Let's take a look at the EU Visa Suspension Mechanism against the countries with Citizenship by Investment Programs.

The European Union's approach to investor passport or citizenship by investment programs has changed from targeting individual schemes to treating the “Golden Passport” programs as formal ground for suspending visa-free access to the Schengen zone.

The visa suspension reached Vanuatu first. Following the rapid growth of its investor citizenship scheme started in May 2015 - marketed heavily on that investor citizens can secure visa-free entry to the Schengen Area. First, the European Commission raised concerns over the rapid application processing times, lack of information sharing with countries of origin, and exceptionally low rejection rates. This led first to a so-called phased partial suspension of Vanuatu’s Schengen and UK visa waiver agreement before a complete revocation.

The Revised Visa Suspension Mechanism: Regulation (EU) 2025/2441

The fresh legal basis for targeting investor citizenship was significantly strengthened  when the EP (European Parliament) and the Council adopted Regulation 2025/2441, amending the underlying Visa Regulation (EU) 2018/1806. Entering into force on the last day of 2025, the amendment  revised Article 8 to allow the Commission to trigger visa-free suspensions when a third country operates an investor citizenship scheme that grants nationality without a genuine link between the applicant and the CIP provider nation.

The exact text updates of reasons for triggering a suspension to include from "the operation of an investor citizenship scheme whereby citizenship is granted in exchange for pre-determined payments or investments without any genuine link to the third country concerned."

The 12 and 24-Month Suspension Timeline of the CIP countries' Schengen visas

Under the structural reforms to the Visa Suspension Mechanism (VSM), the timeline of the process and duration of restrictions follow a strict phased escalation:

- Initial Suspension Period: The updated regulations increased the initial duration of a visa-free suspension from nine to 12 months.
- Extended Suspension Period: If the targeted country fails to resolve the security, vetting, or compliance concerns outlined by the Commission during the initial period, the regulation allows an additional 24-month extension of the suspension.

In line with the EU's 8th VSM Report targeting five Eastern Caribbean states (Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia), Brussels communicated a “compliance framework requesting a program phase-out transition running through June 1, 2028, backed by the enforcement capabilities of the revised mechanism.”

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