The global market for investment visas and citizenships is experiencing a structural shift. Programs, which ten years ago were considered a quick and relatively simple tool for legalization of capital, tax planning and international mobility, today increasingly come under the pressure of regulators, financial monitoring bodies, the EU, the OECD and the FATF.
The main trend is obvious: states do not completely abandon the attraction of wealthy foreigners, but they sharply increase the requirements. Passive buying of real estate gives way to investments in funds, business, technology, jobs and strategic industries. At the same time, checks on the origin of funds, tax status, sanction risks and real economic benefits of the investor are being strengthened.
Golden Visa usually means a residence permit for investments. Separately, there are programs for citizenship by investment, the so-called Golden Passport. It is the "golden passports" that are under the most pressure, as they grant not just the right of residence, but full citizenship, including access to visa-free travel, the financial system and, in the case of EU countries, to the rights of a European Union citizen.
The toughest market is changing in Europe. For several years, the European Commission has considered investment citizenship and investment residence as a source of risks for security, the fight against money laundering, tax transparency and trust between EU countries.
In April 2025, the EU Court recognized the Maltese scheme of citizenship by investment as contrary to EU law. This became one of the most important decisions for the entire market: the sale of citizenship was actually called incompatible with the logic of European citizenship and the principle of loyal cooperation between member states.
Earlier, Cyprus and Bulgaria had already abandoned similar programs. As a result, the possibility of obtaining citizenship through direct investment has almost disappeared in the EU. Residency programs mostly remain, but they are also getting tougher.
Spain closed its Golden Visa from April 3, 2025, which for a long time allowed foreigners to obtain a residence permit by purchasing real estate worth EUR500,000 or more. One of the key reasons was political and social criticism: the authorities linked the program to the overheating of the housing market in Madrid, Barcelona, Malaga and other popular regions.
Portugal already in 2023 removed real estate from the list of eligible investments for Golden Visa. It was one of the most symbolic steps, since the Portuguese program was considered one of the most popular in Europe. It is now refocused on foundations, scientific research, cultural heritage and the creation of companies or jobs.
Greece has not closed the Golden Visa, but has sharply raised entry thresholds. In the most sought-after regions, including Attica, Thessaloniki, Mykonos, Santorini and Crete, the minimum investment in real estate has increased to EUR800,000. In other regions, the threshold is EUR400,000, and the previous level of EUR250,000 has been retained only for certain categories of projects, such as reconstruction or conversion of objects.
The result is already notable: according to Greek media citing the Ministry of Migration and Asylum, in January 2026 the number of Golden Visa applications fell by 63.5% year-on-year. This shows that some investors are not ready to enter the program under new conditions, especially if they considered the Greek residence permit as a relatively inexpensive tool to access the Schengen area.
Ireland closed the Immigrant Investor Program in February 2023. The UK's Tier 1 Investor program was closed back in February 2022 amid concerns about the security and origin of capital. Thus, Anglo-Saxon jurisdictions have also increased the tendency to test capital and to abandon schemes perceived as too vulnerable to abuse.
There are several reasons why 'golden visas' have come under pressure.
The first reason is security. After the invasion of the Russian Federation into Ukraine, Western countries began to pay more attention to who exactly receives residency status or citizenship for money. Investment programs began to be seen not only as an economic tool, but also as a potential loophole for persons with sanctions, political or corruption risks.
The second reason is the fight against money laundering and tax evasion. The OECD and FATF clearly state that citizenship and residency by investment schemes can be used to hide assets, bypass tax reporting and gain access to the financial system of other countries.
The third reason is the housing crisis. In many European cities, the Golden Visa has become a symbol of the conflict between the attraction of foreign capital and the interests of local residents. Rising housing prices, higher rents, empty properties and the displacement of local residents from inner-city areas have become a politically toxic topic. This is especially noticeable in Lisbon, Barcelona, Athens and other tourist and financial centers.
The economic benefit of the program is increasingly compared with the social costs. If an investor simply buys an apartment, but does not create jobs, develop a business or pay significant taxes, it becomes increasingly difficult for governments to explain to society why they should be given a privileged status.
The fourth reason is the weak real connection between the investor and the country. Many programs allowed status to be obtained without actual residency, language skills, integration, or participation in economic life. As a result, real estate became only a formal ticket to residence, and capital remained passive. Therefore, the new rules increasingly require not just to invest money, but to confirm real participation in the economy, create jobs or invest in productive sectors.
The US remains one of the largest markets for investment immigration through the EB-5 program. Formally, this is not a "golden visa" in the European sense, but a path to a green card through investment and job creation.
After the EB-5 Reform and Integrity Act, the American model became noticeably tougher. For investments submitted after March 15, 2022, the minimum threshold is $1.05 million or $800,000 for projects in targeted employment zones or infrastructure projects. At the same time, the investor must confirm the legality of the origin of the funds, the participation of capital in the commercial project and the creation of jobs.
The American approach demonstrates the other side of the global trend. The US is not abandoning investment immigration, but it is transferring it to a regime of stricter inspection. The main emphasis is not on the purchase of real estate and not on passive status, but on jobs, control of regional centers, transparency of sources of funds and responsibility of project participants.
For an investor, this means that EB-5 becomes not just a migration product, but a full-fledged investment agreement with legal, financial and project risks. Errors in the structure of the project, documents or the origin of funds can cost not only money, but also the migration result.
The Chinese model is fundamentally different from the European or Caribbean model. China does not have a mass and simple "golden visa" program for real estate buyers. Permanent residency for foreign investors is possible, but the requirements remain high and selective.
Official rules for foreign investors include direct and stable investment in China, good tax history, no criminal record and compliance with Chinese law. Depending on the region and the type of project, the thresholds can be from $500,000 to $2 million of actually contributed registered capital, which must be maintained for several years.
This shows that China is ready to accept foreign capital, but is not building the investment migration market as a mass product. For Beijing, control, utility of investments, fiscal discipline and compliance with national economic priorities are important.
Hong Kong looks different. In 2024, he relaunched the New Capital Investment Entrant Scheme, i.e. a new entry program for investors. The minimum amount of investment is HK$30 million. This is not about the classic purchase of housing, but about the permissible financial assets, investment portfolio and instruments that should support the financial market and the development of Hong Kong. Thus, Hong Kong is not going by closing, but by reformatting: it wants to attract wealthy investors, but direct their money to financial instruments, innovations, sustainable technologies, biotechnology and other strategic directions. This is no longer a "visa for an apartment", but an investment channel under the control of the state.
A separate segment is Caribbean citizenship by investment programs. For a long time, they were the most popular and the most understandable for investors: a relatively low entry threshold, fast terms, visa-free benefits, no requirement for permanent residence.
But even here, the tightening of rules began. In 2024, a number of Caribbean states agreed to raise minimum investment thresholds and converge due diligence standards. The minimum entry level has actually been raised to $200,000 for a number of programs. At the same time, pressure is increasing from the EU, Great Britain and the United States, which assess the extent to which such passports can be used to circumvent visa, tax and financial restrictions.
For small island economies, these programs remain an important source of budget revenues. Therefore, they are unlikely to disappear completely. But their model is changing: fewer discounts, fewer "fast passports", more checks on the origin of funds, the reputation of the applicant and the transparency of intermediaries.
Latin America looks heterogeneous. If Europe is mostly closing or limiting programs, some Latin American countries, on the contrary, are trying to attract capital through investment residency, tax incentives and simplified routes for wealthy foreigners.
Panama remains one of the most visible examples. Its Qualified Investor Program allows you to obtain permanent residence through investments in real estate from $300,000, securities from $500,000 or a bank deposit from $750,000. For the region, this is one of the most competitive products, as Panama combines its geographic location, dollar economy, logistics, banking sector and territorial tax regime.
Costa Rica also maintains an attractive investment residence format. The minimum threshold is about $150,000, and investments can be related to real estate, business or other eligible assets. Unlike Europe, where the purchase of real estate is increasingly becoming a politically toxic topic, in Costa Rica this format still remains part of the migration policy, although the requirements for the structure of ownership and proof of investment are becoming stricter.
Brazil offers investor visas through investments in business, innovative projects or real estate. In business practice, there is often a minimum threshold of about 500,000 Brazilian reals for investments in the company, and more flexible conditions are possible for innovative and technological projects. This shows that Brazil is betting not so much on the "golden visa" as a product for passive capital, but on an investor that can create business, jobs or technological activity.
Argentina should be watched separately. In 2025, the country created a legal basis for citizenship by investment, but the practical model of the program still needs to be clarified: the final investment thresholds, the criteria for "significant investment" and the operational procedure have not been defined. If implemented, the program could be the first major example of a "golden passport" in South America. But for now it is more correct to talk not about a working product, but about the emerging legal framework.
It is important to understand: strengthening the rules does not mean the disappearance of demand. On the contrary, interest in investment migration persists and even grows in some segments. Wealthy people around the world want a backup residential option, access to stable jurisdictions, secure banking infrastructure, quality education for their children and freedom of movement.
But the customer profile is changing. If previously the Golden Visa was often seen as "buying mobility", now more and more people are forming a so-called sovereign portfolio - a set of residency, tax, education and investment options in different countries. It is no longer a single passport or a single visa, but a strategy for sharing personal, family and financial risks.
Among clients there are more entrepreneurs from politically unstable countries, technology business owners, representatives of capital from emerging markets, as well as wealthy Americans and Europeans looking for tax, political or personal diversification.
The main market shift is the move away from real estate as a universal input. a ticket For states, the purchase of an apartment by a foreigner no longer seems to be a sufficient argument for granting long-term status. All too often, this leads to rising prices, empty properties, and a weak connection between the investor and the economy.
Instead, countries will promote other formats: venture and private investment funds, scientific research, innovation, infrastructure, cultural heritage, company creation, jobs, green energy, regional development and technology projects.
This changes the very nature of the Golden Visa. It becomes not a mass product for real estate buyers, but a more complex tool of economic policy. The investor should not just be rich, but useful for the host country.
For Ukrainians and other citizens of Eastern Europe, the Golden Visa market is becoming more complicated. Previously, the key issue was the entrance fee. Now the source of funds, tax transparency, sanctions compliance, banking history, business origin and absence of reputational risks are no less important.
For Ukrainian investors, war is an additional factor. On the one hand, the demand for reserve residence, education of children abroad, medical infrastructure and international mobility remains high. On the other hand, any large transfers of capital go through stricter checks by banks and migration authorities.
According to Maksym Urakin, the founder of the Experts Club information and analytical center, the investment migration market is entering a new phase, where the decisive factor is not the amount of the contribution, but the quality of the capital.
"States no longer want to sell residence or citizenship as a simple financial product. After the war in Ukraine, sanctions cases, increased financial monitoring and the housing crisis in big cities, it became clear that migration status can be a tool of geopolitical vulnerability, sanctions arbitration and tax evasion. For an investor, this means that the strategy of "buy an object and get status" is gradually becoming a thing of the past. Capital transparency, reputation, tax history and real economic contribution come to the fore," Urakin believes.
He notes that the strengthening of rules will not destroy the market, but will make it less massive and more expensive.
"We are not seeing the end of the Golden Visa, but the end of cheap and weakly verified schemes. The future market will consist of two parts: highly regulated programs in developed countries and more flexible but also more expensive programs in small jurisdictions. For Ukraine and Eastern Europe, this is an important signal: wealthy citizens will increasingly seek not just a second place of residence, but a stable legal, financial and family architecture in case of crises," the expert emphasized.
Five main trends can be expected in the coming years.
The first is the further closure or limitation of citizenship by investment programs, especially if they provide access to large visa spaces without sufficient control.
The second is the preservation, but the complication of residence programs for investments. They will remain, but they will be more expensive, more selective and stricter in terms of compliance.
The third is the reduction of the role of real estate. Buying a home will be less and less enough to gain status, especially in countries with a housing crisis.
Fourth is the growing importance of investment funds, innovation, jobs and strategic industries. States will direct investors' money where they see long-term benefits.
The fifth is to strengthen global data exchange. Banks, tax authorities and migration services will increasingly link the issues of residence, tax status, origin of funds and sanctions risks.
The main conclusion: the era of "golden visas" as a simple and relatively affordable product is coming to an end. In its place comes the market of regulated investment migration, where a passport or residence permit becomes not a commodity, but the result of a complex verification of capital, reputation and real contribution to the economy of the host country.
After comparing Europe, the USA, China, Hong Kong, the Caribbean and Latin America, the picture becomes more complicated. The world is indeed tightening the rules on investment migration, but it is doing so unevenly.
Europe is moving to close the most controversial schemes, especially those related to citizenship and real estate. The US keeps EB-5, but tightens background checks on funds, projects and jobs. China admits investors selectively and under strict control. Hong Kong, by contrast, is restarting investment entry but channeling capital into financial and strategic assets. Latin America still remains more open, but the importance of capital transparency, confirmation of investments and real economic benefit is gradually increasing there as well.
That is why the new market formula looks like this: not "paid - received status", but "proved the origin of the funds, invested in a useful asset, passed compliance and confirmed the economic effect".
