Grenada’s Parliament has taken up legislation that would require new citizens by investment to spend at least 30 days in the country. The Grenada Citizenship by Investment (Amendment) Bill, 2026 went before the House of Representatives on July 28. A government release records that the Senate debated it on Friday, July 31.
Nothing in it has taken effect. Clause 1(2) leaves commencement to a date the minister appoints by Order published in the Gazette, and no such Order has surfaced.
Sixteen clauses amend the Grenada Citizenship by Investment Act, No. 15 of 2013, inserting 23 new sections. Attorney-General Claudette Joseph signed the explanatory notes.
The same release describes the bill as aligning domestic law with the Agreement Establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA). Five governments signed that agreement on September 18, 2025, and the ECCIRA Agreement Act, No. 19 of 2025 gave it force of law in Grenada.
Neither the individual five-day floor nor the two-stage passport appears in the summary the government circulated.
Thirty days across five years, with a five-day floor in year one
Section 7A would require that every main applicant and dependent commit to establishing what the bill calls a “genuine and effective link” to Grenada. In aggregate, that means 30 days of physical presence during or up to any of the first five calendar years after Grenada grants the certificate of citizenship.
Collectively, the main applicant and the dependents named in the application could meet those days. Where two of them stand in Grenada on the same date, the bill would count that date once toward the total.
Underneath the aggregate sits an individual floor the government release does not mention. Each person named in the application would have to be physically present in Grenada for “not less than five (5) days” during the first 12 months following the grant. Only the days that remain would fall to the family to share out.
Every one of those obligations attaches to the people named in the application that produced the grant. Nothing in the bill covers a dependent added later, such as a spouse or a newborn. Whether such a person would owe the five days independently, or draw on the family total, goes unsaid.
Nisha McIntyre, managing director at My Grenada Solutions, expected most of what the bill contains. “Most of the elements of the bill I would expect, because it’s based off the ECCIRA agreement,” she said. What stays unclear is “how the regulations are going to be implemented.”
She would rather the residency days run per person. Counting a family collectively is “unfortunate,” she said, “because they are each experiencing the island individually as citizens.”
“I would have hoped that their time on island would go to the individual requirements,” she said.
Even so, she accepts the logic. On her reading of the bill, “the residency is really treated as a family residency policy rather than an individual one, because the family can satisfy 30 days collectively.”
Her conclusion follows from that. Satisfaction with “a family being able to fulfill the requirements,” she said, means “it falls in line that we should be accepting of this clause as well.”
Jeremy Savory, CEO of Savory & Partners, put the same gap as a question. “If a main applicant already met the 30-day stay requirement and later adds a spouse or newborn, does that dependent have to complete an independent 30-day stay, or do they benefit from the main applicant’s status?”
He expects the obligation to cost Grenada volume whatever the answer. Physical stay rules “will definitely introduce friction, hence reducing the demand for the program,” and that “disincentivizes applicants, developers and international agents, which slows down market appetite and ultimately impacts government revenues.”
Savory does not oppose them in principle. “I am not inherently against physical stay requirements. However, they have to be carefully thought through and balanced,” he said.
Policy should reflect “applicants’ real-world needs and personal circumstances rather than applying a rigid, one-size-fits-all rule.”
Section 7B would permit front-loading, letting applicants and dependents establish residence before Grenada grants citizenship. Verified time would then count toward the requirement, subject to one proviso: They would still have to serve the remaining portion after the grant.
The integration program would itself be mandatory, though the bill leaves its contents open. It could include civic education on Grenadian law, history, and constitutional principles, plus cultural orientation or community service. A further interview would also fall within it, conducted by a competent Grenadian authority or a delegated third party.
Exemptions would run through exceptional and compassionate circumstances, and the bill lists two without closing the list. Grenada could excuse someone with substantial economic, social, or familial ties on humanitarian grounds. Verified inability to travel would also qualify, whether from conflict, medical circumstances, age, or security risk.
Grenada’s committee would have to notify ECCIRA of any exemption granted, along with its reasons.
Conditional passport validity
Under section 7A(11), the government would issue the passport with two different validities.
Initial validity would run five years. Renewal “for a full ten year period” would follow only where the committee certifies that the holder has met the residency and integration obligations.
For McIntyre, that is the one part of the bill carrying no ambiguity. “What is clear is the issuance of the passport, and the fact that it is going to be reduced by half in terms of duration,” she said.
The comparison runs against a recent change. “Right now all Grenadians, however you became a Grenadian, receive a 10-year passport, and that increased about a year and a half ago,” she said. She renewed hers in 2024 and received five years; her husband renewed last year and received ten.
Under the bill, “if you apply after all of this takes effect, you will get a five-year passport.” Ten-year validity would follow “only if you satisfy the regulations of residency and integration before your passport is up for renewal.”
Before renewal, the holder would file a Declaration of Presence with ECCIRA, which could check it against immigration records. Failure to satisfy it “without reasonable excuse” would, by section 7A(12), constitute grounds to initiate the procedures to revoke citizenship and the passport. For those procedures the bill points to section 12(5) of the principal act, adding none of its own.
Who would be affected?
Section 7B(6) governs that question, and it does not key the answer to this bill. The residency sections would reach applications submitted once the ECCIRA Agreement Act comes into force, a date the bill does not name.
Beyond that limb, the same subsection provides that they “may be applied retroactively to pending applications at the discretion of the Minister, subject to transitional guidelines.”
Neither the bill nor the principal act defines a pending application. Read naturally, it covers files already submitted and not yet decided, though the text does not say so.
McIntyre counts the discretion as the wider problem. “There are quite a few elements left up to the discretion of the minister,” she said. Two of them are whether time on island before the grant counts, and whether humanitarian or economic contributions count at all.
Neither question has a published benchmark. “What benchmark are we using to say that applicant A is eligible to write off their economic and humanitarian contributions to Grenada and put them toward their residency, rather than applicant B’s similar contributions?” she asked. “We don’t know what the benchmarks there are going to be.”
No transitional guidelines have appeared either, and the bill sets no criteria governing how the minister would exercise that discretion.
Elena Ruda, co-founder and managing partner at Immigrant Invest, reads the answer as deferred rather than missing. “On timing and pending applications, it’s too early to judge,” she said. The bill “still needs a ministerial Order to take effect, and based on Grenada’s past rule changes, the document that will actually decide who’s affected is the transitional guidelines.”
Her firm has taken clients through two earlier Grenada rule changes. In both cases the cutoff was “tied to the submission date,” she said. When the minimum investment moved to US$200,000, applications “completed before June 30, 2024 proceeded under the previous terms,” and the residence requirement “carried its own separate cutoff.”
That is “established Grenada practice, but practice only, since the 2013 Act contains no savings provision.”
Savory treats retroactive application as damaging, however it lands. “Retroactivity is always a red line; it severely erodes trust,” he said. Changing rules after applicants have committed “destroys the predictability people rely on,” in his account.
The courtroom is not what worries him most. “Legal challenges are a real risk, but the bigger issue is reputational,” he said. “Once applicants feel the goalposts can move after the fact, they pull back.”
He wants the term pinned down before the guidelines arrive. Does it cover “files under review or people who already have CORs and are just waiting on passport printing?” On his reading, “Grandfathering rules need to be clearly defined.”
No license would issue without ECCIRA’s no-objection notice
Clause 5 rebuilds the licensing chain through a new section 3H. Agents, promoters, due diligence providers, developers, and escrow agents would all go through Grenada’s committee first. That committee would assess them against the fit-and-proper criteria in Article 15 of the agreement, then forward the file to ECCIRA.
ECCIRA would have 30 days from a complete application to decide. Its decision would then hold for three years, unless it suspended or revoked the confirmation sooner. A marketing license granted or renewed without one would be void.
Section 3H(11) extends the same voiding beyond marketing licenses. Any registration, license, authorization, or approval issued after a refusal would be “null and void to the extent” that it lets the holder participate in the program.
Where ECCIRA suspended or revoked a confirmation, the minister would have to suspend or revoke the corresponding local agent’s license on the Authority’s recommendation. Grenada’s committee would then stop accepting files from that agent for the duration.
Due diligence providers would clear an additional screen, under which ECCIRA would satisfy itself that the firm is a reputable international provider with proven investigative experience. The same assessment would cover capability across international databases and in several languages.
Conflict-of-interest screening would reach past the applicant to the regulatory apparatus itself. No financial connection could run to an ECCIRA officer, a minister on the Council, a member of parliament, a licensee, or any other regulated person.
McIntyre anticipated the regional layer but not its mechanics. Regulator licensing is “something that I had anticipated based on the ECCIRA agreement, but we’re still unsure as to how that process will unfold,” she said.
“Do we now have to pay both the IMA and the regulator for licensing?” she asked. “Can we still have subagents licensed through us?”
The subagent model may not survive the answer. “If all agents operating with the program ultimately need approval from the regulator, how do you treat the subagents?” she said. “Is it now that they also have to pay to get registered by the regulator?”
Her own conclusion follows from that. “Does it make sense being a subagent, or do you then just become your own marketing agent?”
Interviews from 18, and from 12 where due diligence raises concerns
Clause 7 repeals and replaces the interview provision outright. Personal interviews would become a mandatory component of due diligence for the applicant and for dependents aged 18 or older.
The threshold would drop to 12 for any dependent who is “the subject of any material concern raised during due diligence.” Interviews could run in person or over a secure virtual network.
Waivers would reach dependents only, never the main applicant, and would require ECCIRA’s written permission. Where an applicant failed to attend without just cause, the committee would suspend or reject his application. Grenada would have to record, secure, and control access to every interview for seven years.
That 12-year threshold cuts below current practice. “What was interesting for me too is the whole treatment of due diligence,” McIntyre said. “Right now anyone aged 17 or older is subject to due diligence and an interview, so we know as agents how to bill accordingly to satisfy the IMA’s requirements.”
Pulling younger dependents in raises a billing question the bill does not answer. Younger dependents face no interview today, so “how is the authority going to atone for that as it relates to pricing?” she asked.
“Are you saying that you can now retroactively increase the cost of an applicant’s application fees, because you are subjecting another dependent to due diligence?” she said. “I don’t know how they’re going to manage that.”
A denial in one state would close the door in the other four
A new section 8B would require a register of every application deprived, revoked, denied, withdrawn, or otherwise not approved, with reasons attached. Notification would go to ECCIRA and to the head of each participating state’s unit within three business days.
Section 8C would then bar Grenada from accepting, processing, or approving an application from anyone a participating state has denied. Only ECCIRA’s express written approval would open a route around it. That approval would require compelling evidence of a material change in circumstances, or a procedural irregularity in the original denial.
Withdrawal carries a definition in section 8B(6) broad enough to cover applicants who pull out after being told of an adverse finding or a likely refusal. So do those who abandon a file rather than answer a material due diligence inquiry.
ECCIRA with a majority vote
Clause 3 inserts a supremacy rule: Where an inconsistency arises between Grenada’s CBI act and the ECCIRA Agreement Act, the latter “shall prevail.” The committee would also have to exercise its powers in conformity with ECCIRA’s regulations, standards, directives, timelines, and protocols.
Section 13G sets out what would happen when Grenada falls short. ECCIRA would issue a Notice of Non-Compliance, and the committee would have 30 days to respond. Continued failure would draw a public notice and a reprimand recorded in ECCIRA’s annual report.
Beyond that, ECCIRA’s Board of Directors could approve an Action Plan carrying mandatory steps and timelines. Where the plan failed, the Board could recommend that the Council cut Grenada’s annual maximum number of approved applicants. It could recommend a fine per unrectified breach instead, paid into a Compliance Fund, or both remedies together.
After six months of continued non-compliance, any other participating state could refer the matter to arbitration. All measures would lift automatically once ECCIRA certifies full compliance.
Audit reports would go public within 30 days of submission
Section 3B would require an annual independent financial audit and a biennial independent operational audit. The Director of Audit could conduct it, or appoint an independent external auditor whom ECCIRA would then approve. Either way, the auditor would need no actual or perceived conflict of interest.
Within 180 days of the financial year end, Grenada’s committee would submit the report to ECCIRA. Publication on its own website would follow within 30 days of that submission, and escrow accounts would draw a separate annual audit.
Four triggers would open the door to a special audit by ECCIRA. Two are recurring irregularities across two or more audit cycles, and credible information pointing to systemic governance failures or corruption.
A third is material security, financial, or reputational risk to the regional framework. The fourth arises where the minister fails to lay a bi-annual report before the House within six months, absent valid justification.
Biometrics and source of funds would go into a shared regional database
Sections 13A to 13F would establish the Eastern Caribbean Citizenship by Investment Database as the authoritative regional repository. Grenada would upload biographical data, citizenship decisions, passport records, source of funds documentation, and post-approval vetting records. Biometrics would go in too, meeting International Civil Aviation Organization (ICAO) and International Organization for Standardization (ISO) specifications.
Transmission would run through the secure web portal maintained by the Joint Regional Communications Centre (JRCC), a subagency of the CARICOM Implementation Agency for Crime and Security (IMPACS). Only three groups could reach the data: Authorized JRCC personnel, designated competent authorities, and persons authorized under bilateral or multilateral agreements for security vetting or law enforcement work.
EU sanctions lists appear nowhere in the text
According to Antigua and Barbuda’s government, the European Commission wrote to all five Eastern Caribbean states on June 25, asking for a phase-out by June 1, 2028. Grenada has not published the correspondence it received. Antigua’s account describes interim measures for the transition period, among them full exclusion of individuals subject to EU restrictive measures by September 2026.
On vetting, Grenada’s bill answers much of what the Commission asked for. Its definition of due diligence reaches anti-money laundering, counter-terrorist financing, and proliferation financing standards. Political exposure and source of funds sit in the same definition.
Ruda reads the package as vetting work rather than concession. “This is exactly the kind of measure we pointed to when discussing the EU’s Schengen concerns,” she said. “Caribbean governments are taking concrete steps.”
Mandatory interviews, ECCIRA’s authority over agent licenses, and regional reciprocity on refusals “all strengthen the vetting perimeter,” leaving the 2013 Act “simply catching up with standards that have moved on.”
Savory would rather Grenada held its ground. He calls the sequencing “a case of the chicken and the egg,” and would have Caribbean nations “firmly assert their sovereignty rather than kowtow to external demands from foreign governments.”
Part of his case rests on Europe’s own borders. “Looking at global trends, internal Schengen access is already wobbling, as seen in recent border restrictions between member states like Italy and Spain,” he said. Italy suspended free movement with Spain on August 1 over the Ceuta migrant crisis, and Spain imposed reciprocal checks days later.
For the revenue argument, he points to the Pacific. Vanuatu “has proven that price points relative to perceived market value can actually drive record revenues even without visa-free access to Europe,” in his account, and its citizenship revenue hit a record in the first half of 2026.
“The Caribbean has nothing to fear,” he said. In his account, these programs hold “a robust reputation, thousands of highly vetted applicants who have felt a huge weight lifted off their shoulders by becoming dual citizens, decades of established track records, and Units managed by exceptionally competent individuals (some countries more than others).”
Anyone who truly needs Europe should buy Europe, on his advice. “If visa-free travel to Europe is truly the be-all and end-all for an applicant, my advice would be for them to apply for a European permanent residency program directly, such as Portugal, Greece or Malta,” he said, “because after all, permanent means permanent; it’s linked to an income-generating asset in a highly liquid market with a pathway to citizenship.”
Nowhere in the text do EU restrictive measures appear. Whether Grenada closes that gap through regulations, ECCIRA directives, or a further amendment remains open.
Antigua and Barbuda moved first. Gaston Browne tabled a parallel amendment bill on July 14 that would raise residency from five days to 30 and impose the same audit cycle.
All five governments met in Roseau on July 10 and issued a joint response to the Commission. That statement sought negotiation rather than accepting the phase-out premise.
What still has to happen
Parliament’s published copy leaves the act number and both passage dates blank. ECCIRA itself is expected to begin operating in September, once Saint Lucia deposits the ratification the other four states have already completed.
Whether the authority can carry the load is Savory’s open question. Is ECCIRA “actually equipped to handle the administrative burden of tracking renewal processes and stay requirements across five different countries without creating massive bottlenecks?”
McIntyre is waiting on the paperwork that follows. “There are a few elements in there that I am curious to see how they unfold as an agent,” she said.
“The bill was recently introduced, so we are waiting to see what circulars are released to explain the implementation,” she said.
At least two internal mismatches survive in that published copy. Explanatory notes describe clause 3C as covering corrective action, yet the operative provision numbered 3C addresses modification of the auditor’s report. Section 8C also cross-refers to a subsection of section 8A rather than section 8B.
Grenada’s citizenship by investment program currently requires a minimum contribution of US$235,000 to the National Transformation Fund for a family of up to four, or US$270,000 in approved real estate. Neither figure changes under this bill, which leaves thresholds to regulations.
