Key takeaways
- On 29 April 2025 the EU Court of Justice ruled that granting citizenship in exchange for predetermined payments breaches EU law. Malta closed its programme in July 2025.
- No EU country offers citizenship for a fixed investment in 2026. Any offer of an "EU passport for €X" is either a residence permit described as citizenship, or not genuine.
- Malta and Austria keep discretionary routes for exceptional contributions, with no published price and no guarantee.
- The realistic route for most investors is residence, then naturalisation: from 5 years (Ireland, Germany, Netherlands) to 10 years (Portugal, Italy, Spain).
- For people with the right ancestry, descent routes in Hungary, Romania, Poland or Bulgaria can be the fastest path of all.
Until 2020, three EU countries — Cyprus, Bulgaria and Malta — granted citizenship to investors. Cyprus closed its programme in November 2020 after a media investigation, and later revoked hundreds of passports. Bulgaria repealed its scheme in March 2022. Malta held out until the European Commission took it to court. This guide explains where that leaves investors in 2026 and what genuinely remains.
The ruling that ended EU citizenship for sale
In Commission v Malta (Case C-181/23), decided by the full Grand Chamber on 29 April 2025, the Court of Justice held that a naturalisation procedure granting citizenship in exchange for predetermined payments or investments amounts to the commercialisation of nationality, and so of EU citizenship. Malta was found in breach of the Treaty provisions on EU citizenship and on sincere cooperation between member states.
Two consequences matter for investors:
- No member state can run a "pay and naturalise" programme. The ruling applies to the principle, not only to Malta's version of it.
- Existing citizens keep their nationality. The judgment does not revoke citizenship already granted.
Malta after the ruling: the merit route
Malta amended its Citizenship Act with effect from 24 July 2025, ending the investment route. What replaced it is a discretionary grant for people who render "exceptional services" or make an "exceptional contribution" in fields such as science, the arts, sport, business, technology or philanthropy. There is no fixed investment threshold. Applicants first reside in Malta, then submit a proposal that is assessed case by case — a process that typically takes one to two years with no certainty of approval.
For reference, the former programme required €600,000 or €750,000 in contributions plus property and a donation. Those figures no longer define an entitlement. Malta's Permanent Residence Programme remains open and gives permanent EU residence, not citizenship. See also our Malta page.
Other discretionary routes
Austria’s discretionary grant
Austrian law allows citizenship for "extraordinary achievements" in the interest of the Republic. Grants are discretionary, there is no published amount, no right of appeal, and approvals are rare. It is not a programme you apply to; it is a recognition that follows substantial, genuine engagement with Austria over time.
Outside the EU, but in Europe
Montenegro closed its programme at the end of 2022. North Macedonia's economic citizenship route has been largely dormant, and the EU is pressing for its repeal. Neither confers EU citizenship.
The realistic route: residence, then naturalisation
For most investors, EU citizenship is now the end of a residence path. The years required, and whether you can keep your current nationality, vary widely:
| Country | Residence required | Language / tests | Dual citizenship |
|---|---|---|---|
| Ireland | 5 years (1,825 days in 9 years) | No language test | Allowed |
| Germany | 5 years (fast track abolished 2025) | German B1, civics | Allowed since 2024 |
| Netherlands | 5 years | Dutch integration exam | Usually renounce, broad exemptions |
| Latvia | 5 years of permanent residence | Latvian language and history | Limited list of countries only |
| Malta | about 5 years in total | Maltese or English | Allowed |
| Greece | 7 years | Greek B1, history, civics | Allowed |
| Cyprus | 7 of last 10 years (3–4 for highly skilled) | Greek B1 | Allowed |
| Hungary | 8 years | Constitutional studies exam | Allowed |
| Portugal | 10 years (7 for EU/CPLP) | Portuguese, civics | Allowed |
| Italy | 10 years | Italian B1 | Allowed |
| Spain | 10 years (2 for Ibero-Americans) | Spanish A2, civics | Usually renounce |
Golden visa is not citizenship. Most golden visas require only a few days a year in the country. Naturalisation, by contrast, usually expects genuine residence — Greece in practice looks for more than half the year — plus language and integration. A golden visa gives you the right to start the clock; it does not run it for you.
Where golden visa years count
- Portugal: Golden Visa years count, but the requirement rose to ten years in May 2026 — see Portugal's new citizenship clock.
- Greece: Golden Visa years count towards seven, but you must be genuinely resident and pass the naturalisation exam.
- Hungary, Italy, Cyprus: residence by investment starts the clock towards eight, ten and seven years respectively, with genuine-residence expectations in practice.
Residence programmes that start the clock
If EU citizenship is the long-term goal, the residence programme you choose today sets both the timeline and what "genuine residence" will mean for your family.
| Residence route | Entry cost (from) | Years to citizenship | Stay needed to qualify |
|---|---|---|---|
| Greece Golden Visa | €250,000 (conversion property) | 7 | Genuine residence and exam |
| Cyprus permanent residence | €300,000 + VAT | 7 of 10 | Physical residence, Greek B1 |
| Malta permanent residence | about €170,000 in fees + rent | about 5 | Continuous residence before applying |
| Hungary Guest Investor | €250,000 fund | 8 | Continuous residence, exam |
| Portugal Golden Visa | €250,000 donation or €500,000 fund | 10 | Legal residence; language and civics |
| Italy investor visa | €250,000 startup | 10 | Genuine residence, Italian B1 |
The cheapest entry is rarely the fastest exit. A family willing to move properly to Cyprus or Malta can be naturalised years before a family holding a Portuguese golden visa from abroad.
What EU citizenship gives — and what it does not
EU citizenship brings the right to live, work, study and retire in any of the 27 member states, consular protection from any EU embassy abroad, and one of the strongest passports in the world. It does not, by itself, change your tax residence, and some countries attach duties to citizenship — such as military service for young men in countries that still have conscription. Check those obligations for your children before you apply.
A worked timeline
Consider a family relocating from Dubai to Limassol in 2027 through Cyprus permanent residence. If they live there genuinely, learn Greek to B1 and meet the seven-in-ten-years rule, they could apply around 2034. The same family holding a Portuguese golden visa and spending a few weeks a year in Lisbon would wait until the late 2030s — and would still need to pass language and civics tests. Neither path is quick; one is simply much shorter than the other.
Do you need citizenship, or would residence do?
For many investors, the goals behind "an EU passport" — living in Europe, schooling for the children, a secure base, free movement for business — are largely met by long-term residence. After five years of legal and continuous residence, many non-EU nationals can apply for EU long-term resident status, which gives the right to live permanently in that country and eases moves to other member states. Permanent residence programmes in Malta and Cyprus give security from the start.
Citizenship adds what residence cannot: the right to live anywhere in the EU without conditions, the vote, consular protection and a passport that travels visa-free almost everywhere. It also requires more: longer residence, tests and, in some countries, giving up your current nationality. Deciding which you actually need changes the whole plan.
Citizenship by descent: the fastest route for some
For many readers from the CIS and Eastern Europe, ancestry opens doors that money no longer can:
- Hungary offers simplified naturalisation, with no residence requirement, to descendants of Hungarian citizens who speak Hungarian.
- Romania restores citizenship to descendants — up to the third generation — of former citizens from territories such as today's Moldova and parts of Ukraine, without residence. Procedures were tightened in 2025.
- Poland grants holders of the Pole's Card free permanent residence, and recognition as a citizen after one year with B1 Polish.
- Bulgaria allows descendants of Bulgarian origin up to great-grandparents to naturalise without residence.
- Italy restricted citizenship by descent from March 2025: most people born abroad with another nationality now qualify only if a parent or grandparent held Italian citizenship alone, or a parent lived in Italy before their birth.
Descent cases turn on archives — birth, marriage and emigration records — so the first step is documentary research, not an application.
Building a descent claim
Descent claims are built from records: birth, marriage and death certificates across generations, proof of the ancestor's citizenship, and evidence linking each generation. For Eastern Europe, the records often sit in regional archives, church registers or old passport files, sometimes in a different country from today's border. Expect several months of research, certified translations and, in some countries, a language interview. The cost is usually modest compared with any investment route; the time is spent on paperwork, not waiting.
How long a descent case takes
Once the records are assembled, processing times vary widely: some countries decide within a year, while others have backlogs of two years or more, and interviews or language checks can add time. Applications must usually be filed in person at a consulate or in the country itself. Because the ancestor's citizenship must be proved at a specific historical date, a professional archive search at the start avoids the most common reason for refusal — a gap in the chain between generations.
Spotting a misleading "EU passport" offer
- It names a price for citizenship. No EU country has one in 2026.
- It promises a passport in months. Genuine naturalisation takes years; merit routes are discretionary.
- It sells residence as citizenship. A golden visa card is a residence permit, not a passport.
- It relies on a non-EU country presented as "European", or on a country with an EU candidacy.
- It asks for payment to an individual or an unlicensed company rather than a government or regulated escrow.
A realistic plan for EU citizenship
- Check descent first. A grandparent's birthplace can be worth more than any investment.
- Choose residence where you can actually live. Naturalisation rewards genuine residence; choose a country whose language and life you can commit to.
- Match the clock to your family. Five years in Ireland or Germany and ten in Portugal or Italy are very different plans for a family with teenagers.
- Keep a passport for the meantime. Many clients combine an EU residence with a citizenship-by-investment passport for travel today — see the real-cost ranking.
- Plan tax residence alongside immigration — explained in residence permit vs tax residence.
EU citizenship by investment: FAQ
Can you buy EU citizenship in 2026?
No. Since the EU Court of Justice ruling of 29 April 2025 in Commission v Malta, granting citizenship for predetermined payments is incompatible with EU law, and no member state runs such a programme.
Is Malta citizenship by investment still available?
No. Malta ended the investment route on 24 July 2025. A discretionary route for exceptional services or contributions remains, with no fixed price and case-by-case assessment.
What is the fastest way to get EU citizenship?
For people with qualifying ancestry, descent routes in Hungary, Romania, Poland or Bulgaria can be fastest. By residence, Ireland, Germany and the Netherlands require about five years.
Does a golden visa lead to EU citizenship?
It can start the residence clock, but naturalisation usually requires genuine residence, language and integration tests over 7 to 10 years depending on the country.
Which EU countries allow dual citizenship?
Most, including Ireland, Germany (since 2024), Greece, Cyprus, Malta, Hungary, Portugal and Italy. Spain and the Netherlands usually require renunciation, with exceptions; Latvia allows it only for a list of countries.
Sources
- CURIA — Judgment in Case C-181/23, Commission v Malta (29 April 2025)
- Euronews — Malta’s golden passport scheme rejected by EU top court (April 2025)
- Mifsud & Mifsud — Amendments to the Maltese Citizenship Act: citizenship by merit (2025)
- Irish Immigration Service — Becoming an Irish citizen by naturalisation
- Office of Citizenship and Migration Affairs, Latvia — Naturalisation
- The Local Germany — Law repealing the three-year citizenship track takes effect (October 2025)
- Government of Poland — Recognition as a Polish citizen
- EUR-Lex — Regulation (EU) 2025/2441 on the visa suspension mechanism
About the author
Valentin Niculae — Founder, The Discreet Investor
Valentin Niculae founded The Discreet Investor. He works with families, founders and investors from Europe, the Middle East and the CIS on second citizenship, residence permits, company formation and international banking — and writes these guides from the questions clients bring to him. LinkedIn
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