You can no longer buy Maltese citizenship. Malta’s investor route was ended by an Act that took effect on 24 July 2025, after the EU Court of Justice ruled against it on 29 April 2025. What Malta still offers is a permanent residence programme, which is not citizenship, and ordinary naturalisation after several years of genuine residence, which is discretionary. The Caribbean programmes of Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis and Saint Lucia still grant citizenship for a contribution, but they now face an EU request to phase out by 1 June 2028. So the Malta vs Caribbean citizenship question is no longer a choice between two ways to buy a passport. It is a choice between a real route to EU status that takes years and your presence, and a faster route to a non-EU passport whose value is being questioned.

What actually happened to Malta’s citizenship scheme?

In Commission v Malta (Case C-181/23), the Court of Justice held that granting nationality in exchange for predetermined payments, without a genuine link to the country, is incompatible with EU law. Malta then amended its Citizenship Act through Act XXI of 2025, in force on 24 July 2025, which removed the investor programme from the law.

The old terms are history, and any page still quoting them is out of date. They were a minimum direct investment of €600,000 after 36 months of residence or €750,000 after 12 months, a residential property of at least €700,000 or a lease of at least €16,000 a year, and a donation of at least €10,000, as Community Malta Agency’s own page still describes in archived form.

Existing Maltese citizens are not stripped of citizenship by the ruling, but nobody new can apply under that route. A replacement “merit” route exists, though Community Malta says it is not a programme, scheme or pathway, and it sets no price or investment level. Treat anyone selling it as a product with caution.

What can you still get from Malta?

Route	What it is	Citizenship?
Malta Permanent Residence Programme	Permanent residence for a fee, contribution and property commitment	No
Naturalisation on residence	Live in Malta for 12 months immediately before applying and four years in total in the preceding six	Possible, at the Minister’s discretion
Naturalisation on merit	Discretionary grant for exceptional services or contribution	Possible, no price
Descent or marriage	Registration for family of Maltese citizens	Yes, if you qualify

The residence route is real, but it is demanding. You must also be of good character, have adequate Maltese or English, and be a suitable citizen, with two sponsors who are Maltese citizens, and the final decision is the Minister’s. Residence means actually living there, which a permanent residence card alone does not supply.

What does the Malta residence programme cost?

The Malta Permanent Residence Programme is the investor option that survived. It gives permanent residence and Schengen travel, not a passport. The main costs are:

Item	Amount
Administrative fee, non-refundable	€50,000
Government contribution	€30,000 if buying, €60,000 if leasing
Donation to a Maltese NGO	€2,000
Each dependant	€10,000
Property	Purchase from €375,000, or lease from €14,000 a year, held for five years
Capital to show	€500,000 including €150,000 financial assets, or €650,000 including €75,000 financial assets

A purchase works out at about €457,000, roughly £387,000, before legal fees and dependants. A first year on a lease is around €126,000, about £106,800, plus continuing rent. Our guides to source of wealth and banking questions, the step-by-step process and family applications cover how these cases are handled, and our Malta country page gives the overview.

What do the Caribbean programmes offer?

The five programmes still grant citizenship for a contribution, usually with little or no residence requirement. Headline minimums for a single applicant in 2026, before due diligence, legal and government fees, are:

Programme	Minimum contribution	Approximate sterling
Dominica	US$200,000	About £151,500
Antigua and Barbuda	US$230,000	About £174,200
Grenada	US$235,000	About £178,000
Saint Lucia	US$240,000	About £181,800
St Kitts and Nevis	US$250,000	About £189,400

Our guide to choosing a Caribbean citizenship in 2026 and the Dominica citizenship guide compare them in detail.

Malta versus the Caribbean side by side

Feature	Malta in 2026	Caribbean programmes
Can you buy citizenship?	No	Yes, for a contribution
Entry cost	About £387,000 for permanent residence, which is not citizenship	From about £151,500 for citizenship
Time in the country	Years of genuine residence for naturalisation	Little or none required
Speed	Several years, discretionary	Typically months
EU citizenship rights	Yes, if naturalised	No
Schengen access	Permanent residence gives Schengen travel	Visa-free short stays, under review
Main risk	Long wait, discretionary decision, no price	EU phase-out request, visa changes
Pass to children	Through ordinary rules	Generally hereditary

How real is the EU pressure on the Caribbean?

It is real and moving quickly. The European Commission wrote to all five governments on 25 June 2026 asking them to phase out by 1 June 2028, relying on Regulation (EU) 2025/2441, which took effect on 30 December 2025 and makes running an investor citizenship scheme without a genuine link a ground for suspending visa-free access.

The latest news is from this week. According to IMI Daily’s report on Antigua, Prime Minister Gaston Browne said on 24 October that preliminary Cabinet discussions favoured suspending Antigua’s programme, with 12 November as the date to commit. No final decision has been made, and the other governments are consulting, so treat the situation as fluid. Our review of whether Caribbean citizenship is living on borrowed time sets out the full timeline, including the Commission’s next report due in December 2026.

A suspension of visa-free access would not cancel your citizenship or stop you applying for a Schengen visa, but it would change what the passport is worth. Vanuatu is the precedent.

What does it mean for UK investors?

UK nationals are third-country nationals in the EU, so the practical question is what each route gives you after you have it.

A Caribbean passport gives you a second nationality for security, mobility elsewhere and family planning. It does not give EU residence rights, and some governments are tightening against it. The UK has required a visa for Saint Lucian nationals since 5 March 2026 and for Dominicans since 2023, and Ireland introduced visa requirements for Saint Lucia and St Kitts and Nevis in June 2026, as our guide to shifting visa-free access for Caribbean passports explains.

Malta’s permanent residence gives you a European base and Schengen travel. It sits inside the EU, which matters for travel after the Entry/Exit System, as our guide on the Entry/Exit System for residency investors explains. It does not give you EU citizenship, and no EU country sells that. Portugal now needs ten years for most non-EU applicants, as our note on the ten-year citizenship rule sets out, and Greece and Italy take around seven and ten years.

How should you decide?

1. Be clear what the passport is for. If you need EU rights, no investment buys them quickly, and you will have to live in the country. If you want a second nationality for flexibility, a Caribbean passport can still serve that purpose.
2. Treat Schengen access as a risk, not a given. If visa-free Europe is your main reason for a Caribbean passport, the case is weaker than it was a year ago.
3. Expect heavier vetting. The EU wants stronger due diligence, so prepare a documented source of wealth early, as our guide to Caribbean citizenship background checks explains.
4. Check each programme’s direction. St Kitts and Nevis, for example, is moving towards a genuine-link model, as our notes on the 2026 overhaul and the biometrics process show.
5. Do not rush. Programmes can change quickly, but a rushed application to the wrong country is a bigger risk than a few weeks of research.
6. Use a regulated adviser. Our comparison of lawyers and consultants explains why.

What if EU access is the real goal?

A European residence permit gives you rights that do not depend on another country’s citizenship programme. Italy’s investor visa and the Greece Financially Independent Person visa suit those who can show a stake or income, and our comparisons of Golden Visa investment options and financially independent person visas set them out, alongside our overview of the best Golden Visa options in Europe. The difference between residency and citizenship by investment is worth understanding before you choose, and our note on second passport practicalities covers how people use a second nationality day to day. Many families now combine a European permit with a Caribbean passport, a pattern described in our review of second residency planning in 2026.

Frequently asked questions

Can you still buy Maltese citizenship?
No. Malta’s investor citizenship route ended on 24 July 2025 after the EU Court of Justice ruling of 29 April 2025. Anyone offering a Maltese passport for a fixed payment is describing a scheme that no longer exists.

Does the Malta Permanent Residence Programme lead to citizenship?
Not by itself. It grants permanent residence, and any citizenship would come through ordinary naturalisation, which needs years of genuine residence and is at the Minister’s discretion.

Are Caribbean citizenship programmes still open?
Yes, but they are under pressure. The EU has asked the five governments to phase out by 1 June 2028, and Antigua and Barbuda is reportedly leaning towards suspension, with no final decision yet.

Would a Schengen suspension cancel a Caribbean passport?
No. It would remove visa-free short stays in the Schengen Area for that nationality, but it would not revoke citizenship.

Which is better, Malta or the Caribbean?
It depends on what you need. Malta gives a route into the EU, but it takes time and presence. The Caribbean gives a faster second nationality with less presence, but with real regulatory risk.

If you are weighing a European base against a second passport, Coates Global’s immigration lawyers can compare the routes against your family, funds and travel pattern. Get in touch before you commit, because the right choice depends on what you need your status to do.