The European Commission is signalling a harder line toward Caribbean citizenship-by-investment programs (CIPs), saying the existence of such programs “in itself” may now constitute grounds for suspending visa-free travel to the Schengen area.
In its 8th annual Visa Suspension Mechanism report, the Commission appears to be shifting its language on CIPs programs away from centering “genuine links” concerns and toward characterizing any CBI operation by visa-free nations as an inherent security threat.
“The operation of such programmes constitutes, in itself, a ground for suspending the visa-free status of third countries,” reads the report.
The policy evolution marks a significant tightening of Brussels’ position on CBI programs.
While the report continues to identify the absence of genuine links as one of three risk factors that intensify security concerns, the Commission appears to no longer require demonstrating this deficiency to act against CBI programs.
Commission Zeroes In on Caribbean CIPs
The report identifies Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia as operating programs that pose a significant and ongoing challenge of “much greater scale” than similar schemes in the EU’s immediate neighborhood.
Between them, the five countries have issued over 100,000 passports through their CBI programs, with applications remaining high at 13,113 in 2023 and 10,573 in 2024.
The Commission expressed particular concern about the adequacy of security vetting procedures, noting that processing times remain short while rejection rates remain “very low.”
In 2024, the Commission says, Antigua and Barbuda rejected just 1.7% of applications, Saint Lucia 5.3%, and Dominica 6.5%.
The report acknowledges steps taken by the five nations in response to previous EU concerns, including harmonizing the minimum investment threshold at $200,000, strengthening security screening, and establishing common standards for information-sharing and transparency.
Yet, the Commission states plainly that the situation continues to raise significant concern.
Effective Ultimatum to Caribbean CIPs?
In its formal recommendations to the five Eastern Caribbean countries, the Commission says they should take all necessary measures to ensure adequate security vetting of applicants “pending the discontinuation” of those schemes, according to the report’s annexes.
The wording appears to explicitly contemplate eliminating Caribbean CBI programs rather than focusing on improved due diligence or genuine connections, which the report frames as interim measures rather than long-term solutions.
Under the revised mechanism, failure to address Commission recommendations can trigger formal procedures that ultimately result in the suspension of visa-free travel.
The visa-suspension mechanism Caribbean nations may face is already being tested on Georgia, which drew severe EU scrutiny in the same report for “democratic backsliding.”
Brussels said it will suspend visa-free travel for holders of Georgian diplomatic, service, and official passports by the end of December as a first phase, with the possibility of extending restrictions to all Georgian citizens if authorities fail to address its recommendations.
The phased approach could establish a template that applies to any visa-free country found to be in breach of EU requirements or the Commission’s recommendations.
While the Commission specified no concrete deadlines, it said countries must demonstrate measurable progress toward compliance “without delay” or risk triggering formal suspension procedures.
EU Candidate Countries “Must Abolish Schemes”
For countries seeking EU membership, the Commission reiterated that compliance with EU law requires candidate countries to abolish existing investor citizenship schemes and to repeal the legal basis for such schemes.
This follows an April 2025 European Court of Justice ruling that found Malta breached EU law by operating a CIP and established that member states cannot implement naturalization schemes based on transactional procedures.
