Closed and Suspended CBI Programs: Cyprus, Bulgaria, Moldova and What Replaced Them

In short

Cyprus closed citizenship by investment on 1 November 2020; Bulgaria abolished its investor-citizenship provisions in 2022; Moldova repealed its scheme in 2020. None offers a direct successor passport programme. Cyprus retains a separate permanent-residence route requiring €300,000 investment and €50,000 annual income, rising to €85,000 for a couple with two dependent children.

Are the Cyprus, Bulgaria and Moldova citizenship-by-investment programmes closed or suspended?

All three citizenship-by-investment routes are closed to new applications, rather than merely suspended with an announced reopening date. Moldova initially suspended its programme before repealing it; that earlier suspension still causes confusion in search results and archived programme descriptions.

The distinction matters. A suspension temporarily interrupts a legal route. Repeal or termination removes the basis for new applications. Neither an old application form nor a property developer’s continued use of “citizenship investment” establishes that a programme remains available.

The European Commission records the Cyprus and Bulgaria closures in its official material on investor citizenship schemes. Moldova’s legislative position should be checked against the official State Register of Legal Acts, rather than archived promotional pages.

Closure also does not mean that every passport previously issued was automatically cancelled. Existing citizenship, pending applications, withdrawals and investigations are distinct legal questions. Their treatment depends on the applicable legislation, transitional provisions and individual decisions.

For a new applicant, however, the practical answer is straightforward: historic investment thresholds and fee tables are no longer purchase options. They belong in an explanation of the former schemes, not in a current application budget.

An offer to submit a “new” application under any of these closed programmes should therefore be supported by a current government application channel and an explicit legal basis. Without both, it should not be treated as an available citizenship route.

What replaced the closed citizenship-by-investment programmes?

None of the three countries introduced a like-for-like successor offering citizenship in exchange for a qualifying investment. What remains is a mixture of residence permissions and ordinary nationality law.

The clearest continuing investment option is Cyprus’s accelerated immigration-permit route for investors, commonly described as investor permanent residence. It is separate from the abolished citizenship programme and should not be presented as a renamed version of it.

The published criteria of the Cyprus Migration Department provide for an investment of at least €300,000 in one of four categories:

• A qualifying house or apartment purchased from a development company, generally as a first sale, with VAT additional where applicable.
• Other qualifying real estate, such as offices, shops or hotels; resale property can qualify within this category.
• Share capital in a Cyprus-registered company with a physical presence and activities in Cyprus, employing at least five people.
• Units in qualifying Cyprus collective investment organisations, within the fund categories specified by the government.

These are alternatives, not interchangeable descriptions of any €300,000 asset. Residential property has different purchase conditions from commercial property; an ordinary overseas investment account is not a qualifying Cyprus fund subscription.

Bulgaria likewise requires a distinction between investment-related residence and citizenship. Abolition of its accelerated citizenship provisions did not turn every remaining residence category into a passport route. Applicants must identify the current immigration provision, eligible investment and continuing conditions before committing funds.

Moldova has ordinary residence routes administered through its General Inspectorate for Migration. Those routes should be assessed on their own grounds—such as employment, business activity or family circumstances—not as a revival of the former citizenship programme.

For readers comparing outcomes, the central distinction is:

Permanent residence is permission to reside under national immigration law. Citizenship is nationality. An investment residence permit does not itself confer an EU passport or an EU citizen’s right to settle and work across the Union.

“Replacement” is therefore useful only as a description of the options investors now consider. It is not an accurate legal description of a successor citizenship programme in these countries.

How much does the remaining Cyprus investor-residence route cost?

Cyprus’s published investor-residence criteria require at least €300,000 in qualifying investment, plus applicable taxes and charges, and separate evidence of annual income. The investment threshold is not an all-inclusive price.

The official application charges are much smaller than the investment, but they are only one part of the budget. Property taxation, registration, legal work, insurance and document preparation can materially affect the total.

The following table gives the government application-fee lines for the straightforward Cyprus investor-permit scenario. The family illustration assumes two spouses and two minor children, all included in the relevant family application arrangements, with nobody already holding an Alien Registration Certificate.

The income calculation is explicit: €50,000 for the principal applicant, plus €15,000 for a spouse and €10,000 for each dependent minor child. A couple with two such children therefore needs €85,000 annually.

That does not mean the family must pay €85,000 into a government account, nor should that amount simply be added to the purchase price as a “fee”. It is a separate financial qualification.

For the residential-property category, the government’s criteria require income from abroad. The treatment of income for the other qualifying investment categories differs, making the choice of category relevant to more than asset preference.

The application charges above come from the Migration Department’s published investor-permit information. Property tax and registration questions belong with the official Cyprus Tax Department and Department of Lands and Surveys.

A genuinely complete transaction budget cannot be produced without identifying the asset and tax treatment. In particular, reduced VAT should never be assumed merely because the purchaser is applying for residence.

There is no current new-application CBI fee schedule to quote for Cyprus, Bulgaria or Moldova. Reproducing their historical citizenship charges as present-day costs would be misleading. Separate Bulgarian or Moldovan residence applications require their own current official fee schedules; they should not be merged into this Cyprus calculation.

Who qualifies, and which family members can be included?

Cyprus’s investor permanent-residence route is intended for qualifying third-country nationals who satisfy the investment, income and personal eligibility requirements; family inclusion depends on each dependant’s age and circumstances.

The investment alone is insufficient. Applicants must provide the prescribed evidence, including criminal-record documentation and relevant health cover. The government also requires declarations concerning employment: this is not an unrestricted permission to take salaried work in Cyprus.

Adult-child applications deserve particular care. A family comprising two parents and two university-age children is not equivalent, for application fees and documentation, to the two-minor-child family illustrated above.

The government’s adult-student provisions also contain conditions concerning the course of study and remaining study period. Age alone does not establish eligibility. Families should confirm the position before an approaching birthday, graduation or change in dependency.

The work restriction is equally important. The official criteria contain specific treatment for directorships in a company used for the qualifying investment and for certain shareholder interests. Those provisions should not be interpreted as general labour-market access.

Bulgaria and Moldova must be assessed separately. A spouse or child’s eligibility under one country’s residence law cannot be inferred from Cyprus’s rules—or from the family definitions used by a former citizenship programme.

Finally, immigration eligibility and tax residence are different tests. A qualifying income stream for immigration purposes does not settle where that income is taxable, and a residence permit does not itself establish the holder’s tax-residence position.

How long does residence take, and can it eventually lead to citizenship?

Cyprus publishes an estimated examination period of approximately two months for a complete investor-permit application, but neither approval nor investment creates a guaranteed citizenship timetable.

The two-month indication concerns examination of a duly completed application. It is not a promise covering property selection, banking checks, completion, criminal-record certificates, translations or missing-document requests.

Applicants should separate four stages:

1. Investment preparation: selecting and completing a qualifying transaction.
2. Application preparation: assembling financial, identity and family evidence.
3. Government examination: the stage covered by the published estimate.
4. Post-approval compliance: satisfying entry, residence and continuing permit conditions.

Cyprus’s official guidance also distinguishes permanent permission from the validity of its physical documentation. The immigration right is permanent, while the residence card has its own renewal cycle.

Maintaining that right does not require living in Cyprus for most of every year. However, official immigration-permit guidance provides that an absence of two years can cause the permit to cease to be valid. Separate rules address taking up residence after approval and obtaining permanent residence elsewhere. These should be checked against the individual approval and current departmental guidance.

Continued ownership of the qualifying investment and compliance with the route’s ongoing requirements also matter. “Permanent” does not mean unconditional, or that the asset can automatically be sold without replacement or immigration consequences.

Most importantly, the low-presence model for retaining investor residence must not be confused with the residence required for naturalisation. Occasional visits sufficient to preserve a permit are not a substitute for satisfying nationality law.

Any later citizenship application is a separate process involving the applicable residence, language, character and other statutory conditions. Bulgaria and Moldova likewise require an independent assessment of their current nationality rules; old accelerated-investor timelines are not transferable to ordinary naturalisation.

For an investor whose objective is an immediate passport, none of these three closed programmes supplies a current route. For someone seeking a lawful residence base, Cyprus remains a concrete investment option—but its value should be judged as residence, with a €300,000 entry threshold and continuing conditions, rather than as citizenship deferred.

For the wider context, read our full citizenship by investment 2026: every programme, cost & timeline compared.

Step-by-step timeline

For a new applicant, the practical timeline concerns residence, not a replacement citizenship-by-investment application. The sequence below follows Cyprus’s investor immigration permit under Regulation 6(2). Bulgaria and Moldova should not be treated as alternative filing locations for their former citizenship programmes.

Delays commonly arise from incomplete banking evidence, inconsistencies between family documents, certification problems and investments whose eligibility is less straightforward than the sales material suggests. A property reservation is not proof of immigration eligibility. Nor does the published examination period include the time needed to investigate, purchase and document an investment.

Tax and stay requirements

Immigration residence and tax residence are separate determinations. Holding a Cyprus immigration permit does not, by itself, settle where someone pays tax or end their obligations in another country.

Cyprus’s tax framework includes a residence test based on spending more than 183 days in the country during a calendar year and a separate, conditional test involving at least 60 days. The shorter test is not simply permission to choose Cyprus taxation after a brief visit: the applicable conditions concerning accommodation, economic connections and overseas circumstances must also be examined. Confirm the current wording with the Cyprus Tax Department, particularly before relying on summaries written before tax reforms.

A second country may still regard the applicant as resident under its domestic law. Where two countries claim residence, an applicable tax treaty may determine the treaty position. Property ownership, family location, employment and the centre of personal and economic interests can all matter. Residence status also should not be confused with domicile or an exemption for a particular category of income.

For immigration purposes, Cyprus’s investor permit is designed to accommodate people who do not live there continuously. Official guidance provides for loss of the permit after an absence from Cyprus lasting two years. Initial settlement requirements also apply: an applicant living abroad should check the deadline attached to approval rather than assume the permission can remain unused indefinitely.

Maintenance requires more than occasional visits. The qualifying investment must be retained, and the holder must comply with the continuing evidence requirements, including those concerning investment and health cover. Selling an asset without arranging an acceptable replacement can jeopardise the permission.

Finally, distinguish renewing a physical residence document from renewing the underlying immigration status. A permanent permission can still carry continuing conditions, while its documentary evidence may need replacement. Check current reporting and document-renewal instructions directly with the Migration Department.

How it compares

For readers considering Cyprus as a low-presence European residence option, Greece’s investor residence and Portugal’s investment residence are closer comparisons than any discontinued passport programme. Neither should be described as purchased EU citizenship.

The figures below are qualifying investment thresholds, not total acquisition or application costs.

Cyprus suits applicants who specifically want a Cyprus base and can maintain the investment without confusing occasional visits with a citizenship strategy. Greece is more relevant where Schengen access and eligible property ownership are priorities. Portugal merits consideration where the applicant accepts a non-property investment structure and can tolerate uncertain administrative timing. In each case, investment suitability should be assessed independently of immigration eligibility.

Common mistakes and what they cost

• Buying into a “reopened” passport programme. A residence offer, ordinary naturalisation route or proposed legislative change does not revive a closed CBI scheme. The potential cost is a non-refundable deposit for an immigration outcome that cannot be delivered.

• Treating the threshold as the complete budget. Taxes, legal work, registration, translation, insurance and application charges can sit outside the qualifying investment. Obtain a transaction-specific budget, with official charges checked against the relevant authority’s current schedule.

• Assuming every property qualifies. Cyprus and Greece attach conditions to eligible investments. A commercially attractive resale, conversion or jointly owned asset may not satisfy the chosen category. Correcting the mistake can require another purchase or an expensive restructuring.

• Moving funds before documenting their origin. Immigration authorities and banks undertake different checks. A transfer accepted by one institution does not guarantee that the immigration evidence is sufficient. Weak records can produce delay, additional enquiries or refusal.

• Selling immediately after approval. Residence linked to an investment is not necessarily independent of that asset once granted. An unplanned disposal can put the permission at risk.

• Counting permit-holding as citizenship residence. Maintaining a card while living elsewhere is not equivalent to accumulating qualifying physical residence. The cost can be years of planning around an eligibility date that never arrives.

• Ignoring the family’s separate position. Each person’s immigration status, tax exposure, insurance and future eligibility should be checked individually. The principal applicant’s approval does not resolve every dependant’s circumstances indefinitely.

Frequently asked questions

Can I still buy citizenship in Cyprus, Bulgaria or Moldova?

No: their former citizenship-by-investment programmes are not open routes for a fresh application. A residence permit or an application under ordinary nationality law is a different legal proposition. Before paying anyone who claims otherwise, request the current statutory basis and verify it with the competent government authority, not merely an old programme brochure.

Is Cyprus permanent residence the same as an EU passport?

No: Cyprus permanent residence is permission to reside in Cyprus, not EU citizenship. It does not give the holder the general EU free-movement rights associated with nationality of a member state. Travel and residence elsewhere depend on the destination’s rules, the traveller’s nationality and any applicable visa or residence permissions.

Do I have to live in Cyprus all year to keep investor residence?

No: continuous year-round residence is not the maintenance requirement for this investor permit. However, official guidance provides for the permit to cease after an absence lasting two years, and initial settlement requirements must also be observed. Investment retention and other continuing conditions remain relevant even when the holder spends most of the year elsewhere.

Will a Cyprus residence permit make me tax resident automatically?

No: the permit itself does not automatically determine Cyprus tax residence. Tax residence follows separate statutory tests, including day-count rules and, for the shorter test, additional conditions. Your previous country may also continue to claim residence. Establish the position in both jurisdictions before changing payroll, receiving a major distribution or disposing of an asset.

Can I work in Cyprus with investor permanent residence?

The investor permit is not a general authorisation to take employment in Cyprus. Official criteria restrict employment, with a specific provision concerning directorships in a company used for the qualifying investment. Shareholding and dividend income are separate issues. Check the proposed role against the current rules before assuming that permanent residence permits unrestricted local work.

Can I sell my Cyprus investment after getting residence?

You should not assume that you can sell the investment and retain the permit unchanged. Continuing ownership of a qualifying investment is central to the route, and disposal without an acceptable replacement can lead to cancellation. Obtain confirmation of the replacement requirements and the necessary evidence before completing a sale, rather than trying to regularise matters afterwards.

Does Cyprus investor residence guarantee citizenship later?

No: investor residence does not guarantee naturalisation or remove the requirements of nationality law. A later citizenship application is assessed under the applicable rules, including qualifying residence and other personal conditions. Someone who makes only occasional visits to preserve the investment permit should not assume that those visits build a sufficient record for naturalisation.

Is Greece cheaper than Cyprus for investor residence?

Greece can have a lower qualifying property threshold in specific categories, but it is not generally cheaper across all locations or transactions. Its €250,000 routes concern particular conversions and listed buildings, while standard property thresholds are higher. Compare the actual eligible asset, taxes, works and ownership costs rather than selecting a country from its lowest advertised figure.

Can I get Portugal’s golden visa by buying a house?

No: direct property purchase is no longer a qualifying investment for a new Portuguese investment-residence application. Portugal retains other statutory categories, including qualifying non-real-estate collective investments. Buying a home for personal use is a separate decision and should not be presented as satisfying the investment-residence requirements simply because older guidance described a property route.

What happens if a residence programme closes after I apply?

The effect depends on the closure legislation and its transitional provisions, not on a universal rule protecting every applicant. Pending applications, approved permissions and later renewals may be treated differently. Retain evidence of filing and payment, monitor official notices and check whether the relevant protection depends on submission, completion of the investment or another specified event.

Related guides

• The Complete Guide to Vanuatu Citizenship by Investment
• The 5 Cheapest Citizenship by Investment Programs in 2026
• Vanuatu Citizenship: The Fastest Passport in the World, but Is It Worth It?
• Antigua vs St Kitts: Which Caribbean Passport Wins for Families?
• The Complete Guide to Grenada Citizenship by Investment

Sources

• Cyprus Migration Department — Official portal and immigration-permit guidance
• Cyprus Tax Department — Official tax guidance and legislation
• Greece Ministry of Migration and Asylum — Golden Visa
• Portugal AIMA — Autorização de Residência para Atividade de Investimento, Art. 90.º-A
• European Commission — Investor citizenship and residence schemes in the European Union
• European Commission — Recommendation on investor citizenship and residence schemes following the Russian invasion of Ukraine