European Union
The ECJ ended Malta's citizenship-by-investment. Where EU passport demand goes next.
In April 2025 the European Court of Justice ruled Malta's citizenship-by-investment scheme contrary to EU law. A year on, here is what is actually still available, and where the displaced demand is landing.
Malta was, for years, the only place in the European Union where a direct contribution could lead to a passport. On 29 April 2025, the European Court of Justice ended that, ruling the country’s citizenship-by-investment scheme contrary to EU law. The decision did not just close one programme; it closed the category.
What is still available in Malta
The confusion worth clearing up first: Malta did not close to investors. Its Permanent Residence Programme (MPRP) is unaffected and remains open. It grants lifelong EU permanent residence with Schengen access and no minimum-stay requirement. What ended was the route to citizenship by investment specifically.
Naturalisation in Malta is still theoretically possible after several years of genuine residence, but it is discretionary and not an investment product. Malta has signalled a future “citizenship by merit” framework; until its terms exist, it should be treated as unavailable rather than as a plan.
Where the demand is going
An EU passport by contribution is, for now, off the table everywhere in the bloc. That demand has split three ways.
Toward EU residence programmes with an eventual naturalisation path (Portugal, Greece, Italy), where the investor accepts a multi-year residence clock instead of a direct purchase, a clock that, in Portugal’s case, just got longer.
Toward Caribbean citizenship-by-investment, where the passport is weaker than an EU one but is granted on approval with no residence, suiting buyers whose priority is a second nationality rather than specifically a European one.
And toward non-EU European options and Gulf residence, for investors whose real need was mobility and a base rather than EU citizenship as such.
The honest read
There is no like-for-like replacement for what Malta offered, and any firm presenting one is selling, not advising. The right substitute depends entirely on whether you wanted Malta, an EU passport, or a second citizenship, three different goals that the old programme happened to satisfy at once.
Written by
Robert McCray
Founder, CIVITAS
Robert McCray is the founder of CIVITAS, an independent investment-migration advisory that is paid by its clients rather than by the programs it analyses. He works across more than twenty residence and citizenship-by-investment programs and built the firm's open dataset and scoring tools to make the category legible.