The promise that a citizenship‑by‑investment (CBI) passport can be handed down “for generations” is only true for a minority of programmes. The right of a child born abroad to automatically inherit the parent’s citizenship depends on how the country’s nationality law distinguishes between citizens who acquire status by birth or naturalisation and those who receive it through investment.
How inheritance is determined
When a child is born outside the country, the law asks either:
-
Is at least one parent a citizen at the time of birth?
If yes, the child automatically acquires citizenship, regardless of how the parent obtained it. -
Did the parent acquire citizenship by investment (i.e., not by birth or naturalisation)?
Many Caribbean constitutions and Malta’s law treat “investor” citizenship as a distinct category that cannot be passed on beyond the first generation.
The answer to this second question creates three practical groups.
1. No generational limit – citizenship passes indefinitely
| Country | Legal rule | Practical note |
|---|---|---|
| Turkey | A child born to a Turkish mother or father, anywhere, is Turkish from birth. No reference to how the parent obtained the passport. | Only requirement is registering the birth at a Turkish consulate. |
| Egypt | Since the 2004 amendment, any child of an Egyptian parent is Egyptian, wherever born. | Minor children of naturalised Egyptians are usually added to the parent’s grant. |
| Cambodia | 1996 nationality law treats any legitimate child of a Cambodian mother or father as Cambodian, irrespective of birthplace or parent’s origin of citizenship. | |
| Nauru | If either parent is a Nauruan citizen at the time of birth, the child is a citizen, even if born abroad. No generational cap. | |
| Vanuatu | Constitution states a child born abroad is a citizen if at least one parent is a citizen. Practitioners report a post‑approval application is often required, but the right exists. |
In these jurisdictions the only test at each generation is whether a parent holds citizenship at the child’s birth.
2. One generation only – the grant stops at the grandchild
| Country | How the first generation is covered | Why it stops |
|---|---|---|
| Grenada | Constitution grants citizenship at birth to a child born abroad provided the parent did not inherit citizenship. An investor’s child therefore receives a passport automatically, free of fee. | That child inherits citizenship; the next generation is considered “inherited” and cannot receive citizenship automatically. |
| Saint Lucia | Mirrors Grenada’s wording. A child born abroad to an investor parent receives citizenship at birth; the grandchild does not. | Same inheritance limitation. |
| Malta (old Individual Investor Programme) | A child born abroad is Maltese if, at birth, the parent holds citizenship by birth, naturalisation, or registration. Investors who naturalised qualify, so their children are Maltese. | The child’s citizenship is classified as “inherited,” and Malta does not allow inherited citizenship to be passed on again. The grandchild receives nothing unless the family can restart the chain (e.g., by having the child born on the island, which confers citizenship by birth rather than inheritance). |
The Maltese route also offers a discretionary merit scheme (from July 2025) that does not involve investment, but families that bought citizenship before the programme closed are still subject to the same one‑generation limit.
3. No automatic claim – registration required, often with fees and strict deadlines
| Country | Automatic transmission? | Registration pathway & limits |
|---|---|---|
| St Kitts & Nevis | No. A child born abroad is a citizen at birth only if a parent was born on the islands and held British citizenship before 1983 – impossible for investors. | The Citizenship Act allows the minister to refuse registration of a child of an investor. In practice, a fee of US $7,500 (child < 3 y) or US $10,000 (child born during pending application) is charged. Children left off the original application cannot be added later; a new sponsored application is required. |
| Antigua & Barbuda | No automatic right. | Any child under 18 of a citizen may be registered, with no explicit investor exemption. Fees are typically US $10,000 for newborns/children < 6 y and US $20,000 for ages 6‑17. Investors must also spend five days in the country within the first five years of citizenship. |
| Dominica | No automatic right. | A CBI citizen may register a child born or adopted within five years of obtaining citizenship, provided the child is under 18. After that window, no constitutional route exists. |
| North Macedonia | Automatic only when both parents are citizens. | If one parent is foreign, the child must be registered before age 18, move to the country with the Macedonian parent before then, or apply between ages 18‑23. |
In these programmes the “generational” promise is effectively limited to the first child born after the grant, and each subsequent generation requires a separate, fee‑based registration before a strict age cut‑off.
4. Odd or unsettled cases
- Jordan – Citizenship passes indefinitely through the father only. A child of a Jordanian father is Jordanian regardless of birthplace; a Jordanian mother cannot transmit nationality.
- São Tomé & Príncipe – Constitution treats children of a São Toméan mother or father as citizens, but the implementing regulation for the 2022 nationality law had not been adopted as of April 2024. The exact rules for investor‑derived citizenship remain uncertain.
Why the inheritance rules matter now
-
Tightening of descent limits worldwide – Italy’s Constitutional Court upheld a cap on citizenship by descent in March 2026, signalling a broader trend of limiting generational transmission.
-
Increasing revocation risk –
- Turkey revoked 6,134 CBI passports in a programme‑wide sweep (2025).
- Grenada is considering a retroactive residency requirement that could affect existing passport holders.
- St Kitts & Nevis plans to introduce a physical‑residency requirement in 2026.
A passport that can be passed down without restriction retains higher long‑term value, while a passport sold on a “generations” promise that cannot be fulfilled may generate disputes decades later when grandchildren are denied entry.
Practical take‑aways for prospective investors
- Verify the transmission rule before committing funds. Ask the programme provider (or an independent IMI‑certified professional) to confirm in writing whether the child, grandchild, or further descendants will have an automatic right, a fee‑based registration path, or no right at all.
- Plan for the required registrations where they exist – note the age limits (often 18) and associated fees, and ensure children are added to the original application or registered promptly.
- Consider the “restart” option in jurisdictions like Malta, where having a child born on the island resets the transmission chain.
- Monitor legislative changes that could introduce residency or revocation clauses, especially in programmes that currently rely on a “no‑limit” model.
Understanding the precise inheritance mechanics is essential for families that view a CBI passport as a multigenerational asset rather than a one‑off benefit.
Source article: www.imidaily.com
