From Investment to Merit: Malta’s Citizenship Reset

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.