The Investment Migration Agency Grenada (IMA Grenada) has told stakeholders that the residence requirement scheduled to commence on August 31 will not take effect on that date.
Circular No. 2 of 2026 makes implementation conditional on two events that have not yet occurred. Chief Executive Officer Thomas Anthony signed it on August 21.
Neither the residence requirement nor the other regional obligations will apply until the regional regulator is operating. Participating member states must also agree formally on an effective commencement date and communicate it. IMA Grenada will issue guidance then.
Until then, the agency asked stakeholders to await further official communication on the residence requirement and the related regional requirements.
How the 30 days actually count
Grenada’s amendment sets the obligation at 30 days in aggregate. Those days fall during or up to any of the first five calendar years after the grant of citizenship. New section 7A lets the family meet that total collectively.
Each named dependant must still spend at least five days in Grenada within the first twelve months. One counting rule then shapes the real burden. Where family members are present on the same day, that day counts once toward the aggregate.
Four family members traveling together for five days therefore clear every individual minimum but bank only five days, leaving 25 to complete.
A mandatory integration program travels with the physical presence obligation, covering civic education, cultural orientation or community service, and an interview.
Passports carry an initial validity of five years, and the full ten-year renewal follows only where the Committee certifies compliance. Failure without reasonable excuse opens grounds to revoke both citizenship and passport.
Where the August 31 date came from
Grenada’s Parliament took up the Citizenship by Investment (Amendment) Bill on July 28, and the Senate debated it on July 31. Clause 1(2) leaves commencement to a date the minister appoints by Order published in the Gazette. When IMI covered the bill last month, no such Order had surfaced.
Section 7B(6) raises a second timing question. It applies the residence provisions to applications submitted on or after the coming into force of the ECCIRA Agreement Act, not of the amendment itself. Those are separate instruments carrying separate trigger dates.
Why the regulator is the hinge
Five governments signed the agreement establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) on September 18, 2025. The authority becomes operational 30 days after the fifth participating state deposits its instrument of ratification, a milestone the market has expected in September.
Grenada hosts the authority’s headquarters. Its own agency now points to that authority’s absence as the reason the domestic requirement waits.
Antigua and Barbuda raised its own post-citizenship residency requirement from five days to 30 in a bill Prime Minister Gaston Browne presented on July 14. Browne told Parliament that his government had already applied the higher figure administratively.
Grenada’s circular does not say whether the other four states have taken the same position on commencement.
What applies to applicants now
Elena Ruda, Co-Founder and Managing Partner at Immigrant Invest, said the circular came as no surprise. Her firm “expected the deadline to move once it became clear the regional regulator itself wasn’t ready,” and she called the postponement “the sensible thing to do.”
“There’s no mandatory visit or residence requirement for Grenada citizenship by investment at this point,” Ruda said. The previous conditions “still apply, and they will keep applying until there’s a new official announcement.”
One qualification sits outside that reading. Section 7B(6) allows the minister to apply the residence provisions retroactively to pending applications, subject to transitional guidelines. A file submitted today could still fall within that discretion once a commencement date arrives.