New Citizenship by Investment Programs: What Applicants Should Verify Before Committing Funds

Lower investment thresholds may attract applicants, but newer programs can offer less certainty about processing times, financial commitments…

MIAMI, FL, UNITED STATES, November 9, 2026 /EINPresswire.com/ — Newly introduced citizenship by investment (CBI) programs can offer additional options for individuals and families seeking a second citizenship, but their shorter operating histories may make it more difficult to assess how application requirements work in practice.
While lower investment thresholds and different family eligibility rules may be attractive to prospective applicants, the published requirements do not always provide a complete picture of the financial commitments, due diligence procedures or timeframes involved.
A legal assessment published by Harvey Law Group examines these considerations, including how applicants can establish which rules are in force, assess the total cost of an application and identify potential issues before committing funds.

Lower Investment Thresholds May Not Reflect the Full Cost
The minimum contribution or investment advertised by a CBI program is only one part of the overall cost. Applicants may also be required to pay government processing fees, due diligence charges, professional fees and expenses associated with preparing, certifying and translating supporting documents.
These costs can increase when spouses, children or other eligible dependants are included. Applicants should therefore confirm the full financial commitment for their family, including when payments are due and which amounts may be refundable if an application is refused or withdrawn.
The type of qualifying investment also affects the financial risk. Government contributions are non-refundable, while property and other investments may be subject to minimum holding periods and restrictions on disposal. Even where an investment can eventually be sold, recovering the original amount is not guaranteed.

Family Eligibility and Due Diligence Require Closer Examination
Family eligibility rules differ between CBI programs. Although spouses and children can often apply together, adult children, parents and other relatives may need to satisfy additional conditions relating to age, education, financial dependency or marital status, if eligible at all.
Applicants should also confirm whether family members can be added after citizenship has been granted. Some programs permit later additions, but separate eligibility requirements, fees and due diligence checks may apply.|

Due diligence is another consideration, regardless of how recently a program was established. Applicants may need to provide evidence of their financial history, including how their wealth was accumulated and where the funds used for the qualifying investment originated.
Incomplete records, inconsistencies in supporting documents or failures to disclose relevant immigration and citizenship history can lead to additional enquiries or refusal. Issues involving one dependant may also affect the wider family application, depending on the program’s rules and the circumstances involved.

Newer Programs Offer Less Certainty Over Processing and Rule Changes
Newly launched programs have fewer completed applications from which prospective investors can assess processing times and administrative procedures. Published timeframes should therefore be considered as estimates rather than guaranteed completion dates.
Additional background checks, requests for supporting evidence and delays in obtaining documents can extend the application process. Applicants should also establish whether the advertised timeframe includes document preparation, final citizenship formalities and passport issuance.
Changes to program legislation can also create further uncertainty and instability. Governments may amend investment thresholds, eligibility conditions or application procedures, sometimes while applications are already being processed.

Whether an existing application remains subject to the previous rules depends on the legislation and any transitional provisions. Applicants should confirm which requirements are legally in force rather than relying solely on announcements or earlier program information.

Citizenship Benefits May Change After Approval
The benefits associated with citizenship can change over time, particularly where they depend on decisions made by other countries. For example, visa-free travel arrangements are determined by destination countries and may be changed or withdrawn. A change to those arrangements does not necessarily affect the individual’s citizenship, but it may affect the reasons they originally chose the program.
Applicants should also understand the differences between travel access, residence and employment rights. A passport that permits short-term visits to certain destinations does not necessarily provide the right to live or work there.
Depending on the program, citizenship holders may also need to maintain qualifying investments or comply with other ongoing requirements. Failure to satisfy applicable investment conditions, or evidence that citizenship was obtained through fraudulent or misleading information, can place citizenship at risk under the relevant country’s laws.
Newer CBI programs should not be dismissed solely because they have shorter operating histories. However, a lower investment threshold should not be the deciding factor when selecting a program.
Applicants should consider the legal framework, eligibility requirements, total financial exposure and long-term benefits together before committing to an application. Identifying potential problems at an early stage can help avoid unnecessary costs and complications later in the process.

São Tomé and Príncipe and Argentina Illustrate Different Stages of CBI Development
Two recent developments within the CBI market highlight why applicants need to be aware of the differences between a newly established citizenship by investment programme and one that has been announced but is not yet fully operational.

São Tomé and Príncipe citizenship was introduced under Nationality Law No. 7/2022 and Decree-Law No. 07/2025, which entered into force on 1 August 2025. The programme accepts applications through an established administrative framework, with a minimum contribution of USD 90,000 for a single applicant or USD 95,000 for a family of up to four, excluding additional government and processing fees.
Although the programme provides a relatively low investment threshold, applicants must still consider its eligibility conditions, due diligence requirements and shorter processing history when comparing it with more established alternatives.
Argentina’s CBI has received a lot of coverage but is at a different stage. On 2 October 2026, the Argentine government announced further details of its proposed CBI programme, including a non-refundable contribution of USD 350,000 to the National Treasury or an investment of USD 800,000 in a designated government security.

The government indicated that applications were expected to open during the fourth quarter of 2026. However, the announcement did not establish a confirmed opening date or provide all the operational instructions required for applicants to proceed. Until the relevant filing procedures and official guidance are available, prospective applicants should not treat the programme

Jean François Harvey
Harvey Law Group
+1 786-420-6230
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