand zones.
- €800,000 for property in Athens, Thessaloniki, or islands with more than 3,100 inhabitants.
Non-real-estate options include a €500,000 bank deposit, €500,000 in government bonds with at least three years remaining maturity, or €350,000 in qualifying mutual funds. No ongoing physical presence is required to hold the permit. Greek citizenship requires seven years of residency plus language and integration requirements.
Italy
Italy’s investor visa launched in 2018 and has grown steadily. Minimums vary by asset class:
- €250,000 for investment in an innovative Italian startup.
- €500,000 for investment in an Italian limited company.
- €1,000,000 for a philanthropic donation supporting Italian culture, education, or research.
- €2,000,000 for Italian government bonds.
There is no minimum physical presence requirement to keep the visa. Citizenship eligibility begins after ten years of legal residency, the longest waiting period among the major programs.
Malta
Malta’s residency-by-investment program, the Malta Permanent Residence Programme (MPRP), remains active after the citizenship program’s closure. It requires either buying property worth at least €375,000 or renting at a minimum of €14,000 per year, plus a €37,000 government contribution and a €2,000 donation to a registered Maltese NGO. Applicants must show capital assets of at least €500,000 (including €150,000 in financial assets) or €650,000 (including €75,000 in financial assets). No minimum stay is required.
Hungary
Hungary launched a guest investor visa and residence permit in 2024. The main qualifying route is investment fund shares in a Hungarian real estate fund whose net asset value is at least 40% Hungarian residential real estate. Investments must be completed within three months of visa issuance and certified through Hungary’s Enter Hungary platform.5Hungarian Office of Immigration and Asylum. Guest Investor Visa and Permit Frequently Asked Questions No physical presence is required.
Investment Categories in Practice
The same headline number can mean very different things depending on the asset class.
Real estate remains available in Greece, Malta, and Hungary, though Portugal and Spain have eliminated it. Where property still qualifies, the definition is narrow: programs restrict property type, minimum size, or location zone. Greece’s €800,000 Athens threshold against its €250,000 restoration threshold shows how far the same program can flex.
Investment funds are now the dominant Portuguese path. These are typically venture capital or private equity vehicles regulated by national securities authorities. Capital is locked up for the holding period (five years in Portugal), and early withdrawal jeopardizes your visa. Fund performance is not guaranteed.
Government bonds and bank deposits carry lower risk but tie up capital in low-yield instruments. Greece allows a €500,000 fixed-term deposit or €500,000 in government bonds. Italy prices its bond route at €2,000,000. Business investment and donations round out the list, with Italy’s €250,000 startup route among the lowest entry points in Europe, provided the target company carries the government’s “innovative” classification.
From Residency to Citizenship
Every one of these programs can, in theory, lead to citizenship. In practice, the naturalization rules of each country apply, and they generally assume real residency rather than a dormant permit. Portugal requires five years, Greece seven, and Italy ten. Those timelines typically require you to actually live in the country for a meaningful portion of each year and to demonstrate language proficiency and integration. The light physical-presence rules that make the permits attractive for investors are a poor match for citizenship applications, and applicants who want the passport at the end need to plan for real residence long before the eligibility window opens.
Costs Beyond the Investment
The investment amount is only part of the outlay. Government processing fees, due diligence fees, and administrative charges add up quickly. Malta’s MPRP charges a €60,000 application fee for the main applicant plus €7,500 for each additional adult dependent, alongside the €37,000 government contribution and a separate due diligence fee. Portugal has its own application and renewal fees. These charges are non-refundable regardless of the outcome.
Documentation is heavy, and incomplete files are the main reason for processing delays. Every program demands proof that the investment capital was legally earned: bank statements, tax returns, audited financial records over several years, and a clear source-of-funds trail. Business owners need company ownership documents. Holders of cryptocurrency should expect to produce transaction records and exchange confirmations. Criminal background clearances are mandatory, with each program setting its own threshold (six or 12 months of residence) for which past jurisdictions must be covered. Malta requires at least eight months of remaining passport validity at submission. Private health insurance covering the host country is standard. All foreign documents must be translated into the host country’s language and authenticated with an apostille.
Timelines run from three to six months for a straightforward file in an efficient jurisdiction up to 12 months or more where the applicant has cross-border business interests or complex assets. The initial residence card is typically renewed every one or two years, then every five years on longer-term permits. Biometrics are collected during the initial application or on first entry.
U.S. Tax Obligations Do Not Go Away
The United States taxes its citizens and permanent residents on worldwide income regardless of where they live, so obtaining EU residency does not reduce your U.S. tax burden.6Internal Revenue Service. U.S. Citizens and Residents Abroad – Filing Requirements You continue filing U.S. returns and reporting all foreign income, including rental income, fund distributions, and capital gains, in U.S. dollars.
Bilateral tax treaties between the U.S. and most EU member states can reduce or eliminate double taxation on certain income and generally allow credits for taxes paid to the host country. A “saving clause” in most treaties prevents U.S. citizens from using treaty provisions to escape tax on U.S.-source income entirely. Some U.S. states do not honor federal tax treaty provisions, so state-level obligations need separate attention.7Internal Revenue Service. United States Income Tax Treaties – A to Z
Foreign financial account reporting is separate from income tax. If the combined value of your foreign bank, securities, or financial accounts exceeds $10,000 at any point during the year, you file FinCEN Report 114 (the FBAR) through the BSA e-file system.8FinCEN. Report Foreign Bank and Financial Accounts Form 8938 may also be required if specified foreign financial assets exceed $200,000 on the last day of the tax year, or $300,000 at any time during the year, for individuals living abroad, with higher thresholds for joint filers.9Internal Revenue Service. Do I Need to File Form 8938, Statement of Specified Foreign Financial Assets FBAR penalties reach $10,000 per violation, and unfamiliarity with the requirement is not a defense.
Planning the Exit
Every qualifying investment carries a mandatory holding period, typically five years, during which you cannot sell or withdraw without losing your residency. When that period ends, selling the asset triggers capital gains tax, generally in the country where you are tax-resident at the time of sale. Some EU countries also impose exit taxes when you move your tax residency elsewhere, which can create an unexpected liability if you relocate before selling.
Whether the investment holds its value over the holding period is the practical question most applicants underweight at the outset. Government bonds are relatively predictable. Venture capital funds are not. Real estate in popular tourist areas has historically appreciated, but programs that limit investment to specific zones or property types can narrow the resale market. Get country-specific tax advice for both the host country and your home country before committing capital, and plan the exit before the entry.