THE RECORD
Every index tells you how good a programme is to buy. None of them records what happened to investors when programmes changed. We do.
THE HEADLINE
Ireland closed its investor programme with one day's notice.
Programme ruled unlawful and then ended by statute
The Court of Justice of the European Union ruled on 29 April 2025, in Case C-181/23, that the programme was unlawful. Act XXI of 2025, gazetted on 24 July 2025, ended it. The status of citizens already naturalised under the programme is not cleanly resolved.
Source: curia.europa.eu, Case C-181/23; Malta Government Gazette, Act XXI of 2025
Residence by investment repealed
Organic Law 1/2025, published on 3 January 2025, repealed the route with effect from 3 April 2025. Holders and applicants who filed before the deadline retain their rights and renew in five-year periods while the qualifying investment is maintained.
Source: BOE, Organic Law 1/2025
Residence requirement extended from five to ten years
An October 2025 law extended the naturalisation requirement from five to ten years. The Constitutional Court blocked the initial version in January 2026. Grandfathering for existing residents is likely but not yet confirmed.
Source: Diário da República; Constitutional Court ruling, January 2026
Real estate route removed by Mais Habitação
Law 56/2023, the Mais Habitação package, removed the real estate route with effect from 7 October 2023. Existing investors were grandfathered, and renewals and family reunification were preserved.
Source: Diário da República, Law 56/2023
Programme closed to new applications
The Immigrant Investor Programme closed on 15 February 2023 with one day's notice. Existing holders and approved projects were unaffected, and applications already in hand were processed. €1.252 billion had been approved across 1,788 applications.
Investor citizenship route ended
The investor citizenship route ended in 2022.
Source: State Gazette, 2022 amendment
Programme scrapped, existing citizenships challenged
The programme was scrapped in 2020 after scandal. Authorities subsequently attempted to revoke 26 investor citizenships, and legal challenges are continuing in the courts.
Source: Republic of Cyprus announcements, 2020; Documented in Surak, LSE, 2021
Grandfathering has been the norm. It has never been a guarantee.
Six of seven events protected existing investors. Cyprus is the seventh.
Hungary's 2024 reopening, Greece's threshold increases, and the United Kingdom's 2022 investor visa closure are known events not yet confirmed to primary sources, and are therefore not in the record.
Nothing enters the record without a primary source.
Check the legislative process of the country, not the marketing of the seller.
Assume protection is conditional on maintaining the qualifying investment.
Treat any programme under supranational legal pressure as carrying the Malta risk, not the Portugal risk.
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If you hold one of these programmes and do not know which verdict would apply to you, that is a fifteen-minute conversation.