We believe this article is accurate at the time of writing, but regulations evolve. We'd welcome you to contact us for a quick, up-to-date confirmation—we're always glad to help.

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Before a client commits to a European golden visa, it is worth asking a more fundamental question: do they already qualify for EU citizenship through a personal connection? Recent legislative changes across Portugal, Italy, Spain and Germany have narrowed several routes, but five meaningful pathways remain open.

What this article covers:

  • The five non-investment routes to EU citizenship currently available
  • Key 2025-2026 rule changes that have affected eligibility timelines
  • What the end of Malta's citizenship programme means for investors
  • How to assess personal eligibility before exploring a golden visa

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What Has Changed in 2025-2026

The landscape of EU citizenship has shifted materially over the past eighteen months. Portugal has extended its naturalisation timeline from five to ten years, effective May 2026, making long-term residence a slower path than many clients anticipate. Italy's Constitutional Court upheld caps on citizenship by investment by descent in March 2026, while Spain closed its Democratic Memory Law route to new applicants in October 2025.

Germany simultaneously scrapped its three-year fast-track naturalisation.

With Malta's scheme having ended in 2025, no EU member state now offers direct citizenship by investment — making golden visa residency the primary investment-led route to a European passport.

The Advisory Angle for HNW Clients

For high-net-worth clients, the practical implication is clear: a thorough eligibility check should precede any investment conversation.

Ancestry, prior residence, and family connections can open doors that are faster and more cost-effective than a formal programme. Marlow Bray's advisers routinely run this assessment as a first step, mapping personal circumstances against all available routes before recommending a residency by investment programme.

For clients who do not qualify on personal grounds, Portugal and Italy remain among the most credible pathways in our current portfolio.

If you would like a complimentary eligibility assessment covering both personal and investment-led routes, our team is available to discuss your specific circumstances.