EU Pushes Caribbean Nations to Phase Out Citizenship by Investment Programs by 2028

The European Commission has sent official letters to the governments of Caribbean countries requesting that they gradually phase out their Citizenship by Investment (CBI) programs by 1 June 2028.

The letters were sent to Antigua and Barbuda, St Kitts and Nevis, Dominica, Grenada, and Saint Lucia. If these countries refuse to close their programs, the European Union may suspend their visa-free access to the Schengen Area.

The reason is the revised EU visa suspension mechanism, which entered into force on 31 December 2025. While previous discussions focused primarily on the quality of Due Diligence procedures and the security of CBI programs, the very existence of a Citizenship by Investment program is now considered an independent ground for reviewing visa-free access to the European Union.

What Investors Need to Know

At this stage, there are no plans for the immediate closure of Caribbean Citizenship by Investment programs. The European Commission has proposed a 24-month transition period. However, by September 2026, participating countries must further strengthen applicant screening procedures, exclude individuals subject to EU sanctions from their programs, and implement a number of additional compliance measures.

Nevertheless, the central issue remains unchanged: the European Union ultimately expects these programs to be phased out rather than simply subjected to stricter requirements.

The first public response came from Antigua and Barbuda’s Prime Minister, Gaston Browne. According to him, the country’s Citizenship by Investment program remains one of its principal sources of non-tax revenue, and the government is not prepared to agree to its closure without discussions regarding possible compensation.

This is hardly surprising. In some years, CBI revenues accounted for as much as 36.6% of GDP in Dominica and approximately 22% of GDP in St Kitts and Nevis, making these programs a critical source of funding for small island economies.

What Happens to Existing Caribbean Passport Holders?

If the programs are ultimately discontinued, this is not expected to affect individuals who have already obtained citizenship. Instead, only the acceptance of new applications would cease.

However, given the economic importance of these programs, many observers believe the more likely outcome is not their closure but the suspension of visa-free access to the Schengen Area. Such a decision would affect all current holders of the relevant Caribbean passports, including both investors and citizens of these countries.

The European Union’s approach has evolved gradually over several years. It began with stricter Due Diligence requirements, followed by mandatory biometric data collection and in-person attendance, higher minimum investment thresholds across the Caribbean (from $100,000 to at least $200,000), and has now progressed to a direct request for participating countries to terminate their programs.

In practice, Caribbean countries have already implemented most of the European Union’s previous recommendations, yet these measures have proved insufficient.

How to Secure Long-Term Access to the Schengen Area

One of the most reliable long-term solutions is to obtain an additional residence status in Europe, such as the Greece Golden Visa. Greece is a member of the Schengen Area, and the program grants a renewable five-year residence permit provided the qualifying investment is maintained. There is no requirement to reside permanently in the country.

The most popular investment option is the purchase of real estate, with minimum investment thresholds starting from €250,000, depending on the type and location of the property. Applicants may include their spouse, children, and parents, subject to the program’s eligibility requirements.

If you would like to explore the opportunities offered by the Greece Golden Visa program, leave a request on our website. Astons provides end-to-end support throughout the entire process, from property selection and legal due diligence to transaction completion and residence permit approval. We work with one of the largest portfolios of investment properties on the Athens Riviera and have our own team of experts, licensed lawyers, and an office in Glyfada.