Malta just closed the door on its citizenship-by-investment program. The European Court of Justice ruled in April 2025 that Malta’s MEIN scheme violated EU law, officially ending what many considered the last direct route to EU citizenship through investment.
But here’s what most people don’t realize: this actually creates new opportunities for savvy investors.
With Malta’s citizenship program gone, three residency-by-investment programs now dominate the European landscape. The Malta Permanent Residence Programme (MPRP), Portugal’s reformed Golden Visa, and Greece’s property-focused program each offer distinct advantages.
The question isn’t which program is “best”—it’s which one aligns with your specific goals, budget, and timeline.
Why Malta’s MPRP Gained Prominence After the CBI Closure
Malta’s permanent residence program wasn’t just a consolation prize after the citizenship route closed. It was always there, quietly offering something many investors actually preferred: immediate residency rights with lower financial commitments.
The MPRP grants permanent residence status from day one. No waiting periods, no temporary permits that might not renew. You get Schengen mobility, family reunification rights, and access to Malta’s English-speaking, common-law environment.
What makes this particularly attractive now is Malta’s response to the EU ruling. The government has doubled down on compliance, making the MPRP one of the most legally secure residency programs in Europe. When EU regulators scrutinize investment migration programs, Malta’s residency route consistently passes muster.
The due diligence process is rigorous—sometimes frustratingly so. But that’s actually a feature, not a bug. Malta’s stringent vetting means your residency status carries weight with banks, business partners, and other EU governments.
For comprehensive details about the MPRP (Malta Permanent Residence Program), including current investment thresholds and documentation requirements, specialized advisors can provide the most up-to-date information since these details change via legal notices.
Portugal’s Post-2023 Reality: Funds Over Property
Portugal’s Golden Visa transformed dramatically in 2023. The real estate route that attracted thousands of investors? Gone. The coastal properties in Lisbon and Porto that defined the program? No longer eligible.
What remains is a fund-based investment system starting around €500,000. These aren’t just any funds—they must meet specific regulatory criteria, focusing on Portuguese businesses, startups, or cultural projects.
Here’s what this change means in practice: Portugal’s Golden Visa became more complex but potentially more rewarding. Fund investments can generate returns, unlike the pure real estate plays that dominated before 2023. Some investors are seeing better financial outcomes through carefully selected Portuguese private equity funds than they ever would have through Lisbon apartments.
The processing timeline tells a different story. Portugal’s AIMA (formerly SEF) has struggled with backlogs that can extend applications well beyond the official timeframes. Where Malta processes MPRP applications in months, Portuguese Golden Visa applicants often wait over a year.
Portugal’s five-year path to citizenship remains attractive, but it requires genuine ties. The minimal stay requirements for maintaining the Golden Visa don’t automatically translate to citizenship eligibility. Language requirements, tax residency considerations, and proof of integration all factor into naturalization success.
Greece’s Property-Led Approach: Regional Variations Matter
Greece maintained its property-focused Golden Visa model, but recent changes created a two-tier system. High-demand areas like Athens, Thessaloniki, and popular islands now require significantly higher investments—sometimes double the base threshold.
This regional approach reflects Greece’s attempt to balance investor interest with local housing concerns. Areas experiencing gentrification pressure got higher thresholds, while regions seeking development maintained lower entry points.
Greece’s processing efficiency often surprises first-time applicants. Once property acquisition completes and documentation is submitted, residence permits typically issue within months. Regional variations exist, but Greek authorities have streamlined their systems considerably compared to pre-2020 procedures.
The property maintenance requirement creates ongoing obligations that some investors overlook. Unlike Malta’s MPRP, which allows rental options, Greece’s Golden Visa ties you to specific real estate. Property taxes, maintenance costs, and market risks become permanent considerations.
Greece’s seven-year naturalization path requires actual residence, not just permit possession. Golden Visa holders who spend minimal time in Greece find citizenship applications challenging, regardless of their investment size.
Investment Requirements: Real Numbers, Real Differences
Malta’s MPRP involves multiple components: government contributions, administrative fees, real estate (purchase or rental), and charitable donations. The total typically falls between the Portugal fund minimums and Greece’s elevated property thresholds, but exact figures vary based on chosen options and current legal notices.
Portugal’s fund route starts around €500,000, but successful investments require careful selection. Not all qualifying funds offer the same risk-return profiles, and some have struggled to meet regulatory requirements. Due diligence on fund managers becomes crucial for protecting both your residency application and investment returns.
Greece’s regional pricing creates wide variations. Prime Athens locations might require double the investment of northern Greek properties, but appreciation potential and rental yields differ dramatically. Location selection in Greece involves both residency strategy and investment analysis.
Processing Times and Approval Predictability
Malta’s MPRP timeline depends heavily on document preparation and due diligence complexity. Straightforward applications with complete documentation often process within months. Complex wealth sources or multiple jurisdictions can extend timelines, but Malta’s structured approach provides clear expectations.
Portugal’s backlog situation improved through 2024, but processing times remain unpredictable. Fund-based applications sometimes move faster than expected, while others stall in administrative review. The lack of clear timeline guarantees frustrates many applicants.
Greece typically offers the fastest processing once property acquisition completes. Regional offices vary, but most residence permits issue within six months of complete application submission.
Family Inclusion and Long-Term Considerations
All three programs accommodate families, but definitions and age limits differ. Malta’s comprehensive family coverage under permanent residence status provides stability that temporary permits cannot match.
Portugal and Greece both allow dependent inclusion, but age restrictions and proof requirements vary. Adult children face particular challenges in maintaining dependent status as family circumstances change.
For detailed comparisons, investors often find it helpful to compare the Portugal and Greece Golden Visas directly, as these two programs share more similarities than either does with Malta’s permanent residence approach.
Tax Implications: Beyond Residency Status
None of these programs automatically create tax residency. Malta’s remittance basis system, Portugal’s reformed post-NHR landscape, and Greece’s optional non-dom regime all require separate analysis with qualified advisors.
Malta’s approach often suits investors seeking flexible tax planning. The remittance basis allows non-resident treatment of foreign income, while various special regimes accommodate different business structures.
Portugal’s tax incentives changed significantly post-2023. The generous NHR benefits that attracted many Golden Visa investors were reformed, requiring new applicants to evaluate alternative Portuguese tax regimes.
Greece’s flat-rate non-dom regime appeals to retirees and investors with significant foreign income, but it requires careful structuring and ongoing compliance.
Making the Right Choice for 2025
Your choice between these three programs shouldn’t depend on which offers the “easiest” path. Instead, consider which aligns with your genuine plans and circumstances.
Choose Malta’s MPRP if you value legal certainty, English-language environment, and permanent status from day one. The island’s compact size suits some lifestyles perfectly while constraining others.
Select Portugal if you prefer fund-based investments with potential returns and eventual citizenship through a five-year naturalization path. Accept that processing may take longer and fund selection requires expertise.
Pick Greece if property investment aligns with your portfolio strategy and you appreciate regional diversity within the EU. Understand that citizenship requires genuine residence, not just permit possession.
The era of purchasing EU citizenship ended with Malta’s CBI closure. What remains are three solid residency pathways, each suited to different investor profiles and long-term objectives.
Expert advisors like Global Residence Index and Vancis Capital specialize in helping investors navigate these complex decisions, providing current information on requirements, processing times, and strategic considerations that can make or break your application success.
The key is starting with clear goals and choosing the program that genuinely fits your circumstances, not just the one that sounds most appealing in marketing materials.
Advertise with the mоѕt vіѕіtеd nеwѕ ѕіtе іn Antigua!
We offer fully customizable and flexible digital marketing packages.
Contact us at [email protected]
