The end of golden visas in the EU: what are the alternatives?

With Portugal and Ireland announcing they’d be closing their golden visas and Spain announcing the proposed elimination of their real estate investment category in this same week, does this spell the beginning of the end for European residency-by-investment programmes? We look at this and other investment options outside of the EU.

Residency- and citizenship-by-investment programmes (sometimes called golden visas) enable individuals to acquire residency and/or citizenship of a country by making a significant financial investment in that country. One of the key benefits of these programmes is access to strong passports that promise visa-free travel to many countries. Currently, the passports of Spain, Ireland and Portugal are among the strongest in the world, ranking in the top ten.

End of days for European golden visas

Last month was an eventful one for EU golden visas. On 14 February, the Irish government announced that it would shut down the popular Ireland Immigrant Investor Programme (IIP). In the wake of this announcement, the Portuguese Prime Minister held a press conference on 16 February to present the outline of a housing reform proposal. This included proposed changes to immigration law and the Golden Visa investment programme.

Shortly after Portugal’s announcement, Spain’s left-wing political party, Mas Pais, announced that it had submitted a bill to Congress to repeal Spain’s Golden Visa. It argues that the programme does not benefit the country and has driven up property prices and should therefore be abolished.

These announcements follow EU-wide discussions on limiting golden visas, which have placed the spotlight on preventing people involved in money laundering, tax evasion and other crimes from benefiting from such visas.

For those who have already invested in the Portugal Golden Visa programme, it is important to understand that no changes have yet been legislated or approved. Ireland’s IIP programme ended abruptly on 15 February, but the government has given approved funds (such as Sable International’s partner, the IDLF) three months to attract final investors and submit final applications.

Remaining EU citizenship-by-investment programmes

A few attractive European programmes are still available, for instance Malta and Greece.

The Mediterranean island of Malta offers two separate programmes – the Exceptional Services by Direct Investment (ESDI) programme, for citizenship, and the Malta Permanent Residence Programme (MPRP), for permanent residency. Both of these programmes do not require you to relocate and allow you to include your spouse and children among other family members.

The ESDI requires a minimum investment amount of €610,000 or €760,000 non-refundable contributions plus real estate purchase or five-year property lease. Each additional dependant will also need to make a €50,000 non-refundable government contribution. The MPRP requires a minimum investment amount of only €100,000 plus real estate purchase or five-year property lease. The main applicant is, however, required to possess capital/assets of not less than €500,000, of which €150,000 must be in financial assets.

Buying property in Greece is another way to obtain a residence permit and build wealth in Europe. With the purchase of a property worth €250,000 or more, you are eligible to apply for a long-term residence permit, which cannot be revoked once granted. The only requirement is that you maintain ownership of property in Greece in order to keep your residence permit. The residence permit for Greece opens many doors for investors and their families. After seven years of residence in the country, it’s possible to apply for citizenship through naturalisation. Greece allows its citizens to hold multiple citizenships.

Citizenship by investment options outside of the EU

As appealing as the EU is, there are many great programmes outside of Europe that offer excellent benefits.


Grenada’s citizenship-by-investment programme, with a processing time of seven to nine months, is the best option for South Africans seeking global mobility and the security of a second passport without the hassle of moving abroad. A minimum investment amount of $150,000 NTF government donation or $220,000 real estate investment plus $50,000 government contribution will secure your passport.

A visit to the island is not required during your naturalisation process, nor is there a minimum stay required afterward. With this freedom, you can travel to your heart’s content, as a Grenadian passport grants visa-free entry to over 140 countries (compared to 105 countries for South Africans), including the Schengen area, the United Kingdom, Hong Kong, Singapore, China and Russia.

Feel free to bring your closest family members along on any trips you plan in this region, as this passport also allows you to include your spouse and children among other relatives.

Read also: Business and leisure travel made easier with the Grenada citizenship-by-investment programme


The Mauritius investment programme presents a simple, efficient and straightforward procedure for obtaining a residence permit. Investors and their family members can obtain long-term residency status by purchasing a qualifying property in a government-approved development with a minimum investment of $375,000. As in Greece, as long as the investor owns the property, their residency status remains valid.

Investors considering Mauritius’s residency programme will be interested in the generous tax regime. Mauritius-based companies enjoy significant tax benefits. The full corporation tax rate is 15%, although tax credits that apply to global businesses mean an effective tax rate of only 3%. In addition, there is no capital gains tax and no withholding tax on dividends in Mauritius.


The US EB-5 visa is a route to permanent US residency for those willing to make a significant investment in the USA. For the EB-5 programme there are two qualifying investment options, a passive or an active investment.

The preferred investment option is via the Regional Centre programme. To meet the EB-5 eligibility criteria, applicants are required to make a qualifying investment of $900,000 into a Regional Centre project located in a Targeted Employment Area (TEA) (or rural area). Each investment must generate employment for a minimum of 10 US workers. Sable International’s expert advisers can help you choose the one that’s right for you.

The EB-5 is currently the quickest way for you and your family to obtain a green card. Permanent green card holders are allowed to live and work in the United States and have access to almost all the same benefits as US citizens. You will not be restricted to the state in which you invest, which opens a wide range of opportunities for you and your family.

With so many options still available, despite the EU closing their golden visa programmes, South Africans are still able to seek a second passport through residency and citizenship-by-investment programmes and reap all the benefits they offer.

With over 20 years of experience assisting people with their complex cross-border financial and emigration needs, Sable International can help answer your questions and choose the best investment programme for you and your family, tailored to your specific needs.

Get in touch with an investment migration consultant now at [email protected] or call us on +27 (0) 21 657 1584.

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