At a glance: Citizenship by investment (CBI) can grant nationality and a passport after an approved application. A European “golden visa” is a residence route, not a passport; naturalisation is a separate process with country-specific residence and other requirements.
These options are not interchangeable. The right comparison is the legal status you want, the time you can spend in-country, total costs, family eligibility and how policy or visa-free travel rules may change. This guide reflects information checked on 12 October 2026; figures and rules should be reconfirmed before any commitment.
1. Second passport or residence permit: what is the difference?
| Question | Citizenship by investment | Residence by investment (“golden visa”) |
|---|---|---|
| What is granted? | Citizenship and, after the required formalities, a passport. | A residence permit. It does not itself grant citizenship or an EU passport. |
| Time frame | JHM’s source briefing gives indicative planning ranges of about 4–15 months, depending on programme and due diligence. | The source briefing estimates roughly 8–16 months for an initial permit; processing and appointments vary. |
| Residence | Many programmes do not require long-term residence, but application, interview and collection steps differ. | Permit renewal conditions are programme-specific. Naturalisation generally requires qualifying residence and other statutory conditions. |
| Investment scale | Examples below begin around USD 200,000, with route-specific fees and family costs. | Examples range from qualifying routes around EUR 250,000 to higher thresholds; the programme, location and asset type matter. |
Processing ranges above are planning estimates from the source briefing, not official service standards or a promise of timing. Government, due-diligence, legal, property and other costs are additional unless expressly stated.
2. Citizenship by investment: four options in the source briefing
| Programme | Indicative qualifying route | JHM planning estimate* | Points to check |
|---|---|---|---|
| Turkey | Real estate of at least USD 400,000, held for three years. Other routes have different thresholds, generally USD 500,000 or 50 jobs. | About 4–6 months | Family inclusion and property eligibility are specific. Turkish nationality may support an E-2 treaty-investor application, but it does not automatically qualify an applicant for a U.S. visa. |
| Dominica | From USD 200,000 through a qualifying contribution route; approved real-estate routes and fees differ. | About 8–10 months | Confirm the current route, government and due-diligence charges, family definition and any interview or passport-delivery steps. |
| St Kitts and Nevis | The official Sustainable Island State Contribution route starts at USD 250,000 for an eligible application; approved real-estate options have separate conditions. | About 10–12 months | Contribution totals depend on the applicant group and applicable fees. Check the current CIU schedule and approved project list. |
| Grenada | From USD 235,000 through the National Transformation Fund; approved real-estate routes have separate thresholds and charges. | About 13–15 months | Family eligibility, due diligence and route costs vary. Grenadian nationality is listed for E-2 treaty purposes, but each U.S. application must independently meet E-2 requirements. |
*JHM planning estimates reproduced from the source document; actual processing may be longer or shorter and is controlled by the programme authority and case circumstances.
For Turkey, see JHM’s Turkish investment immigration page. For official programme information, review the Türkiye Investment Office, Dominica CBI Unit, St Kitts and Nevis CIU and Grenada Investment Migration Agency.
3. European residence routes: four options
| Programme | Current route overview | Indicative timing in source | Important distinction |
|---|---|---|---|
| Greece | Property thresholds vary by location and statutory route, commonly described within a EUR 250,000–800,000 range. The lower threshold is limited to specified categories; it is not the general price for every property. | About 12 months | A residence permit, not citizenship. Check the exact property category, location, permitted use and current law before paying a deposit. |
| Cyprus | Qualifying permanent-residence investor routes start at EUR 300,000, subject to the investment category and other criteria. | About 12 months | Confirm whether the chosen investment qualifies and review income, family and ongoing conditions. |
| Malta MPRP | A residence programme distinct from citizenship by investment. The current framework includes property purchase of at least EUR 375,000 or a qualifying lease of at least EUR 14,000 per year, plus programme contributions, administration and other fees. | About 4–6 months | Do not confuse the residence programme with Malta’s former investor-citizenship scheme, which the EU Court of Justice ruled unlawful. |
| Portugal ARI | One eligible route is EUR 500,000 in qualifying non-real-estate investment funds, subject to AIMA’s criteria, including fund term and portfolio conditions. | About 12–16 months | Real estate is not a qualifying ARI investment route. Residence and eventual naturalisation have separate requirements. |
Residence permits may allow short visits elsewhere in the Schengen area under the applicable rules (generally up to 90 days in any 180-day period for short stays); they do not provide an unrestricted right to live or work throughout Europe. Family definitions, renewal rules and the residence needed for naturalisation differ by country.
See JHM’s Europe immigration overview and our Greece Golden Visa 2026 update. Official guidance: Greek Ministry of Migration, Cyprus Migration Department, Residency Malta Agency and Portugal’s AIMA.
4. Match the route to your goal
- You want citizenship rather than a permit: compare CBI routes, but weigh due diligence, full costs, passport-use limits and programme stability.
- You want a European base: compare residence routes by location, renewal conditions, family eligibility and the time you can genuinely spend there. A residence permit is not an immediate passport.
- You have a set budget: compare total outlay, not only the headline investment. Include government charges, due diligence, legal and advisory fees, taxes, property expenses and currency risk.
- You are considering Turkey for a possible U.S. E-2 application: E-2 is a nonimmigrant investor visa. Treaty nationality alone is insufficient: the enterprise, ownership/control, substantial investment and other U.S. requirements must be met, and the application is adjudicated separately.
5. Risks and claims to verify before deciding
- Caribbean CBI and Schengen access: EU Regulation 2025/2441 provides a mechanism under which operating a CBI scheme may be considered when suspending visa-free travel. Separately, Antigua and Barbuda’s government said it received a European Commission communication dated 25 June 2026 asking it to phase out its programme by 1 June 2028. This is not evidence that all five Eastern Caribbean states received identical letters, nor does it mean visa-free access has already been automatically suspended. Check the EU regulation and the Antigua and Barbuda government statement.
- Dominica passport delivery: the CBI Unit describes applications from abroad and delivery arrangements through an authorised agent or an embassy, depending on the case. The source document’s blanket statement that new applicants must travel to Dominica to collect a passport is not supported by the official process, so confirm the individual arrangement with the CBI Unit.
- Greece property tax: the source document’s claim that transfer tax for non-EU buyers will rise from 3% to 15% in January 2027 could not be verified in official guidance and is not repeated here. Obtain current local tax advice for the specific property and transaction.
- Spain and Malta: Spain’s investor-residence provisions ceased to apply from 3 April 2025 under its official law. On 29 April 2025, the EU Court of Justice ruled that Malta’s investor-citizenship scheme breached EU law. Malta’s residence-by-investment programme is legally distinct; neither development should be described as ending every residence route in Europe.
- Dual nationality: check the nationality laws and personal circumstances of every country involved. Hong Kong/PRC treatment should be reviewed with a suitably qualified adviser.
- Turkey-linked U.S. visas: an E-2 is not a green card and is not granted simply because a person obtains Turkish citizenship. See the U.S. Department of State’s E visa guidance and treaty-country list.
6. What is included in the real cost?
The qualifying investment is only one component. Budget for government and application fees, due diligence, professional advice, translation and document costs, property transaction and holding expenses, taxes, fund charges and currency movements. Ask for an itemised, route-specific quotation and understand exit, resale or holding restrictions before committing capital.
Frequently asked questions
Is a second passport the same as a golden visa?
No. CBI is a citizenship route; a golden visa usually grants residence first. Citizenship may be possible later only if the applicant meets the country’s separate naturalisation rules.
Which programme is fastest?
The source briefing lists Turkey as the shortest planning estimate among the CBI examples, but it is not an official timetable or a guarantee. Due diligence, documents and government processing affect every case.
Are Caribbean passports still worth considering?
That depends on the family’s objectives, complete costs, programme stability and the possibility that visa-free travel rules may change. Confirm current official information and obtain advice specific to your circumstances.
Can a European residence permit be used to settle anywhere in the EU?
No. A national residence permit is not an EU-wide right to live or work. Schengen short visits are subject to the applicable 90/180-day and other rules.
Explore your options with JHM
There is no universal “best” second passport or residence route. John Hu Migration Consulting has 17 years of experience supporting families with overseas identity and asset planning. Speak with our team to compare the routes against your objectives, family composition and risk tolerance.
Enquiry hotline: (852) 3568 1436 · WhatsApp: (852) 9178 8523 · Book a free assessment.
Outcomes, eligibility, processing times and subsequent status depend on each applicant, programme conditions, complete documentation and official decisions. This article is general information only and is not legal, tax or investment advice or a promise of approval. Rules can change; verify the latest official requirements before making a decision. Information checked 12 October 2026.