Europe's Golden Doors Are Closing — What's Actually Left

Between February 2022 and April 2025, six European countries closed a citizenship or residency-by-investment route — Britain, Ireland, the Netherlands, Hungary, Portugal's real-estate route, and Spain outright. Then, on 29 April 2025, the European Court of Justice went further: it ruled an EU member state cannot sell citizenship at all. I've spent the past year fielding calls from British, European and Canadian clients who assumed Europe was closed for business. It isn't. Two genuine doors are still open, a third is quietly the best value in the region, and a fourth country just outside the EU launched a tax offer that may beat all of them on that one measure alone.

But the more useful version of the question isn't "what's left in Europe." It's "Europe closed the passport door — so what does a British or Canadian family actually do now?" That's the one I'll answer.

The call I take most often runs the same shape every time. A family — British more often than not, Canadian a close second — has a Portugal fund quote in front of them at €500,000, and they want to know whether to sign it. What decides it is almost never the money. It's the clock. That €500,000 is capital locked into a fund for a passport that now sits ten years away, against roughly US$230,000–$250,000 and five to fourteen months for St Kitts & Nevis, Grenada or Antigua & Barbuda. So the fork is this: if what they actually want is an EU life — a base, schools, a residence card, the right to be there — Portugal or Greece wins, and it isn't close. If what they want is a second passport in hand, the €500,000 buys them a wait and the Caribbean buys them the document. Two different products. Half of what I do on that call is establishing which one the family is really buying, because a surprising number of them have never separated the two.

The short answer

Europe no longer sells a passport to anyone, at any price. If a passport is the actual goal, the honest answer for most British, European and Canadian families is now the Caribbean: St Kitts & Nevis, Antigua & Barbuda or Grenada, at US$230,000–$250,000 through a fund contribution, in roughly five to fourteen months, on passports reaching 147 to 155 destinations visa-free or visa-on-arrival. Inside Europe, two golden visas remain genuinely viable: Portugal's investment-fund route (from €500,000, no property required) and Greece's tiered real-estate program (from €250,000 to €800,000 by location) — both residence, not citizenship, though Portugal still leads to a passport, now on a 10-year clock instead of five. Malta's golden passport is dead: the EU's top court ruled on 29 April 2025 (Case C-181/23) that selling citizenship breaches EU law, and Malta replaced it with a discretionary "citizenship by merit" framework that explicitly excludes investment as qualifying — what Malta still sells is strong permanent residence, not a passport. And one non-EU option deserves a serious look for the tax-conscious: Turkey still grants citizenship for a $400,000 real estate purchase in under a year, and just added a 20-year exemption on foreign-source income for new tax residents — the most interesting tax offer anywhere near Europe in 2026, though the passport it comes attached to reaches a bit over 100 destinations and none of the EU, UK or US.

What's actually left, side by side

Everything in this article compresses into one table. Residence programs and citizenship programs are genuinely different products, and the visa-free column is where that difference stops being abstract — a golden visa doesn't upgrade the passport you already travel on.

Read the visa-free column against the "time to a passport" column and the article writes itself. Turkey is fast and cheap, and it is the weakest travel document on this table by a wide margin. Portugal and Greece are excellent European residence and confer no travel upgrade at all. The three Caribbean programs are the only rows that deliver a stronger passport, in months, at a lower entry number than Portugal's fund minimum in any currency you convert it into.

Which European golden doors have actually closed?

Start with the graveyard — it's larger than most people realize, and it explains why everyone's suddenly anxious about the doors still open.

• The UK closed its Tier 1 (Investor) visa on 17 February 2022, part of the crackdown on illicit money after Russia's invasion of Ukraine.
• Ireland shut its Immigrant Investor Program — €500,000 donation or €1 million investment — on 15 February 2023.
• The Netherlands ended its golden visa in January 2024, citing EU transparency and security concerns.
• Portugal killed the route behind roughly three-quarters of its applications — the €500,000 real-estate purchase and a €1.5 million capital-transfer option — on 7 October 2023, under Law 56/2023. Prior applications were grandfathered.
• Hungary relaunched its Guest Investor Program in 2024, then scrapped the €500,000 direct real-estate option again on 15 January 2025, leaving €250,000 into a regulated property fund or a €1 million education donation.
• Spain abolished its golden visa outright, effective 3 April 2025. Prime Minister Sánchez was blunt about why: 94 of every 100 golden visas issued were tied to real estate in housing markets already under strain.

Six countries, four years, one direction. If you're working from a 2023 comparison table of European golden visas, more than half the rows in it are wrong today.

The ECJ ruling that actually ended Malta's golden passport

The single biggest shift came not from a national government but the European Court of Justice. On 29 April 2025, the Grand Chamber ruled in Commission v Malta (Case C-181/23) that Malta's citizenship-by-investment scheme — contributions of up to €750,000 for a passport — breached EU law, calling it a "commercialisation" of EU citizenship in violation of Article 20 TFEU and the duty of sincere cooperation between member states.

Get the scope right, because most coverage doesn't. The ECJ outlawed selling citizenship — a golden passport. It said nothing about golden visas — residence by investment — which remain entirely lawful across the EU, Malta included. Passports already issued stay valid; the ruling applies only going forward.

Malta complied. Act XXI of 2025 abolished citizenship-by-direct-investment and replaced it with a discretionary "citizenship by merit" framework: naturalization for exceptional service or contribution to Malta or humanity, assessed case by case over a reported 12 to 24 months. The statute is explicit that investment alone does not constitute merit. If someone tells you they can still buy a Maltese passport, they're selling you something that no longer exists.

What Malta still sells: excellent residence, not a passport

What survived is the Malta Permanent Residence Program — genuine permanent residence, card renewed every five years, for life. After a 2025 overhaul: a €37,000 government contribution, a €60,000 administration fee, a €2,000 NGO donation, and either a €375,000 property purchase or €14,000-a-year rent held for five years — plus €10,000 per additional dependant. All in, before the property, roughly €99,000 in non-recoverable fees under Legal Notice 146 of 2025.

That overhaul — Legal Notice 310 of 2024 — also added a dual asset test (€500,000 total with €150,000 liquid, or €650,000 with €75,000 liquid), ended the old Gozo and South-of-Malta discounts, and capped dependent children at under 29.

Be clear about what this buys: excellent EU-adjacent residence, not an EU passport. Naturalization now runs through years of genuine residence and the merit framework above — not a cheque.

Portugal: still open, but the clock just doubled

Portugal remains the most-used golden-visa program in Europe, and it's still accepting applications — just not through real estate. The dominant route is a minimum €500,000 into a CMVM-regulated investment fund (at least 60% in Portugal-headquartered companies, no direct real estate). Smaller routes remain: a €250,000 cultural-heritage donation, research and company-formation options, and a ten-job-creation route.

What changed is the destination, not the door. Portugal's parliament passed a new Nationality Law in spring 2026, signed by the President in May and in force soon after. It doubles the ordinary naturalization clock from five years to ten (seven for Portuguese-speaking-country citizens), counted from your first residence card, and adds a language, culture and civic-knowledge test. Anyone filing after that law took effect now faces a decade-long wait for a passport.

Two things soften the blow. Portugal's Constitutional Court ruled in December 2025 that applying the rule retroactively to pending files was unconstitutional, so pre-reform applicants keep the old five-year clock. And golden-visa holders can apply for ordinary permanent residence after five years regardless of the citizenship timeline — freeing up the investment without needing the passport at all.

The market noticed: fund redemptions reportedly ran well ahead of pace through early 2026 versus all of 2025, and reports describe 500-plus holders, many American, weighing collective legal action. Americans had become Portugal's number-one golden-visa nationality by late 2023, with applications reportedly still surging into 2025 — against a backlog of 20,000-plus investors waiting on a first appointment.

Greece: still the volume value play

While Portugal and Malta dominate the headlines, Greece quietly runs the largest golden-visa program in Europe by volume — and it never stopped being good value. Since Law 5100/2024, the country runs three tiers: €800,000 in Attica, Thessaloniki, Mykonos, Santorini and the larger islands; €400,000 everywhere else; €250,000 preserved nationwide for converting commercial space to residential use or restoring listed buildings.

The scale is real: roughly 27,800 main-investor permits were valid as of December 2025, and more than 79,000 including family members — Europe's largest golden-visa population, with billions of euros channeled into Greek real estate since the program's launch. Reported cumulative totals vary by source and cut-off date, but the scale of capital involved isn't in question. Approvals accelerated through 2025 as the Migration Ministry worked through a backlog of tens of thousands of files, even as fresh applications cooled in early 2026 at the higher thresholds.

Greece's newest law — 5275/2026 — is the biggest immigration overhaul in a decade, and keeps the golden visa intact while tightening the edges: the five-year clock now runs from card issuance rather than investment date, a statutory 90-day processing deadline applies, and golden-visa properties can no longer be listed on Airbnb or Booking.com.

What hasn't changed is the value proposition: no minimum-stay requirement to renew, the whole family included, and €400,000 still buys qualifying property across most of the mainland and smaller islands — a lower bar than Portugal's fund-only €500,000 or Malta's roughly €99,000 in fees alone before property.

Turkey: the passport Europe's neighbours can still buy — plus a new 20-year tax play

None of the above gets you a passport quickly. If that's the actual goal, Turkey remains the fastest, most affordable citizenship-by-investment program bordering Europe, and it just got more interesting for the tax-conscious.

The core terms haven't changed: a minimum $400,000 real estate purchase (independently valued, verified through the government's EIDS system, three-year no-resale restriction on the title), or $500,000 via bank deposit, bonds, fund shares, or fixed capital investment. Citizenship follows in 10 to 12 months, spouse and children under 18 included, no residence or language requirement. Turkey has issued passports under this program to an estimated 50,000-plus foreign nationals since its 2017–18 reset — by industry estimates, the highest-volume citizenship-by-investment program in the world. It has also gotten more rigorous. The currency-protected version of the deposit route (YUVAM/KKM accounts) was closed to new CBI applicants in January 2025, and the underlying FX-guarantee scheme was terminated entirely in August 2025 — the $500,000 deposit option itself remains available, now without exchange-rate protection. Source-of-funds diligence tightened mid-2025, and as of 2026 applicants must appear in person for biometrics.

Here's what changes the calculus for Brits, Europeans and Canadians specifically. In 2026, Turkey enacted Law No. 7582, inserting Article Mükerrer 20/D into its Income Tax Law. New Turkish tax residents — provided they had no Turkish domicile or material Turkish tax liability in the prior three years — pay zero Turkish income tax on foreign-source income and capital gains for twenty years from establishing residency. That's a full exemption on foreign income, though Turkish-source income stays fully taxable and foreign tax credits don't apply against the exempt portion. The same package added a discounted flat rate on inheritance and gifts for qualifying beneficiaries, plus a one-time "asset peace" repatriation option — 5% tax on declared offshore assets, scaling toward zero if held five years in Turkish instruments.

Put the two together and you get something genuinely new: a $400,000 passport paired with a twenty-year tax holiday, landing barely a year after the UK scrapped its own non-dom regime for a four-year window — a shift I've covered in my piece on the end of UK non-dom. For a client who wants a low-cost, EU-adjacent base and two decades of breathing room on foreign income, Turkey is currently offering a tax proposition no EU country will sell at any price.

Now the part that decides it for most of the people reading this, and it deserves better than the footnote it usually gets. The Turkish passport reaches a bit over 100 destinations visa-free or visa-on-arrival — and none of the EU, UK or US is among them. Compare that to 155 for St Kitts & Nevis, 154 for Antigua & Barbuda and 147 for Grenada, all of which include Schengen and, with prior authorisation, the UK. If your reason for wanting a second passport is mobility — and for most British and Canadian families it is — Turkey is the wrong instrument, however good the tax regime is. It's a tax-residency play with a passport attached, not a mobility play. Those are not the same purchase.

I'll also be straightforward about my own position, because you should weigh advice by who's giving it: I don't place clients in Turkey. It isn't a jurisdiction I practise in, I earn nothing if you go there, and I'm describing it here because leaving it out would make this a less honest article — not because I'd steer you into it.

Contrast that with Italy: its investor visa stays open, but its flat tax for new residents jumped again in the 2026 budget, from €200,000 to €300,000 a year — 1.5 times pricier in the same window Turkey's became free.

What's left if the passport is the point: the Caribbean

Everything above is a European answer to a European question. But most people who land on this page aren't asking how to move to Lisbon — they're asking what to do now that Europe has stopped selling passports. That's a different question, and it's the one I answer for a living, from an office on Nevis rather than a desk in London.

Five Eastern Caribbean states still sell citizenship outright. Three of them are where I'd start a British or Canadian family:

• St Kitts & Nevis — US$250,000 through the Sustainable Island State Contribution, or approved real estate from US$325,000 on a seven-year hold. The fastest of the five, averaging around five months on agent-reported data, and 155 destinations visa-free or visa-on-arrival on the 2026 Henley Passport Index. No physical-presence requirement. It's where I live and work, so read that recommendation with my address in mind.
• Antigua & Barbuda — US$230,000 to the National Development Fund covering a family of up to four, or US$300,000 in approved real estate. 154 destinations. Around fourteen months on agent-reported averages, and the only one of the three with a presence condition: 30 days on-island within the first five years, up from five. Antigua applies the thirty administratively; the Citizenship by Investment (Amendment) Bill 2026 that would put it in the statute was presented on 14 July 2026 and I cannot confirm it has passed. Plan on thirty. I hold this passport myself.
• Grenada — US$235,000 to the National Transformation Fund, or real estate from US$350,000 for a sole purchase — the lower US$270,000 figure being a per-share minimum that applies only where two or more buyers jointly take a tourism-accommodation unit worth at least US$540,000 — plus a US$50,000 government contribution either way. 147 destinations, plus two things no European program offers: visa-free access to China and a US E-2 investor treaty — though a December 2022 change to US law requires three continuous years of genuine domicile in Grenada before an investment-acquired citizen can apply for E-1 or E-2.

Set those against the table at the top and the trade is clear enough to state in one sentence. What you give up is Europe — none of these is an EU residence, none of them lets you live in Spain or Portugal beyond the Schengen visitor allowance, and if your goal is genuinely to relocate into the EU then Portugal or Greece is your answer and the Caribbean is a distraction. What you get is a passport, in months rather than a decade, at a lower entry number than Portugal's €500,000 fund minimum, with meaningfully more visa-free access than Turkey delivers.

Two caveats I'd be negligent to leave out. Add government, due-diligence and professional fees to every figure above — the headline is never the invoice. And all five programs now sit under a new regional regulator, ECCIRA, and under sustained EU and US pressure that I keep current in the objective audit of every Caribbean CBI program; for the three-way detail on cost, speed and family fit, I've written St Kitts vs Grenada vs Antigua.

And for any American reading this: US citizens remain taxed by the United States on worldwide income regardless of a second citizenship — none of the five Caribbean programs has a US income tax treaty. The Caribbean answer above is a mobility answer, not a tax one.

How I'd think it through

Having guided over 100 families to citizenship or residency in 2025 alone, here's the filter I actually use:

1. If an EU passport by investment is the goal, stop looking — that door is shut everywhere. The ECJ closed the only real route (Malta) in April 2025. No amount of shopping around changes that.
2. If what you want is a passport rather than a European address, look at the Caribbean first. It is the only place still selling a strong travel document quickly, at St. Kitts & Nevis, Antigua & Barbuda and Grenada — faster timelines, lower minimums and better visa-free access than anything else on this page. Run them side by side on the comparison page. This is also the work I actually do, so weigh it accordingly.
3. If EU residence with an eventual path to citizenship matters, compare Portugal and Greece on your own timeline, not a headline. Portugal's clock is now ten years from card issuance; Greece is cheaper to enter and faster today, though it runs its own naturalization path.
4. If you want strong EU-adjacent residence and don't care about ever holding an EU passport, Malta's MPRP is genuinely competitive — permanent, renewable, no minimum stay.
5. If the goal is a tax-efficient base more than mobility, Turkey deserves a serious look — twenty years of exempt foreign income is a real offer. Just go in knowing the passport reaches a bit over 100 destinations and none of the EU, UK or US, and that I don't practise there.
6. Separate the passport question from the tax-residency question. A second citizenship is insurance and mobility; where you establish tax residency — Turkey, a territorial-tax Caribbean base, or Puerto Rico's Act 60 for US persons — is a different decision, and conflating the two costs clients real money.

None of this replaces proper cross-border tax advice in your home country before you file anything. What I bring is the other half — an honest read on which jurisdiction fits, informed by my own advisory practice. If you're weighing Europe against the Caribbean, book a call and I'll walk you through it plainly.

Key takeaways

• No EU state sells citizenship any more, so if a passport is the goal the answer sits outside Europe: St Kitts & Nevis (US$250,000, ~5 months, 155 destinations), Grenada (US$235,000, ~7 months, 147) and Antigua & Barbuda (US$230,000, ~14 months, 154) are the realistic shortlist for a British or Canadian family.
• Six European investor-visa routes have closed since 2022 — the UK, Ireland, the Netherlands, Hungary's real-estate option, Portugal's real-estate route, and Spain outright — and the EU's top court closed a seventh: Malta's golden passport.
• The ECJ's 29 April 2025 ruling (Case C-181/23) killed citizenship-for-investment, not residence-by-investment — golden visas remain lawful EU-wide.
• Portugal's golden visa is still open via investment funds, but its citizenship clock doubled from five to ten years under the 2026 nationality law.
• Greece remains Europe's highest-volume, best-value golden visa: from €250,000, no minimum stay to renew, family included.
• Turkey pairs a $400,000 citizenship-by-investment passport with a new 20-year foreign-income tax exemption — the strongest tax offer near Europe today, but the passport reaches only a bit over 100 destinations and none of the EU, UK or US, which makes it a tax-residency play rather than a mobility one. I don't practise there.

Frequently asked questions

Can I still buy EU citizenship in 2026? No. The ECJ ruled on 29 April 2025 that Malta's citizenship-by-investment scheme breached EU law, and Malta replaced it with a discretionary merit-based framework that excludes investment alone. No EU state currently sells citizenship outright.

Is Portugal's golden visa still worth it? Yes, for residence — the fund-based route from €500,000 remains open. The citizenship timeline changed: applicants filing after Portugal's 2026 nationality law face a ten-year path instead of five, though pending pre-reform applications kept the old five-year clock.

What's the cheapest European golden visa in 2026? Greece, at €250,000 for qualifying commercial-conversion or heritage-restoration properties, or €400,000 for standard property outside the highest-demand areas — with no minimum stay required to renew.

Does Turkish citizenship come with tax benefits? As of 2026, yes. New Turkish tax residents — including those who obtain citizenship through the $400,000 real estate route — can qualify for a 20-year exemption on foreign-source income under Turkey's newly enacted Law No. 7582, provided they had no material Turkish tax presence in the prior three years.

Should I choose a European golden visa or a Caribbean second passport? It depends entirely on which product you're buying. A European golden visa is residence — it lets you live there, and it does nothing for the passport you already travel on. A Caribbean program is citizenship — a second travel document, in months, at US$230,000–$250,000. If you want to move to the EU, Portugal or Greece. If you want a passport, St Kitts & Nevis, Grenada or Antigua & Barbuda. Some clients pair a passport with a separate, more tax-efficient residency instead — that's a third decision again.

Europe won't sell a passport any more — what's the fastest alternative for a British or Canadian family? St Kitts & Nevis, on current agent-reported averages of around five months, at US$250,000 through its fund contribution, on a passport reaching 155 destinations visa-free or visa-on-arrival. Grenada runs around seven months at US$235,000 and adds visa-free China and a US E-2 treaty. Antigua & Barbuda is cheapest at US$230,000 for a family of up to four but slower, closer to fourteen months, and asks for 30 days on-island within the first five years — applied administratively, with the Bill that formalises it presented in July 2026 and not confirmed enacted. Add government, due-diligence and professional fees to all three.