Every residence and citizenship by investment (RCBI) program will admit a spouse. The interesting question, and the one applicants rarely ask until it becomes urgent, is what happens when there is no marriage certificate: a couple together for 15 years who never saw the point, a same-sex couple whose marriage is valid in Copenhagen but not in Basseterre, or a fiancé whose wedding is planned for after the application deadline.
In 2026, the answers range from “show us a joint lease” to “each of you will need your own investment.”
In the Caribbean, where family inclusion policy determines the cost per passport, an unrecognized partner does not add a dependent fee to the file; they require an entirely separate qualifying contribution.
Broadly, the world’s programs sort into three camps. Some treat partnership as a question of fact, provable with bank statements and utility bills. Others treat it as a question of registration, satisfied only by a civil union or a notarized agreement.
The rest treat it as a question of traditional, legal marriage, and several of those specify whose marriages count.
Where Living Together Is Enough
🇳🇿New Zealand sets a high benchmark for pragmatism. The Active Investor Plus Visa admits a partner, married or de facto, of the same or opposite sex, provided the couple can show a genuine, stable relationship and at least 12 months of living together.
No registration, no ceremony, no notary; Immigration New Zealand wants evidence of a shared life, not a certificate. With the relaunched program drawing hundreds of applications since April 2025, that flexibility now matters to more families than ever.
🇦🇺Australia takes the same view for its National Innovation Visa, admitting a spouse, de facto partner, or civil partner alongside dependent children under 23.
The standard 12-month cohabitation rule can even be waived if the couple registers their relationship in an Australian state that offers a relationship register.
Same-sex and opposite-sex de facto couples are treated identically.
🇪🇺Europe’s fact-based camp is smaller but includes two heavyweights.
🇲🇹Under the Malta Permanent Residence Programme (MPRP), the eligible partner is one in a relationship the Residency Malta Agency recognizes as equivalent to marriage, explicitly including de facto partnerships supported by adequate evidence.
That wording survived the program’s 2025 overhaul intact, leaving Malta among the most partner-friendly jurisdictions on the continent.
🇵🇹Portugal codified the concept decades ago. A união de facto, defined in law as two people of any sex who have lived together for more than two years in conditions comparable to marriage, qualifies a partner for the Portugal Golden Visa on the same footing as a spouse.
Couples prove it with lease agreements, joint accounts, shared bills, and a sworn declaration from both partners.
Portugal also delivered 2026’s most consequential twist. Law 61/2025, in force since October 2025, imposed a two-year residence wait before most permit holders can sponsor family from abroad, yet golden visa holders are exempt from the waiting period entirely, while D7 holders are not.
For a couple weighing Portuguese routes, the golden visa is now the only one that brings a partner over without a multi-year separation; unmarried couples elsewhere in the system can cut the wait to 15 months by documenting 18 months of cohabitation before the sponsor’s arrival.
🇪🇸Spain closed its golden visa in April 2025, but the rules still matter to thousands of grandfathered holders renewing their permits. Spanish law recognizes the registered pareja de hecho, and a 2024 regulation went further by accepting 12 months of documented cohabitation as an alternative to formal registration. Even unregistered stable couples now have a route.
🇳🇷Nauru’s new citizenship program, which launched in late 2024, lists a monogamous de facto partner as an eligible dependent in licensed-agent guidance, a first that would make it the only citizenship by investment (CBI) program anywhere to accept unmarried partners.
The same guidance limits both spouses and de facto partners to opposite-sex couples.
Where the Notary Decides
🇬🇷Greece sits in a category of its own: unmarried partners are excluded on paper yet admitted in practice, through a procedural fix built into the law.
The Greece Golden Visa recognizes only the partner with whom the applicant has concluded a cohabitation agreement in Greece, signed before a Greek notary and registered locally.
Whether the authorities will accept a foreign equivalent is less settled. “Even though there is an uncertainty whether the Greek application office accepts foreign PACs( civil unions), the safest and most straightforward route is to execute a Greek cohabitation agreement before a Greek notary and have it duly registered,” says Alexander Risvas of Athens-based Risvas & Associates.
The sequencing is well rehearsed by Athens law firms. The investor completes the property purchase and files alone, receives the temporary residence certificate, then the couple signs the notarial agreement and the partner’s application is folded into the open case, with both residence cards typically issued together.
Risvas adds a caveat couples signing purely for immigration purposes should hear first: the agreement is not just a document to qualify for the golden visa. “It creates a genuine legal family relationship under Greek law and can have consequences extending well beyond the Golden Visa, including matters relating to property relations, financial claims between the partners, and inheritance,” he says.
Greek cohabitation agreements have been open to same-sex couples since 2015, and following the country’s 2024 marriage equality law, same-sex spouses married abroad qualify directly.
🇮🇹Italy’s rules allow investor visa holders to bring a spouse or a civil-union partner, and civil unions have been equated to marriage for immigration purposes since 2016.
But Italian civil unions exist only for same-sex couples, and mere registered cohabitation confers no reunification rights. The result: a gay couple with a foreign civil partnership has a route onto an Italian investor visa that a straight unmarried couple simply does not have, short of marrying.
🇨🇾Cypriot law has recognized civil unions, including same-sex ones, since 2015, and the recognition extends to the fast-track investor permit.
According to Demetris Demetriades of Andreas Demetriades & Co. in Paphos, a partner in a civil union concluded under Cyprus’s Civil Union Law can be included in the investor’s application on the same qualifying investment, in the same manner as a spouse. Unions registered abroad qualify too, with one caveat on terminology: “Civil unions are accepted, rather than civil partnerships,” as “civil partnerships do not have the same legal status in all countries.”
The line holds at marriage itself: “Cyprus doesn’t recognize same-sex marriage; however, it recognizes civil unions between people of the same sex,” says Demetriades. A same-sex couple married abroad cannot file on the marriage certificate, but the civil-union route is open to them.
🇭🇺Hungary’s Guest Investor Program and 🇸🇬 Singapore’s Global Investor Programme sit in the same drawer: both build the family file on a marriage certificate, and Singapore relegates common-law partners to a long-term visit pass rather than permanent residence.
For same-sex couples, Hungary’s marriage requirement is a closed door rather than a paperwork hurdle. “Hungary does not recognize same-sex marriages, so the residence permit cannot include the partner, whatever their legal situation outside of Hungary,” says Laszlo Kiss of Discus Holdings, noting that the excluded partner “also cannot apply for family reunification” as a fallback.
Marriage Required, Any Valid Marriage
A third group of programs draws the line at legal marriage but accepts any marriage lawfully celebrated, regardless of the spouses’ genders.
🇺🇸The US EB-5 program is the archetype: United States Citizenship and Immigration Services (USCIS) recognizes no civil partners and no common-law partners, however long the relationship, yet a same-sex spouse qualifies as a derivative so long as the marriage was valid where officiated. The certificate is everything; its letterhead is irrelevant.
🇹🇭Thailand supplies the cleanest before-and-after case in this entire survey. Until 2025, spouses of Thailand LTR (Long-Term Resident) visa holders had to be of the opposite sex.
The Marriage Equality Act, in force since January 23, 2025, rewrote the Civil and Commercial Code in gender-neutral terms, and the Board of Investment now states plainly that same-sex marriages qualify under the dependent category, part of a broader 2025 loosening that also scrapped the dependent cap and added parents.
The same official guidance is equally plain about the limit: unmarried partnerships remain unrecognized under Thai law and remain ineligible.
🇵🇦Panama’s Qualified Investor Visa belongs here too, at least formally: the eligible partner is the legal husband or wife, evidenced by an apostilled marriage certificate.
Since Panama does not recognize same-sex marriage domestically, couples holding a foreign certificate should treat their eligibility as a question for a Panamanian lawyer rather than an assumption.
Where Marriage Means One Man and One Woman
The Caribbean’s five CBI programs share a uniform baseline: the only partner who counts is a legally married, opposite-sex spouse.
🇰🇳St Kitts & Nevis is the most explicit, recognizing a family unit composed of a husband and a wife; either may serve as principal applicant, and families of any other composition are welcome to apply, but only as individuals.
For a same-sex married couple, that means two full applications and two qualifying contributions where a married opposite-sex couple would pay for one.
🇱🇨Saint Lucia specifies that where an applicant is in a lawful polygamous marriage, “spouse” means the first husband or wife.
🇦🇬 Antigua & Barbuda, whose dependent definitions are otherwise the region’s broadest, monetizes marriage timing instead of accommodating partnership: a future spouse of the principal applicant can be added after citizenship for a US$50,000 fee.
There is a slower workaround built into ordinary nationality law. A CBI citizen who marries after naturalization can typically pass status to the new spouse through standard citizenship-by-marriage provisions, since economic citizens hold the same rights as any other citizen.
For an unmarried couple in no hurry, one solo application plus a later wedding is often cheaper than two files, though it leaves the partner exposed in the interim.
🇹🇷Turkey applies the same logic through private international law: the eligible spouse is one whose marriage is valid under the Turkish conflict-of-laws framework, with the certificate apostilled and translated.
Turkey recognizes neither same-sex marriage nor any registered partnership institution, so a foreign same-sex certificate fails the validity test, and no unmarried partner concept exists at all.
The Gulf runs on chains of attestation.
🇦🇪Sponsoring a spouse under the UAE Golden Visa requires a marriage certificate legalized in the country of issue, at the UAE embassy there, and by the UAE’s foreign ministry.
Since the 2021 personal status reforms decriminalized cohabitation, an unmarried couple can lawfully share a Dubai apartment; what neither partner can do is sponsor the other, leaving each to qualify independently through property, employment, or talent routes.
🇸🇦Saudi Arabia’s Premium Residency and 🇶🇦Qatar’s family residence framework follow the identical marriage-certificate model, layered over legal systems in which cohabitation outside marriage is itself impermissible.
🇲🇾Guidance for the Malaysia My Second Home (MM2H) program states that common-law marriage and same-gender marriage are not accepted, directing unmarried couples to file two separate applications, each with its own fixed deposit. Vanuatu admits only a legally married spouse and, unlike the Caribbean, permits no post-approval additions at all, which makes the marry-first decision unusually final.
🇮🇩Indonesia’s golden visa dependent category covers a legally married spouse, but the country’s new Criminal Code, in force since January 2, 2026, goes further than non-recognition: Article 412 criminalizes cohabitation outside marriage, punishable by up to six months’ imprisonment.
Prosecution requires a complaint from a spouse, parent, or child, and officials insist tourists are not the target, but no other golden visa jurisdiction asks an unmarried couple to weigh their living arrangement against a penal code.
The Playbook
For couples planning around these rules, sequence is strategy. In marriage-only jurisdictions, marrying before filing converts a partner from an impossibility into a standard dependent at standard fees.
In Greece, budget a notary appointment rather than a wedding, and file the investor’s application first so the cohabitation agreement can be added to an open case.
Same-sex married couples face the sharpest fork. Thailand, the United States, and most of Europe will honor the certificate; the Caribbean five, Turkey, the Gulf, and Malaysia will not, and the honest advice there is to price two applications from the outset or choose a different region.
Unmarried couples targeting the fact-based programs should start building the paper trail now: 12 to 24 months of joint leases, shared accounts, and utility bills in both names is the difference between a routine approval and a request for further evidence.
The definitions above shift more often than investment thresholds do, and several of the finer points, from Cyprus’s treatment of civil unions to Nauru’s de facto clause, turn on how a specific officer reads a specific file.
Before structuring an application around any of them, put the question to a professional who has run it before.
