“national interest” may be equated with economic or commercial interest10. Discretionary
naturalisation procedures can be used in individual cases to grant citizenship in exchange for
investment. Such discretionary naturalisation procedures are highly individualised and used
on a limited basis. They are therefore not the object of this report.
Bulgaria, Cyprus and Malta introduced in 2005, 2007 and 2013 respectively11 broader
schemes aimed at attracting investment from third-country nationals by facilitating access to
their citizenship. These schemes are a new form of naturalisation as they systematically grant
citizenship of the Member State concerned, provided the required investment is made and
certain criteria fulfilled12.
Since Bulgaria13, Cyprus and Malta are the only Member States which operate investor
citizenship schemes, this section of the report focusses on the legislation and practice of these
countries.
2.2. Type and amount of investment required
Investor citizenship schemes aim to attract investment by offering citizenship in return for a
defined amount of money. In Bulgaria, an overall investment of EUR 1 million is requested
under its fast-track14 investor citizenship scheme. In Cyprus, a minimum investment of
EUR 2 million is necessary, together with ownership of property in Cyprus. In Malta, a
contribution of EUR 650,000 must be paid into a national investment fund, together with an
investment of EUR 150,000 and a requirement to own or rent property in Malta15. In Cyprus
and Malta, additional investments for family members are required.
Various investment options can be observed among the three Member States operating
investor citizenship schemes: capital investment16; investment in immovable property17;
investment in government bonds18; and one-off contributions to the State budget19. In addition
to the investment requirement, applicants must also pay non-refundable administrative fees as
10
11
12
13
14
15
16
17
18
19
Countries where the legislation explicitly equates “national interest” with the economic or commercial
interest of the state are Austria, Bulgaria, Slovenia and Slovakia. For details, see Study Overview, ibid,
note 4.
For details of these schemes see the Study, ibid, note 4.
See J. Dzankic, The pros and cons of ius pecuniae: investor citizenship in comparative perspective, Robert
Schuman Centre for Advanced Studies, EUDO Observatory, Issue 14.
In Bulgaria, on 15 February 2018 a working group was set up by the Minister of Justice to draft
amendments to the Bulgarian Citizenship Act, including to the investor citizenship scheme which Bulgaria
is considering abolishing in the future.
Details of the differences between the fast-track and ordinary investor scheme in Bulgaria are set out in the
Staff Working Document.
Regulation 7(5) of LN 47/2014 requires that the main applicant must acquire and hold a residential
immovable property in Malta having a minimum value of EUR 350,000; or (b) take on lease a residential
immovable property for a minimum annual rent of EUR 16,000.
Under the capital model, the requirement is to invest a definite sum either in (i) a company (Bulgaria,
Cyprus) or (ii) credit or financial institutions instruments such as investment funds or trust funds (Bulgaria,
Cyprus, Malta).
This model requires buying or renting a real estate property of a definite value (Cyprus, Malta). More
details are included in the Staff Working Document.
Bonds are purchased from the governments by the investors (Bulgaria, Malta).
Maltese legislation requires a “contribution” be paid to the Maltese government, which is deposited in the
National Development Funds.
3