Buying an EU passport: why no EU scheme is left and which route remains

A passport is a right, not a permission. A visa can be refused or withdrawn; a nationality cannot. That is exactly why the wish for a European passport is so understandable: it ties that right to the largest single market in the world, with freedom of movement from Lisbon to Helsinki. And that is exactly why Europe has decided that this right is not sold over the counter.

For you, this does not mean your plan has failed. It means you reorder it: the route to an EU passport takes time, ancestry or a marriage. Whatever needs to be fast lies outside the EU. And whoever combines the two often ends up holding more than someone who simply bought a Maltese passport in 2019. Every programme still open today is in the overview buying citizenship.

Can you buy EU citizenship?

No. And that is not a question of price or of knowing the right people, but of law. Anyone who holds the nationality of a member state is automatically a citizen of the Union. The European Commission sets out what comes with that: the right to move, live and work freely throughout the EU, and the right to vote in local elections and in elections to the European Parliament. A state that sells its passport is therefore also selling access to 26 other countries.

For a long time, three member states offered exactly that. The Commission named them in 2020: on 20 October 2020 it opened infringement procedures against Cyprus and Malta and asked Bulgaria for information about its investor scheme. In March 2022 it went further and called on every member state to abolish any remaining investor citizenship schemes immediately. By then two of the states had already scrapped their schemes or were in the process of doing so. Malta held on to its scheme and let the case go to court.

Since 29 April 2025 the question has been settled. A search for “buy an EU passport” has led nowhere since then, whether you are thinking of Malta, Cyprus, Bulgaria or Austrian citizenship. The Court's standard applies to every member state. What some member states keep is naturalisation for extraordinary achievements, without a price and at the state's discretion, for example in Austria under section 10(6) of the Citizenship Act (StbG) or in Italy under Article 9(2) of its citizenship law.

The ruling against Malta: EU citizenship is not for sale

In case C-181/23 the Commission took Malta to court. At issue was the scheme Malta had set up after a change in the law in July 2020: naturalisation for exceptional services by way of direct investment. Foreign investors could be naturalised if they met a set of conditions that were mainly financial.

The Court found for the Commission. Its reasoning in three steps:

1. Competence stays national. Each member state decides for itself to whom it grants its nationality and from whom it withdraws it. But it must exercise that freedom in line with EU law.
2. Nationality is a relationship. According to the Court, the bond between a state and its citizens rests on solidarity, good faith and reciprocal rights and duties.
3. A sales contract does not create that relationship. A state that grants nationality in direct exchange for set payments or investments turns its acquisition into a mere commercial transaction. This commercialisation breaches the principle of sincere cooperation and undermines mutual trust between the member states.

The Court's press release sums up the core in one sentence: acquiring Union citizenship cannot be the result of a commercial transaction. That takes not only Malta's scheme off the table but any comparable model in any other member state.

What happens to passports already granted

For passports granted before the judgment, Malta has taken a clear position. On the day of the judgment the Maltese government declared that decisions taken under the current and the earlier legal framework remain valid. The judgment obliges Malta to change the law; it does not revoke any naturalisations. Legal Notice 159 of 2025 confirms this and draws a line at the same time: investor applications the minister had not approved before 29 April 2025 have ceased to have effect.

Cases where something was already wrong at the time of acquisition are a different matter. What can happen then is described by Perspektive Ausland using the example of Cyprus: why Cyprus annulled 8 purchased citizenships (in German). And in 2022 the Commission recommended examining whether citizenships from such schemes that had gone to sanctioned Russian or Belarusian nationals should be withdrawn. So a purchased EU passport was a passport under watch even before the judgment.

Maltese citizenship today: what applies after the ruling

Malta reacted quickly. Parliament passed the Maltese Citizenship (Amendment) Act on 23 July 2025, and it entered into force on 24 July 2025. The act removes the term “individual investor programme” from the citizenship law and rewrites naturalisation under Article 10(9).

Naturalisation by merit: no programme, no product

Under the new wording, the competent minister may grant citizenship by merit to foreign nationals who render exceptional services to Malta or to humanity, or whose naturalisation is of exceptional interest to the Republic. The law gives scientists, researchers, athletes, artists, entrepreneurs, philanthropists and technologists as examples. Since Legal Notice 159 of 2025 the procedure has two stages. First you submit a detailed proposal to the Evaluation Board through the agency: your achievements, the exceptional contribution you intend to make and how you will keep contributing after naturalisation. Only once the minister approves it in principle does the actual application follow. For that application you must have lived in Malta for at least eight months beforehand and own adequate residential property in Malta.

What matters is what this provision is not. On 5 February 2026 the agency Komunità Malta made clear that naturalisation by merit is neither a programme nor a pathway, nor a continuation of or alternative to the former investor model. Every decision is discretionary, each case is examined strictly on its own merits, and the agency does not allow the provision to be advertised. So anyone offering you a Maltese “merit passport” with a price list is offering something the authority itself rules out. What lies behind such offers is set out by Malta One in its warning about a golden passport through the back door (in German).

The regular route: residence, language, time

The route Malta really keeps open is set out in Article 10(1) of the citizenship law. You can be naturalised if you

• have lived in Malta continuously for the twelve months immediately before your application,
• have lived in Malta for at least four years in total during the six years before that,
• speak adequate Maltese or English,
• are of good character and appear suitable to be a citizen.

As an EU citizen you start this route without a visa and without an investment scheme: by registering your residence. How that works in practice is explained by Malta One on residence as an EU citizen (in German). Everything else about Maltese naturalisation, from the evidence you need to the oath of allegiance, is in the article Malta: naturalisation through residence.

Marriage and dual citizenship

If you are married to a Maltese citizen, you can register as a citizen once the marriage has lasted at least five years on the day of application and the couple live together. And Malta expressly allows multiple citizenship: Article 7 of the law makes clear that you may be a citizen of Malta and of another country at the same time.

Which routes to an EU passport remain

With buying ruled out, you are left with the routes by which states have always found their citizens: origin, life in the country and family. They differ above all in what they ask of you.

Descent: the underrated route

Many families from Germany, Austria and Switzerland carry a second EU passport in their history without knowing it. Parents, grandparents and, depending on the country, earlier generations from another EU state can give rise to a claim for which you invest nothing and often do not even move. What counts is documents and patience. Which countries keep this door open, and how to check whether it applies to you, is shown in citizenship by descent.

Residence: the long but certain route

Naturalisation through residence is the route that costs nothing, and in the end it often gives you the stronger passport. But it demands years of real life in the country: at least five in Malta, more in many other EU states. How the countries compare and how to count your periods of residence correctly is in naturalisation abroad. The routes to Cyprus and Portugal are covered in the articles on the Cypriot passport and on naturalisation in Portugal.

The faster second passport: programmes outside the EU

If you do not want to wait five or ten years, the route leads out of the EU. Programme countries outside the Union are not affected by the Court's judgment, because their nationality makes no one a Union citizen. Their programmes are set out in their own laws, with their own authorities, their own vetting of applicants and fixed amounts.

They do not replace an EU passport. But they give you what usually lies behind the wish for a second passport: a second nationality, a right instead of a permission, and with the Caribbean passports, visa-free travel to Europe as well.

Sierra Leone comes first because it is the most direct route to a second nationality: the whole process runs remotely, with no travel and no embassy appointment, and as a rule 90-120 days pass between a complete application and the passport. Sierra Leone accepts multiple citizenship without restriction. Holders of this passport usually need a visa for the Schengen area, which does not affect you as a German: you travel to Europe on your German passport anyway.

According to the German Federal Foreign Office's list of countries, the passports of Dominica, Antigua and Barbuda, Grenada and St Lucia let you travel to Germany without a visa for up to 90 days in any 180-day period. Vanuatu shows that this freedom to travel is no law of nature: the EU suspended visa-free travel for Vanuatu with Regulation (EU) 2025/11. What that can mean for the Caribbean and how to protect yourself is covered in the EU visa suspension. All amounts, fees and family rules are under costs and in the comparison of all programmes.

For Germans: you already have the EU passport

One thought often gets lost in the search for an EU passport: as a German you are already a citizen of the Union. Freedom of movement, the right to settle and to work in any member state: you have all of that already. A second EU passport adds hardly any new rights for you in Europe.

What it gives you is a second state. And a programme passport does exactly the same: a second country that issues you a passport if your first one is lost, stolen or held abroad, a second consulate, a second option for your children. The eight reasons for a second passport are set out in why a second passport.

Since 27 June 2024 you lose nothing of what you already have. The German Federal Office of Administration confirms that acquiring a foreign nationality no longer leads to the loss of German nationality and that the retention permit procedure (Beibehaltungsgenehmigung) has been abolished. How this works in detail is in CBI passport and German passport. Stricter rules apply to Austrians, and you should know them before any application: second citizenship for Austrians.

The best plan: a fast passport now, an EU passport later

“Buy or naturalise?” is the wrong question. The best answer is almost always: both. Naturalisation in Europe costs nothing and in the end often gives you the stronger passport, but it takes years and genuine residence. A programme passport buys you exactly those years. It gives you a second nationality within months while you walk the long road in Malta, Portugal or another country, or gather your grandparents' certificates.

In practice it looks like this:

1. Now: you secure a second nationality through a programme, as a rule without moving your residence.
2. In parallel: you check whether descent opens an EU passport for you, or you take up residence in the country that fits your life.
3. Later: once the waiting periods are over, you apply for naturalisation and end up holding three passports instead of one.

How the two routes interlock is shown in CBI and naturalisation. Malta has taken its passport off the market. It has not closed the road to Europe; it has only moved it back to where it always belonged: to the people who live there and to the families who come from there.

Frequently asked questions