European Citizenship by Investment: From Expansion to EU-Led Reform and the Rise of Contributive Belonging

Over the past decade, Europe has undergone one of the most significant recalibrations in international mobility policy. What began in the mid-2010s as a period of rapid growth for citizenship-by-investment (CBI) offerings gradually evolved into a continent-wide shift away from investment-driven naturalisation. The transition has been shaped by political pressures, rule-of-law considerations, and an increasingly assertive European regulatory environment. Nowhere is this trajectory clearer than in Malta’s 2014–2020–2025 reforms, which chronicle Europe’s movement from transactional investment routes toward frameworks emphasising residence, contribution, and integrity.

This article follows the chronological development of CBI in Europe, the closure of Cyprus and other programmes, the influence of EU law, and the emergence of Contributive Belonging, a doctrine introduced by Dr Jean-Philippe Chetcuti that is increasingly informing the future architecture of citizenship and long-term residence globally.

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1. Early Expansion of CBI in Europe (2013–2017)

The European CBI landscape emerged strongly between 2013 and 2017, when a number of countries explored naturalisation frameworks linked to meaningful economic investment. Malta launched its Individual Investor Programme (IIP) in 2014, the first European programme operating with explicit EU-level engagement. Other jurisdictions followed suit, most notably Cyprus, which adapted its naturalisation rules in 2013–2014 to create a capital-based route to citizenship.

This period coincided with rising global demand for mobility, increasing diversification of family wealth structures, and the expansion of the investment migration industry. Programmes positioned themselves as tools for attracting capital inflows, strengthening small economies, and integrating successful international families into European society.

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2. The EU’s Growing Regulatory Engagement (2017–2020)

By 2017, the European Commission intensified its scrutiny of CBI mechanisms, focusing on due diligence, anti-money laundering standards, and the risk that insufficient checks could allow individuals to access EU citizenship rights through purely financial pathways. A series of Commission reports (see EU Commission Reports on Investor Citizenship) explicitly flagged concerns around:

• insufficient residence or integration requirements

• perceived circumvention of the principle of genuine links

• potential security vulnerabilities linked to Schengen mobility

• the broader political integrity of EU citizenship

This period marked the beginning of a European expectation that nationality should arise from a meaningful relationship between individual and state—a principle later reinforced in infringement proceedings and CJEU engagement.

3. The Cyprus Programme and Its Termination (2020)

The turning point for European CBI came in 2020 with the closure of the Cyprus Investment Programme. Following investigative journalism, political shifts, and enhanced EU pressure, the Cypriot government suspended the route indefinitely. This closure was widely interpreted as signalling the end of Europe’s tolerance for citizenship frameworks framed primarily around capital investment, regardless of strong due diligence layers.

The closure also accelerated EU engagement with Malta’s second-generation programme, ultimately contributing to the reassessment and restructuring of naturalisation routes across the continent. Analysts at CCLEX provide a comparative overview of both the Cypriot and Maltese developments, including the distinct legal foundations underpinning each.

4. Malta’s Three-Phase Evolution: 2014 → 2020 → 2025

Malta provides the clearest illustration of Europe’s shift from investment to merit-based integration. Its reforms unfolded in three distinct phases:

4.1 The Individual Investor Programme (2014–2020)

The IIP was launched with structured contributions, multi-layered due diligence, and an obligatory residence period. It set several international benchmarks for governance in investment migration and was the only EU-engaged CBI framework of its time.

4.2 The 2020 Regulations: Exceptional Services by Direct Investment (2020–2025)

After the IIP reached capacity in 2020, Malta introduced a more limited naturalisation route based on exceptional service. This required a 12- or 36-month residence period and adhered to stricter compliance standards. Yet, despite these safeguards, the European Commission initiated infringement proceedings against Malta, arguing the model still constituted an investment-based path to citizenship inconsistent with EU principles.

Extensive legal commentary on the case is available at

• CJEU’s Decision in EC v Malta: Legality of Citizenship by Investment Under EU Law.
• IBA Papers

4.3 The 2025 Citizenship by Merit (CBM) Framework

In July 2025, Malta enacted a full structural transformation. The former investment-linked route was repealed and replaced by a transparent, EU-aligned model emphasising:

• a minimum of eight months of legal residence

• active engagement in Maltese cultural, scientific, social, or philanthropic initiatives

• no investment transaction or pre-defined financial contribution

• a merit-based assessment rooted in measurable national value

• alignment with broader Malta Vision 2050 and sustainability goals

This shift, extensively documented in Chetcuti Cauchi Advocates' Citizenship by  Merit publication, represents the European Union’s preferred direction: naturalisation grounded not in capital, but in contributive integration.

5. The Broader European Retreat from CBI

Between 2020 and 2024, the European space for CBI diminished rapidly. Bulgaria phased out its expedited naturalisation route, Montenegro discontinued its programme as part of its EU accession trajectory, and Western Balkan states faced heightened pressure from Brussels to resist investment citizenship.

By 2024, no EU member state operated a CBI scheme in its traditional form.

A broader comparative review of “post-CBI Europe” can be found at CCLEX’s EU Citizenship resources.

6. EU Law and the Shift Toward Meaningful Connection

Three areas of EU engagement shaped the transition away from CBI:

6.1 Reinterpreting Genuine Links

On the subject of European Citizenship by Investment, while nationality remains a sovereign competence, the EU stresses compatibility with core principles - especially genuine links, a concept rooted partly in international jurisprudence such as the Nottebohm case.
The Maltese analysis of this doctrine is available in Maltese Citizenship & the Nottebohm Principle.

6.2 EU Citizenship and Mutual Trust

The Commission consistently asserted that investor citizenship risked weakening mutual trust between member states by enabling third-country nationals to obtain EU citizenship without adequate integration checks.

6.3 The EC v Malta Case

The infringement procedure and the pending CJEU assessment served as a catalyst for the 2025 reforms. Malta’s pivot to a merit-based model was widely seen as aligning its naturalisation framework with the EU’s vision of credible and value-driven citizenship.

7. The Emergence of Contributive Belonging

In recent years, the conversation around citizenship and long-term residence has moved decisively beyond the narrow, mid-20th-century interpretation of “genuine links”. Earlier iterations of this principle were rooted in assumptions of territorial permanence, fixed domicile, and single-jurisdiction life patterns-conditions that no longer reflect the realities of globally mobile families, entrepreneurs, and knowledge-driven individuals.

It is in this evolving landscape that the doctrine of Contributive Belonging, introduced by Dr Jean-Philippe Chetcuti, has become increasingly influential in European and international policy debates. The doctrine reframes the relationship between the individual and the state for the 21st century, by anchoring citizenship and long-term residence not in immobility, but in meaningful engagement, intentional contribution, and ongoing alignment with national values and interests.

Rather than treating global mobility as incompatible with national belonging, Contributive Belonging recognises that high-achieving international families form multi-jurisdictional lives, often contributing intellectually, philanthropically, scientifically or economically in more than one country. Their mobility does not diminish their capacity to belong; rather, it can enhance the quality and diversity of the contribution they bring to the jurisdictions with which they choose to engage.

Under this doctrine, genuine links are interpreted not as ties arising from physical permanence, but as genuine in character: authentic, measurable, consistent with the applicant’s life pattern, and aligned with the country’s long-term strategic priorities. Contributive Belonging therefore:

• reframes citizenship as a relationship of reciprocity, not transaction;

• emphasises sustained value creation rather than passive capital inflows;

• acknowledges that the modern globally mobile individual can cultivate deep, meaningful ties without remaining geographically fixed;

• aligns naturalisation with public interest contribution, whether philanthropic, cultural, scientific, educational, or economic; and

• supports policy models that are integrity-driven, transparent, and resistant to commodification.

It replaces the outdated notion that nationality requires geographic permanence with the more nuanced idea that belonging arises from engaged contribution, integration of values, and active participation in the receiving state’s societal priorities—whether through philanthropy, innovation, research, cultural participation, or nation-building initiatives.

In doing so, Contributive Belonging offers a coherent intellectual and policy framework for jurisdictions seeking to attract global talent and purposeful individuals, while maintaining the credibility and integrity of their citizenship regimes. It is a doctrine that aligns with the realities of modern international life and aligns with the trajectory of contemporary EU policy— firmly repudiating transactional models in favour of contribution-based, value-driven naturalisation.

8. Looking Forward: The Post-CBI Settlement in Europe

Europe appears to have moved decisively into a new era—one where:

• merit-based naturalisation replaces investment

• residence and engagement form the backbone of integration

• public interest contribution becomes the primary criterion

• due diligence and transparency are universally expected

• talent attraction strategies shift from capital inflows to strategic value creation

Malta’s 2025 Citizenship by Merit model is the first complete expression of this new policy direction and may serve as a future blueprint for other advanced jurisdictions seeking to balance openness with institutional integrity. European Citizenship & Residency in 2025

About Dr Jean-Philippe Chetcuti

Dr Jean-Philippe Chetcuti is a Maltese lawyer, policy advisor and academic author specialising in citizenship, residency, and private client law. With more than 20 years of cross-border advisory experience, he has contributed to the development of modern naturalisation and residency frameworks and is the originator of the Contributive Belonging doctrine. His works are frequently referenced in European and international mobility policy discussions.