The 2021 CBI Index: Key findings - Caribbean nations remain on top

The CBI Index is intended as a practical tool, both for those who wish to compare citizenship by investment (CBI) programmes as a whole and for those who wish to compare specific aspects of each programme. These aspects are reflected by the CBI Index’s nine pillars: Freedom of Movement, Standard of Living, Minimum Investment Outlay, Mandatory Travel or Residence, Citizenship Timeline, Ease of Processing, Due Diligence, Family and Certainty of Product.

Pillar 1: Freedom of Movement 

Schengen Area countries Austria and Malta maintain their scores of 10 in this year’s Index, closely followed by the sole remaining fellow EU member state in the Index, Bulgaria, with a score of nine. It is worth noting that Bulgaria, like Cyprus, Croatia and Romania, is not a Schengen state; however, like Austria and Malta, it offers citizens the right to live and work in all 27 EU member states. Among the free movement regimes assessed in this Index, the EU continues to provide the greatest opportunities for human development.

Outside of the EU, citizenship of the Caribbean countries of Antigua and Barbuda, Grenada, St Kitts and Nevis and St Lucia offers the greatest mobility with a score of seven, while Dominica scores six. Notwithstanding its lower number of visa-free or visa-on-arrival destinations, Dominica was the Caribbean nation with the greatest increase in its visa-free and visa-on-arrival offering for the second year in a row — perhaps heralding a better overall pillar score for 2022. All five Caribbean jurisdictions are also members of the Caricom Single Market and Economy (CSME), which comprises 12 member states and facilitates the right to work for certain categories of workers.

In the 2021 CBI Index, Vanuatu scores five, as it does not belong to a free-movement regime and offers visa-free access to 13 out of 20 CBI Index business hubs. This year, Vanuatu joins Dominica with the highest overall increase in visa-free and visa-on-arrival destinations out of all 14 jurisdictions under evaluation.

Once again, EU candidate Montenegro is followed in descending order by Turkey and Cambodia, with respective scores of four, three and two. Citizens of Montenegro can travel without pre-applying for a visa to more than double the number of nations than citizens of Cambodia, and nearly
two-and-a-half times the number of business hubs than citizens of Turkey. 

This year, the lowest score is shared between Egypt and Jordan. Unfortunately, Egypt’s membership of the Community of Sahel-Saharan States and the Common Market for Eastern and Southern Africa offers no relief for the country, as free movement is yet to be implemented throughout the member states of each regime.

Pillar 2: Standard of Living

In 2021, Austria emerges as the leader in the Standard of Living Pillar, with a total of nine points to Malta’s eight. Austria’s gross national income (GNI) increase bolstered its performance, and the country also marginally outperforms Malta across gross domestic product (GDP) growth, relative safety and freedom metrics. As was the case in 2020, however, Malta retains the edge with respect to life expectancy and equals Austria’s expected years of schooling with 16.1 on average. These two nations’ historic accomplishments in life expectancy, safety and the upholding of basic freedoms all contribute to their high rankings despite the economic damage caused by Covid-19 in 2020.

In joint third position, with a score of seven, are Bulgaria and Turkey. While both countries are fairly evenly matched with respect to safety and GNI, each outdoes the other in different key areas: Turkey outscores Bulgaria for life expectancy, education and GDP growth, while Bulgaria achieves a significantly higher freedom score.

Ranking fifth with six points are Antigua and Barbuda, Grenada, Montenegro and St Lucia. All countries in this tier exhibit similar scores across a range of different measures, such as life expectancy and GNI, but some notable differences include Montenegro’s stronger performance in terms of relative safety and all three Caribbean countries presenting citizens with more rights and freedoms. For education, Grenada is again the strongest performer with 16.6 years of expected schooling on average — the highest of any of the 14 jurisdictions. While all countries in this tier experienced sharp, pandemic-fuelled GDP declines in 2020, the economies of Antigua and Barbuda and St Lucia were more severely affected.

In eighth position are a diverse group of countries comprising Dominica, Egypt, Jordan, St Kitts and Nevis and Vanuatu, all with a score of five. Here, the Caribbean countries attain higher for freedom, GNI and life expectancy, with Dominica in particular scoring highly with a life expectancy of 78.2 years and with a perfect freedom score. Egypt recorded a 3.6 per cent GDP growth during this period, while Jordan saw its GDP shrink by 1.6 per cent — their larger, more diversified economies weathering the Covid-19 storm more easily than smaller island nations. Additionally, Egypt and Jordan also achieved top scores for safety. Although Vanuatu appears at the bottom of the table for education and GNI, the South Pacific island’s respectable score is owed to the continued high levels of freedom and security it offers its citizens.

Cambodia shores up the final position for the Standard of Living Pillar — its score of four points nonetheless reflecting how the country’s first economic contraction in a decade was not as severe as the double-digit declines seen elsewhere, as well as its robust performance in the realm of personal safety.

Pillar 3: Minimum Investment Outlay

This year’s Index reflects the fact that several jurisdictions have altered their minimum investment thresholds for applicants. This has resulted in some score changes under the Minimum Investment Outlay Pillar, which, excluding the new entrant, had remained unchanged since the 2019 CBI Index.

These changes, however, did not affect the Caribbean and Vanuatu, which remain the top scorers under this Pillar. With a minimum contribution amount of US$100,000, Dominica and St Lucia continue to offer the lowest threshold of all 14 jurisdictions assessed, and receive a score of 10. Of the four countries with a score of nine points, Antigua and Barbuda and Vanuatu are the next most affordable options at US$130,000. Despite a minimum contribution amount of US$100,000, Antigua and Barbuda continues to levy a hefty government fee of US$30,000. Grenada and St Kitts and Nevis’ minimum contributions remain at US$150,000.

In the 2021 CBI Index, newcomer Egypt joins Cambodia and Turkey with a score of eight. Egypt’s most affordable investment option is a US$250,000 donation to the Central Bank of Egypt.

Having made several changes to its investment options in 2021, Bulgaria overtakes Montenegro, increasing its score from five to seven. Now that the option to invest in government bonds has been eliminated, applicants looking for the most affordable route to citizenship can invest in a Bulgarian company employing 10 or more Bulgarian nationals for a minimum of €257,000.

Montenegro is followed by Malta and Jordan, both of which attain a score of four. In December 2020, the Jordan Investment Commission revealed that the country’s minimum investment amount had been reduced from US$1m to US$750,000, resulting in Jordan’s score increasing by one point since last year’s Index. Malta’s score remains unchanged, despite its new offering having a lower minimum threshold of €705,000 for those choosing to reside in Malta for 36 months or more. Malta’s new threshold is made up of a €600,000 Exceptional Direct Investment, €80,000 over five years of rent, a €10,000 charitable donation and a sizeable €15,000 due diligence fee (twice as high as under the Malta Individual Investor Programme [IIP]).

Austria retains its place as the most expensive CBI nation.

Pillar 4: Mandatory Travel or Residence

With the exception of new entrant Egypt, the scores under the Mandatory Travel or Residence Pillar remain unchanged from the 2020 CBI Index. Dominica, Grenada, St Kitts and Nevis, St Lucia and Jordan maintain their perfect scores as they require neither travel nor residence on the part of applicants.

Egypt makes its CBI Index debut with a score of eight, joining Austria, Cambodia, Montenegro, Turkey and Vanuatu. All six of these nations require applicants to make one trip to their new country of citizenship. Egypt, for example, requires applicants to make at least one trip to the country to complete the procedures to obtain a National ID Card. With respect to Vanuatu, it is worth noting that although the requirement that applicants take the oath of allegiance in front of a Commissioner for Oaths has been temporarily suspended as a result of the Covid-19 pandemic, the CBI Index does not consider temporary changes that are liable to being quickly reverted.

Antigua and Barbuda and Bulgaria follow with a score of six. Antigua and Barbuda requires applicants to travel to the country, or one of its embassies, to take the oath of allegiance and implements a minimum physical presence requirement of five days within five years of the grant of citizenship. As with Vanuatu, it is important to note that the residence requirement has been temporarily suspended due to ongoing Covid-19 restrictions and provision has been made for applicants to take the oath of allegiance remotely; however, this change is expected to be short-lived.

Like the Malta IIP, Malta’s new offering obtains a score of two. Prospective Maltese citizens must spend a minimum of either 36 or 12 months in Malta, with the 12-month option needing a higher overall investment outlay. Applicants must also make two trips to Malta, the first to provide biometrics for the issuance of the residence card, and the second to take the oath of allegiance within six months of the letter of approval from Community Malta Agency.

Pillar 5: Citizenship Timeline

St Kitts and Nevis once again leads the Citizenship Timeline pillar by virtue of its Accelerated Application Process, which offers citizenship to qualifying applicants within a maximum of 60 days and, under certain circumstances, as little as 45 days. For applicants who do not want to pay a premium, St Kitts and Nevis’ standard route has an average processing time of three months. Also offering decisions to applicants in three months, with Grenada adhering to a 60-business day response time, Dominica, Grenada, Jordan, Montenegro and St Lucia each score nine. After issuing its first approval in 2020, Montenegro’s CBI Programme did not receive the high application volumes expected, so its processing time remains largely unchanged from last year.

Vanuatu also scores nine. Despite increasing investor demand, Vanuatu maintains last year’s score and continues to process applications at pace. This may change in the future, given Vanuatu’s ongoing efforts to implement more stringent vetting controls on applicants.

Similarly, in Turkey, rocketing application numbers do not seem to have impacted processing times in the country, resulting in Turkey maintaining its score of eight, along with Cambodia.

Egypt’s CBI Programme enters the running with a score of six, with between six and nine months considered a reliable timeframe estimate. Antigua and Barbuda, the Caribbean country with the slowest processing times, also receives a score of six.

With three points, Malta finishes just above its European counterparts Austria and Bulgaria. In Malta, the best-case scenario for applicants is a processing time of 13 months, inclusive of both application submission and minimum residence requirements; while in Bulgaria, fast-track applicants obtain citizenship after around 18 to 24 months, inclusive of a 12-month nominal residence period. Austria grants citizenship to investors in an average of 24 months.

Pillar 6: Ease of Processing

The Caribbean nations achieve scores of 10 in the Ease of Processing Pillar for their continued commitment to ensuring the CBI process is as straightforward as possible. The region’s CBI Units work to maintain accessible, up-to-date programme websites and applicants are not burdened with mandatory interviews, examinations or requirements to demonstrate business acumen. Also scoring 10 is Vanuatu, whose Development Support Programme (DSP) adopts this same streamlined philosophy toward processing applications.

Concerns were however raised this year with respect to Vanuatu because, while applicants are not, in practice, asked to undertake a language test, the nation’s Citizenship Act fails to exclude DSP applicants from the requirement to speak and understand English, French, Bislama or a vernacular of Vanuatu. This conflict should be resolved or clarified by local lawmakers to ensure applicants continue to face straightforward processing and to reduce programme uncertainty.

Were it not for the fact that its official CBI Unit website is still not up-and-running, and therefore that official information is not made readily available for prospective applicants, Egypt would have also attained a score of 10. Instead, it joins Malta’s new offering with a score of nine. Malta’s score is a result of it requiring applicants to purchase real estate to obtain citizenship — a time-consuming, document-heavy process that CBI applicants can avoid, should they wish to, in the Caribbean and Vanuatu.

Jordan and Turkey receive a score of seven. Neither tests applicants’ business acumen, language skills or knowledge of local culture, but both should seek to establish dedicated entities and an online presence for the running of their programmes. 

Bulgaria and Montenegro achieve a score of six. Not only do these countries lack a dedicated entity to manage and oversee their programmes, they also require the making of complex investments. Although Montenegro’s CBI Programme has an official website, the domain has been inaccessible since the 2020 edition of the CBI Index. 

Austria and Cambodia remain at the bottom and were dealt scores of four for their more gruelling applicant requirements, with Austria being the only country to require a proven track record of business achievement and Cambodia being the only country to implement a language and history and culture test.

Pillar 7: Due Diligence

Once again, Dominica, Grenada, Malta and St Kitts and Nevis earn top scores in the Due Diligence Pillar. Since the CBI Index’s introduction in 2017, this has been a consistent outcome for Dominica, Malta and St Kitts and Nevis, while Grenada has attained a perfect score every year since 2019. Malta’s new offering is no exception, with applicants having to undergo multiple layers of vetting, including external checks by two reputable due diligence firms.

Antigua and Barbuda and Montenegro form the second tranche of countries, both scoring nine. Although they have biometric requirements, restrict applications from citizens of at-risk nations, and use independent due diligence firms for on-the-ground checks, there is room for improvement with respect to ascertaining criminal activity for the former and source of funds for the latter.

This year, Vanuatu joins Bulgaria and St Lucia with a score of seven for due diligence. For Vanuatu, this is an increase of one point since the 2020 CBI Index, owing to new requirements for applicants to submit bank statements showing six months of transaction history. As Vanuatu seeks to enhance its external due diligence component, next year’s CBI Index could see further improvements for the Pacific island-nation. However, St Lucia remains the lowest-scoring Caribbean nation. It has not imposed fingerprinting or biometric requirements since last year, and it could do more to authenticate source of funds.

Newcomer Egypt enters the ranking with six points. Despite requiring applicants to provide biometrics and requiring the submission of a clean police certificate from both an applicant’s country of citizenship and residence, Egypt does not employ a third-party specialist firm to provide an extra layer of vetting. Instead, desktop internal checks are conducted by three government agencies. 

Similarly, in Austria and Cambodia, on-the-ground checks are not performed. Austria and Cambodia’s score of four reflects this, as well as their lower standard of due diligence when it comes to police certificate requirements and source of funds checks. In Cambodia, for example, it is not clear whether any checks are performed on an applicant’s source of funds.

Turkey finishes one point above Jordan with a score of two, with neither country looking set to meet the standard of due diligence that is expected of more circumspect CBI nations, despite their programmes becoming more established in the industry.

Pillar 8: Family

Joining Dominica and Grenada with a score of 10, Antigua and Barbuda and St Kitts and Nevis also occupy the top spot in the Family Pillar this year. Antigua and Barbuda’s two-point increase is a result of changes in November 2020 that reduced restrictions on children over 18 years and allowed siblings of the main applicant or spouse to be included in an application, if unmarried. St Kitts and Nevis also widened its definition of dependant to include siblings of the main applicant or spouse if 30 years or under, unmarried, childless and financially dependent on the main applicant.

St Lucia retains its score of nine, falling short of the top spot as it is the only Caribbean nation that does not allow grandparents to form part of an application. Malta’s new offering also scores nine, reflecting the fact that, although siblings are ineligible, children over 18 are permitted with few restrictions, as are dependent parents and grandparents of the main applicant or spouse over the age of 55.

Vanuatu scores seven and Montenegro follows with six. In both countries, children over 18 years can be included. Vanuatu, however, requires a higher degree of dependency to be shown as adult children must be residing with or dependent upon the main applicant or spouse and attending full-time education. On the other hand, while Vanuatu allows parents of the main applicant or spouse to be included, Montenegro does not allow the inclusion of extended family, and the family tie for all dependants must be with the main applicant.

Egypt enters the running with a score of five, level with Turkey. While Egypt and Turkey both make provision for children over the age of 18, Turkey only allows adult children to be included if rendered dependent as a result of a medical condition. In the 2021 CBI Index, countries are only awarded points in the Family Pillar if a particular family member receives citizenship at the same time as the main applicant. In Egypt, spouses of the main applicant can only obtain citizenship two years after the main applicant, and Egypt therefore receives no point for spouse dependants.

Austria and Jordan retain scores of four, with neither country allowing family members of the main applicant’s spouse to be included in an application. Cambodia is next with a lowly score of two, allowing only a spouse or minor child of the main applicant to obtain citizenship with the main applicant. Bulgaria takes last place this year due to the 2021 CBI Index not considering family members who cannot obtain citizenship at the same time as the main applicant. Bulgaria only facilitates citizenship for spouses and children after citizenship is obtained.

Pillar 9: Certainty of Product

For the second year, Dominica achieves a score of 10 in the Certainty of Product Pillar — a result of its transparent and highly renowned programme. At 28 years old and with a track record of good governance, the Dominica CBI Programme has led the way in providing clarity as to how CBI funds are used, this year earmarking US$370m for the construction of an international airport. Furthermore, 2215 applications were approved in the 2019/2020 fiscal year (which runs from 1 July to 30 June) — showing strong interest even amid the Covid-19 pandemic.

The industry’s most longstanding programme, that of St Kitts and Nevis, scores nine. This score also reflects St Kitts and Nevis’ ability to adapt to present need and to attract high numbers of investors. St Kitts and Nevis could, however, provide more guidance on its new investment options, in particular the ‘Alternative Investment Option’.

Antigua and Barbuda, Grenada and Vanuatu each receive seven points. Antigua and Barbuda lost a point in this year’s CBI Index for its reduced application volume in 2020. Grenada also lost a point owing to reputational implications arising from the developer of Grenada’s CBI-approved Kimpton Kawana Bay Resort seeking international arbitration against Grenada. In Vanuatu, however, growing application numbers and more efforts to improve due diligence and promote the DSP internationally led to a two-point increase.

St Lucia and Turkey retain scores of six, with neither programme suffering any major setbacks in the last year. In 2020, approvals under Turkey’s Programme are estimated to have increased by 325%, demonstrating that Turkey’s popularity shows no signs of abating.

Both Austria and Bulgaria obtain a score of five, a one-point increase compared to the 2020 CBI Index. When the European Commission (EC) initiated infringement proceedings against Cyprus and Malta last October and sent a letter to Bulgaria, Austria was notably absent from the firing line. This suggests that Austria’s Programme is one of the most stable in the EU. Bulgaria’s increase is due to recent sweeping changes to investment options under the Programme, demonstrating a higher level of adaptability and putting to bed any rumours of the Programme’s closure. 

Cambodia, Jordan and Malta are next with scores of four. Having been established at the tail end of 2020, Malta’s new offering loses points for longevity. Further, in June 2021 a letter of formal notice was sent from the EC concerning Malta’s new policy, despite more stringent residence requirements. Having had longer to establish itself in the industry and having made amendments to its minimum investment outlay, Jordan’s score increases by two from last year. Cambodia’s increase of one point is a result of reports from Cambodia’s Ministry of Interior that suggest 700 foreign nationals applied for Cambodian citizenship between 2000 and 2013.

Egypt enters the race towards the bottom of the table, having had little time to establish a reputation, while Montenegro drops to last place, owing largely to the fact that the Programme will be closing at the end of 2021.

Final Scores: The Highest-Ranking Programmes

For the first time in the history of the CBI Index, St Kitts and Nevis joins Dominica in first place overall, making Dominica and St Kitts and Nevis the best CBI programmes the industry has to offer in 2021.

For Dominica, first place has been a consistent result for five consecutive years. Maintaining a perfect score in six out of the nine pillars assessed, Dominica once again promises, among other things, an affordable minimum investment outlay, a streamlined application process, and certainty to investors. However, the hit taken to Dominica’s economy as a result of Covid-19 ultimately lowered Dominica’s overall score.

St Kitts and Nevis remains the CBI nation with the fastest processing time and is the Caribbean country with the largest visa-free or visa-on-arrival offering. This year, St Kitts and Nevis also achieves a perfect score in the Family Pillar, thanks to changes allowing siblings to be included in an application. Some level of uncertainty was recorded this year, primarily due to the introduction of two new investment options, the full workings of which require greater clarity.

In third place, Grenada continues to offer investors an efficient application process, takes a thorough approach to vetting and ensures wide family eligibility. Closing some of the gap between itself and Grenada, St Lucia is the only nation whose Standard of Living score is displayed as one point higher in this year’s CBI Index, as the impact of the pandemic was offset by increases in GNI and relative safety.

Finishing below St Lucia for the third year, Antigua and Barbuda maintains its percentage score of 77, despite efforts to become more family friendly. Greater application volumes, a re-think of its five-day residence requirement and an improved citizenship timeline would help Antigua and Barbuda increase its score in future editions of the CBI Index.

In sixth place, Vanuatu finishes as the best scoring CBI programme outside of the Caribbean. A renewed focus on due diligence, with applicants now being asked to provide six-month bank statements, and a better reputation helped Vanuatu increase its overall score by two points. Efforts to improve applicant vetting in the country are ongoing and a confirmed system of on-the-ground checks would see Vanuatu continue on its upward trajectory.

Malta’s brand-new offering debuts in seventh place, maintaining the same position as its predecessor. Like the IIP before it, the new policy performs respectably in five pillars, with a well-deserved perfect score in the Freedom of Movement and Due Diligence Pillars. Malta is, however, the country with the most arduous travel and residence requirements, and a 13-month citizenship timeline is the best possible outcome for applicants. Malta’s certainty of product continues to falter as pressure from the EC shows no sign of letting up.

Placing eighth, Montenegro’s overall score is three points lower than last year — putting it on par with Turkey in the 2021 CBI Index. Despite a respectable result underpinned by no residence requirements and a speedy processing time, investor interest in Montenegro’s Programme remains low, resulting in it being slated for cancellation at the end of 2021.

Even with this year’s addition of Egypt, Turkey remains the best-performing CBI programme in the Middle East and North Africa owing to its undeniable popularity with investors, higher standard of living, and access to more than double the number of destinations and five times more business hubs than Egypt and Jordan. As Turkey’s popularity increases, it is essential that the Programme’s lacklustre due diligence procedures be overhauled.

Newcomer Egypt enters the running one point above Bulgaria. Egypt premieres with commendable scores for its relatively low minimum investment outlay, low travel and residence requirements, and straightforward programme — missing out on a perfect score in the Ease of Processing Pillar due to the Programme’s official website being inaccessible. The CBI Index will continue to chart the Programme’s development in the coming year and monitor investor interest.

In eleventh place, Bulgaria increases its percentage score this year. Changes to investment options in early 2021 led to a lower minimum investment amount and demonstrated that Bulgaria can adapt to meet investor demand. Burdensome travel requirements, a lack of official government guidance, and one of the longest citizenship timelines in the industry, however, continue to prevent Bulgaria from climbing up the table. Fellow EU member state Austria follows, having done little to de-mystify its procedures for applicants and being both the slowest and most expensive programme in the CBI industry.

Finishing above Cambodia for the first time since 2018, Jordan’s overall score increases by five points, primarily due to its CBI Programme’s growing popularity and reductions in threshold amounts across investment options. As Jordan refines its offering, it would do well to uphold higher due diligence standards, including mandating the use of external firms to perform on-the-ground checks and ensuring the authentication of applicants’ source of funds.

In last place for 2021 is Cambodia. The country’s visa-free and visa-on-arrival offering leaves much to be desired, and it offers the lowest standard of living of all 14 programmes assessed. If Cambodia wishes to raise its profile in the industry, significant strides must be made with respect to improving transparency and simplifying processes for applicants.