The European Commission has dramatically intensified its stance against Caribbean Citizenship-by-Investment (CBI) programs, declaring that the mere operation of such schemes now constitutes legitimate grounds for suspending visa-free access to the Schengen area. This hardened position emerges from the Commission’s 8th annual Visa Suspension Mechanism assessment, which represents a fundamental shift in policy rationale.
Rather than focusing on whether investors establish ‘genuine links’ to host nations, Brussels now categorizes all investor citizenship programs operated by visa-exempt countries as inherent security threats. The report explicitly identified five Eastern Caribbean nations—Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia—as presenting challenges of ‘much greater scale’ than European neighboring countries with similar programs.
These nations have collectively issued over 100,000 passports through CBI arrangements, maintaining robust demand with 13,113 applications in 2023 and 10,573 in 2024. The Commission raised serious concerns regarding security vetting procedures, highlighting remarkably low rejection rates: Antigua and Barbuda refused just 1.7% of applicants in 2024, while Saint Lucia and Dominica rejected 5.3% and 6.5% respectively.
Despite acknowledging recent reforms including standardized minimum investment thresholds of $200,000 and enhanced screening protocols, Brussels concluded that substantial risks persist. In formal recommendations, the Commission urged these nations to strengthen vetting procedures ‘pending the discontinuation’ of their programs—language suggesting the EU ultimately envisages complete termination of Caribbean CBI schemes.
The revised mechanism establishes that non-compliance could trigger suspension of visa-free travel privileges, mirroring measures already implemented against Georgia. The EU previously announced plans to suspend visa-free access for holders of Georgian diplomatic, service, and official passports by December’s end, with broader restrictions possible if concerns remain unaddressed.
The Commission emphasized that countries must demonstrate ‘without delay’ measurable progress to avoid formal suspension procedures. The report further reinforced that EU candidate countries must completely abolish investor citizenship programs, following an April 2025 European Court of Justice ruling that found Malta in violation of EU law for operating a CBI scheme, establishing that member states cannot offer naturalization through transactional procedures.
