European Parliament research estimates that citizenship-by-investment schemes in EU member states involved 8,769 people and €7.497 billion between 2011 and 2019. A comprehensive new 519-page, 267-source study examines what ended and what remains, using a detailed reference case to illustrate how separate legal instruments can address some of the objectives that drove demand.

CAPE TOWN, South Africa, Aug. 11, 2026 /PRNewswire-PRWeb/ -- Kestrel Private has published a comprehensive 519-page, 267-source research report examining where the demand for Europe's golden passports went following the end of formal investor-citizenship programmes in EU member states. It sets out what remains legally available and uses a detailed reference case to show how a second citizenship outside the EU, a European residence permit and qualifying property can be coordinated to address some of the objectives that drove that demand.

"After the EU's Golden Passports: What Ended, What Remains, and How a Lawful Structured Alternative Should Be Assessed" distinguishes the end of Europe's purchasable, repeatable citizenship product from the continuing demand for geographic resilience, lawful residence, easier short-stay Schengen movement and internationally diversified assets.

European Parliament research cited in the report estimates that 3,811 citizenship-by-investment applications in EU member states between 2011 and 2019 covered 8,769 people, including family members, compared with 38,369 investor-residence applications covering 123,374 people. Estimated investment over the same period was €7.497 billion through citizenship schemes and €13.877 billion through residence schemes.

The two legal statuses are not equivalent, and the report does not treat them as such. The figures nevertheless show that investor residence — not citizenship — accounted for the substantially larger volume of participants even before EU investor-citizenship programmes ended.

Demand for European residence remains significant in stock terms. In Greece, official data recorded 30,439 investor permits and 56,917 permits for family members in force in March 2026 — 87,356 in total. New initial investor-permit filings nevertheless fell from 864 in March 2025 to 427 in March 2026.

"The end of European investor citizenship did not end the objectives that created the market. It did make precision more important. A passport, a residence permit, a property and a tax position can be coordinated as one international position, but they remain distinct legal instruments, and each must justify itself on its own terms," said Andrew J. Taylor, Founder and Managing Partner of Kestrel Private.

The report examines the legal position following the Court of Justice of the European Union's judgment in Commission v Malta (C-181/23) on 29 April 2025. Among its findings, it concludes that the Court did not create a general "genuine link" test for nationality. It held that Malta had breached EU law — Article 20 TFEU and Article 4(3) TEU — by establishing and operating a transactional naturalisation scheme. The judgment was declaratory under Article 258 TFEU; Malta subsequently repealed the investment route itself.

What remains at the citizenship level is naturalisation for merit or exceptional service, decided case by case, with no published price and no entitlement to approval. The closed schemes were discretionary in form as well; what set them apart was that they were priced, published and repeatable.

To demonstrate its assessment method, the report places three independently assessed components side by side: citizenship under São Tomé and Príncipe's 2025 framework; a five-year Greek investor residence permit supported by qualifying property under Greece's restricted €250,000 change-to-residential-use category; and the qualifying Greek property assessed separately as a retained asset. Only where appropriate may a distinct company, banking or tax-residence layer be added.

The report is explicit about the legal boundaries. São Tomé and Príncipe citizenship creates no EU rights. A Greek investor residence permit provides the right to reside in Greece and short-stay mobility across the Schengen Area, but it is not EU citizenship, does not confer EU free-movement rights and does not establish a right of access to any form of employment. The property must also justify itself independently on title, value, income potential, permitted use, resale and downside risk.

No component is presented as curing a weakness in another, and the reference case is not offered as a universal recommendation.

"Our report includes a comprehensive worked example of how a second citizenship outside the EU, a European residence permit and qualifying property can be coordinated to address some of the objectives that drove demand for European investor citizenship," Taylor said. "Every family starts from a different position: the citizenships its members already hold, the countries they need to reach and the rights they want available."

The research separates statutory law, official administrative material, market evidence and practitioner interpretation. Claims are supported through 267 cited sources and a claim-and-evidence register, while matters the research could not establish conclusively are identified as such.

The full report is available at:

https://kestrelprivate.com/research/after-the-golden-passports

Supporting findings, media materials, author information and publication-ready images are available at:

https://kestrelprivate.com/media

ABOUT KESTREL PRIVATE

Kestrel Private is a principal-led private-client firm headquartered in Cape Town. The firm advises private families worldwide on residence and citizenship, coordinating the qualifying investments and structures around them. Every engagement is led personally by Founder and Managing Partner Andrew J. Taylor, from initial assessment through final delivery and aftercare. Regulated legal, tax and immigration work is performed by admitted local counsel in each jurisdiction. Kestrel Private is an advisory and end-to-end coordination firm, not a law firm or an authorised financial services provider.

Media Contact

Media Relations, Kestrel Private, 27 87 813 4027, media@kestrelprivate.com, https://kestrelprivate.com

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SOURCE Kestrel Private