The investment migration market enters 2026 facing its most uncertain regulatory environment in recent memory.
The European Union has hardened its stance on citizenship-by-investment (CBI) programs, warning that operating such schemes may now constitute grounds for visa suspension.
Meanwhile, the United States has imposed travel restrictions on all citizens of two Caribbean nations due to their CBI operations.
Against this backdrop of escalating scrutiny, new RCBI programs are advancing in Argentina, Saint Vincent and the Grenadines, and possibly in Botswana and Tonga.
Portugal’s Constitutional Court has delivered a split decision on nationality law reforms, and the European Travel Information and Authorization System (ETIAS) threatens to transform visa-free access into pre-screened entry requiring advance approval.
These developments could reshape the competitive landscape for citizenship and residence programs throughout 2026.
Five questions stand out as potentially consequential for the year ahead.
1. Will The European Union Actually Suspend Caribbean Visa Access?
The European Commission’s latest Visa Suspension Mechanism report states that operating citizenship programs “in itself” constitutes grounds for visa suspension.
Brussels now recommends that five Eastern Caribbean nations ensure adequate vetting “pending discontinuation” of their programs; language that explicitly contemplates elimination rather than reform.
The Commission has already begun testing phased restrictions on Georgia, suspending diplomatic passport privileges by year-end with potential extension to all citizens.
Will Brussels move from warnings to action against Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia in 2026?
2. Will Saint Vincent, Botswana, and Tonga Proceed With CBI Plans Despite International Pressure?
In late December, Prime Minister Goodwin confirmed plans to establish a CBI program in 2026, citing more than $1 billion in public debt as an economic necessity.
Deputy Prime Minister Major St Clair Leacock has outlined a multi-institutional oversight framework emphasizing accountability.
The announcement comes weeks after the Trump administration suspended specific visa categories for Antigua and Barbuda and Dominica, explicitly citing citizenship programs as the motive.
Botswana also said it will soon launch one of the most affordable CBI programs, with an initial donation option of $75,000 to $90,000.
Tonga’s new PM, Lord Fatafehi Fakafanua, has proposed a CIP charging $190,000 for single applicants.
Can Saint Vincent, Botswana, and Tonga successfully launch while CBI countries face American restrictions, and all five Caribbean programs confront escalating EU pressure?
3. What Will Argentina’s Citizenship Program Actually Look Like?
Argentina’s Ministry of Economy has issued a tender for consultancy services to design and operate the country’s first CBI program. The procurement closes January 20 with potential contract awards in April or May.
No preset investment thresholds appear in official documents for the planned program, despite media speculation that cites $500,000.
The winning consultancy will design investment categories and recommend thresholds, with tender language suggesting preferences for productive sectors including agribusiness, renewable energy, mining, technology, and infrastructure.
Can Argentina sustain political will across administrations and volatile economic conditions to actually launch and maintain the program?
4. Will Portugal Extend The Citizenship Timeline For Current Residents?
Portugal’s Constitutional Court has upheld the extension of naturalization timelines from five to ten years for non-EU, non-CPLP nationals while striking down four other contested nationality law provisions.
More than 20,000 golden visa investors await appointments with Portugal’s migration agency, extending into 2026, some waiting since 2021.
The court rejected automatic citizenship denial for criminal convictions longer than two years and eliminated vague fraud language, but left unclear when residence counting begins and which applicants receive transitional protections.
Will current golden visa holders face effective timelines of 12-14 years due to processing delays, or will Parliamentary provisions protect those already in the system?
5. Will ETIAS Become A Tool For Discriminating Against CBI Holders?
The European Travel Information and Authorization System (ETIAS) is set to launch in late 2026 and to become mandatory by October 2027.
Presuming the status quo continues, Caribbean citizenship programs will technically retain visa-free Schengen access, but ETIAS would introduce pre-screened entry requiring advance approval that takes anywhere from minutes to 30 days.
One-third of investment migration executives believe ETIAS will become a tool for discriminating against CBI passport holders.
Will European authorities approve citizenship-derived passports at rates similar to other nationals from the same countries, or will ETIAS become a mechanism for algorithmic discrimination?
