Refusals of Vanuatu Citizenship: The Trend in 2021-2026

For many years the main criticism of Vanuatu was the absence of refusals. The criticism was well founded: according to the European Commission, by the end of 2020 the country's authorities had rejected exactly one application in the entire life of the programme. The picture has since changed, and changed quickly.

We analyse the trend from the official figures, explain how the checks work and show where exactly cases stall today. This is not statistics for their own sake: understanding what is checked and how directly determines whether a case goes through or comes back with a request.

In short: how strictness has changed

• Before 2020 — one rejected application in the programme's entire history.
• 2021 — 4 refusals out of 1,072 applications, or 0.37 per cent.
• 2022 — 5 refusals out of 872 applications, 0.57 per cent.
• 2023 — 22 refusals out of 1,113 applications, almost 2 per cent.
• A multiple increase in two years, and the trend continues.
• The main reason for rejection is the source of funds, not criminal records.

The refusal trend by year

In absolute numbers there are still few refusals. What matters, though, is not the absolute figure but the speed of change: in two years the indicator rose more than fivefold. For a programme criticised for years for the formality of its checks, that is a fundamental change of approach.

How the check works now

The key change is not in the number of refusals but in where the decision is actually made.

Previously an application went to the Citizenship Commission, and the check was largely formal. Now the case first goes to Vanuatu's financial intelligence unit, and it is there that the background and origin of funds are assessed. The Commission receives a case that has already been checked, and decides quickly — which, incidentally, is where the programme's overall speed comes from.

The practical consequence: a weak case is stopped at the first stage, before it reaches the Commission, and often does not even appear in the official refusal statistics. Real strictness is higher than the figure shows.

We covered the mechanics of each stage in detail in the article on due diligence for Vanuatu citizenship.

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Where cases stall

The distribution of causes from our case practice.

Note the right-hand column: almost everything that leads to rejection can be closed by preparation. A refusal on the merits — where a person simply does not qualify — is rare. Far more often a case stalls because it was not prepared.

The specific grounds for rejection are analysed in reasons for refusal of Vanuatu citizenship, and cases involving a criminal record or a previous refusal by another programme in a separate article on Vanuatu citizenship with a criminal record.

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Why the source of funds has become decisive

The shift of focus to the origin of money happened not in Vanuatu alone but across the whole investment citizenship market. The cause is external: the requirements of international anti-money-laundering standards.

What this means in practice: what is checked is not the balance in the account but the path by which the money got there. A statement showing the sum proves nothing — a chain is needed: where the income came from, which contracts, which taxes were paid, how the funds moved between accounts.

The typical mistake looks like this: an applicant brings a bank certificate showing two hundred thousand dollars and considers the matter closed. A request arrives: what evidences the origin of this sum? Documents are then gathered after the fact, and the case drags on for months. The right order is the reverse — the chain is assembled before filing.

What a correct pack looks like is covered in the article on documents for Vanuatu citizenship.

What a reviewer's request looks like

Between "approved" and "refused" there is an intermediate stage that is rarely written about: the additional request. Formally it is not a refusal, but it is what stretches the timeline, and it is what most rejections grow out of.

A typical request reads: confirm the origin of the sum received into the account on such-and-such a date; explain the discrepancy in the spelling of the surname between the passport and the birth certificate; provide documents on the company whose stake was sold. The time to reply is limited, and while it runs the case stands still.

In our practice a correctly prepared case goes through without a single request. Each additional request adds two weeks to a month and a half to the timeline.

What to do after a refusal

A refusal does not always close the road. What to do next depends on the ground.

• Incomplete documents. The most common case and the most solvable: the case is rebuilt and filed again with the gaps closed.
• Questions about the source of funds. Solvable if the origin of the money can in principle be evidenced. A full pack covering the chain is needed, not an additional certificate.
• A criminal record. Depends on the offence and how long ago it was. Such situations are analysed in the article on Vanuatu citizenship with a criminal record.
• Sanctions restrictions. There are no prospects, and it is better to hear that at once than after the contribution has been paid.

A separate warning about a common mistake: applying to another programme immediately after a refusal. A refusal under one programme is recorded, and the next application form asks about it. Concealing that fact turns a solvable situation into an unsolvable one.

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What the financial intelligence unit asks about

To show what the check looks like from the inside, here are typical requests that arrive on cases. The wording is generalised; no case specifics are disclosed.

Note that none of the typical requests concerns the applicant as a person. They are all about documents. That is why a fully assembled case goes through without requests, while a partially assembled one receives them in batches and drags on for months.

Where the indicator goes next

Our estimate: the refusal rate will rise to three to four per cent within two years. Three reasons.

• Biometrics. Since November 2025 applicants' data pass through a biometric system, which makes checks against international databases complete.
• External requirements. Pressure on investment citizenship programmes is growing overall, and Vanuatu is responding by tightening rather than relaxing.
• Experience. The reviewers have built up practice and now recognise schemes that used to pass.

There is one practical conclusion for an applicant: requirements will keep rising, and a case that passes today may need twice as much evidence a year from now. A detailed outlook for the programme as a whole is in the outlook for Vanuatu's programme to 2028.

Reasons for refusal →How applicants are checked →

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