Comparisons · Malta
Citizenship of Cyprus or Malta in 2026: comparison of paths to an EU passport

Contents
Just a few years ago, the “EU passport for investment” was strongly associated with two islands - Cyprus and Malta. In 2026, the picture has changed completely. Cyprus closed citizenship by investment back in 2020, and on April 29, 2025, the EU Court of Justice declared Malta’s “golden passport” scheme to be contrary to Union law. Today, neither Cyprus nor Malta sell citizenship for money. There is only one path left - real naturalization after years of residence. We will analyze without illusions where and under what conditions you can get an EU passport, how the deadlines, language, Schengen and taxes of the two countries differ.
Major change for 2026: You can no longer buy an EU passport
Let's start with a fixation that overturns all the old ideas. For many years, Cyprus and Malta have been symbols of “citizenship by investment” - the two fastest and most expensive ways to obtain an EU passport. By 2026, both of these routes are closed, and closed in different ways, but with the same outcome for the investor.
Cyprus scrapped its citizenship investment program (CIP) back in 2020 amid high-profile investigations and pressure from Brussels. Since then, there has been no direct purchase of a Cypriot passport - we write more about this in the article about cancellation of investment citizenship of Cyprus.
Malta held out the longest and remained the last EU country to effectively sell citizenship - until 29 April 2025, when the Court of Justice of the European Union ruled in Case C-181/23. The court ruled that Malta's "golden passport" scheme is contrary to EU law, since Union citizenship cannot be the result of a commercial transaction without a real connection with the state. After this decision, Malta's classic investment program was effectively terminated.
The conclusion is simple and important: in 2026, no EU country will sell passports “for money” legally and quickly. The only way left is real naturalization after years of living in the country. Next we will look at how this works in Cyprus and Malta, and where this path is shorter and more logical.
Judgment of the European Court of Justice against Malta: what happened on April 29, 2025
This is a turning point for the entire investment migration industry, and it needs to be understood accurately, without exaggeration and without hushing up.
The European Commission has been conducting infringement proceedings against Malta for several years - infringement. The subject was Malta's Citizenship for Exceptional Services through Direct Investment Program (known as MEIN, successor to the former IIP). On 29 April 2025, the Court of Justice of the European Union in Luxembourg ruled in case C-181/23 against Malta.
Key findings of the Court:
- EU citizenship is not a commodity. The acquisition of Union citizenship cannot be the result of a commercial transaction in exchange for a financial contribution without a real, genuine connection of the person with the country.
- Violation of the foundations of trust. The scheme undermines mutual trust between member states and devalues the essence of EU citizenship (Article 20 Treaty on the Functioning of the EU).
- Violation of the principle of loyal cooperation. Malta was found to be in breach of the duty of good faith (Article 4(3) EC Treaty).
Bottom line: Malta must stop selling citizenship by investment in its current form. The MEIN program in investment format has been stopped. As a replacement, the Maltese authorities announced a narrow procedure of “citizenship for merit” (by merit) - but this is no longer the purchase of a passport, but an exception for people with an outstanding contribution to the country or humanity. Previously made decisions on naturalization remain in force.
Cyprus today: naturalization only, no purchase
In Cyprus, there has been no direct purchase of citizenship for several years. Today, a Cypriot passport can be obtained in three ways: by naturalization after years of residence, by marriage to a citizen and by descent. There is no “put money in - get passport” thing left.
The basic logic of naturalization is as follows: the state observes a person for several years, verifies that he actually lives on the island, pays taxes, does not break the law, has learned Greek and integrated into society, and only then can he grant citizenship.
- Settlement qualification - according to the standard path, about 7 years of legal residence within the last decade (formulated as “8 out of 10”), and the last year must be continuous.
- Fast track - 4 years for highly qualified specialists at Greek level B1 or 5 years at A2.
- Language - compulsory exam in Greek, for the standard path level B1.
- Cyprus knowledge test - fundamentals of political and social reality, passing grade 60%.
Important: investments in Cyprus still work, but do not lead to a passport, but to resident status - residence permit and lifelong permanent residence. We describe in detail how naturalization works step by step in the guide about Cypriot citizenship by naturalization, and a general overview of all routes is in the material about Cypriot citizenship.
Malta today: residency exists, citizenship is banned by the EU
Following the decision of the Court of Justice of the EU, the Maltese passport-for-investment model no longer works. But this does not mean that Malta has closed to foreigners - it is just that investments now lead to a residence permit rather than citizenship.
The key tool is the Malta Permanent Residence Program (MPRP). This is a residence permit/permanent residence status, not a passport. Key parameters for 2026:
- Applicant's assets - at least 500,000 € (including 150,000 € in financial assets) or 650,000 € (including 75,000 €).
- Real Estate - rent from 14,000 € per year for 5 years or purchase from 375,000 € with retention for 5 years.
- Contributions - state fee, administrative fee and mandatory charitable donation from €2,000.
- Accommodation - there is no strict requirement for the number of days; the status is convenient for mobile people.
But MPRP is precisely residency. To get a Maltese passport, after receiving a residence permit, you need to undergo regular naturalization for long-term residence, as in any EU country: years of real life, impeccable reputation, integration. The fast investment corridor to citizenship that existed until 2025 no longer exists. Citizenship by merit is a rare exception for outstanding individuals and is not a replacement for the previous investor program.
Comparison table: Cyprus vs Malta in 2026
Let's collect the key differences between the two countries in one table. This is the framework for the solution - next we will analyze the most important lines in more detail.
| Parameter | Cyprus | Malta |
|---|---|---|
| EU membership | Yes | Yes |
| Schengen area | Not yet (target - 2026) | Yes, since 2007 |
| Citizenship by Investment | Canceled in 2020 | Discontinued after the ECJ 2025 decision |
| The real way to the passport | Naturalization by residence | Naturalization by residence |
| Naturalization period | ~7 years (4-5 for highly qualified) | Long-term residence, ~5+ years according to general rules |
| Language for citizenship | Greek, exam B1 | Knowledge of Maltese/English, integration |
| Investments give | Residence permit and lifelong permanent residence | Residence permit/permanent residence through MPRP |
| Real estate threshold (residency) | from €300,000 + VAT (permanent residence Reg 6.2) | purchase from 375,000 € or rent from 14,000 €/year |
| Climate and lifestyle | Large island, active business environment | Compact archipelago, English spoken |
The main conclusion from the table: in essence, the paths to a passport for both countries have now converged at one point - real naturalization. The differences are in speed, language, Schengen and lifestyle.
Conditions and real terms: where the EU passport is closer
Since the purchase is no longer necessary, the main practical question is where the real path to the passport is shorter and more predictable. Let's compare based on the most valuable resource - time.
Cyprus. The standard qualification is about 7 years of legal residence over the last decade. But there is a serious advantage: the 2024 reform introduced an accelerated path for highly qualified specialists of Cypriot companies - 4 years with a Greek B1 or 5 years with an A2. For families who have moved for work relocation to IT, fintech, shipping or consulting, this is a real window: an EU passport in 4-5 years instead of seven.
Malta. After stopping the investment program, general naturalization by residence remains. First - residency through MPRP, then years of real life on the islands and the standard citizenship procedure. The fast “investment” corridor of 1-3 years, which existed until 2025, no longer exists.
- If speed is important and there is specialized work - the accelerated naturalization of Cyprus looks more predictable.
- If Schengen is important at the residence stage - Malta is in Schengen now.
- If you need lifelong EU resident status without language - it is worth looking at Cyprus permanent residence Regulation 6.2.
In any case, we are talking about a project for years, not a deal for months. BRIDGES GLOBAL lawyers will help you choose a route for your specific situation.
An expert's view: typical misconceptions and how to count
Over the years of practice, we see the same mistakes in client expectations, and almost all of them come from the old era of “golden passports”. We'll sort them out so you don't waste time and money.
- “You can still buy a passport in Malta.” No. Following the decision of the Court of Justice of the European Union on April 29, 2025, the investment scheme was terminated. What remains is residency (MPRP) and the rare "merit citizenship" rather than purchasing a passport.
- “Cypriot permanent residence is almost citizenship.” No. Permanent residence in Cyprus is lifelong and convenient, but only real naturalization with years of residence and Greek language leads to a passport.
- “An EU passport means immediately Schengen.” Cyprus is still outside Schengen, and this needs to be included in travel plans, without confusing Schengen with freedom of movement within the EU.
- “You can keep your status from another country and accumulate time.” No. Both Cyprus and Malta look at real physical presence at the naturalization stage rather than status on paper.
a calculation always begins with one question: are you really ready to live in the country for several years. If yes, an EU passport is legally attainable. If not, it is wiser to focus on resident status and not create illusions about quick citizenship.
“Clients come with a question from a bygone era: where is it now cheaper to buy an EU passport - in Cyprus or Malta. I answer : nowhere. Cyprus closed citizenship by investment back in 2020, and on April 29, 2025, the EU Court of Justice recognized the Maltese scheme as contrary to Union law - citizenship can no longer be obtained as a commodity for a fee. This is not bad news, but a game changer. Today, the winner is not the one who is willing to pay more, but the one who competently builds a legal path: first residency, then years of real life in the country and naturalization. Therefore, I always start with a simple question - is the family really ready to live on the island for several years. If so, an EU passport is absolutely achievable: in Cyprus - through accelerated naturalization in 4-5 years for specialists with Greek, in Malta - through Schengen residency and subsequent citizenship. If not, it’s wiser to stick with lifelong resident status and not have any illusions about a quick passport.”
Taxes and lifestyle: what to consider when choosing an island
Tax logic and lifestyle are something that is worth looking at no less than the terms of citizenship, because you will have to live here for more than one year.
Both islands are established jurisdictions with developed infrastructure for foreign capital, a transparent banking system and regimes for new residents. The specific tax burden greatly depends on the structure of income, tax resident status and the presence of special regimes, so the exact figures are always calculated individually with a tax consultant - there is no universal “rate for everyone”.
What is important for choosing a lifestyle:
- Cyprus - a large island with an active business environment: IT, fintech, shipping and consulting are concentrated here, many international companies and, as a result, jobs for specialists. This also opens up an accelerated path to naturalization.
- Malta - a compact archipelago with an English-speaking environment, dense infrastructure and convenient logistics throughout Europe thanks to Schengen.
- Families - both islands have a developed system of international schools; in Malta it is easier because of English, in Cyprus there is a wider choice and more space.
Tax planning should be done before moving, and not after: the correctly chosen residence status and income structure affect both the burden and the speed of integration required for citizenship.
Who is Cyprus best suited for?
Cyprus is logical for those who are ready to really connect their lives with the island and want a more predictable path to a passport in terms of timing.
- Highly qualified professionals and their families - those who move to work for a Cypriot company in IT, fintech, shipping or consulting. For them, accelerated naturalization works in 4-5 years, and Greek is converted into speed.
- For those who need lifelong EU resident status without language - Cypriot permanent residence Regulation 6.2 gives indefinite status with a maintenance visit every two years, without residence and language requirements. More details in the material about Cyprus permanent residence.
- For entrepreneurs - those who want to do business in an active business environment with international companies around.
Let’s be about the disadvantage of Cyprus: the country is still outside Schengen, and Greek is required for citizenship. But if your goal is to actually live and work on the island, these barriers are worth it with a predictable route to an EU passport.
Who is Malta best suited for?
Malta remains attractive to a certain profile - it's just that the emphasis has now shifted from citizenship to residency and lifestyle.
- For those who care about Schengen now - Malta has been in the zone since 2007, and this eliminates the issue of border control when traveling around continental Europe.
- For English-speaking families - ubiquitous English removes the language barrier in everyday life, schools and during adaptation, which in Cyprus will have to be achieved through Greek.
- Mobile residents - MPRP does not require a strict number of days of presence, which is convenient for those who move a lot but want a European base.
An important fair disclaimer: the path to a Maltese passport after 2025 has become longer and only goes through ordinary naturalization by residence - there is no longer a fast investment corridor. Therefore, it is reasonable to consider Malta in 2026 primarily as a quality EU residence in Schengen, and citizenship as a long-term prospect for a real move. We provide a detailed comparison of the residence statuses of the two countries in the material about comparison of residency in Cyprus and Malta.
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Schengen, movement and passport power
One of the main practical issues is freedom of movement. And here there is a and important difference between the two countries.
Malta has been part of the Schengen area since 2007. This means that a Maltese residence permit, and especially a passport, provide the usual Schengen logic of movement across continental Europe without internal borders.
Cyprus remains a member of the EU, but is not yet part of Schengen. The country's authorities state 2026 as the target date for accession and report that technical preparations have been completed, but in practice accession has not yet taken place. This must be taken into account : Cypriot permanent residence in itself does not provide visa-free Schengen, and a Cypriot passport is full-fledged EU citizenship, but with a reservation about the current status of the country outside the Schengen zone.
It is important not to confuse the two concepts. Citizenship of any EU country, including Cyprus, gives the right to live, work and study freely in any EU country - this is the right of free movement within the Union, and it works independently of Schengen. Schengen refers to the lack of border controls at the internal borders of the zone. For most families, the difference is felt at the stage of travel: with Maltese status it has already been removed, with Cypriot status it depends on the progress of Cyprus’ entry into the zone.
Language and Integration: B1 Greek vs English Comfort
The language and integration barrier is what distinguishes citizenship from simple residence. And here the countries differ noticeably.
Cyprus. For naturalization, a Greek language exam is required - for the standard path level B1, for highly qualified specialists B1 for 4 years or A2 for 5 years. This is not a formality: Greek from scratch to B1 is really 1-2 years of preparation, which should be started in parallel with the accumulation of qualifications. Plus a separate test on knowledge of the history, culture and realities of Cyprus with a passing score of 60%.
Malta. The official languages are Maltese and English, and English is widely spoken. At the everyday level, a foreigner feels comfortable here almost immediately, without a language marathon. For naturalization, integration and connection with the country are assessed, and the English-speaking environment significantly facilitates daily life and family adaptation.
- Cyprus - the language threshold is higher (Greek), but there is an accelerated path in terms of deadlines.
- Malta - a comfortable English-speaking environment, but without a quick investment corridor to a passport.
For families with school-age children, this factor often turns out to be decisive: in Malta it is easier to integrate into English-language schools, in Cyprus you will have to rely on learning Greek.
Bottom line: how to choose between Cyprus and Malta in 2026
The main result sounds unusual to those who remember the era of “golden passports”: neither Cyprus nor Malta no longer sells EU citizenship for money. Cyprus closed the investment program in 2020, the Maltese scheme was stopped by a decision of the EU Court of Justice in 2025. There is only one path left - real naturalization after years of living in the country.
To briefly summarize the choice in practice:
- Need a predictable and relatively quick path to your passport - look at Cyprus with its accelerated naturalization in 4-5 years for highly qualified specialists, laying down the study of Greek.
- Schengen and the English-speaking environment are important already at the stage of residence - look at Malta, realizing that citizenship there now comes only through long-term naturalization.
- Requires lifelong EU resident status without language or residence - Cypriot permanent residence Regulation 6.2 solves this problem best.
Any of these routes is a project that lasts for years, where the result depends on a competent strategy from the first day. Current requirements and forms for Cyprus should always be checked on the official portal Ministry of Internal Affairs of Cyprus (gov.cy), and it is better to discuss the choice of country and route for your family and capital with a lawyer who will calculate the real terms in your situation.
- Cypriot permanent residence vs Cypriot citizenship: what to choose
- Cyprus Permanent Residency Law: Regulation 6(2)
- Northern Cyprus Citizenship (TRNC): what yes
- How much does Cyprus citizenship cost
- Cyprus permanent residence or Turkish residence permit: what to choose
- Investing in Cyprus real estate: guide
Frequently asked
Questions people ask before deciding
01Is it possible to buy citizenship of Cyprus or Malta by investment in 2026?
No. Cyprus closed its citizenship investment program in 2020. The Maltese “golden passport” scheme was declared by the EU Court of Justice to be contrary to Union law in a decision of April 29, 2025, and it was terminated. No country sells EU passports for money anymore. What remains is real naturalization through years of residence.
02What exactly did the EU Court of Justice decide in the case against Malta?
On 29 April 2025, the Court of Justice of the European Union ruled in Case C-181/23 that Malta's citizenship by investment program violates Union law. The court stated that EU citizenship cannot be the result of a commercial transaction without a real connection with the country, and ordered Malta to stop selling citizenship by investment in its previous form.
03Is there any other way to get a Maltese passport?
There is no more direct investment purchase. What remains is general naturalization by long-term residence: first residency, for example through the MPRP program, then years of real life on the islands and the standard citizenship procedure. There is also a narrow “citizenship for merit” (by merit) - but this is a rare exception for people with outstanding contributions, and not a replacement for the previous program.
04How many years do you need to live for Cypriot citizenship?
The standard route is about 7 years of legal residence within the last decade, with the last year being continuous. For highly qualified specialists of Cypriot companies, the qualification is reduced: 4 years at the Greek level B1 or 5 years at A2.
05Where can you really get an EU passport faster - in Cyprus or Malta?
All other things being equal, Cyprus looks more predictable thanks to accelerated naturalization in 4-5 years for highly qualified specialists. In Malta, after 2025 there is no rapid investment corridor; ordinary naturalization for long-term residence remains.
06Are Cyprus and Malta both in the Schengen area?
No. Malta has been a member of Schengen since 2007. Cyprus is a member of the EU, but is still outside the Schengen zone; The authorities declare 2026 as the target date for accession, but accession has not yet taken place. This should be taken into account when planning your trips.
07Does a Cypriot passport give freedom of movement within Europe if the country is outside Schengen?
Yes. Citizenship of any EU country, including Cyprus, gives the right to live, work and study freely in any country of the Union - this is the right of free movement within the EU, and it applies independently of Schengen. Schengen refers to the lack of border controls at the internal borders of the zone.
08Is a language required for citizenship of Cyprus and Malta?
In Cyprus, a Greek exam is required: B1 for the standard path, B1 or A2 for the accelerated path. Plus a test of knowledge of the realities of the country. In Malta, the official languages are Maltese and English, and English is spoken everywhere, which greatly facilitates integration.
09What is the MPRP in Malta and does it grant citizenship?
MPRP (Malta Permanent Residence Program) is a permanent residence program, that is, residence permit/permanent residence, not citizenship. It requires confirmation of assets, real estate (rent from 14,000 € per year or purchase from 375,000 €) and contributions. The MPRP itself does not lead to a passport - citizenship requires a separate long-term naturalization.
10Is it possible to obtain EU resident status without language and residence?
Yes, there is such an option in Cyprus - this is permanent residence under Regulation 6.2. The status is lifelong, supported by a visit to the island once every two years, and does not require knowledge of the language or permanent residence. But this is precisely residency; it is not equivalent to a passport.
11Is it possible to accumulate the period of naturalization while living in another country?
No. Both Cyprus and Malta at the naturalization stage evaluate the real physical presence in the country, tax residence and center of vital interests, and not just the presence of status on paper. A property owner who appears occasionally does not meet the citizenship requirements.
12What is more profitable from a tax point of view - Cyprus or Malta?
There is no universal answer: the tax burden depends on the structure of income, tax resident status and special regimes, therefore it is calculated individually with a tax consultant. Both islands are established jurisdictions with transparent systems and regimes for new residents; It's worth planning your taxes before moving.
Transparency
How this material was prepared
- Author
- Anna Kovalevskaya, head of Legal, BRIDGES
- Terms and costs last verified
- June 2026
- Sources
- official government authorities of the relevant country and state publications
- Methodology
- government minimum requirements are stated separately from due diligence charges, state fees, legal and banking costs
Sources and methodology
Figures, terms and timelines are checked against official sources as of June 2026. Link availability verified in August 2026. Third-party blogs and agent websites are not used as a source of programme terms.
- [1]Identità MaltaResidence, citizenship and documentsidentita.gov.mt
Methodology: tables and charts state government minimum investment requirements; due diligence charges, state fees, legal, banking and other costs are calculated separately and are not included in the minimum thresholds.
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