CBI.me Research Desk · editorial guide ·
Citizenship vs residency by investment
Citizenship by investment can lead to nationality after an approved application. Residency by investment grants immigration status first. A residence permit does not by itself confer nationality or an ordinary citizen passport. Panama has a separate noncitizen special-passport framework.
| Route | Initial outcome | Passport |
|---|---|---|
| Direct citizenship | Nationality after approval | Separate issuance |
| Investor residence | Residence status | Later naturalisation if eligible |
| Special merit | Individual assessment | No fixed purchase entitlement |
Direct citizenship
The Caribbean contribution programmes, Nauru, São Tomé and Príncipe and other investor-citizenship routes assess a citizenship application. The qualifying payment does not guarantee approval.
Residence first
Portugal ARI, Greece Golden Visa, US EB-5 and Malta MPRP grant residence rather than direct citizenship. Later naturalisation involves separate rules. Permit-renewal presence can be much lighter than the physical residence required for nationality.
Staged and discretionary routes
Samoa’s statute includes a three-year permanent-residence stage and at least 15 days each year before a conditional citizenship application. Austria’s exceptional-achievement provision and Malta’s merit rules are individual assessments, without a published passport purchase price.
Georgia is not a fixed-price passport offer
Georgia’s property and investment permits grant residence. Article 17 citizenship by exception involves a presidential state-interest or merit assessment, with no published purchase price in the cited guidance.
Panama’s special travel passport
Law 493 authorises special passports for recognised Rentista Retirado and Qualified Investor residents and their dependants. The document does not confer nationality or replace the ordinary passport. Do not assume ordinary Panamanian citizen visa-free access.
Why the document name can mislead
Hong Kong permanent residence is different from Chinese nationality. Armenia’s special residence document uses the word passport. Jordan’s temporary passport stage must be distinguished from an eventual citizenship decision. Check the legal status being granted.
Sources
- 8 USC1153(b)(5), statutory EB-5 capital requirements ↗US Government Publishing Office · Legislation · Checked
What this source supports
USD1050000 ordinary; USD800000 targeted/infrastructure;10 jobs; scheduled adjustment from1January2027.
- Residence for investment, article 90-A ↗Portugal AIMA · Government guidance · Checked
What this source supports
EUR 250k cultural support,20% low-density reduction; EUR 500k nonproperty fund; investments cannot target real estate.
- Malta Permanent Residence Programme ↗Residency Malta Agency · Government guidance · Checked
What this source supports
EUR 60k administration,37k contribution; rent 14k/year or buy 375k; asset requirements; explicitly separate from citizenship.
- Eligibility for an HKSAR passport ↗Hong Kong Immigration Department · Government guidance · Checked
What this source supports
Chinese citizenship, HKSAR permanent residence and a permanent identity card are required; investor residence is not passport eligibility.
- Golden Visa application for investors ↗Dubai Land Department · Government guidance · Checked
What this source supports
AED 2m property; 10-year renewable residence.
- Citizenship Investment Act, sections 16–17 ↗Samoa Ministry of Commerce, Industry and Labour · Legislation · Checked
What this source supports
Three-year PR stage; 15 days annually; citizenship application conditional on compliance.
- Malta citizenship by merit ↗Community Malta Agency · Government guidance · Checked
What this source supports
Merit is discretionary and expressly not a continuation/alternative to former investment scheme.
- Migration and residence permits ↗Georgia Public Service Development Agency · Government guidance · Checked
What this source supports
Property value must exceed USD150,000 for short-term residence. Investment residence requires at least USD300,000 investment or property value exceeding USD300,000; household, assessment, five-year and turnover conditions apply.
- Georgian citizenship by exception ↗Georgia Public Service Development Agency · Government guidance · Checked
What this source supports
Article17 presidential discretion; substantial economic investment is a state-interest consideration, not a published purchase price.
- Law 493 of 2025: special passports for foreign residents ↗Panama Official Gazette / Procuraduría de la Administración · Legislation · Checked
What this source supports
Authorises special passports for recognised Rentista Retirado and Qualified Investor residents and dependants; validity follows residence permission; no nationality and no substitution for an ordinary passport.
- Rentista Retirado requirements and renewal ↗Panama Servicio Nacional de Migración · Government guidance · Checked
What this source supports
Current linked PDF: B/.850 monthly interest exclusively from an unencumbered fixed deposit in Banco Nacional or Caja de Ahorros; minimum five years; five-year temporary permit renewable; qualifying dependants.
- Qualified Investor changes under September 2026 decree ↗Panama Ministry of Commerce and Industry · Government guidance · Checked
What this source supports
B/.300000 first-sale property; B/.500000 resale property; B/.500000 state-bank deposits; these qualify for residence, not a citizenship purchase.