Argentina’s Ministry of Economy has cancelled the international tender to appoint a master agent for the country’s first citizenship by investment (CBI) program.
Resolution 522/2026, signed by Minister Luis Caputo on April 14, 2026, voids Tender 34-0001-CPU25 in its entirety. No contract was awarded, no compensation is owed to any bidder, and bid maintenance guarantees will be returned.
The cancellation comes six weeks after the evaluation commission, on March 5, recommended awarding the four-year contract to a four-firm consortium operating under the name Asesorías Legal Advisor Limitada. That recommendation never advanced to a formal award.
What Triggered the Review
After the dictamen was notified through the COMPR.AR system, two bidders filed impugnaciones (formal challenges) within the three-day window permitted under Article 73 of Decree 1030/2016. Henley & Partners, which had placed second in the evaluation, was one challenger.
Latitude Consultancy, which had been declared inadmissible at the threshold stage for failing financial solvency indices, was the other.
The resolution identifies the impugnación documents in the Ministry’s records as IF-2026-23119614, IF-2026-24886582, and IF-2026-25220209. Their substance is not disclosed in the cancellation text.
In response to the challenges, the Secretaría Legal y Administrativa of the Ministry of Economy, acting as the requesting unit, produced a new technical report (IF-2026-28784861-APN-SLYA#MEC) that reviewed both the challenges and the underlying bids.
The report concluded that although two offers were formally admissible, “relevant divergences persist regarding the proposed approaches and their integral adequacy to the public policy objectives to be developed.”
Continuing the procedure “under the current conditions,” the report found, “could not ensure the degree of coherence, integrality, and strategic articulation required for the adequate implementation of the program, making it advisable to undertake a re-evaluation of the operational pertinence of the process in course.”
The resolution cites Article 20 in fine of Decree 1023/2001 and Article 9 of Decree 1030/2016 as authority to cancel without compensation.
How the Tender Got Here
The Ministry of Economy published Tender 34-0001-CPU25 on December 5, 2025, calling for an integral consultancy service to design, implement, launch, and promote Argentina’s CBI program over a four-year contract. Eleven firms expressed interest. Six submitted formal offers by the January 20, 2026 closing date.
Four bidders were declared inadmissible at the March evaluation stage: Hong Kong Qian Cheng Business Co., Ltd. and Salzburg International for Law LLC on bid maintenance guarantee defects (a non-curable procedural failure under Article 66 of Decree 1030/2016); Latitude Consultancy on financial solvency indices; and Ancova Associates FZCO on grounds that its response to a clarification request modified the original bid, in violation of the principle of inmodificabilidad de las ofertas established in Article 15 of the General Conditions.
That left two finalists: the consortium and Henley & Partners. Both received identical 48-point technical scores. The economic evaluation, weighted at 40 percent, separated them. The consortium had bid $10,000 per tranche across five tranches of 1,000 applications, totalling $50,000 for the entire contract. Henley’s tranches escalated from $2 million to $8 million, totalling $25 million. Final composite scores: 88.00 for the consortium, 48.09 for Henley.
What Remains, What Doesn’t
The cancellation ends the master agent procurement, but it does not undo the legal architecture that produced it. Decree 366/25, which amended Argentina’s Citizenship Law to permit naturalisation through “relevant” investment regardless of residency duration, remains in force. So does Decree 524/25, which created the Agencia de Programas de Ciudadanía por Inversión (APCI) and set out the inter-agency procedure for evaluating applications.
The amendment decoupling CBI citizens from automatic tax residency also stands.
What does not exist, and never did, is the operational substance of the program: the qualifying investment thresholds, the eligible sectors, the processing routes, the global outreach apparatus, the agent ecosystem. The master agent tender was the mechanism for building all of it.
Specialists who had weighed in on the program’s design over the past year now wait to see whether the Ministry will issue a new tender, restructure the procurement, or build operational capacity within APCI directly. The Ministry has not indicated which.
The resolution leaves one procedural door open. Bidders have 20 business days from notification to file a motion for reconsideration with the Ministry of Economy, which automatically escalates to a higher-authority appeal if denied.
Alternatively, they may skip the reconsideration step and file that higher-authority appeal directly within 30 business days. Whether any of the disqualified or displaced bidders will contest the cancellation itself remains to be seen.
The decision was signed the same day as Argentina’s March inflation reading, which President Milei described as “bad,” and one day before Caputo’s meeting in Washington with IMF Managing Director Kristalina Georgieva to advance the second review of the country’s IMF program.
For applicants, agents, and observers who had been waiting on the program’s parameters since the framework was first established in mid-2025, the immediate effect is a reset to zero. The legal pathway exists. The pathway to operationalising it does not.
