European Union (EU) officials are considering using the European Travel Information and Authorization System (ETIAS) to scrutinize Caribbean citizenship-by-investment (CBI) citizens more closely after new survey data showed growing concern.
The shift comes as executives warned that the EU may tighten entry rules for travelers linked to these programs.
Concerns grow within industry
Investment migration executives said that the EU may begin using its new travel screening system, ETIAS, to scrutinize Caribbean passport holders who acquired citizenship through investment.
A recent industry survey revealed that one-third of firms believe that the EU could apply the system selectively against CBI nationals.
In the 2025 Investment Migration Executive Survey, 33% of firms said that they expect the EU to start “openly” using ETIAS to discriminate against individuals with CBI-linked passports.
The data was published by IMI Daily and reflects growing concern about how EU travel frameworks might evolve in response to pressure over security and transparency.
The same survey found that 50% of respondents doubted that the five Caribbean CBI countries would enforce the 30-day physical presence requirement that was agreed upon with the EU.
These include Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia.
Meanwhile, 75% of firms predicted that at least one new CBI program will launch in 2026, continuing a trend from the previous year, which saw new programs announced in Nauru, São Tomé and Príncipe, and Sierra Leone.
How ETIAS works
The ETIAS is a new EU requirement for visa-exempt travelers. According to the European Commission, ETIAS will launch in the last quarter of 2026, and will apply to travelers from 59 countries and territories.
It will be mandatory for short stays in 30 European countries, including Schengen states and others like Cyprus.
ETIAS is not a visa. It is a pre-travel authorization linked to a traveler’s passport and valid for up to three years, or until the passport expires. It allows for short stays of up to 90 days within any 180-day period, but does not guarantee entry.
Border guards may still deny access if entry conditions are not met.
Travelers will need to apply online or through a mobile app, and the application costs EUR 20. Some travelers may be exempt from the fee.
Most applications are expected to be processed within minutes, though it may take up to 30 days if additional documentation or interviews are required.
Visa-free access “under threat”
The IMI survey shows that while only 15% of executives believe a Caribbean country will lose visa-free Schengen access in the next year, the fear remains significant.
In fact, 55% still consider the loss of Schengen access a top concern—down slightly from 63% in 2023.
This concern ties into recent EU warnings. The bloc has previously criticized “golden passport” schemes and urged third countries offering CBI to ensure their programs are not misused.
In past years, the EU has pressured governments to tighten applicant vetting and align more closely with EU security standards.
While ETIAS does not include any clause targeting CBI holders specifically, the system’s discretionary nature allows authorities to flag travelers before arrival.
That has led to speculation within the migration industry that ETIAS could become a “pressure valve” for the EU—used to enforce informal restrictions without suspending visa waivers altogether.
Skepticism around 30-day rule
To address EU concerns, the five Caribbean countries with CBI programs had agreed to impose a 30-day physical presence requirement for new applicants. But many in the industry questioned whether this will be enforced.
According to the IMI report, half of the surveyed firms do not believe all five countries will follow through with the rule.
This casts doubt on whether the EU will be satisfied with current reforms, and whether the bloc might turn to systems like ETIAS to apply pressure instead of pursuing formal diplomatic measures.
New programs still expected
Despite tightening rules and reputational risks, the survey found optimism about the future of the CBI market. Three-quarters of respondents expect at least one new CBI program to open in 2026, extending momentum from 2025.
Recent additions to the global CBI landscape include Nauru, São Tomé and Príncipe, and Sierra Leone.
Other countries reportedly considering similar programs include Argentina, Solomon Islands, and Botswana, though no official launches have been confirmed as of December 2025.
Reputation, regulation remain key issues
Beyond EU pressure, CBI firms are dealing with internal challenges. According to the 2025 survey:
- 43% cited concerns about major program closures
- 38% worried about the effects of CBI discounting schemes
- 35% raised concerns about reputational harm from unethical conduct within the industry
These figures suggest a general recalibration. While some programs have closed—such as Spain’s Golden Visa and Malta’s MEIN—others are gaining traction in new markets, especially in regions like Latin America and Southeast Asia.
In terms of expansion, 25% of firms said that they plan to open new offices in North America in 2026. Only one firm reported plans to open in China, and interest in Africa has declined sharply from 33% in 2023 to just 18% in 2025.
Why ETIAS matters
ETIAS gives the EU a pre-screening mechanism to detect potential security, health, or migration risks before travelers board their plane or cross the border. Applications can be denied for several reasons, including concerns over public health, criminal records, or travel history.
These checks are done automatically using databases and watchlists.
Although ETIAS does not directly mention CBI or dual citizenship, its framework allows for flexible enforcement.
As the system processes applications based on passport and biometric data, concerns remain that countries with economic citizenship programs may come under increased scrutiny.
Importantly, having an approved ETIAS does not guarantee entry. Border guards retain the right to refuse access even with valid authorization, giving national authorities more discretion at the point of entry.
No action needed yet
According to the European Commission, no immediate action is required from travelers. The official launch of ETIAS will occur in the final quarter of 2026, and the EU has promised to announce the start date several months in advance.
Until then, travelers from visa-exempt countries can continue to enter the Schengen zone without applying for ETIAS.
However, migration firms are preparing their clients and reviewing how ETIAS could affect mobility for high-net-worth individuals and CBI clients in particular.
Passport perks under pressure
The EU plans to link ETIAS checks with Caribbean CBI programs signal more than a travel policy tweak; they hint at a shift in how citizenship itself is judged.
As the industry waits for a formal move, the outcome could change the map for global mobility and investment migration.