NEBA Market Update
Citizenship and Residency by Investment
The investment migration industry has experienced significant regulatory changes over the past year. These developments have had a material impact on both Citizenship by Investment (CBI) and Residency by Investment (RBI) programmes globally.
EU Legislation Affecting Caribbean Citizenship by Investment
The European Union has passed legislation removing visa-free access to the EU for several Caribbean citizenship-by-investment passports. As a result, holders of these passports will no longer benefit from visa-free travel to the 27 EU member states.
Visa-free access to the EU has historically been one of the key advantages of Caribbean CBI programmes. The removal of this benefit has therefore reduced the overall attractiveness of these passports for many prospective applicants.
Impact on Market Demand
Market sentiment has shifted following this regulatory change. Many potential clients believe that programme prices may decline in response to the reduced benefits.
As a result, a significant number of prospective applicants are currently delaying decisions while they wait to see whether price adjustments or programme changes occur. The current market environment is therefore characterised by a “wait-and-see” approach from many buyers, which has slowed new applications.
Wider Impact on the Investment Migration Industry
These developments have occurred alongside other important changes affecting the residency-by-investment sector.
Two major industry shifts have taken place almost simultaneously:
Regulatory and structural changes affecting Portuguese residency programmes
The EU decision impacting Caribbean citizenship programmes
These developments have affected two of the most widely used solutions in the investment migration market:
Residency by Investment programmes, particularly Portugal
Caribbean Citizenship by Investment programmes, including the five primary Caribbean options
In addition, Malta’s citizenship-by-investment programme has also been closed by the EU.
As a result, activity across the investment migration industry has slowed considerably as both advisers and clients assess the evolving regulatory environment.
Industry Outlook
The past year has therefore proven challenging for both the CBI and RBI sectors. Some of the most popular programmes have either changed significantly or closed entirely. Spain has closed its residency programme, Portugal’s programme has become significantly more difficult to market, and the Caribbean programmes have lost a key travel benefit.
Despite these changes, global demand for second residency and citizenship solutions remains strong, particularly given ongoing geopolitical uncertainty. However, strong interest from prospective clients does not automatically translate into completed applications while regulatory conditions remain uncertain.
Looking Ahead
2026 is likely to be a period of adjustment and observation for the industry. Governments are expected to reassess existing programmes and potentially introduce new structures or alternatives.
NEBA will continue to monitor developments closely and assess which new programmes provide credible, compliant, and sustainable solutions suitable for our clients.
We will provide a further update during the summer once the market direction becomes clearer.
As always, our team remains available to provide guidance and support. Please do not hesitate to contact us should you require further information.