Somewhere around 2045, the grandchild of a man who bought a Caribbean passport in the 2020s will walk into a consulate to claim citizenship, and in three of the five program countries, the answer will be that there is nothing to claim. The grant reached his parent and stopped.
Where that line falls varies more than buyers realize. A family that acquires citizenship in Dominica and has another child six years later will find that child has no automatic citizenship, no right to apply, and no way into the program at any price. A family that buys into Grenada and has a child the same year gets that child a passport at birth, for free, and then watches the chain end with the grandchild.
None of this is new. A 2020 opinion piece for IMI argued that, Grenada aside, the Caribbean programs did not let investors pass citizenship to future generations at all: the grant reached the applicant’s children and stopped there. Six years on, the underlying law has tightened in some places and clarified in others, while the sales pitch of citizenship “for generations” carries on regardless.
The Ways a Country Decides Who Inherits
When a child is born abroad to a citizen parent, every country asks one of two questions. The question it asks determines how long a bought passport survives in a family.
The easy question is: is your parent a citizen? If the answer is yes, the child is a citizen too, wherever he was born and however his parent got it.
The harder question is: how did your parent become a citizen? This is the model written into the Caribbean constitutions drafted in London in the 1970s and 1980s, and into Maltese law. It separates citizens who acquired their status in their own right, by being born on the island or by naturalizing, from citizens who merely inherited it. Only the first kind can pass citizenship on.
That model then splits again, depending on which side of the line the drafters put investors, and this is where the five Caribbean programs part ways.
Group One: No Generational Limit
🇹🇷 Turkey is the clearest case in the market. Its citizenship law says a child born to a Turkish mother or father, inside or outside the country, is Turkish from birth. Nothing in that provision asks how the parent got the passport, and no cut-off applies after one or two generations; the only practical step is registering the birth at a Turkish consulate.
Murat Yüksel of Yüksel Law, the in-house law firm of CIP Turkey, says the point clients most often get wrong is assuming that citizenship bought through investment is “a special form of citizenship that is personal to the investor, limited in its transmission to future generations, or somehow weaker than citizenship acquired through other routes.”
It isn’t, he says: “What is transmitted to future generations is not a special ‘CBI status,’ but Turkish citizenship itself.”
At each generation, the only test is whether at least one parent is a Turkish citizen at the time of the child’s birth, with legal parentage established.
🇪🇬 Egypt works the same way. Since a 2004 amendment placed mothers and fathers on equal footing, anyone born to an Egyptian parent is Egyptian, wherever the birth happens. Minor children of someone who naturalizes are usually folded into the parent’s grant rather than filing separately.
🇰🇭 Cambodia also transmits without limit. Its 1996 nationality law treats any legitimate child of a Cambodian mother or father as Cambodian, regardless of where the child is born, and draws no distinction between naturalized parents and native ones.
🇳🇷 Nauru has the simplest rule of the five. Under its citizenship act, a child born outside Nauru is a citizen if either parent was a citizen when the child was born. No clause limits that to parents born on the island, and none cuts the chain off after a set number of generations.
🇻🇺 Vanuatu reads the same way on paper. Its constitution says anyone born after independence, in Vanuatu or abroad, becomes a citizen if at least one parent is a citizen. However, practitioners report that children born after an investor’s grant are put through a paid post-approval application rather than recognized automatically.
Group Two: One Generation, Then It Stops
🇬🇩 Grenada comes closest to matching the sales pitch, on the strength of a single clause. Its constitution grants citizenship at birth to a child born abroad provided the parent did not inherit citizenship himself. An investor who registered under the Grenada program bought his citizenship rather than inheriting it, so his child born in Dubai or London is Grenadian automatically, at birth, with no fee and no deadline.
That child, however, did inherit. Therefore, his own child, born abroad, gets nothing automatic, which means “for generations” turns out to mean just two.
🇱🇨 Saint Lucia copies the Grenadian wording almost verbatim and produces the same outcome. The program also lets a citizen add a child born after the original application was filed through a post-grant application to the CBI Board. Dependants who already qualified at the time but were left off the file face a five-year deadline instead.
🇲🇹 Malta no longer sells citizenship at all: the EU’s top court ruled in April 2025 that the program had to close, and Malta replaced it with a discretionary merit route that July. The transmission rule still governs the thousands of families who bought in beforehand.
Malta’s citizenship agency frames the question around who the parent is. A child born abroad is Maltese if, at the moment of birth, the parent holds citizenship by having been born in Malta, by naturalizing, or by registering.
An investor naturalized under the old program qualifies on the second of those three grounds, so his child born abroad is Maltese. That child, though, inherited his citizenship, and Malta does not allow inherited citizenship to be passed on again. The grandchild born abroad gets nothing.
It is fair to assume the grandchild could fall back on Maltese ancestry instead, since Malta does allow people with Maltese roots to claim citizenship. That door is shut as well. When Malta opened the ancestry route in 2007, it restricted it to people descended from an ancestor born in Malta whose own parent was also born in Malta, a bloodline no investor family has.
Alex Hopkin, director of operations at Latitude Group, notes that no family has actually hit this wall yet: “The IIP began in 2014 and MEIN in 2020, so this likely remains a prospective issue, as we are not aware of any investor family that has had two successive generations born after the original naturalization.”
There is also a way to prevent the loss of citizenship after the second generation. “For a family wishing to ensure that the grandchild acquires citizenship automatically, our recommendation would be to consider having the child born in Malta,” says Hopkin, elaborating that a child born on the island to a citizen parent holds citizenship by birth in Malta rather than by inheritance, which restarts the transmission chain.
Group Three: No Automatic Claim at All
🇰🇳 St Kitts and Nevis runs the oldest program in the world and the most restrictive rule in it. A child born abroad is a citizen at birth only if a parent was born in St Kitts and Nevis and held British citizenship immediately before independence in 1983, which rules out every investor. The fallback, a right to register any child of a citizen under 18, is then withdrawn from investors specifically: the Citizenship Act gives the minister express grounds to refuse where the applicant is the child of someone who obtained citizenship through investment.
What operates in practice is a fee schedule rather than a legal right. Official guidance from the Citizenship by Investment Unit (CIU) sets $7,500 for a child under three born after the certificate is issued and $10,000 for a child born while the application is still in process, on top of standard fees. Children who were eligible at the time but simply left off the original application cannot use this route at all, and must start again through a sponsored application.
The 18-year cliff is real enough that the government has taken to warning citizens abroad about it publicly, and a petition put to the National Assembly in October 2025 asked lawmakers to amend the provision that limits descent to the first generation born abroad.
🇦🇬 Antigua and Barbuda also confines automatic birth-abroad citizenship to children of independence-era or island-born citizens. Its registration provision is more generous than the Kittitian one, giving an unqualified right to register any child under 18 of a citizen, and it makes no exception for investors. A disciplined family could keep registering each generation before children turn 18.
The CIU prices that right rather than blocking it. Licensed agents publish the post-citizenship schedule as $10,000 for a newborn or newly adopted child under six and $20,000 for a child aged six to 17. Antigua separately requires that investors spend five days in the country within their first five years as citizens.
🇩🇲 Dominica stops hardest of all. Both its automatic-descent clause and its registration clause are limited to children of people who were citizens when Dominica became independent, or who were born there, leaving an investor’s child with no constitutional route whatsoever.
Everything therefore runs through the program’s own rules, which permit a CBI citizen to register a child born or adopted no more than five years after he obtained citizenship, and only while that child is under 18. Beyond that window, nothing.
🇲🇰 North Macedonia reaches the same place through a calendar rather than a category. Where both parents are citizens, transmission is automatic; where one parent is foreign and the child is born abroad, the child acquires citizenship only if registered before turning 18, or if he moves to the country with the Macedonian parent before then, or by applying between the ages of 18 and 23.
The Odd Cases: Jordan and São Tomé
🇯🇴 Jordan transmits without generational limit, but only through fathers. A child born anywhere to a Jordanian father is Jordanian; a Jordanian mother married to a foreign national cannot pass her nationality to her child at all. No brochure in the market states this, and it is the sharpest inequality in CBI transmission anywhere.
🇸🇹 São Tomé and Príncipe launched the market’s newest and cheapest program on 1 August 2025. Its constitution treats children of a São Toméan mother or father as citizens, and descent for children born abroad appears to run through registration.
The complication is that the implementing regulation for the 2022 nationality law had still not been adopted as of April 2024. Until it exists, the rules for investor bloodlines are unsettled, and anyone quoting a generational answer for São Tomé is guessing.
Why This Is About to Matter More
Every other feature of a CBI program gets tested. Pricing is compared line by line, processing times are tracked, visa-free counts are ranked and re-ranked, and due diligence standards are audited by three governments and a regional regulator. The multi-generational claim, however, is not placed under the same scrutiny.
Two things are now happening at once. Countries everywhere are making citizenship harder to inherit, and Italy is the clearest example: it has limited how far down a family line its citizenship can pass, and its highest court upheld that limit in March 2026. Inheritance used to be assumed, and it is now rationed.
At the same time, bought citizenship is becoming less permanent. Turkey recently stripped 6,134 investors of their citizenship, Grenada is weighing a residency requirement that could reach people who already hold its passport, and St Kitts and Nevis plans to require investors to spend time in the country.
Both trends raise the stakes on the same question. A passport that passes down cleanly is now worth noticeably more than one that does not, and a passport sold on a promise it cannot keep is a complaint that will surface 20 years later, when a client’s grandchild is turned away at a consulate.
Every family buying a Caribbean passport for its grandchildren should be told, in writing and before the wire transfer, whether that grandchild will have a claim, an application, or nothing. For three of the five Caribbean programs, the answer today is nothing.
