Citizenship by investment undergoing transformation: will centralized control come to the Caribbean CBI?

Today we are going to explain the changes in 2026 to citizenship by investment programs in the Caribbean. These changes will involve the creation of a new regional authority, more control, and less flexibility in CBI passports.

The Caribbean is currently working on greater centralization of its popular citizenship by investment programs. The plan is to establish a common authority that will set standards, monitor compliance, and, in part, harmonize participating CBI (citizenship by investment) programs. Mandatory residency requirements, annual quotas, and uniform standards are planned, all under the pretext of preventing abuse. However, in reality, this means stricter control and the elimination of the flexibility that has made these programs attractive to people who value freedom. We have never really recommended these programs, and with the current developments, they are becoming even less attractive.

On the other hand, Vanuatu remains as attractive as ever, with most of the process being done remotely and only requiring a visit to one of the consulates in Dubai, Noumea, or Hong Kong. In addition, Vanuatu is improving greatly in many respects and, despite its historical volume, remains the second fastest and easiest nationality to obtain.

The supply of citizenship-by-investment programs is growing

The demand for citizenship-by-investment programs has never been greater, not only among investors but also among governments that actively offer these solutions. This is because with every CBI application that is approved, a significant sum goes directly to the state coffers or to specific development projects in the country. It is understandable that this model is well received in many countries.

In any case, this interaction between supply and demand has led to an all-time high in the availability of programs, as we have shown in our historical comparison. However, not all programs were attractive from the outset; many had their shortcomings and problems. Some models had to be revised or repositioned to meet investor expectations. As a result, there is now a much more differentiated and competitive offering.

But even some of the offers that seemed attractive at first glance and were recommended time and again ultimately did not stand up to closer scrutiny: endless processing times, lack of reputation, loss of access to Schengen, poor acceptance by banks, etc., are just some of the issues we observe in our daily work with CBI programs.

This was and remains particularly clear in the example of Caribbean passports: these programs, which were once the flagship of the CBI market, now want to establish a central supervisory authority with new potential rules and a new draft agreement between the “Caribbean Five.” This affects Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and St. Lucia.

New agreement on Caribbean citizenship-by-investment programs in draft form with 92 articles

The new 92-article agreement, still in draft form, for the creation of the Eastern Caribbean Citizenship by Investment Regulatory Authority (EC CIRA) represents the most ambitious attempt to date to coordinate regional oversight of CBI, following years of international pressure from the US Treasury Department and the European Union.

It represents a profound change for the CBI programs of the Eastern Caribbean countries. The legislative initiative aims to provide existing programs, some of which are very different from each other, with a uniform, much stricter, and more transparent basis. As already mentioned, this is mainly a concession to pressure from the EU and the US, who find the programs troublesome. However, this will change little. For the US, there has always been a visa requirement, and for the EU this will soon also be the case due to ETIAS pre-authorization. Only citizens born in the country will be able to travel easily to Schengen; CBI citizens will be second-class citizens and will need a corresponding visa. These changes are very likely to take place in 2025.

Obligation to be present in the new country of residence

One of the most significant changes is the mandatory length of stay: those who obtain a passport under a CBI program will be required to spend at least 30 days physically in the country in question during the first five years after obtaining citizenship, regardless of whether the days are consecutive or not. This will make the practice of many new citizens never having to set foot in the country a thing of the past. In addition, integration measures will be introduced, including mandatory interviews and training courses on the legal system, history, and social values of the country in question. Those who fail to comply with these obligations risk heavy penalties (up to 10% of the investment amount) and, in extreme cases, the withdrawal of citizenship.

A significant part of the appeal of a CBI program lies precisely in not being obliged to live in a foreign country or submit to its rules. For many people, it is a backup, an option for emergencies, and not a way to submit to new state obligations, regardless of their duration and scope. Anyone who introduces presence requirements somehow devalues the concept of truly sovereign second citizenship. This further devalues Caribbean passports, which are already not very desirable for us. The constant monitoring of the wishes of “more powerful” blocs is not particularly appealing. We prefer a small state like Vanuatu, which openly shows its rejection of the EU, even if this means losing the freedom to travel without a visa in the Schengen area.

Maximum limits for nationalities granted

In addition, maximum limits will be introduced for the number of nationalities granted annually: in the future, the new authority will recommend a maximum value for each country, which will be based on international standards, demand, economic benefits, and risk potential. The aim is to explicitly move away from a purely quantitative model in order to avoid “oversupply.”

In reality, the upper limits are nothing more than a planned economy for nationalities. Instead of letting the market decide how much demand there is, the aim is to create artificial scarcity in order to maintain supposed political control. In this way, freedom becomes a commodity whose availability is determined by political bodies. This is a development that must simply be viewed with a critical eye.

Creation of a new transnational regulatory authority

A central element of the new plans is the creation of a transnational regulatory authority, the EC CIRA. From now on, this body will supervise all programs in the participating states. It wants to impose uniform standards, regularly checks applications, can impose sanctions, and wants to ensure the harmonization of due diligence procedures. A new escrow account management system ensures that no investment amounts are paid out before all checks have been completed and all legal conditions have been met.

At the same time, a regional database with applicant data will be created, which will show rejected or suspicious applicants for all countries in particular. It will also allow for the reuse of data, for example through biometrics.

The expanded due diligence requirements are also particularly sensitive: the agreement provides for extremely thorough background checks, including comparisons with national and international watch lists, databases on politically exposed persons, and sanctions lists. In addition, criminal records from all countries where the applicant has lived or held citizenship in the last ten years will be evaluated. This effectively establishes a global investigation that meticulously examines every stage of private life and potentially subjects all applicants to general suspicion.

Centralization of CBI programs in the Caribbean

This measure represents a massive expansion of state surveillance and a centralization of sensitive information that, in the long term, not only subjects all applicants to generalized suspicion, but also collects your data for no reason. For the applicant, this also often means higher costs and longer procedures. It means that your life is turned upside down, that every stay, every relationship, every previous address is examined.

However, a centralized authority is always an instrument for securing power. As we know from experience, the further decisions are removed from local parliaments or courts, the less control nations and citizens have over the rules that affect them. Anyone who has ever created a centralized regulatory authority will soon see new restrictions, fees, and bans emerge without any real (democratic) control.

This has consequences, especially for supply: every time individual programs are unified, even if only in some marginal aspects, diversity and real choice are lost. This significantly weakens the opportunity to diversify in a targeted manner and choose the most suitable option for each individual. Those who acquire a second citizenship often do so for very individual reasons, whether to have more freedom to travel, for tax reasons, or as a plan B. The more programs are centralized, the more difficult it becomes to find tailor-made solutions. In the end, there is always the risk—although, of course, we are still a long way from that—that a single model will be imposed, one that is more suited to political commitments than to the real needs and expectations of applicants.

Other new developments include:

• In the future, all requested and licensed CBI agents, brokers, promoters, and developers will be required to submit a prequalification certificate from the EC CIRA.
• Uniform grounds for revocation and stricter conditions for passport return will be defined.
• Citizens of other CBI countries whose application has been rejected in one country will not be able to submit a new application in any other participating country, except with the express consent of the authority.

More external control instead of national freedom of decision

The last point, in particular, is very worrying for future Caribbean CBIs. The rule is that countries cannot accept, review, or approve applications if the applicant has already been rejected in another participating country. The only exception is if the new central authority expressly gives the green light. This creates a de facto regional veto right that greatly limits individual considerations at the local level. In addition, a centralized CARICOM database will store the biometric data and application history of all applicants, paving the way for unprecedented surveillance and permanently linking and making accessible sensitive personal information.

All these reforms show that Caribbean states are unanimously bowing to growing international pressure and tightening their programs in a way that, at least in the long term, will deter investors. Under the pretext of combating money laundering, identity verification, and quality standards, what is being undermined here is, above all, the attractiveness as a liberal alternative option. The aim is apparently to make the programs more restrictive, bureaucratic, and controllable at all times by people outside the system. Although the announced measures only affect new applications for now and have not yet been ratified, they mark a dangerous shift toward greater state control and centralized management. Current passport holders from these countries should also think about where this may lead.

Vanuatu CBI remains the best option by far

In contrast, it is encouraging to look to the South Pacific. The Vanuatu citizenship program, which we often recommend for a variety of reasons, is becoming increasingly attractive without the country having to actively contribute to it. And with the aforementioned postponement of mandatory biometrics, the process can still be completed entirely remotely. And even when this changes, the task of making a brief visit to the embassy to have your fingerprints taken is not comparable to the strict requirements of Caribbean CBI programs.

Vanuatu’s CBI remains one of the fastest and easiest options in the world for obtaining a second passport. The entire process can be completed in a few weeks. Here you can read about our own example, it only took us four weeks from submitting the application to obtaining the passport, as, as always, we do not recommend anything that we have not tried ourselves. This tremendous speed is one of the biggest advantages of the program. Caribbean passports can easily take between 12 and 18 months, even under the old regulations prior to the 2024 reforms.

In addition to speed, Vanuatu also stands out for its relatively moderate investment requirements. With a donation to the state development fund, citizenship can be acquired for a fraction of the cost required in other jurisdictions. For a family of up to four people, the amount is around US$170,000, which is absolutely competitive in the world of legal and recognized naturalization programs, of which US$50,000 is a refundable investment after four years.

In addition, the Vanuatu passport offers a solid visa waiver. It allows visa-free or visa-on-arrival travel to over 100 countries, including the United Kingdom, Ireland, Russia, Hong Kong, and Singapore. It is the ideal CBI passport if you are also looking for a Plan B.

Finally, the process is very discreet and easy to plan, especially when compared to the Caribbean. There is no need to travel to Vanuatu in person to apply for or obtain citizenship. The entire process can be done conveniently from abroad, making it very attractive to many. From October 2025, you will only need to provide your fingerprints, as Vanuatu passports will be biometric, further increasing their value in the future. For the time being, this will only be possible in person in Dubai, Hong Kong, and Nouméa (New Caledonia) and will require travel to the location. There will be no interview or anything of the sort, only fingerprinting. But, as already mentioned, this will only be the case from October 2025.

In summary, Vanuatu offers an extremely fast, legally secure, and relatively affordable citizenship-by-investment program, providing a flexible and simple solution for anyone wishing to expand their freedom of movement and independence.

Get advice now on the topic of second passports and citizenship by investment!

If you are considering obtaining a second citizenship as a strategic safeguard, to complement your freedom of travel, or to diversify internationally, you should leave nothing to chance. Selecting the right program requires experience, market insight, and a sense of the individual advantages and disadvantages. Because, as you may have noticed, not all offers deliver what they promise.

We accompany you every step of the way: from the objective analysis of your goals, through the selection of the optimal program for you, to the complete submission of the application and its successful processing. In this way, you will benefit from independent and practical advice, as well as our experience with a wide range of international CBI options. Less official options and even the acquisition of diplomatic passports are also possible. By hiring our services, you can be sure that your investment is not only formally correct, but also transparent, secure, and the option best suited to your personal needs and overall goals, strategically speaking.

Book a consultation session and plan your path to greater international freedom and flexibility with us. If you have any questions about citizenship by investment options and our services, you can ask Christoph for free.