North Macedonia’s Interior Ministry has proposed removing the €400,000 threshold and its accompanying ten-job requirement from the country’s citizenship by investment framework, according to draft amendments to the Law on Citizenship published on the government’s regulatory register in June.
The European Commission considers the proposal insufficient, Balkan Insight reported on September 14, because the state would retain the power to naturalize individuals deemed of “special interest,” whether economic, cultural, or sporting.
What the Draft Law Changes
The amendments, prepared by the Ministry of Internal Affairs, remove the predetermined monetary criteria that have defined North Macedonia’s economic naturalization track since 2016: a €400,000 direct investment in new business facilities employing at least ten people, and, since 2021, an alternative €200,000 contribution to an approved private investment fund.
In their place, the draft installs a case-by-case model.
Under the proposed system, each application would require opinions from competent state institutions assessing whether the candidate genuinely represents a special scientific, economic, cultural, sporting, or other national interest. An investment would no longer automatically confer eligibility.
The ministry previously told Deutsche Welle that the amendments respond directly to the Commission’s findings that economic citizenship carries migration and security risks, particularly given the divergent criteria applied across cases.
Adopting the changes, the ministry stressed, does not abolish investment as a relevant consideration; it eliminates the possibility of its “transactional” abuse.
A second, less-noticed provision cuts the waiting period for former citizens to re-acquire citizenship from three years to three months. Skopje frames that measure as part of a strategy to draw diaspora talent back into the economy.
Brussels: Abolish It, Don’t Rebrand It
The Commission’s position leaves little room for creative drafting. Its Eighth Report under the Visa Suspension Mechanism, published in December 2025, instructed North Macedonia to “abolish the scheme and repeal its legal basis,” disclose all applications submitted under the special-economic-interest provision, and subject each to rigorous background checks.
The same report anchors that demand in the Court of Justice of the European Union (CJEU) judgment against Malta’s investor citizenship program of April 29, 2025.
Since that ruling, the Commission’s 2025 Enlargement Package has treated the abolition of investor citizenship frameworks, legal basis included, as a condition of compliance with EU law for candidate countries.
Under the revised Visa Suspension Mechanism, operating an investor citizenship program is now, in itself, grounds for suspending a third country’s visa-free access to the Schengen area.
A Program More Legal Basis Than Reality
For all the attention it draws, North Macedonia’s economic citizenship track has produced remarkably few citizens.
Between 2005 and 2022, 121 people acquired citizenship on special-economic-interest grounds against 40 refusals, according to the Commission’s Sixth Visa Suspension Mechanism Report.
The Eighth Report counts one grant in 2023 and two in 2024.
Local reporting, citing official data, puts naturalizations under Article 11 of the Law on Citizenship (the provision covering all merit grounds, from scientists to athletes) at more than 370 over the years. The economic subset alone has averaged roughly seven passports a year.
The government first began granting citizenship at the €400,000 level in 2016, purely on a discretionary basis, before a decree defined formal criteria for special-interest naturalization.
In early 2021, a €200,000 fund-contribution route emerged, complete with authorized agents, a master compliance agent for Asia, and, by August that year, pre-approval letters issued through the country’s embassy in Abu Dhabi.
Momentum never followed. The Commission’s subsequent monitoring recorded a handful of economic citizenship applications pending without processing, and the program drifted into a dormancy from which it never seemed to emerge.
Theodora Jantol of The Passport Investor, who works across the Western Balkans, cautions against describing the reform as abolishing an active program. North Macedonia’s framework “had not developed into an actively functioning mainstream program” and had “been largely dormant for some time,” she observes.
What the government is doing, in her reading, is removing the elements that most resemble a conventional CBI model “while preserving a broader discretionary mechanism based on citizenship by merit or national interest.”
The Distinction Skopje Is Betting On
The government’s wager is that removing the price tag transforms the provision from a CBI program into ordinary citizenship by exception, a power most countries in the world, including EU member states, retain. Jantol thinks the distinction is defensible in principle.
“I do not think citizenship by exception or citizenship by merit should disappear simply because the beneficiary happens to be an investor,” she argues, adding that any state should keep the discretion to reward someone who invests tens or hundreds of millions of euros, creates many local jobs, or builds a strategically important industry, just as it naturalizes exceptional athletes and scientists.
For her, the line runs between two propositions. Saying “invest €400,000 and create 10 jobs and you may qualify for citizenship” describes “a rules-based investment product with defined qualification criteria”; concluding after an individual assessment that a person’s extraordinary contribution justifies naturalization in the national interest is “citizenship by merit or exceptional contribution.”
Malta, she notes, drew the same distinction after the CJEU judgment, abandoning predetermined financial contributions while retaining a framework for exceptional merit.
“I think North Macedonia may be trying to make a similar distinction: remove the published investment formula while preserving the state’s sovereign ability to naturalize someone whose contribution is genuinely exceptional,” she explains.
The Commission’s worry, Jantol adds, is that a repeatable “special economic interest” path could simply replace a defined investment framework with a more discretionary one unless strong safeguards accompany it.
Laszlo Kiss of Discus Holdings is more skeptical about the framework’s track record and about the risks ahead.
“From the beginning, the legal and practical side did not work well,” he remarks, noting that Skopje itself never published statistics on its grants; the only tallies available come from EU monitoring reports rather than the government. “We have no data about how many citizenships were granted at all.”
Kiss sees the direction of travel as inevitable for any state exposed to Brussels’ financial leverage: a country “which can be pushed by the EU Commission” can, in his view, “operate only a merit-based solution.”
In non-EU countries especially, “the lack of transparency and also the ambiguity of ‘merit’ could quickly cause wholesale corruption.”
The Accession Backdrop
North Macedonia has held EU candidate status since December 2005, longer than any current candidate, and its citizenship policy cannot be separated from that grinding accession saga.
A Greek veto over the country’s name blocked progress until the 2018 Prespa Agreement, which unlocked NATO membership in 2020. France then delayed the opening of talks in 2019, and Bulgaria imposed its own block in 2020 over disputes about history, language, and the Bulgarian minority.
A French-brokered compromise finally allowed the first intergovernmental conference on July 19, 2022. The catch: opening the first negotiating cluster requires constitutional amendments listing Bulgarians among the country’s constituent peoples, a step Prime Minister Hristijan Mickoski’s government refuses to take without guarantees against further bilateral vetoes.
That impasse persists. The European Parliament’s June 2026 report on the country, adopted by 411 votes, again pressed for the amendments, and Enlargement Commissioner Marta Kos repeated in July that adopting them remains the necessary next step.
Until Cluster One opens, the Commission’s principal levers over Skopje’s citizenship policy remain the visa-free regime and the annual enlargement reports, and it is applying both.
Jantol points out that this context cuts both ways. As a candidate rather than a member state, North Macedonia’s relationship with EU law “has to be viewed in that context,” and how the framework evolves will depend on the country’s progress toward membership and the political compromises accompanying it.
Implementation Will Decide
Whether the reform satisfies Brussels will turn on practice rather than statutory language.
A limited number of genuinely exceptional naturalizations, a strategic investor creating thousands of jobs or a world-class athlete, would sit comfortably within the citizenship-by-exception traditions of many EU states. A steady flow of passports to ordinary investors at an unpublished price point would not.
“If, however, ordinary investors continue receiving passports simply because they invest a certain amount of money, even if that amount is no longer officially published, then I would expect Brussels to argue that the substance of the previous program has not materially changed,” Jantol says.
Facing similar pressure from Brussels, some states closed their programs and others were forced to rebuild them. Montenegro closed its program at the end of 2022, Moldova terminated its own in 2020, and Malta’s yielded to the CJEU in 2025; whether that separation can survive contact with the Commission is the question the coming months will answer.
For now, the reform remains a draft, and North Macedonia’s legislative machinery gives it a long way to travel. The Interior Ministry posted the text on the ENER public register in June, which starts a consultation window before it reaches the Cabinet. Only after the government adopts the draft in an official session does it go to the Assembly, where it faces committee scrutiny and up to three readings before a vote.
