Citizenship by Investment Challenged, Residency by Investment Unaffected

On April 29th, the European Court of Justice (ECJ) ruled that Malta’s Citizenship-by-Investment program is not compatible with EU law, stating that Union citizenship “cannot result from a commercial transaction.” The decision emphasises that EU citizenship must reflect a genuine connection to a member state, not be granted solely on the basis of financial investment.


While the ruling addressed the program’s legal basis, it did not clarify whether citizenships already granted under the scheme would be affected. The European Commission said it would review the judgment to assess its implications. Malta’s government has maintained that its program includes strict due diligence and serves national interests. The country remains the only EU member offering direct citizenship through investment.


In comparison, Greece offers a residency-by-investment program (commonly known as the Golden Visa), which grants legal residence to non-EU nationals who invest in real estate or other qualifying assets. While it does not provide immediate citizenship, it allows residents to apply for naturalisation under the same rules as other long-term residents, based on residency duration, language skills, and integration.


Greece’s program has been in operation since 2013 and has not faced legal challenges or objections from the European Union. It is considered compliant with EU norms, as it does not offer citizenship outright but instead facilitates legal residence with a clear path to citizenship under established naturalisation laws.

Reach out today to explore your residency-by-investment options in Greece


Please contact our team for any inquiries about the Greek Golden Visa and how you can start your process.

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