Argentina’s Ministry of Economy has issued an official tender for a four-year consulting contract that will design, implement, and operate the country’s first citizenship by investment (CBI) program.
The tender, number 34-0001-CPU25, closes January 20, 2026, with the formal bid opening taking place immediately as the submission period ends..
The Agencia de Programas de Ciudadanía por Inversión (APCI), a decentralized agency created under Decree 366/2025 and regulated by Decree 524/2025, will oversee the program.
Government officials project the initiative will process up to 5,000 favorable recommendation reports during the initial contract period.
Payment Structure Prevents Distribution Monopoly
Argentina will compensate the winning consultancy only for applications that independent agents or third parties submit. The tender explicitly excludes payment for cases that the contractor sources directly.
The documents state that “the co-contractor will receive the fixed amount solely for applications submitted by local agents or managers or third parties unrelated to the awardee itself.”
This clause forces the master operator to build a certified agent ecosystem rather than control the entire market.
Bidders will receive US dollar payments at a fixed fee per approved application, structured across five tranches of 1,000 applications each. For bid evaluation purposes, the tender applies declining weighted coefficients (2.00, 1.75, 1.50, 1.25, 1.00) to successive tranches when comparing competing proposals.
The contractor receives compensation only after APCI issues an informe circunstanciado recomendando la aprobación (detailed report recommending approval) for each application. Rejected applications generate no payment. Invoices carry 45-day payment terms.
The tender permits the consultancy to charge investors directly for processing and due diligence services. Government payments cover applications from certified agents, while investor fees compensate for self-sourced cases and operational costs.
Four Implementation Milestones Over 48 Months
Milestone 1: Design
- Completion required within two months of contract start
- Program rules, processes, manuals
- Staffing profiles and cost estimates
- Implementation timeline
- Deliverable requires APCI Director approval
Milestone 2: Implementation + Launch Planning
- Completion required within six months of contract start
- Operational capacity development
- International positioning strategy
- APCI certification as ready to receive applications
- Approved launch plan
Milestone 3: Launch Execution
- Completion required within 12 months of contract start
- International marketing strategy implementation
- Target market penetration
- APCI Director approval of execution
Milestone 4: Annual Promotion + Technical Assistance
- Ongoing promotion and technical support through month 48
- Marketing strategies for years two, three, and four
- Control point deliverables reviewed at months 24, 36, 48 (and potentially month 60 if contract extended)
Bidder Qualification Requirements Exceed Standard Procurement
Firms must demonstrate proven expertise in residence and citizenship by investment programs. At least one governmental mandate within the past 10 years constitutes a mandatory requirement.
Legislative drafting experience carries particular weight. Contractors must have written CBI legislation or regulations for other jurisdictions.
Senior team composition requires a minimum of five directors or executives, each possessing at least five years of RCBI-specific experience. Detailed CVs with project specifics must accompany all bids.
International networks factor heavily into evaluation. The tender requires relationships with CBI agents, financial institutions, due diligence firms, legal advisors, and wealth management companies.
Technical Merit Carries 60% Weight
Evaluation assigns 60% weight to technical criteria and 40% to economic competitiveness. Technical scoring allocates 20 points each across five categories:
Program Uniqueness (20 points)
- Innovation and economic impact
- Alignment with national development goals
- Global competitiveness strategy
Expertise (20 points)
- Human capital, technology, infrastructure
- Legal experience and operational support
- Digital solutions and international communications deployment
Track Record (20 points)
- Demonstrated program design and launch experience
- Case studies and governmental stakeholder engagement
- Regulatory and supranational environment navigation
Business Plan (20 points)
- Strategic vision for development, launch, execution, promotion
- Long-term sustainability
- Economic benefit to Argentina
International Network (20 points)
- Global reach and promotional alliances
- Relationships with agents, financial institutions, audit firms, legal advisors, and wealth managers
Financial Solvency Standards Eliminate Undercapitalized Bidders
Contractors must submit certified fiscal year reports demonstrating:
- Debt-to-equity ratio ? 0.50
- Current ratio ? 1.00
- Solvency (assets/liabilities) ? 2.00
- Profit margin ? 0.10
A certified public accountant must verify all financial statements.
Mandatory Declarations Span Eight Compliance Areas
Bidders must submit sworn statements covering:
- Eligibility to contract (no tax/social security debts, criminal convictions, or government employment)
- Anti-competitive conduct absence
- Sustainable procurement compliance
- Disability workforce requirements (Decree 312/2010)
- Information security policy compliance
- Integrity programs (Law 27.401 on corporate criminal liability)
- Conflict of interest disclosures (Decree 202/17)
- Relationships with the President, Vice President, Cabinet Chief, Ministers, or decision-making authorities
Three officials hold decision authority over the tender: Minister of Economy Luis Andrés Caputo, Legal and Administrative Secretary José Ignacio García Hamilton, and Undersecretary of Administration Gabriel Martín Crugeiras.
Performance Benchmarks Enable Unilateral Termination
The contract permits government termination if application volumes fall short of specific targets:
- Fewer than 200 approvals by month 24
- Fewer than 300 approvals by month 36 (or fewer than 100 between months 25-36)
- Fewer than 400 approvals by month 48 (or fewer than 100 between months 37-48)
Early termination compensation equals payment for 100 approvals, recognizing sunk costs for completed milestones. The government will not pay lucro cesante (lost profits).
Contract duration extends to four years or 5,000 approved applications, whichever occurs first. A single one-year extension remains possible.
Penalty Provisions Enforce Timeline Compliance
Missing Milestone 1, 2, or 3 deadlines costs 1% of the total contract value. Each missed annual control deliverable at months 24, 36, or 48 (and potentially month 60 if extended) incurs a 0.5% penalty.
Five total violations or two or more violations of the same type permit contract rescission.
Investment Thresholds Remain Undefined
The tender provides no preset investment minimums. The winning consultancy will design investment categories, establish criteria, advise APCI on suitability, and help establish evaluation standards.
Neither Decree 366/2025 nor Decree 524/2025 specifies investment amounts. Media reports and industry speculation have cited figures such as $500,000, but no such threshold appears in any official government document or legal text.
The winning consultancy gains influence over threshold recommendations while final authority remains with APCI and the Ministry of Economy.
The winning consultancy’s business plan must demonstrate alignment with “national development goals,” indicating investments supporting Argentina’s economic priorities will receive favorable consideration. Emphasis on “real economy investment” suggests preferences for productive sectors over passive holdings.
Based on the tender’s emphasis on economic development and productive investment, eligible areas could include agribusiness, renewable energy, mining, technology, tourism infrastructure, industrial capacity, job creation pathways with employment requirements, and knowledge economy investments.
Real estate may qualify only as part of productive investment projects, though the tender does not explicitly enumerate eligible sectors.
Required Services Include Multiple Categories
The tender mandates a range of services, including:
- Legislative consulting and comparative advantage analysis
- Functional program development (structure, mechanisms, processes, optimized application forms, service standards, policies, procedures, workflows, timelines)
- Implementation agendas with action plans and schedules
- Initial launch planning (international outreach, applicant pipeline, positioning at the highest international standards)
- Annual international promotion strategies requiring APCI Director approval
- Foreign direct investment attraction strategies
- Implementation programs, guidance, and APCI training
- Online application and evaluation system with multi-level due diligence
- Government facilities and resources utilization plans
- Financial projections (revenue, costs, application volumes)
- Ad hoc support tasks throughout contract execution
APCI Starts Without Existing Infrastructure
The Ministry of Economy resolution establishing the procurement notes that “APCI is not yet constituted and does not have a formal structure or appointed head.”
The winning consultancy will define early processes, build operational capacity, and transfer institutional competence over time. This positions the contractor as an institutional architect rather than a mere operational vendor.
Submission Requirements Demand Comprehensive Documentation
Bidders must provide:
- Cover letters
- Executive summaries (?3,000 words) addressing firm history, key personnel biographies, service descriptions, program outline, regulatory compliance, international networks
- Organizational profiles with corporate structure and key personnel CVs
- Certified experience documentation
- Financial solvency reports
- Management plans with timelines
- Proposed services descriptions
- Financial impact assessments with investment projections and applicant fee proposals
Guarantee Structure Protects Government Interests
Bid Bond: 5% of total offer
- Mandatory at submission
- Waived for contracts below 1,000 módulos (approximately 40 million Argentine pesos)
Challenge Bond: 3% of challenged line item
- Required only when contesting another bidder’s evaluation
Under the general regime for open purchase order contracts (orden de compra abierta), this procurement does not require a separate performance guarantee beyond the bid and challenge guarantees.
All guarantees must carry US dollar denomination.
Timeline Leaves 46 Days for Proposal Development
| Event | Date |
|---|---|
| Publication | December 5, 2025 |
| Consultation period | December 5, 2025 through January 9, 2026 |
| Submission deadline | January 20, 2026, 10:00 |
| Bid opening | December 5, 2025, through January 9, 2026 |
The tender explicitly allows confirmation of offers up to the moment of opening, explaining why both timestamps match.
What This Means for Investment Migration Consultancies
The payment exclusion clause creates a hybrid ecosystem by design rather than accident. Argentina structures the contract to prevent gatekeeping while ensuring professional operation.
Master Operator Role
The winning consultancy becomes the program’s technical and operational backbone. Processing all applications, whether from certified agents or self-sourced, the contractor operates the evaluation system and issues recommendation reports to APCI.
This positions the master operator as an infrastructure provider rather than a market monopolist.
Mandatory Ecosystem Development
The government pays the contractor only for applications that independent agents submit. This payment structure forces ecosystem development.
Agent Certification Framework Coming
The tender presumes a future certification system governing agent registration, though specific requirements remain undefined. Investment migration consultancies will likely need certification to submit applications through the official channel.
Certification frameworks may establish:
- Due diligence requirements for agents
- Code of conduct standards
- Marketing compliance rules
- Application submission protocols
- Annual re-certification processes
Early Mover Advantages
APCI starts without existing infrastructure or appointed leadership. The winning consultancy will define initial processes, establish operational standards, and shape agent relationships during the critical first two years.
Revenue Model Flexibility
The tender permits the consultancy to charge investors directly for processing and due diligence. This creates pricing flexibility independent of government fee structures.
Master operators can design tiered service levels, expedited processing options, or premium advisory packages while maintaining baseline compliance with APCI requirements.
Real Economy Investment Focus
Business plan evaluation emphasizes alignment with national development goals and real economy impact.
Based on tender language emphasizing economic development, likely eligible areas could include agribusiness, renewable energy, mining, technology, tourism infrastructure, industrial capacity, job creation pathways, and knowledge economy investments.
Real estate may qualify only as part of productive investment projects, though the tender does not explicitly enumerate sectors.
Quality Over Volume
The 60/40 technical-economic weighting prioritizes expertise over cost minimization. This evaluation structure appears to favor established firms with proven governmental relationships and legislative drafting experience.
Performance Accountability
Volume-based termination rights and milestone deadline penalties introduce enforcement mechanisms absent from most citizenship programs. Investment migration consultancies must deliver applications, not just design programs.
The 200-approval threshold by month 24 suggests government expectations of roughly 100 applications annually during the initial years.
No Preset Investment Minimums
The absence of legally established thresholds creates strategic flexibility but also uncertainty. Investment migration consultancies cannot market specific figures until the winning contractor finalizes program design with APCI approval.
Industry speculation has centered on figures around $500,000, but these remain unconfirmed projections rather than binding policy. The winning consultancy could propose lower thresholds ($300,000-$400,000), higher amounts ($600,000-$750,000), or multi-tier structures with varying minimums across investment categories.
Dual Revenue Optimization
Contractors face competing incentives between government-paid applications (from certified agents) and higher-margin self-sourced cases. The payment structure mitigates this tension by prohibiting government compensation for consultant-sourced applications.
This alignment encourages ecosystem development while protecting direct investor relationships.
Geographic Universality Appears Likely
The tender contains no explicit geographic or nationality restrictions, which suggests potential universal program eligibility subject to due diligence.
Anti-money laundering compliance, source of funds verification, and reputational screening could determine individual eligibility rather than categorical exclusions.
Contract Award Timeline
The 90-day offer validity period, auto-renewable unless providers object 10 days before expiration, allows extended evaluation. Contract awards may not occur until April or May 2026.
Full operational capacity within six months of contract start could place program launch in late 2026 or early 2027.
