The European Union has given five Caribbean nations notice that they need to end their citizenship-by-investment programs or risk losing visa-free access to Europe’s Schengen area by 2028.
The ability to enter the 29 countries in the Schengen area can be a substantial selling point for these “golden passport” programs. Currently, foreigners can obtain citizenship in one of the countries by making a qualified investment in its economy, such as buying real estate or contributing to a government fund. With costs starting around $200,000, these programs provide vital revenue to the Caribbean nations.
The EU in late June sent letters to the governments of Antigua and Barbuda, Dominica, Grenada, St. Lucia, and St. Kitts and Nevis. The countries are planning a coordinated response, including a mission to Brussels, according to a statement.
The Caribbean Response
“Our citizenship-by-investment programs are critical pillars of our non-tax revenue base. They cannot simply be abandoned without viable, credible and sustainable replacement sources of revenue,” said Antigua and Barbuda Prime Minister Gaston Browne.
Passports from these nations allow visa-free travel to some 140 countries and territories.
The EU’s Shift
The EU has cracked down on CBI programs in other nations before, including Malta. However, this request is unusual because it doesn’t cite specific security concerns or propose remedies to address them, according to Ron Klasko, immigration attorney and co-founder of Exodus Migration.
“There’s always been pressure from the EU on the Caribbean countries, mostly related to security issues, and all of them have bolstered their security issues in response to EU requests in recent years. The new thing is different,” Klasko said. “They’re saying we are opposed to the concept of a commercial transaction resulting in you getting a passport.”
In late 2024, the EU revoked visa-free travel for citizens of Vanuatu due to security and migration concerns. In 2025, the European Court of Justice struck down Malta’s “golden passport” program as illegal.
What’s Next
Reaz Jafri, senior counsel at Charles Russell Speechlys, said he views the EU request as a starting point for negotiations rather than a firm ultimatum. “This conversation has been going on as long as I can remember,” said the immigration attorney of 30 years. “I think the EU is looking to maybe get more diligence or a better handle on certain things with regards to who gets in and who doesn’t come in.”
Even if a compromise can’t be reached, Jafri said the Caribbean nations rely too much on revenue from CBI programs to phase them out. More than half of his clients are Americans, who don’t need a visa-free perk, he added.
The Bottom Line
The EU has given five Caribbean nations until 2028 to end their citizenship-by-investment programs or lose visa-free access to Europe’s Schengen area. The ultimatum marks a shift from previous security-focused concerns to opposition to the concept of selling passports. Antigua and Barbuda’s prime minister said the programs are “critical pillars” of their economies. Negotiations are expected, with some attorneys viewing the EU request as a starting point for dialogue rather than a firm deadline.
