The European Commission has given the five Eastern Caribbean states that run citizenship‑by‑investment (CBI) schemes a deadline to end the programmes by 1 June 2028. The demand arrives despite recent reforms that the region says already address the EU’s security concerns.
EU demand and timeline
- In early July 2024 the Commission sent a letter to all five CBI states – Antigua & Barbuda, Dominica, Saint Lucia, Saint Kitts & Nevis and Grenada – ordering a phased‑out of the programmes by the 2028 deadline.
- Antigua & Barbuda published the letter on 7 July 2024; Saint Lucia has not yet released its copy.
- The Commission also requires, by September 2024, the exclusion of any applicant subject to EU restrictive measures and a reinforced vetting process for all nationalities.
- A regional regulatory authority, created by agreement signed in September 2025, is expected to become operational in September 2024 to oversee compliance.
- The EU will review the situation in a visa‑suspension report due in December 2024.
Reforms already implemented
Saint Lucia’s Deputy Prime Minister Ernest Hilaire, who oversees the CBI portfolio, said the governments have already introduced several changes:
- Strengthened legislation and “value metrics” to assess applicants.
- Creation of a regional regulatory body tasked with overseeing the programmes and ensuring legislative requirements are met.
- Enhanced due‑diligence procedures, biometric data collection and transparency measures.
Shift in EU policy
Hilaire argued that the EU’s stance is no longer focused on the technical design of the programmes but on a broader policy shift:
- The Commission has been urging EU member states to replace direct citizenship routes with residence‑first pathways.
- The EU’s legal action against Malta – culminating in an April 2025 Court of Justice ruling that member states must not maintain such programmes – is cited as evidence of this change in mood.
Financial stakes for the Caribbean
The potential phase‑out would have a major fiscal impact. The Dominica Freedom Party (DFP) released figures from Dominica’s 2025/2026 budget:
| Item | Amount (EC$) | Approx. US$ |
|---|---|---|
| Non‑CBI recurrent revenue | 456.2 million | 169 million |
| Recurrent expenditure | 679.9 million | 252 million |
| Revenue gap without CBI | ≈ 224 million | ≈ 83 million |
- 56.7 % of Dominica’s recurrent revenue is projected to come from CBI.
- The shortfall would affect public‑officer salaries, the National Employment Programme, healthcare, road maintenance and financing for the international airport.
Industry perspective
- Daisy Joseph‑Andall (Joseph Rowe Law) noted that the Caribbean has already delivered the EU‑requested reforms – due‑diligence, biometric data, regional cooperation and a regulator – and questioned whether further compliance is realistic.
- Nick Stevens (NTL Trust) framed the issue as a choice between retaining visa‑free EU travel and keeping CBI programmes, suggesting that lost Schengen access could be offset by EU subsidies, trade, tourism and reparations.
- Vanuatu is highlighted as a case study: despite losing Schengen access in December 2024, its CBI revenue reached a record in the first half of 2026, underscoring the economic importance of the schemes.
- Patrick Peters (ClientReferrals) warned applicants that the window for securing a second residence or citizenship under current terms is closing, as governments may raise investment thresholds or tighten benefits with little notice.
What lies ahead
- By September 2024 the regional regulator must be fully functional and the EU’s vetting requirements met.
- The outcome of the December 2024 EU visa‑suspension report will determine whether the Caribbean states retain any visa‑free access to the Schengen area.
- The five governments have pledged to discuss the path forward collectively, but no definitive decision has been announced.
Source article: www.imidaily.com
