Europe’s Golden Doors Are Closing — What’s Left

Between February 2022 and April 2025, six European countries closed a citizenship or residency-by-investment route — Britain, Ireland, the Netherlands, Hungary, Portugal’s real-estate route, and Spain outright. Then, on 29 April 2025, the European Court of Justice went further. It ruled that an EU member state cannot sell citizenship at all. I’ve spent the past year fielding calls from British, European and Canadian clients who assumed Europe was closed for business. It isn’t. Two golden visas are still open, Malta still sells permanent residence, and one country just outside the EU has added a twenty-year exemption on foreign income.

But the more useful version of the question isn’t "what’s left in Europe." It’s "Europe closed the passport door — so what does a British or Canadian family do now?" That’s the question this article answers.

The call I take most often runs the same shape every time. A family — British more often than not, Canadian a close second — has a Portugal fund quote in front of them at €500,000. They want to know whether to sign it. What decides it is almost never the money. It’s the clock. That €500,000 is capital locked into a fund for a passport that now sits ten years away. Set against it: roughly US$230,000–US$250,000 and five to fourteen months for St Kitts & Nevis, Grenada or Antigua & Barbuda. So the fork is this. If what the family wants is an EU life — a base, schools, a residence card, the right to be there — Portugal or Greece is the answer. If what they want is a second passport in hand, the €500,000 buys them a wait and the Caribbean buys them the document. Two different products. Half of that call goes on establishing which one the family is really buying, because a surprising number have never separated the two.

One sentence of context before the table, because it is the fact everything else hangs off: Europe no longer sells a passport to anyone, at any price. Not to a better-advised applicant, not at a higher number. That is now law rather than policy, which is why none of what follows is a workaround — it is the set of genuinely different things still on offer.

What’s left, side by side

Everything in this article compresses into one table. Residence programs and citizenship programs are genuinely different products. The visa-free column is where that difference stops being abstract: a golden visa doesn’t upgrade the passport you already travel on.

Read the visa-free column against the "time to a passport" column and the article writes itself. Turkey is fast and inexpensive, and its passport reaches the fewest destinations on this table: 112, against 144 (Dominica) to 157 (St Kitts & Nevis) for the Caribbean four. Portugal and Greece are European residence, and confer no travel upgrade at all. The four Caribbean rows are the only ones that deliver a passport reaching 144 destinations or more, in months. Each does it at an entry number below Portugal’s €500,000 fund minimum, in any currency you convert it into.

The European golden doors that have closed

Start with the graveyard. It is larger than most people realise, and it explains why everyone is suddenly anxious about the doors still open.

• The UK closed its Tier 1 (Investor) visa on 17 February 2022, part of the crackdown on illicit money after Russia’s invasion of Ukraine.
• Ireland shut its Immigrant Investor Program — €500,000 donation or €1 million investment — on 15 February 2023.
• The Netherlands ended its golden visa in January 2024, citing EU transparency and security concerns.
• Portugal closed the route behind roughly three-quarters of its applications on 7 October 2023, under Law 56/2023: the €500,000 real-estate purchase and a €1.5 million capital-transfer option. Prior applications were grandfathered.
• Hungary relaunched its Guest Investor Program in 2024, then scrapped the €500,000 direct real-estate option again on 15 January 2025. What remains is €250,000 into a regulated property fund or a €1 million education donation.
• Spain abolished its golden visa outright, effective 3 April 2025. Prime Minister Sánchez gave the reason: 94 of every 100 golden visas issued were tied to real estate in housing markets already under strain.

Six countries, four years, one direction. If you’re working from a 2023 comparison table of European golden visas, more than half the rows in it are wrong today.

The ECJ ruling that ended Malta’s golden passport

The single biggest shift came not from a national government but the European Court of Justice. On 29 April 2025, the Grand Chamber ruled in Commission v Malta (Case C-181/23) that Malta’s citizenship-by-investment scheme breached EU law. The scheme took contributions of up to €750,000 for a passport. The Court called it a "commercialisation" of EU citizenship, in violation of Article 20 TFEU and the duty of sincere cooperation between member states.

Get the scope right, because most coverage doesn’t. The ECJ outlawed selling citizenship — a golden passport. It said nothing about golden visas — residence by investment — which remain entirely lawful across the EU, Malta included. Passports already issued stay valid. The ruling applies only going forward.

Malta complied. Act XXI of 2025 abolished citizenship-by-direct-investment and replaced it with a discretionary "citizenship by merit" framework. That means naturalisation for exceptional service or contribution to Malta or humanity, assessed case by case over a reported 12 to 24 months. The statute is explicit that investment alone does not constitute merit. No route to a Maltese passport by investment remains open.

What Malta still sells: residence, not a passport

What survived is the Malta Permanent Residence Program — permanent residence, on a card renewed every five years, for life. After a 2025 overhaul, the cost is a €37,000 government contribution, a €60,000 administration fee and a €2,000 NGO donation. On top of that sits either a €375,000 property purchase or €14,000-a-year rent held for five years, plus €10,000 per additional dependant. All in, before the property, that is roughly €99,000 in non-recoverable fees under Legal Notice 146 of 2025.

That overhaul — Legal Notice 310 of 2024 — also added a dual asset test: €500,000 total with €150,000 liquid, or €650,000 with €75,000 liquid. It ended the old Gozo and South-of-Malta discounts, and capped dependent children at under 29.

Be clear about what this buys. It is EU-adjacent residence, not an EU passport. Naturalisation now runs through years of genuine residence and the merit framework above — not a cheque.

Portugal: still open, but the clock just doubled

Portugal remains the most-used golden-visa program in Europe, and it’s still accepting applications — just not through real estate. The dominant route is a minimum €500,000 into a CMVM-regulated investment fund, with at least 60% in Portugal-headquartered companies and no direct real estate. Smaller routes remain: a €250,000 cultural-heritage donation, research and company-formation options, and a ten-job-creation route.

What changed is the destination, not the door. Portugal’s parliament passed a new Nationality Law in spring 2026, signed by the President in May and in force soon after. It doubles the ordinary naturalisation clock from five years to ten, counted from your first residence card, with seven years for Portuguese-speaking-country citizens. It also adds a language, culture and civic-knowledge test. Anyone filing after that law took effect now faces a decade-long wait for a passport.

Two things soften the blow. Portugal’s Constitutional Court ruled in December 2025 that applying the rule retroactively to pending files was unconstitutional, so pre-reform applicants keep the old five-year clock. And golden-visa holders can apply for ordinary permanent residence after five years regardless of the citizenship timeline. That frees up the investment without needing the passport at all.

The market noticed. Fund redemptions reportedly ran well ahead of pace through early 2026 versus all of 2025, and reports describe 500-plus holders, many American, weighing collective legal action. Americans had become Portugal’s number-one golden-visa nationality by late 2023, with applications reportedly still surging into 2025. That is against a backlog of 20,000-plus investors waiting on a first appointment.

Greece: Europe’s highest-volume golden visa

Portugal and Malta dominate the headlines. Greece quietly runs the largest golden-visa program in Europe by volume. Since Law 5100/2024, the country runs three tiers. It is €800,000 in Attica, Thessaloniki, Mykonos, Santorini and the larger islands; €400,000 everywhere else; and €250,000 preserved nationwide for converting commercial space to residential use or restoring listed buildings.

The scale is real. Roughly 27,800 main-investor permits were valid as of December 2025, and more than 79,000 including family members. That is Europe’s largest golden-visa population, with billions of euros channelled into Greek real estate since the program’s launch. Reported cumulative totals vary by source and cut-off date, though the scale of capital involved isn’t in question. Approvals accelerated through 2025 as the Migration Ministry worked through a backlog of tens of thousands of files. Fresh applications cooled in early 2026 at the higher thresholds.

Greece’s newest law — 5275/2026 — is the biggest immigration overhaul in a decade, and it keeps the golden visa intact while tightening the edges. The five-year clock now runs from card issuance rather than investment date, a statutory 90-day processing deadline applies, and golden-visa properties can no longer be listed on Airbnb or Booking.com.

What hasn’t changed is the entry proposition: no minimum-stay requirement to renew, the whole family included, and €400,000 still buying qualifying property across most of the mainland and smaller islands. That is a lower bar than Portugal’s fund-only €500,000, and lower than Malta’s €375,000 property plus roughly €99,000 in non-recoverable fees.

Turkey: the passport Europe’s neighbours can still buy — plus a new 20-year tax play

None of the above gets you a passport quickly. If that’s the actual goal, Turkey still sells citizenship outright on Europe’s doorstep, and the 2026 tax package has changed the arithmetic.

The core terms haven’t changed. A minimum US$400,000 real estate purchase qualifies — independently valued, verified through the government’s EIDS system, with a three-year no-resale restriction on the title. So does US$500,000 via bank deposit, bonds, fund shares or fixed capital investment. Citizenship follows in 10 to 12 months, spouse and children under 18 included, with no residence or language requirement. Turkey has issued passports under this program to an estimated 50,000-plus foreign nationals since its 2017–18 reset — by industry estimates, the highest-volume citizenship-by-investment program in the world.

The process has also become more rigorous. The currency-protected version of the deposit route (YUVAM/KKM accounts) was closed to new CBI applicants in January 2025, and the underlying FX-guarantee scheme was terminated entirely in August 2025. The US$500,000 deposit option itself remains available, now without exchange-rate protection. Source-of-funds diligence tightened mid-2025, and as of 2026 applicants must appear in person for biometrics.

Here’s what changes the calculus for Brits, Europeans and Canadians specifically. In 2026, Turkey enacted Law No. 7582, inserting Article Mükerrer 20/D into its Income Tax Law. New Turkish tax residents pay zero Turkish income tax on foreign-source income and capital gains for twenty years from establishing residency. The exemption applies only where they had no Turkish domicile or material Turkish tax liability in the prior three years. It is a full exemption on foreign income. Turkish-source income stays fully taxable, and foreign tax credits don’t apply against the exempt portion. The same package added a discounted flat rate on inheritance and gifts for qualifying beneficiaries. It also created a one-time "asset peace" repatriation option: 5% tax on declared offshore assets, scaling toward zero if held five years in Turkish instruments.

Put the two together and the pairing is genuinely new. A US$400,000 passport now comes alongside a twenty-year tax holiday, landing barely a year after the UK scrapped its own non-dom regime for a four-year window. For a client who wants a low-cost, EU-adjacent base, that is two decades of breathing room on foreign income.

Now the part that decides it for most of the people reading this, and it deserves better than the footnote it usually gets. The Turkish passport reaches 112 destinations visa-free or visa-on-arrival — and none of the EU, UK or US is among them. Compare that to 157 for St Kitts & Nevis, 154 for Antigua & Barbuda and 148 for Grenada, all of which include Schengen and, with prior authorisation, the UK. If your reason for wanting a second passport is mobility — and for most British and Canadian families it is — Turkey is the wrong instrument, however good the tax regime is. It’s a tax-residency play with a passport attached, not a mobility play. Those are not the same purchase.

I don’t place clients in Turkey and earn nothing if you go there. It isn’t a jurisdiction I practise in. It is in this article because leaving it out would misrepresent the picture — not because I’d steer you into it.

Italy makes the contrast. Its investor visa stays open. But its flat tax for new residents jumped again in the 2026 budget, from €200,000 to €300,000 a year — 1.5 times the old figure.

What’s left if the passport is the point: the Caribbean

Everything above is a European answer to a European question. But most people who land on this page aren’t asking how to move to Lisbon. They’re asking what to do now that Europe has stopped selling passports. That’s a different question, and it’s the one this practice answers, from an office on Nevis rather than a desk in London.

Five Eastern Caribbean states still sell citizenship outright. Three of them are where I’d start a British or Canadian family:

• St Kitts & Nevis — US$250,000 through the Sustainable Island State Contribution, or approved real estate from US$325,000 on a seven-year hold. The fastest of the five, averaging around five months on agent-reported data, and 157 destinations visa-free or visa-on-arrival on the Henley Passport Index, October 2026. No physical-presence requirement. It’s where I live and work, so read that recommendation with my address in mind.
• Antigua & Barbuda — US$230,000 to the National Development Fund covering a family of up to four, or US$300,000 in approved real estate. 154 destinations, and around fourteen months on agent-reported averages. It is the only one of the three with a presence condition: 30 days on-island within the first five years, up from five. Antigua applies the thirty administratively. The Citizenship by Investment (Amendment) Bill 2026 that would put it in the statute was presented on 14 July 2026, and I cannot confirm it has passed. Plan on thirty. I hold this passport myself.
• Grenada — US$235,000 to the National Transformation Fund, or real estate from US$350,000 for a sole purchase, plus a US$50,000 government contribution either way. The lower US$270,000 figure is a per-share minimum, and it applies only where two or more buyers jointly take a tourism-accommodation unit worth at least US$540,000. 148 destinations, plus two things no European program offers: visa-free access to China and a US E-2 investor treaty. A December 2022 change to US law requires three continuous years of genuine domicile in Grenada before an investment-acquired citizen can apply for E-1 or E-2.

A fourth belongs here for a reason that has nothing to do with the passport. Dominica is the cheapest way in — US$200,000 to the Economic Diversification Fund, or the same figure in approved real estate — with 144 destinations, no presence requirement, and roughly six to nine months on agent-reported averages. On the passport alone it sits behind the three above. What sets it apart is a tax change: Dominica’s 2026/27 budget commits to ending tax on worldwide income, taxing only income earned on the island, alongside a flat 10% rate on what remains, from 1 January 2027. For a family leaving Europe partly to get out from under a worldwide-income regime, that is the only program on this page whose home jurisdiction is moving toward them. It is a budget commitment rather than enacted law, and it only helps someone who genuinely relocates and breaks residency at home — I set out both conditions in Dominica Is Ending Tax on Foreign Income.

Set those against the table at the top and the trade is clear enough to state in one sentence. What you give up is Europe — none of these is an EU residence, and none of them lets you live in Spain or Portugal beyond the Schengen visitor allowance. If your goal is genuinely to relocate into the EU, then Portugal or Greece is your answer and the Caribbean is a distraction. What you get is a passport, in months rather than a decade, at a lower entry number than Portugal’s €500,000 fund minimum, with meaningfully more visa-free access than Turkey delivers.

Two caveats belong with all of the above. Add government, due-diligence and professional fees to every figure — the headline is never the invoice. And all five programs now sit under a new regional regulator, ECCIRA, and under sustained EU and US pressure, tracked in the objective audit of every Caribbean CBI program. For the three-way detail on cost, speed and family fit, see St Kitts vs Grenada vs Antigua.

And for any American reading this: US citizens remain taxed by the United States on worldwide income regardless of a second citizenship — none of the five Caribbean programs has a US income tax treaty. The Caribbean answer above is a mobility answer, not a tax one.

How I would work through what is left

Having guided over 100 families to citizenship or residency in 2025 alone, here’s the filter I use:

1. If an EU passport by investment is the goal, stop looking — that door is shut everywhere. The ECJ closed the only real route, Malta, in April 2025. No amount of shopping around changes that.
2. If what you want is a passport rather than a European address, look at the Caribbean first. It is the only place still selling a strong travel document in months, at St. Kitts & Nevis, Antigua & Barbuda and Grenada. Minimums start at US$230,000, and the passports reach 157 (St Kitts & Nevis), 154 (Antigua & Barbuda) and 148 (Grenada) destinations. Run them side by side on the comparison page. This is also the work I do, so weigh it accordingly.
3. If EU residence with an eventual path to citizenship matters, compare Portugal and Greece on your own timeline, not a headline. Portugal’s clock is now ten years from card issuance. Greece enters at €250,000 and runs its own naturalisation path.
4. If you want EU-adjacent residence and don’t care about ever holding an EU passport, Malta’s MPRP stays open — permanent, renewable, no minimum stay.
5. If the goal is a tax-efficient base more than mobility, Turkey is worth reading closely — twenty years of exempt foreign income is a real offer. Just go in knowing the passport reaches 112 destinations and none of the EU, UK or US, and that I don’t practise there.
6. Separate the passport question from the tax-residency question. A second citizenship is insurance and mobility. Where you establish tax residency — Turkey, a territorial-tax Caribbean base, or Puerto Rico’s Act 60 for US persons — is a different decision, and conflating the two costs clients real money.

None of this replaces proper cross-border tax advice in your home country before you file anything. The other half is a straight read on which jurisdiction fits, informed by my own advisory practice. If you’re weighing Europe against the Caribbean, apply for a private call and we’ll go through it plainly.

What remains open

• No EU state sells citizenship any more, so if a passport is the goal the answer sits outside Europe. St Kitts & Nevis (US$250,000, ~5 months, 157 destinations), Grenada (US$235,000, ~7 months, 148) and Antigua & Barbuda (US$230,000, ~14 months, 154) are the realistic shortlist for a British or Canadian family.
• Six European investor-visa routes have closed since 2022 — the UK, Ireland, the Netherlands, Hungary’s real-estate option, Portugal’s real-estate route, and Spain outright — and the EU’s top court closed a seventh: Malta’s golden passport.
• The ECJ’s 29 April 2025 ruling (Case C-181/23) killed citizenship-for-investment, not residence-by-investment — golden visas remain lawful EU-wide.
• Portugal’s golden visa is still open via investment funds, but its citizenship clock doubled from five to ten years under the 2026 nationality law.
• Greece runs Europe’s highest-volume golden visa: from €250,000, no minimum stay to renew, family included.
• Turkey pairs a US$400,000 citizenship-by-investment passport with a new 20-year foreign-income tax exemption. The passport reaches only 112 destinations and none of the EU, UK or US, which makes it a tax-residency play rather than a mobility one. I don’t practise there.

Frequently asked questions

Can I still buy EU citizenship in 2026? No. The ECJ ruled on 29 April 2025 that Malta’s citizenship-by-investment scheme breached EU law, and Malta replaced it with a discretionary merit-based framework that excludes investment alone. No EU state currently sells citizenship outright.

Is Portugal’s golden visa still worth it? Yes, for residence — the fund-based route from €500,000 remains open. The citizenship timeline is what changed. Applicants filing after Portugal’s 2026 nationality law face a ten-year path instead of five, though pending pre-reform applications kept the old five-year clock.

What’s the cheapest European golden visa in 2026? Greece, at €250,000 for qualifying commercial-conversion or heritage-restoration properties. Standard property outside the highest-demand areas runs €400,000, with no minimum stay required to renew.

Does Turkish citizenship come with tax benefits? As of 2026, yes. New Turkish tax residents can qualify for a 20-year exemption on foreign-source income under Turkey’s newly enacted Law No. 7582, provided they had no material Turkish tax presence in the prior three years. That includes those who obtain citizenship through the US$400,000 real estate route.

Should I choose a European golden visa or a Caribbean second passport? It depends entirely on which product you’re buying. A European golden visa is residence — it lets you live there, and it does nothing for the passport you already travel on. A Caribbean program is citizenship — a second travel document, in months, at US$230,000–US$250,000. If you want to move to the EU, Portugal or Greece. If you want a passport, St Kitts & Nevis, Grenada or Antigua & Barbuda. Some clients pair a passport with a separate, more tax-efficient residency instead — that’s a third decision again.

Europe won’t sell a passport any more — what’s the fastest alternative for a British or Canadian family? St Kitts & Nevis, on current agent-reported averages of around five months, at US$250,000 through its fund contribution, on a passport reaching 157 destinations visa-free or visa-on-arrival (Henley Passport Index, October 2026). Grenada runs around seven months at US$235,000 and adds visa-free China and a US E-2 treaty. Antigua & Barbuda is cheapest at US$230,000 for a family of up to four, but slower, closer to fourteen months. It also asks for 30 days on-island within the first five years — applied administratively, with the Bill that formalises it presented in July 2026 and not confirmed enacted. Add government, due-diligence and professional fees to all three.

Image credits: Valletta by TerryDOtt (CC BY 4.0); Lisbon by Alejandro (CC BY 2.0); Santorini by Giles Laurent (CC BY-SA 4.0); Istanbul by Alvesgaspar (CC BY-SA 4.0), via Wikimedia Commons. Images were resized and cropped.