What is the future of these investment and citizenship-by-investment schemes around the world?

Dubbed “golden visas,” citizenship/residency-via-investment programmes in a variety of countries have been under pressure. Some of the opposition comes from politicians who claim these programmes push up property prices unduly, impeding citizens’ ability to buy a home; other policymakers have claimed that they are weak spots in the fight against international dirty money. On their defence, advocates say they provide small jurisdictions with valuable sources of revenue and that in any event, they are typically meant to be temporary. Golden visas are also evolving to meet some of these concerns. In many cases, golden visas are part of a wider debate about inequality, globalisation and open capital movement. 

Whatever the state of the sector, Isobel Neilson (pictured below) of global mobility advisory firm Fragomen takes us on a tour of the terrain. The editors are pleased to share these ideas; the usual disclaimers apply. To comment, email tom.burroughes@wealthbriefing.com and amanda.cheesley@clearviewpublishing.com

Isobel Neilson

Investment-based residency options, commonly known as golden visas, have narrowed significantly in recent years, due largely to political optics and public pressure. 

Investment migration became closely associated with real estate investment, which the public often viewed negatively, particularly where housing costs are a defining political issue. Governments and regulators faced criticism where programmes were perceived to attract wealthy individuals seeking diversification, raising concerns around money laundering, tax evasion, corruption and inadequate due diligence. As a result, many countries have either tightened these programmes considerably or closed them altogether. 

The era of passive investment, such as purchasing property or maintaining a bank deposit, has given way to an emphasis on active and meaningful contribution. 

Many jurisdictions have removed real estate as a qualifying investment entirely, steering applicants towards direct investment in local companies, philanthropic donations or business activity that generates local employment. At the same time, governments have strengthened due diligence and increased residence requirements to reduce risk and ensure greater economic value to the host country. 

Where golden visas have disappeared, applicants increasingly turn to passive income and digital nomad routes, particularly when the objective is lifestyle relocation rather than passive residence rights alone. Talent-based and entrepreneurial visas are also capturing a greater share of the market. The UK’s Global Talent visa is a prominent example, attracting increased interest since the closure of the Tier 1 Investor visa. France and Australia offer similar routes that prioritise expertise, innovation and achievement over capital investment alone. 

Europe illustrates the divergence in national approaches. Spain closed its programme in April 2025, eliminating not only property investment but also financial investment routes such as funds and bank deposits. Spain remains highly attractive, but those seeking relocation are now exploring alternatives, including passive income and digital nomad routes. 

Portugal adopted a different approach. While real estate was removed as a qualifying investment route in late 2023, the investor visa remains available through alternative options, including regulated fund investment and contributions to cultural or scientific initiatives. However, forthcoming changes to nationality law, combined with ongoing processing delays, are expected to significantly extend the path to citizenship for Portuguese residents to seven or 10 years, depending on the applicant’s circumstances. Despite this, the programme remains attractive because only minimal physical presence is required of applicants to maintain residency and continue progressing towards citizenship. 

Ireland presents a more nuanced example. Although the Immigrant Investor Programme formally closed to new applications in 2023, limited opportunities remain available through previously approved projects that continue to seek qualifying investors. In practice, the remaining route is now largely focused on philanthropic donations to preapproved healthcare, education and community initiatives, rather than traditional investment structures. Ireland continues to attract interest from high net worth individuals seeking flexible residence rights with minimal physical presence requirements, even as the programme gradually winds down.

Italy is emerging as one of the EU’s more attractive investor visa options, offering routes through government bonds, investment in Italian companies, innovative startups and philanthropic donations. The programme has benefited from favourable tax regimes, relatively quick processing times and the absence of strict physical presence requirements. Greece also remains popular because it continues to permit real estate investment at a time when many European countries have moved away from property-based routes, albeit with higher thresholds and tighter restrictions in key areas. 

Beyond Europe, policy is evolving in different directions. New Zealand has refined its investor pathway to encourage active investment aligned with national priorities, while the UAE has expanded its Golden Visa programme as part of a broader strategy to attract investors, entrepreneurs and highly skilled professionals. Costa Rica has also seen increased interest, particularly from US nationals, because of comparatively moderate investment thresholds and limited physical presence requirements. In the US, the longstanding EB-5 investor programme is now complemented by the Trump Administration’s Gold Card program, which aims to offer additional options for high net worth individuals. 

Citizenship-by-investment programmes tell a similar story. Demand for second citizenships remains strong as wealthy individuals seek greater optionality during a period of geopolitical uncertainty, but scrutiny continues to intensify. 

The Caribbean remains active in this space, although the region faces increasing pressure to strengthen due diligence standards or risk losing visa-free access to key jurisdictions. Argentina has announced plans to introduce a citizenship-by-investment programme in 2026, while new offerings have emerged in countries including El Salvador and São Tomé and Príncipe. Malta, which closed its citizenship-by-investment programme in 2025, has transitioned to a discretionary citizenship-by-merit framework favouring applicants that are able to demonstrate exceptional contribution and meaningful ties to the country. 

These developments show that investment migration is not disappearing but is being reshaped by political and economic realities. The focus is shifting away from purely transactional models towards expectations of credibility, contribution and genuine connection to the jurisdiction.

About the author

Isobel Neilson is a director in the worldwide private client practice at global mobility advisors Fragomen LLP. www.fragomen.com