The European RCBI landscape has been transformed by unprecedented regulatory intervention. In April 2025, the Court of Justice of the EU (CJEU) delivered a landmark judgement outlawing “golden passport” citizenship-by-investment schemes. In a case brought by the European Commission against Malta’s Individual Investor Programme, the EU’s top court held that granting nationality in exchange for payments or investments violates EU law. The court found that such schemes lack the “bond of solidarity and good faith” between a state and its citizens and “amount to the commercialisation” of EU citizenship rights.
This ruling compels Malta – the last EU country offering direct citizenship by investment – to shut down its passport-for-sale program, and effectively bars any EU member state from trading citizenship for cash going forward. EU officials hailed the decision, emphasising that “European citizenship is not for sale.” Malta, which had argued nationality was solely its sovereign domain, conceded it would respect the judgement and align its laws. With this court victory, the European Commission has achieved via judiciary what it had long pushed for in policy: an EU-wide ban on golden passports, ending a controversial era in which thousands of investors obtained EU citizenship through payments of €1 million+ with only minimal ties to the issuing country.
Golden residence (golden visa) programs – which offer residency rights (and a path to citizenship) against investment – are also facing headwinds across Europe, though not an outright ban. The European Commission and Parliament have warned that investor residence schemes pose security risks and should include strict conditions if not phased out. Notably, current EU law does not prohibit golden visas per se, leaving regulation to member states.
However, political sentiment has turned against these programs in several countries. Ireland abruptly closed its Immigrant Investor Programme in 2023, citing “public policy” concerns. Portugal followed suit, deciding to end new applications under its popular Golden Visa programme as part of a housing affordability package. Greece has doubled the minimum investment to €500,000 in prime areas and plans further hikes, while Spain faces domestic debate on curbing its programme. Cyprus and Bulgaria had already terminated their citizenship-by-investment schemes.
The EU has also introduced a new mechanism to enforce higher standards indirectly. In June 2025, reforms to the Schengen Visa Suspension Mechanism added “the operation of an investor citizenship scheme” as grounds to revoke visa-free access for third countries. The EU had already suspended Vanuatu’s visa waiver in 2022 over poor due diligence; the new law formalises this approach and directly targets investor citizenship.
AML and sanctions compliance are reshaping European golden visas. Since 2022, no EU scheme accepts Russian or Belarusian applicants. Banks are required to apply enhanced due diligence to all RCBI clients. A new EU AML Authority, due in 2024, will likely set further standards affecting agents and sponsors.
In short, Europe is moving towards a transparent, security-first model. Legitimate investors are still welcomed – particularly through Malta’s Permanent Residence Programme and Greece’s Golden Visa – but the era of commoditised EU citizenship is definitively over.