The European Court of Justice (ECJ) has delivered a pivotal ruling against Malta’s controversial citizenship-by-investment program. The decision is poised to reshape the landscape of Golden Visa and citizenship-by-investment (CBI) programs across Europe — and beyond.
As relocation and global mobility trends continue to rise, this ruling sends a strong signal to investors and policymakers alike. Here's what you need to know.
What is a Golden Visa?
A Golden Visa is an immigration program that offers residency — and sometimes a pathway to citizenship — in exchange for substantial investment into a country’s economy. Typical qualifying investments include real estate purchases, business development, job creation, or government bonds.
Originally designed to attract foreign capital during economic downturns, Golden Visas have grown immensely popular among high-net-worth individuals seeking greater global mobility, access to education, healthcare, and long-term security.
Learn more about finding an immigration advisor to explore your Golden Visa options.
A Brief History of Golden Visas in Europe
Golden Visa programs first emerged in Europe during the early 2010s, particularly after the financial crises that crippled Southern European economies.
- Portugal launched its now-famous Golden Visa program in 2012, offering residency in exchange for investments as low as €280,000 in real estate.
- Greece and Spain soon followed with their own attractive schemes, helping to boost their real estate markets and foreign investment portfolios.
- Over time, the appeal expanded beyond residency to citizenship, with countries like Malta and Cyprus offering direct citizenship to investors — sometimes within months.
However, fast-track citizenship programs attracted mounting scrutiny from the European Union (EU), concerned about potential money laundering, tax evasion, and the commodification of European nationality.
The Malta Ruling: What Happened?
On April 25, 2025, the European Court ruled that Malta’s direct sale of citizenship to investors, without a genuine link to the country, violated EU principles.
The court found that citizenship-by-investment programs (CBIs) that offer nationality without "effective connection" — such as long-term residence, integration, or cultural ties — undermine the essence of EU citizenship rights.
This ruling marks a critical legal precedent: while countries retain the sovereign right to grant nationality, they must respect overarching EU values and obligations.
Impact on Other Countries: Portugal, Greece, Spain, and Beyond
The implications are immediate and far-reaching:
- Portugal recently tightened its Golden Visa program, eliminating the real estate investment option in popular urban areas and shifting focus toward job creation and cultural investments. The Malta ruling could further pressure Portugal to demonstrate that Golden Visa recipients have genuine integration into Portuguese society. You can find more information about relocating to Portugal on Relocate.world.
- Greece has seen a surge in demand for its Golden Visa, especially from American investors, but rising scrutiny could accelerate program reforms, possibly including stricter residency requirements or limitations on passive investment routes like real estate. If you're considering Greece, check out our updated Complete Guide to the Greece Golden Visa.
- Spain and other countries offering similar programs may preemptively revise their structures to emphasize deeper ties, such as minimum physical presence requirements, language proficiency, or integration courses. Caribbean CBI programs, which often grant passports without any residence obligations, may also face indirect consequences as the EU seeks to tighten border security and harmonize citizenship standards.
In short, the era of purely transactional citizenship appears to be coming to an end in Europe.
What Investors Should Expect
- Stricter Residency Requirements: Future programs may require investors to spend significant time in the country to qualify for citizenship or even permanent residency.
- Longer Timelines: Instant citizenship could become a thing of the past; expect longer periods (five years or more) before naturalization is possible.
- Increased Due Diligence: Governments are likely to implement even more robust vetting procedures to ensure investors meet ethical and financial standards.
- Shift Toward Impact Investment: Some countries may prioritize investment categories that have demonstrable social or economic impact — such as startup funding, rural revitalization, or innovation hubs.
If you are planning your move and seeking professional support, browse our network of trusted relocation advisors to build your custom roadmap.
Frequently Asked Questions (FAQ)
❓ Is Malta’s citizenship-by-investment program still active in 2025?
As of April 2025, Malta’s direct citizenship-by-investment program has been ruled in violation of EU law by the European Court of Justice. While the government may attempt to revise or restructure the program, the current model is unlikely to continue in its existing form.
❓ What’s the difference between a Golden Visa and citizenship-by-investment?
A Golden Visa typically grants residency rights in exchange for investment, while citizenship-by-investment provides a passport and full nationality, often with fewer residency requirements. The EU has been more critical of programs that offer direct citizenship without genuine ties to the country.
❓ How does the Malta ruling affect Portugal’s Golden Visa?
Portugal has already begun phasing out certain parts of its Golden Visa program, especially real estate investments in urban centers. The Malta ruling could pressure Portugal to further tighten regulations and emphasize deeper integration requirements for applicants.
Explore more about moving to Portugal »
❓ Is the Greece Golden Visa still a good option in 2025?
Yes, Greece remains one of the most accessible Golden Visa programs in Europe. However, the Malta decision may influence future reforms, such as the introduction of residency or cultural integration requirements.
Read our Complete Guide to the Greece Golden Visa »
❓ What should investors do if they’re considering a Golden Visa?
It’s critical to consult with an experienced immigration advisor to understand which programs are compliant, sustainable, and best aligned with your goals. Find a trusted advisor on Relocate.world.
Conclusion: A New Chapter for Global Mobility
The European Court's ruling against Malta represents a watershed moment for citizenship and residency-by-investment programs. While Golden Visas remain a viable option for global citizens, the model is evolving to align more closely with societal integration and EU values.
At Relocate.world, we continue to monitor these developments to provide accurate, up-to-date insights for those seeking new opportunities abroad. Whether you're considering Portugal, Greece, Spain, or beyond, our global community of experts is ready to guide you through your relocation journey.