• Insights

From Investment to Merit: Malta’s Citizenship Reset

September 11, 2026

Countries / Territories

  • MaltaMalta
  • United KingdomUnited Kingdom
  • IrelandIreland

Related contacts

Isobel Neilson - web porthole

Isobel Neilson

Director

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9325

Photo of Sophie Jo Wasson

Sophie Jo Wasson

Manager

Dublin, Ireland

Email

[email protected]

T:+44 (0) 20 7090 9143

Related insights

  • Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Related offices

  • London
  • Dublin

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Isobel Neilson - web porthole

Isobel Neilson

Director

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9325

Photo of Sophie Jo Wasson

Sophie Jo Wasson

Manager

Dublin, Ireland

Email

[email protected]

T:+44 (0) 20 7090 9143

Related insights

  • Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Related offices

  • London
  • Dublin

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Isobel Neilson - web porthole

Isobel Neilson

Director

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9325

Photo of Sophie Jo Wasson

Sophie Jo Wasson

Manager

Dublin, Ireland

Email

[email protected]

T:+44 (0) 20 7090 9143

Related insights

  • Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Related offices

  • London
  • Dublin

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Isobel Neilson, Sophie Jo Wasson

How Malta responded to the end of its citizenship by investment programme by strengthening and expanding its existing provisions for merit-based naturalisation.

In April 2025, the Court of Justice of the European Union ruled that Malta's citizenship by investment (CBI) programme was contrary to EU law, effectively bringing the programme to an abrupt end.

Among its concerns, the Court found that a naturalisation process in which citizenship was granted in direct exchange for predetermined payments or investments through a transactional procedure amounted to the commercialisation of Maltese citizenship and, by extension, EU citizenship.

In July 2025, the Maltese Citizenship Act was amended, removing references to the investment-based route and returning to the national competence concept - a concept already embedded in its citizenship legislation - exercised consistently with EU law, to naturalise individuals on the basis of exceptional merit.

Malta is not the only country in the EU who allows naturalisation based on merit. Most other EU countries have legislation to allow this mechanism take place - there have been several highly-publicized cases of athletes, high-profile international artists, philanthropists, scientists or business leaders being granted discretionary citizenship in this manner – so the concept is not new. The exact legal test, and the frequency this kind of citizenship is granted, varies significantly between countries.

The distinction between investment-based and merit-based naturalisation is important.

Under a conventional CBI programme, the process is generally structured around prescribed financial and eligibility requirements. The state determines the qualifying investment or contribution, the applicant satisfies those requirements and, subject to eligibility and due diligence, the assessment follows a comparatively standardised framework.

Malta’s citizenship by merit framework starts from a different premise.

There is no prescribed investment which creates an entitlement to citizenship. Instead, the focus is on the individual: who they are, what they have achieved, why they may be of exceptional interest to Malta, and what extraordinary service or contribution they can offer to Malta or to humanity.

That contribution may arise through entrepreneurship, science, technology, philanthropy, culture, sport, research or another field in which the individual’s experience and achievements can provide genuine value. Crucially, the legislation does not create a simple financial equation between contribution and citizenship.

This makes the framework more complex and less predictable than a traditional CBI programme. For the right applicant, however, that selectivity may be one of its greatest strengths, offering an opportunity to make a meaningful contribution aligned with their existing profile and achievements. This raises an interesting question - if merit-based citizenship is inherently more selective, is that necessarily a disadvantage?

Why selectivity has value

For many internationally mobile families acquiring additional citizenship is a long-term strategic decision. They consider not only current mobility benefits, but also how the citizenship was obtained and whether its basis will remain credible over time.

Against that backdrop, selectivity has value.

A framework that cannot be reduced to a prescribed payment, requires an individual assessment of merit and asks applicants to demonstrate genuine added value is inherently more difficult to access. It is also considerably harder to characterise as the simple purchase of citizenship.

For the right applicant, therefore, the absence of a prescribed formula should not necessarily be regarded as a weakness.

However, the credibility of the revised framework will ultimately depend not only on its legal design, but also on how selectively, consistently and transparently it is applied in practice. The absence of a prescribed formula does not determine whether an individual case satisfies the principles identified by the Court.

What makes a compelling merit-based case?

Where citizenship is sought based on exceptional merit and national interest, an applicant’s relationship with Malta cannot sensibly be treated as a box-ticking exercise.

Although the legislation does not reduce the assessment to a single test of connection, a persuasive application should demonstrate that the applicant’s proposed contribution arises from a credible and meaningful engagement with Malta.

Visits, memberships, donations or other engagements may support an application, but will carry limited weight if they appear to have been undertaken solely for that purpose. They are most persuasive when they reflect a broader connection arising naturally from the applicant’s circumstances, achievements, interests and long-term intentions.

The focus is on demonstrating a credible connection between the applicant and Malta, and this includes alignment between the applicant's background, expertise and interests and the country's long-term priorities, together with a genuinely distinctive contribution and a broader engagement with Malta that stands on its own merits.

For an entrepreneur, that connection may develop through investment, business activity and job creation. For a scientist or technologist, it may arise through research, innovation or the transfer of expertise. For a philanthropist, it may involve sustained support for an area of genuine national need. For others, culture, sport or another field of exceptional achievement may provide the natural connection.

The precise form of the connection matters less than its authenticity.

A compelling application should tell a coherent story, with the applicant’s achievements, proposed contribution and relationship with Malta reinforcing one another and demonstrating why their naturalization would genuinely serve Malta’s national interest. The applicant and the proposal are then subject to individual assessment and due diligence with the ultimate decision remaining exceptional and discretionary.

This requires a fundamentally different mindset from asking how an applicant can do the minimum necessary to satisfy a programme.

The better question to consider is what would a genuine and meaningful relationship with Malta look like for this individual?

Even where that question can be answered convincingly, a compelling case creates a basis for consideration, not an entitlement to citizenship.

Need to know more?

For more information, please contact Director Isobel Neilson at [email protected] or Manager Sophie Jo Wasson at [email protected].

This blog was published on 11 September 2026 and reflects information available at that time. Updates may occur as policies evolve. To stay informed on the latest immigration news and analysis, please subscribe to our alerts and follow us on LinkedIn, Twitter, Facebook and Instagram.  

Countries / Territories

  • MaltaMalta
  • United KingdomUnited Kingdom
  • IrelandIreland

Related contacts

Isobel Neilson - web porthole

Isobel Neilson

Director

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9325

Photo of Sophie Jo Wasson

Sophie Jo Wasson

Manager

Dublin, Ireland

Email

[email protected]

T:+44 (0) 20 7090 9143

Related insights

  • Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Related offices

  • London
  • Dublin

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Isobel Neilson - web porthole

Isobel Neilson

Director

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9325

Photo of Sophie Jo Wasson

Sophie Jo Wasson

Manager

Dublin, Ireland

Email

[email protected]

T:+44 (0) 20 7090 9143

Related insights

  • Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Related offices

  • London
  • Dublin

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Isobel Neilson - web porthole

Isobel Neilson

Director

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9325

Photo of Sophie Jo Wasson

Sophie Jo Wasson

Manager

Dublin, Ireland

Email

[email protected]

T:+44 (0) 20 7090 9143

Related insights

  • Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Related offices

  • London
  • Dublin

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Media mentions

Conexão Ásia: Além da China, profissionais das Filipinas, Índia, Japão e Bangladesh se destacam na imigração laboral asiática para o Brasil

Managing Director Diogo Kloper examines how immigration trends reveal the diverse economic ties between Brazil and Asia and the role of international mobility in supporting business growth.

Learn more

Media mentions

AILA Law Journal: Administrative Proxies in Immigration Adjudication

Partner David Grunblatt examines how USCIS uses administrative proxies in immigration adjudication and explains why these tools must support, rather than replace, statutory standards and individualized legal analysis.

Learn more

Blog post

International Talent in the Netherlands: Building a Talent Pipeline Without Losing Sight of Compliance

Manager Cherida Hooijer and Immigration Assistant Manager Kaatje Droesbeke examine how employers in the Netherlands can build an international student-to-graduate talent pipeline while managing the immigration and employment compliance requirements that apply at each stage.

Learn more

Video

Moving to Costa Rica? Visa and Residency Options Explained

Senior Immigration Program Manager Ana Carro explains Costa Rica's immigration pathways for digital nomads, retirees, individuals with stable income and investors, highlighting key eligibility requirements and considerations for choosing the appropriate option.

Learn more

Media mentions

Business Insider: The Winners and Losers of the New H-1B Era

Partner Catherine Macris discusses how evolving H-1B policies are shaping employers’ ability to recruit foreign talent, particularly in highly specialized fields.

Learn more

Awards

Fragomen Professionals and Employee Network Shortlisted for 2027 TLC Lions Human Awards Europe

Two Fragomen professionals and our BeYou@Fragomen employee network have been shortlisted for the 2027 TLC Lions Human Awards Europe, recognising their contributions to inclusive leadership and a people-centred workplace culture.

Learn more

Awards

Fragomen’s Worldwide Immigration Trends Report 2026 Wins at the FEM EMEA EMMAs

Fragomen is honored with the 2026 FEM EMEA EMMA in the "Thought Leadership - Best Survey or Research Study of the Year" category for its 2026 Worldwide Immigration Trends Report. 

Learn more

Media mentions

Law360: How A New Case Redefines The Birthright Citizenship Battle

Partner Daniel Pierce and Senior Associate Daniel D. Schaeffer examine US birthright citizenship challenges and the implications of recent court rulings for nationwide relief in immigration litigation.

Learn more

Video

What Is ESTA? Five Common Mistakes to Avoid When Traveling to the US

Los Angeles Partner Emily Allen explains what ESTA is, who may be eligible under the US Visa Waiver Program and five common mistakes travelers should avoid when visiting the United States for business or tourism.

Learn more
Generic Insights

Fragomen news

Case Study: Securing a Positive Outcome in a Complex Adult Dependent Relative Appeal

Fragomen supported an Adult Dependent Relative applicant through a complex appeal, using coordinated medical and social care evidence to demonstrate his holistic care needs before the Home Office withdrew its refusal and indicated that the application would be granted.

Learn more

Blog post

Moving Talent, Moving Families: Navigating Family Reunification in Europe

Senior Manager Andreia Ghimis and Senior Immigration Consultant Louise Farren explore how family reunification rules across Europe can affect international moves and why employers should assess family eligibility, immigration requirements and likely timelines alongside an employee’s work authorization.

Learn more

Media mentions

Business Insider: How Would the $70,000 Fee on International Students Working in the US Impact Schools and Grads? 2 Lawyers Break It Down.

Partner Aaron Blumberg discusses how a proposed $70,000 fee for international students seeking US work authorization could affect students, universities and employers.

Learn more

Media mentions

Conexão Ásia: Além da China, profissionais das Filipinas, Índia, Japão e Bangladesh se destacam na imigração laboral asiática para o Brasil

Managing Director Diogo Kloper examines how immigration trends reveal the diverse economic ties between Brazil and Asia and the role of international mobility in supporting business growth.

Learn more

Media mentions

AILA Law Journal: Administrative Proxies in Immigration Adjudication

Partner David Grunblatt examines how USCIS uses administrative proxies in immigration adjudication and explains why these tools must support, rather than replace, statutory standards and individualized legal analysis.

Learn more

Blog post

International Talent in the Netherlands: Building a Talent Pipeline Without Losing Sight of Compliance

Manager Cherida Hooijer and Immigration Assistant Manager Kaatje Droesbeke examine how employers in the Netherlands can build an international student-to-graduate talent pipeline while managing the immigration and employment compliance requirements that apply at each stage.

Learn more

Video

Moving to Costa Rica? Visa and Residency Options Explained

Senior Immigration Program Manager Ana Carro explains Costa Rica's immigration pathways for digital nomads, retirees, individuals with stable income and investors, highlighting key eligibility requirements and considerations for choosing the appropriate option.

Learn more

Media mentions

Business Insider: The Winners and Losers of the New H-1B Era

Partner Catherine Macris discusses how evolving H-1B policies are shaping employers’ ability to recruit foreign talent, particularly in highly specialized fields.

Learn more

Awards

Fragomen Professionals and Employee Network Shortlisted for 2027 TLC Lions Human Awards Europe

Two Fragomen professionals and our BeYou@Fragomen employee network have been shortlisted for the 2027 TLC Lions Human Awards Europe, recognising their contributions to inclusive leadership and a people-centred workplace culture.

Learn more

Awards

Fragomen’s Worldwide Immigration Trends Report 2026 Wins at the FEM EMEA EMMAs

Fragomen is honored with the 2026 FEM EMEA EMMA in the "Thought Leadership - Best Survey or Research Study of the Year" category for its 2026 Worldwide Immigration Trends Report. 

Learn more

Media mentions

Law360: How A New Case Redefines The Birthright Citizenship Battle

Partner Daniel Pierce and Senior Associate Daniel D. Schaeffer examine US birthright citizenship challenges and the implications of recent court rulings for nationwide relief in immigration litigation.

Learn more

Video

What Is ESTA? Five Common Mistakes to Avoid When Traveling to the US

Los Angeles Partner Emily Allen explains what ESTA is, who may be eligible under the US Visa Waiver Program and five common mistakes travelers should avoid when visiting the United States for business or tourism.

Learn more
Generic Insights

Fragomen news

Case Study: Securing a Positive Outcome in a Complex Adult Dependent Relative Appeal

Fragomen supported an Adult Dependent Relative applicant through a complex appeal, using coordinated medical and social care evidence to demonstrate his holistic care needs before the Home Office withdrew its refusal and indicated that the application would be granted.

Learn more

Blog post

Moving Talent, Moving Families: Navigating Family Reunification in Europe

Senior Manager Andreia Ghimis and Senior Immigration Consultant Louise Farren explore how family reunification rules across Europe can affect international moves and why employers should assess family eligibility, immigration requirements and likely timelines alongside an employee’s work authorization.

Learn more

Media mentions

Business Insider: How Would the $70,000 Fee on International Students Working in the US Impact Schools and Grads? 2 Lawyers Break It Down.

Partner Aaron Blumberg discusses how a proposed $70,000 fee for international students seeking US work authorization could affect students, universities and employers.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
October 21, 2026 | JapanJapan: Mandatory Tuberculosis Screening for Certain Visa Applicants Forthcoming
October 21, 2026 | AustraliaAustralia: Character Considerations for Visa Decisions Strengthened
October 21, 2026 | AustraliaAustralia: Student Visa Application and Family Inclusion Rules Tightened
October 21, 2026 | BrazilConexão Ásia: Além da China, profissionais das Filipinas, Índia, Japão e Bangladesh se destacam na imigração laboral asiática para o Brasil
October 21, 2026 | New Zealand, IndiaIndia/New Zealand: Free Trade Agreement Will Provide New Zealand Increased Access to Talent from India
October 21, 2026 | JapanJapan: Mandatory Tuberculosis Screening for Certain Visa Applicants Forthcoming
October 21, 2026 | AustraliaAustralia: Character Considerations for Visa Decisions Strengthened
October 21, 2026 | AustraliaAustralia: Student Visa Application and Family Inclusion Rules Tightened
October 21, 2026 | BrazilConexão Ásia: Além da China, profissionais das Filipinas, Índia, Japão e Bangladesh se destacam na imigração laboral asiática para o Brasil
October 21, 2026 | New Zealand, IndiaIndia/New Zealand: Free Trade Agreement Will Provide New Zealand Increased Access to Talent from India
October 21, 2026 | JapanJapan: Mandatory Tuberculosis Screening for Certain Visa Applicants Forthcoming
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.