Residency by Investment vs Citizenship by Investment: The 2026 Guide
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Residency by Investment vs Citizenship by Investment: The 2026 Guide
Residency vs citizenship by investment comes down to one distinction: residency by investment buys the right to live in a country, while citizenship by investment buys its nationality and passport. In the EU, formal citizenship by investment schemes have closed, so European programmes now sell residence. Turkey still grants citizenship for investment, and a second citizenship can cost you your first.
This guide is general information about residence and citizenship by investment and is not legal, tax or immigration advice. It gives no advice on any home country’s citizenship law. Programme rules, thresholds and nationality laws change. Obtain independent professional advice, including from a lawyer qualified in your home country, before making any application or investment decision.
On this page
- What is the difference?
- What is citizenship by investment?
- Why the EU’s golden passport schemes closed
- Residency by investment in Europe: the programmes that remain
- Citizenship by investment: Turkey
- From residence to citizenship: how long it really takes
- When a second citizenship costs you your first
- Does a second passport help with a US E-2 visa?
- Which fits you: residence or citizenship?
- Frequently asked questions
- The bottom line
What is the difference between residency and citizenship by investment?
Residency by investment gives you a residence permit: the legal right to live in a country, renewable or permanent depending on the programme. Citizenship by investment gives you the country’s nationality and, with it, a passport and a vote. Holding residence does not change your existing citizenship. Acquiring a new citizenship can, depending on your home country’s law.
The two concepts side by side:
| Residency by investment (RBI) | Citizenship by investment (CBI) | |
|---|---|---|
| What you receive | A residence permit (temporary or permanent) | Nationality, a passport and the rights of a citizen |
| Vote and passport | No | Yes |
| Effect on your existing citizenship | None triggered by holding residence alone | Depends on your home country’s law (see the home-country table below) |
| Can it be taken away? | Depends on each programme’s permit rules | In Turkey, citizenship obtained by a false statement can be annulled |
| Route to citizenship | Ordinary naturalisation after years of residence | A grant by the state, at its discretion |
That last row is the one most people miss. Residence programmes can lead to citizenship, but only through ordinary naturalisation, on the host country’s clock and conditions. Nobody buys the passport directly.
What is citizenship by investment?
Citizenship by investment is a legal route under which a state grants its nationality to a foreign investor who makes a qualifying investment. Turkey is the working example, and within the countries we cover it is the only one left.
The legal mechanism is precise. Under Turkish Citizenship Law 5901, art. 12(1)(b), the President may grant citizenship to holders of an investor residence permit (Law 6458, art. 31(1)(j)), together with their foreign spouse and their minor or dependent children. Note the verb: may. Meeting the investment criteria gives no absolute right to citizenship (Law 5901, art. 10(1)). Where there is a national security or public order obstacle, the law requires refusal (art. 12(2)). Citizenship obtained through a false statement can be annulled (art. 31), and the annulment also reaches a spouse and children who acquired citizenship through the same grant (art. 32).
Two further points shape the decision. Turkey permits multiple citizenship, and its Citizenship Regulation (art. 20(3)) asks for no renunciation document. And Turkey publishes no official processing time, so any fixed timeline you are quoted is an estimate, not a legal deadline.
Why the EU’s golden passport schemes closed
Three EU member states in our coverage ran citizenship by investment schemes. All three formal schemes have now closed, one after another.
- Cyprus, 2020. Cyprus abolished its investment naturalisation scheme from 1 November 2020, by a Council of Ministers decision of 13 October 2020. See our Cyprus golden visa scandal explainer.
- Bulgaria, 2022. Bulgaria repealed its investor citizenship provisions (Bulgarian Citizenship Act, arts. 12a and 14a) by an act adopted on 24 March 2022 and promulgated in State Gazette No. 26 of 1 April 2022. See Bulgaria citizenship by investment.
- Malta, 2025. The Court of Justice of the European Union ruled against Malta’s investor naturalisation scheme in Case C-181/23, judgment of 29 April 2025 (press release No 52/25). Malta’s citizenship by investment scheme has closed. What Malta still offers investors is permanent residence under the MPRP, never a passport. See Malta citizenship by investment: why it closed.
Is there any EU citizenship by investment in 2026?
No formal scheme remains. Formal citizenship by investment schemes have closed across the EU, so for an investor the path to an EU passport now runs through ordinary naturalisation after years of legal residence. One qualifier matters: some EU states keep discretionary naturalisation for exceptional merit. That is a state honouring a person, not a product you can buy, and no investment amount qualifies you for it.
Residency by investment in Europe: the programmes that remain
These are the EU residence programmes in our coverage. Each grants residence, not nationality.
| Programme | Instrument | Minimum qualifying investment | Status granted |
|---|---|---|---|
| Malta MPRP | Property purchase or lease | EUR 375,000 purchase or EUR 14,000 a year lease, anywhere in Malta or Gozo, plus EUR 37,000 contribution, EUR 60,000 administrative fee and EUR 2,000 donation | Permanent residence |
| Greece golden visa | Real estate | EUR 250,000, 400,000 or 800,000 depending on the property’s location and type | Residence permit |
| Portugal ARI | Fund units, research or company | EUR 500,000 (fund, research, or company plus 5 jobs) | Residence permit |
| Hungary guest investor | Real estate fund units or donation | EUR 250,000 (MNB-registered real estate fund) or EUR 1,000,000 donation | Residence permit |
| Cyprus Reg 6(2) | Property plus income | EUR 300,000 plus VAT, with a secured annual income test | Permanent residence permit |
| Bulgaria art. 25 | Funds, concession, securities, projects, company capital | EUR 511,291.88 (fund units or concession) to EUR 3,067,751.29 (company capital) | Residence permit |
| Italy Investor Visa | Bonds, company, startup, donation | EUR 250,000 (innovative startup) to EUR 2,000,000 (government bonds) | Residence permit |
In more detail:
- Malta: the single EUR 375,000 / EUR 14,000 threshold applies from 1 January 2025 under Legal Notice 310 of 2024. Guide: Malta Permanent Residency Programme.
- Greece: thresholds follow the Law 5100/2024 zone regime; Law 5275/2026 did not change them. Guide: Greece golden visa through property.
- Portugal: the fund route means non-real-estate collective investment undertakings with at least five years to maturity and at least 60% invested in Portuguese companies. Guide: Portugal golden visa investment funds.
- Hungary: the direct property route was abolished with effect from 30 December 2024. Guide: Hungary’s guest investor programme.
- Cyprus: secured income of EUR 50,000, plus EUR 15,000 for a spouse and EUR 10,000 per dependent minor child, with funds transferred from abroad. Guide: Cyprus permanent residency by investment.
- Bulgaria: the law states amounts in leva, read here at the fixed 1.95583 euro rate; listed shares or bonds, or a certified priority project, need EUR 1,022,583.76. Guide: Bulgaria golden visa.
- Italy: TUI art. 26-bis. The EUR 500,000 option covers an Italian company or, since 18 December 2024, an Italian venture capital fund; a EUR 1,000,000 donation route also exists. There is no real estate route.
Citizenship by investment: Turkey
Turkey sits in its own table because it sells a different thing. These are routes to Turkish nationality, not to residence, and Turkey is outside the EU.
| Route | Amount | Hold |
|---|---|---|
| Real estate | USD 400,000 | 3-year no-sale annotation on the title |
| Bank deposit | USD 500,000 | 3 years |
| Government debt instruments | USD 500,000 | 3 years |
| Real estate or venture capital investment fund units | USD 500,000 | 3 years |
| Private pension | USD 500,000 | 3 years in the system |
| Fixed capital investment | USD 500,000 | Attested by the Ministry of Industry and Technology |
| Employment | 50 jobs | Attested by the Ministry of Labour and Social Security |
The USD 400,000 real estate threshold applies from 13 June 2022 (Presidential Decision 5554, published 13 May 2022). Three practical consequences follow for anyone weighing Turkey against a European residence route:
- Travel. Turkey is not in the Schengen Area, and Turkish nationals need a Schengen visa. According to the Henley Passport Index, the Turkish passport gave access to 112 destinations in data read in September 2026, ranking 49th in 2026.
- Military service. Men naturalised at 22 or over in the year of naturalisation are deemed to have done Turkish military service; younger sons join the regular cohort, with a two-year deferral on request (Law 7179, art. 43(1)).
- Discretion. As above, the grant is never guaranteed.
Full detail: Turkey citizenship by investment and Turkish citizenship by real estate.
One family, two routes (minimum public amounts only)
A family of four: applicant, spouse and two children under 18.
Turkey, real estate route: one USD 400,000 qualifying purchase in the applicant’s own name covers all four. The Regulation (art. 20(2)) sets no extra amount per dependant, and purchases in a spouse’s name do not count.
Malta MPRP, purchase route: EUR 375,000 property plus EUR 99,000 in fixed charges (EUR 37,000 + 60,000 + 2,000; the spouse and minor children pay no dependant fee) = EUR 474,000, of which EUR 375,000 is property the family owns.
Taxes, fees and advisory costs are excluded. The outcomes differ: Turkish nationality versus Maltese permanent residence.
From residence to citizenship: how long it really takes
If a European passport is the long-term goal, the naturalisation clock is the number that matters, and it is longer than many marketing pages suggest. Three verified clocks:
- Portugal: 10 years. Under Organic Law 1/2026 (in force 19 May 2026), naturalisation needs 10 years of legal residence, or 7 for nationals of EU countries and countries with Portuguese as an official language, counted from the first residence card. Periods can be aggregated within 12 years (9 for the EU and Portuguese-speaking group). Only nationality procedures already pending on 19 May 2026 keep the old rules. Detail: Portugal golden visa to citizenship.
- Italy: 10 years of legal residence for non-EU nationals (Law 91/1992, art. 9). A June 2025 referendum proposing to cut this to five years failed for lack of quorum.
- Cyprus: about 8 years in practice, built from 12 continuous months plus 7 cumulative years within the preceding 10 (Law 149(I)/2023). Detail: Cyprus golden visa to citizenship.
For the other programmes, see each guide: how to get Hungarian citizenship, Hungary dual citizenship, the Malta Permanent Residency Programme, the Greece golden visa and the Bulgaria golden visa.
When a second citizenship costs you your first
Turkey allows dual citizenship. Your home country may not. This is the question to settle before any citizenship application, because the rule that bites is your home country’s, not the issuing state’s.
| Country | What happens if you acquire another citizenship | Law |
|---|---|---|
| India | Voluntary acquisition of another citizenship ends Indian citizenship on acquisition. OCI is a registration for foreign nationals, not dual citizenship | Citizenship Act 1955, s.9(1) |
| Pakistan | Pakistani citizenship ceases unless the other nationality is renounced, with exceptions including the countries on the official dual nationality list. Turkey is not on the list; Italy is; Malta, Cyprus, Greece, Portugal and Hungary are not | Citizenship Act 1951, s.14(1); DGI&P list, last modified 9 January 2026 |
| China | No dual nationality. A citizen settled abroad who voluntarily acquires a foreign nationality loses Chinese nationality automatically | Nationality Law, arts. 3 and 9 |
| Nigeria | Citizens by birth may hold another citizenship. A citizen by registration or naturalisation who acquires another citizenship (not held by birth) forfeits Nigerian citizenship at once | Constitution, s.28(1) |
| South Africa | The automatic loss rule was declared invalid from 6 October 1995 | Democratic Alliance v Minister of Home Affairs [2025] ZACC 8 (6 May 2025) |
| Vietnam | Acquiring a foreign nationality is not a ground for loss | Law on Vietnamese Nationality 2008, art. 26 (consolidated text as amended up to Law 79/2025, in force 1 July 2025) |
| Israel | Dual nationality is permitted | Nationality Law 1952, s.14 |
| Turkey (issuing state) | Turkey itself permits multiple citizenship | Citizenship Regulation, art. 20(3) |
Read the table as a map of risk, not as advice for your case. For India, confirm with a lawyer qualified in India. For Pakistan, the list is administrative and can change, so confirm with a lawyer qualified in Pakistan. For China, the statute speaks of a citizen “settled abroad”; the position of someone still living in mainland China is not settled, so confirm with PRC counsel. For Nigeria, how you hold your citizenship decides the answer, so confirm with a lawyer qualified in Nigeria. For South Africa, the table states the legal consequence of the judgment; how the Department of Home Affairs applies it in practice is a question for a lawyer qualified in South Africa. For Vietnam and Israel, confirm with a lawyer qualified in each country.
Residence alone does not trigger these rules. Later naturalisation in an EU country can.
Does a second passport help with a US E-2 visa?
Only with a condition. Turkey has an E-2 treaty investor agreement with the United States in force since 18 May 1990 (9 FAM 402.9). But a 2022 change to US law added a rule for investment citizens: since 23 December 2022, a national who acquired the nationality through a financial investment must have been domiciled in the treaty country for a continuous period of not less than three years at any point before applying, unless previously granted E status (INA 101(a)(15)(E)).
In plain terms: a new Turkish passport does not by itself open the E-2 route. Three continuous years of living in Turkey, at some point before you apply, do. Consult US immigration counsel on your own facts.
Which fits you: residence or citizenship?
Work from what you need, not from what is on sale.
- You want a base in the EU without changing nationality. Residence is the answer. Every European programme in the RBI table gives you a permit and leaves your passport alone.
- You want a second nationality, and your home country allows dual citizenship. Within the countries we cover, citizenship by investment now means Turkey, which is outside the EU and the Schengen Area.
- Your home country ends your citizenship when you naturalise elsewhere. Residence keeps your existing passport. Naturalisation, in any country, is the step to check with a lawyer first.
- You want an EU passport eventually. Plan for ordinary naturalisation: 10 years in Portugal or Italy, about 8 in practice in Cyprus.
Frequently asked questions
What is the difference between residency and citizenship by investment?
Residency by investment gives you a residence permit, the right to live in a country. Citizenship by investment gives you that country’s nationality and passport. Holding residence alone does not change your existing citizenship; acquiring a second citizenship may, depending on your home country’s law.
Can you still buy EU citizenship in 2026?
No formal scheme remains. Cyprus closed its scheme from 1 November 2020, Bulgaria repealed its provisions in 2022, and Malta’s scheme closed after the EU Court of Justice ruling in Case C-181/23 (2025). Some EU states keep discretionary naturalisation for exceptional merit, but citizenship otherwise comes through ordinary naturalisation.
Which countries still offer citizenship by investment?
Within the countries Aegir covers, Turkey. It grants citizenship for a USD 400,000 real estate purchase or USD 500,000 financial routes, at the President’s discretion. The EU’s formal schemes have closed, and the European programmes on this page sell residence only.
Can I have dual citizenship through investment?
Turkey allows multiple citizenship, so the question is your home country’s law. India and Pakistan end citizenship on acquiring another (Pakistan with listed exceptions). South Africa, Vietnam and Nigeria for citizens by birth allow you to keep it. Confirm with a lawyer qualified in your home country.
Does a golden visa lead to citizenship?
Only through ordinary naturalisation. Portugal requires 10 years of legal residence from the first residence card (7 for EU and Portuguese-speaking countries), Italy 10 years, and Cyprus about 8 years in practice. No European residence programme sells a passport.
Is Turkey a golden visa?
No. A golden visa grants residence. Turkey grants citizenship for investment, which is a different product, and Turkey is outside both the EU and the Schengen Area. That is why it never shares a table with the European residence programmes on this page.
Does Turkish citizenship qualify me for a US E-2 visa?
Not on its own. Since 23 December 2022, someone who gained a treaty nationality through a financial investment must have been domiciled in that country for at least three continuous years at any point before applying, unless previously granted E status. Consult US immigration counsel.
The bottom line
Money can still buy you the right to live in Europe. It can no longer buy you a European passport through any formal scheme. If residence is what you need, compare the programmes above, starting with how much a golden visa costs; US citizens should also read our golden visa for US citizens guide. If a second nationality is the goal, Turkey is the investment route in our coverage, and your home country’s nationality law is the first thing to check, before any money moves.
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