HNIs explore other foreign shores after EU's citizenship blow
New Delhi: As Europe slams the door shut on one of the most sought-after fast-track citizenship programmes, that of Malta, India's wealthy elite find themselves on the lookout for new 'affordable' footholds abroad, whether it be for residence or nationality.
The European Court of Justice recently held that Malta's golden passport scheme, which granted citizenship in exchange for investment of about $672,500, effectively reduced the acquisition of nationality to a 'mere commercial transaction,' violating European Union law.
According to experts, Indian high net worth individuals (
HNWIs
) are recalibrating their strategies, with growing interest in European residence-by-investment programmes instead of
citizenship-by-investment
schemes as well as the
US EB-5 programme
that requires an investment of $800,000 and the UAE Golden Visa, pegged at about $272,300. They're also looking at such schemes in the Caribbean, Southeast Asia and New Zealand. To be sure, the Greek and Portuguese golden visa programmes are still in place, for now at least.
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Malta was ranked No 1 in Henley & Partners' 2025 Global Citizenship Program Index.
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This made the ECJ's ruling particularly consequential, as it disrupts what was considered one of the most attractive citizenship-by-investment schemes globally.
Also Read:
Green cards could be revoked at any time under newly proposed rule
'This ruling will impact all EU states offering citizenship-by-investment, effectively closing the door for Indian HNIs seeking a fast-track to EU citizenship,' said Poorvi Chothani, managing partner at LawQuest. 'This will push investors to explore alternative jurisdictions offering security, mobility, and business access.'
In the interim, applications may be delayed or subjected to stricter scrutiny.
'While the ruling does not retroactively invalidate citizenships already granted under Malta's programme, it is likely to subject these passport holders to increased scrutiny... which may affect their travel and residency rights,' said Hemang Laaheru, director at UK immigration attorney firm Conroy Baker Ltd.
Also Read:
As US visa options shrink, Indian families turn to EB-5 for security and mobility
For Indian investors, the shift is already underway.
'Interest continues to remain high in US programmes like EB-5, the UAE golden visa. Individuals are also expressing heightened interest in lifestyle residencies in Southeast Asia,' said Chothani.
According to Henley & Partners' 2024 Private Wealth Migration Report, 4,300 Indian HNIs relinquished their citizenship in 2023 to relocate abroad, placing India among the top three countries, behind China and the UK, in terms of millionaire outflows.
The Caribbean nations are now considered safer, more stable routes for wealth migration. This list includes Grenada, Dominica and St Kitts & Nevis, whose citizenship-by-investment (CBI) programmes remain popular for visa-free or visa-on-arrival access to many countries, including parts of the Schengen area.
'These nations also offer favourable tax regimes — with no capital gains or inheritance taxes,' Laaheru pointed out, adding that 'Grenada's CBI programme has already seen a high number of approvals in 2024, reflecting strong demand.'
The cost in the Caribbean varies.
'For example, Dominica is the cheapest at $200,000, and other countries can charge $250,000,' he said.
New Zealand's new programme is also gaining traction, said David Lesperance, managing director of immigration advisor Lesperance Associates.
'It grants permanent residence for investing ~$2.95 million and spending 21 days there over a three-year investment period,' he said. 'No additional investment, physical presence or tax residency required.'
The Malta crackdown underscores a growing bifurcation between golden passport (citizenship) schemes and golden visa (residency) programmes.
'India has traditionally been and continues to be a PR (permanent residency) market, and not too many Indians living in India were buying the Malta passport,' said Rajneesh Pathak, founder, Global North Residency and Citizenship. 'But a lot of global Indians consider citizenship options, especially when they wanted to give up a US Green Card or citizenship and wanted an equally strong one.'
After the ECJ ruling, they will have to either consider Caribbean passports or look at the
Portugal golden visa
, which can lead to EU citizenship in the sixth year. Malta has a PR programme that continues, Pathak pointed out.
'While direct citizenship-by-investment routes like Malta's are being phased out, there continues to be significant interest in
residency-by-investment
(RBI) programmes offered by Portugal and Greece,' said Laaheru. 'These offer a more structured, long-term pathway to EU residency and, potentially, citizenship.'
Greek and Portuguese golden visas cost about $280,200, whereas the now-scrapped Spanish golden visa used to be about $560,400.
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