Residence without a passport: why countries are separating investor residence from citizenship

In brief

• Residence through investment less and less often leads to citizenship automatically. Countries either lengthen the route or close it to investors altogether.
• The clearest example is the Turks and Caicos: from 1 December 2026 an investor receives a 25-year permit, and its holders are expressly excluded from permanent residence.
• In the EU the same shift is gentler: Portugal has lengthened the route to citizenship to 10 years, Spain and Latvia have closed residence through property, and Greece is tightening control.
• Citizenship by investment programmes continue to operate, but they too are under pressure, above all in the Caribbean.
• My conclusion: choose by clearly separating two goals, the right to live in a country and a second passport. They are often best served by different instruments.

What is happening: the facts of recent months

For a long time the logic of investment migration was simple: invest money, get residence, live there for five years, apply for citizenship. The golden visas of Portugal, Spain, Greece and Latvia were sold exactly like that, and for many investors residence was the first step towards a European passport. Over the past year and a half this ladder has started to come apart piece by piece. Below are the events that, in my view, matter for understanding the direction.

Individually, each event has local causes: the housing crisis in Spain and Portugal, political scandals in Latvia, the budget in Malta, pressure on jobs in the Turks and Caicos. But together they show a common trend. States want investors' money but do not want money to turn automatically into citizenship. The right to live is becoming a product, and citizenship a separate reward for real life in the country, language and time.

What this means for you. If you are buying residence with a future passport in mind, check whether the programme leads to citizenship now and on what terms. Promises made five years ago may no longer apply.

Turks and Caicos: the pure model of "the right to live without a passport"

The clearest case is the British territory of the Turks and Caicos. Previously an investor bought a home from USD 300,000 on the smaller islands or USD 1 million on Providenciales, received an indefinite Permanent Residence Certificate and after a year could apply for British Overseas Territories citizenship with five years of residence. The new Immigration Act 2026 replaces the certificate with a renewable 25-year permit, and its holders are expressly excluded from permanent residence. Details are in our news story on the Turks and Caicos law.

The immigration minister explained the logic plainly: citizenship is not for sale. It is an important formulation. The islands are not turning away investors: they still need money and villa buyers. They are refusing to let money buy status. A similar model has long operated in the neighbouring Cayman Islands. I think it will become a template for small jurisdictions that value their passport.

What this means for you. If you need a home on the islands and the right to live there for long periods, the Turks and Caicos still work. If you need a passport, this route is closed, and you should look at citizenship programmes.

Europe: the route remains but grows longer and more expensive

In the EU the shift is gentler, but in the same direction. Since 19 May 2026 Portugal has required 10 years of lawful residence before citizenship for most non-EU nationals instead of five; for EU and Portuguese-speaking countries' citizens, 7 years. Portugal's golden visa through funds still works, but it is now a route to a passport over a decade rather than five years; see the article on naturalisation in Portugal and our news story on the citizenship backlog.

Spain abolished its golden visa through property in April 2025. From 15 September 2026 Latvia closed residence through property and bank investments, and on 26 October began checking permits issued through companies; see our stories on Latvia's new law and the residence permit check. Greece keeps its golden visa, but the migration minister promised to revoke it over hidden rebates and nightly lets, and the government has proposed a 15% tax for non-EU buyers; see the story on revocations and the story on the 15% tax. Malta has made life without long-term status more expensive; see the story on Malta's budget.

Cyprus stands apart. Its citizenship by investment programme was closed in 2020, and it is now reportedly preparing to tighten permanent residence before joining Schengen; see the story on the review of Cyprus golden visas. On 15 October the appeal court barred passing citizenship by registration to a new spouse; see the story on the ruling. We reviewed European programmes this autumn in our piece on EU golden visas in autumn 2026.

What this means for you. EU golden visas are not disappearing, but they are becoming what they were originally meant to be: the right to live in a country. A European passport through them now requires 7-10 years of real life and language.

Three scenarios

I do not presume to predict the decisions of individual governments. But the direction makes it possible to describe three scenarios for how the market will develop over the next few years. Most likely, different scenarios will play out in different countries, and that is normal: what matters is understanding which logic the programme you choose follows.

The first scenario, long residence without a passport, has already been implemented in the Turks and Caicos. I expect other small jurisdictions with expensive property and strong local demand to protect citizenship to follow. The second scenario, a longer route, has already been implemented in Portugal. In the EU, in my assessment, it will be the main one: Europe needs investors, but countries want citizenship to go to those who really live there. The third scenario, closing passive investments, has already happened in Spain and Latvia and will probably affect other countries where housing is rising faster than wages.

What this means for you. When choosing a programme, ask yourself which of the three logics it follows and how likely the logic is to change in 3-5 years. That matters more than the investment amount today.

What about citizenship programmes

Citizenship by investment programmes continue to operate: Vanuatu, Turkey, Saint Kitts and Nevis, Grenada and others. They give a passport straight away, without years of residence. But pressure is growing here too. The EU is demanding that five Caribbean countries wind down their programmes by 2028 and is threatening Schengen visa-free access; Antigua is discussing a pause; see my analysis of Caribbean passports under EU pressure. Why some countries sell citizenship and how sustainable it is, I examined in the piece on why countries sell passports.

An important practical conclusion follows. If your goal is a second passport, citizenship programmes remain the fastest route, but they should be chosen with visa-free risks and tightening residence requirements in the region in mind. If your goal is to live in Europe, EU residence works, but the route to a passport through it has become long. It often makes sense to combine two instruments: for example, a Vanuatu passport and Greek residence through it. The fastest passport options are compared in the article on the fastest second citizenship.

What this means for you. Do not expect from residence what only a citizenship programme gives, and vice versa. A passport and the right to live are different products, and the market is separating them ever more clearly.

What I advise investors now

First: separate your goals. Write down what you need: the right to live in a specific country, freedom of travel, a back-up passport for the family, tax residence, children's education. For the right to live, residence and permanent residence work: Greece, Cyprus, Hungary, Portugal, the UAE. For a passport, citizenship programmes. I described how to choose in general in the article on choosing a programme.

Second: check not only the amount but also the route. Does the programme lead to permanent residence and citizenship, after how many years, with what residence and language requirements, and how has this changed in recent years? Presence requirements by country are collected in the guide to presence requirements. Third: apply before the changes if you have decided. Almost all of this year's reforms protected those who filed before the effective date: this was the case in Portugal, Latvia and the Turks and Caicos.

Fourth: prepare source of funds documents in advance. The stricter the market, the more attention to the origin of funds: it is the key document in almost any programme. The procedure is described in the source of funds guide. Fifth: think about the family. Rules on passing status to children and spouses are also tightening, and the Cypriot ruling is a good example; the general approach is in the guide to citizenship for the family.

What to watch in the coming months

In November - December 2026 several events are worth watching. 12 November: the deadline for Antigua and Barbuda's reply to the European Commission on the future of its citizenship programme. 1 December: the target commencement date of the Turks and Caicos law. December: the Commission's report on the visa suspension mechanism. In Greece: the fate of the 15% tax for non-EU buyers and the practice of revoking permits. In Cyprus: the draft tightening of permanent residence before Schengen. We will cover each event in our news and update this analysis.

How we prepare our analysis and which sources we use is described in our methodology. All residence programmes are on the residence page, and citizenship programmes on the citizenship page. The terms permanent residence and citizenship by investment are explained in the glossary. We covered the UK dropping its investor visa in our news story on the UK budget. To discuss your situation, book an online consultation; all BRIDGES services are on the home page.

How this article was prepared

This analysis is based on laws and official statements covered in BRIDGES news: Portugal's citizenship law (Organic Law No. 1/2026, in force since 19 May 2026), Latvia's Immigration Law (in force since 15 September 2026), Spain's law abolishing the investor visa through property (in force since 3 April 2025), the Turks and Caicos Immigration Act 2026, Malta's 2027 budget, the Cyprus Legal Service statement on the appeal court ruling of 15 October 2026, and statements by Greece's migration minister. The scenarios and conclusions are my assessment as Managing Partner of BRIDGES, not a forecast of government decisions. This article does not replace a consultation.