By Sam Bayat
(This article was originally published on the LinkedIn page of Sam Bayat on December 31, 2025.)
2026 will likely further reshape global mobility. It will make it harsher, more technical, and far less forgiving for weaker investment-based migration programs. What we already observe today is clear: there are few quick fixes ahead, and greater scrutiny at border crossings will continue.
Cheap’ CBI Under Fire and Budgetary Strain
The primary pressure points in 2026 will remain donation-heavy, low-cost Citizenship by Investment (CBI) programs that prioritize volume over substance. Authorities in Europe and other major destination states are likely to continue tightening the screws on low-ticket, low-substance schemes, following the same playbook seen throughout 2025: suspensions of visa-free travel, public political signalling, and informal guidance to banks and border agencies to treat certain passports as higher risk.
Notably, many CBI-dependent states are approaching a point of fiscal strain. For years, CBI revenues have quietly supported national budgets. As application volumes fall and the practical usability of some passports deteriorates, that income is likely to contract faster than public spending can adjust.
As fiscal and regulatory gaps become more visible, the public will begin asking uncomfortable questions about the past: how much revenue was actually collected, how much was eroded through discounting, side arrangements and opaque commissions, and where accountability ultimately rests. Retroactive transparency will increasingly be difficult to avoid. Former applicants may be asked to document how much they paid and to whom, not only to satisfy compliance reviews, but also to reconcile state accounts and allow current administrations to draw a clear line between past practices and future policies.
These dynamics also help explain the push toward regional oversight. The signing of the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) agreement in September 2025 by five Caribbean governments, with full operationalization expected in 2026 following St Lucia’s ratification, reflects an effort to restore credibility through shared standards, transparency, and enforcement. Whether this framework will meet the expectations of the European Union and the United States remains to be seen. Much will depend not on formal commitments, but on how ECCIRA functions in practice, how independent it proves to be, and whether political incentives align with sustained regulatory discipline.
The “Norway syndrome”: algorithms vs economic citizens
What happened with Norway and some Caribbean CBI passports is a preview, not an anomaly. In 2025, Norway reportedly refused entry to certain travellers holding passports obtained through Caribbean CBI programs, despite their formal visa-free rights. This move is widely interpreted as a test of algorithmic and administrative discretion.
In 2026, more high-value destinations such as Schengen states, the UK, Canada, the US, Australia, and Japan are likely to copy elements of that approach: formally maintaining visa-free access while, in practice, treating certain economic citizens as a separate, higher-risk category. This can be done quietly through pre-travel screening systems, risk flags, and carrier instructions that flag specific passports for refusal or intensive secondary screening. What the Norway incidents showcased was a border questioning about how a person obtained a passport, whether they had ever travelled to the country for which they held the passports, and the actual level of investment.
As algorithms learn to identify “mail-order passports,” the number of economic citizens enjoying friction-free travel will shrink, eroding the core value of many CBI offerings. A small group of investors who use these passports primarily as identity documents, rather than mobility tools, may continue to apply. Still, for most clients, rigorous questioning and unpredictable travel outcomes will act as a strong deterrent.
New Paths: Marriage, Merit, and Exceptional Citizenship
As formal CBI comes under pressure, use of “quiet” channels for high-net-worth and ultra-high-net-worth individuals is likely to grow. Citizenship by merit (CBM), or discretionary naturalization based on exceptional contributions, along with citizenship through residency with flexible presence rules, will become increasingly central to individual strategies, especially in countries that have moved away from direct CBI but still seek to attract capital, talent, or political connections.
These routes are numerically small and fall outside the high-volume CBI narrative, making them politically attractive. However, once border systems and partner governments observe clusters of new citizens with similar profiles, rapid marriages, sudden naturalizations, or minimal time spent in the country, these cases can be tagged and scrutinized unless fully documented and justified. The real question for 2026 and beyond is not just which legal route was used, but whether that route produces citizens that other states’ algorithms and officials are willing to trust.
Malta’s experience illustrates this trend: the government has indicated its intention to shift away from direct investor citizenship toward a CBM model. These grants will focus on select individuals whose contributions, financial, social, or professional, align with national priorities. This approach signals how some jurisdictions aim to preserve strategic attraction while mitigating reputational and regulatory risk.
These “exceptional citizenship” routes may also appeal to a new cohort of mobile professionals who combine economic value with expertise or philanthropy. Planners in 2026 will need to carefully design mobility strategies that leverage these channels without triggering red flags in border, tax, and regulatory systems.
Data-Sharing, CRS, and the End of Informal Arrangements
A defining trend for 2026 is the growing integration of tax and migration data. The Common Reporting Standard (CRS) already enables tax authorities to cross-check foreign account information against declared residence and citizenship, and an increasing number of governments are linking these feeds with entry-exit records, visa databases, and national registries.
For large expatriate communities, such as Indian nationals in the Gulf, this integration means that home and host states can clearly track where people live, work, bank, and invest, leaving less room for informal arrangements. For “golden visa” or “golden passport” holders, stacking passports and residencies without coherent tax planning is increasingly risky: authorities will evaluate not only how a status was acquired, but also whether the holder’s declared tax residence, presence pattern, and financial footprint tell a consistent story.
Tax Residence and Substance Move to the Centre
In 2026, tax residency will be central to any serious discussion of mobility. Authorities will increasingly assess travel patterns, local spending, and asset ownership, making it harder to claim non-residence while effectively living and working in a jurisdiction.
Investment-based migration programs offering clear, coherent residency rights, predictable paths to citizenship, and transparent tax regimes, whether low-tax or standard, will retain their value. Ambiguous offerings that suggest one can live nowhere, pay tax nowhere, yet enjoy multiple residencies and passports will attract early scrutiny from auditors and regulators.
High-net-worth individuals and globally mobile families will need to coordinate residency, citizenship, and tax planning proactively, treating mobility as an integrated strategy rather than a series of isolated choices.
Residency by Investment (RBI) and “Soft CBI”: Slower but Safer
On the RBI side, the market is set to become more differentiated. In the core EU, golden visa programs will increasingly focus on funds, innovation, and business activity, with higher minimum investment amounts and slower, more compliance-intensive processing. In Eastern Europe, low-cost residency options are likely to persist but will face stronger due diligence and closer alignment with EU standards. EU institutions have long agreed to introduce common regulatory standards for RBI programs, and in 2026 these policies will begin to be institutionalized.
In the Americas and Asia, residency-first, citizenship-later programs are increasingly positioned as “soft CBI”: they require more time and some physical presence but provide a pathway to citizenship that is politically cleaner and more sustainable. For many clients, particularly Western nationals and heavily taxed entrepreneurs, the trade-off of slower, more involved processes for greater reliability and security is likely to become the rational choice compared with unstable or heavily discounted CBI offers.
The Industry Pivot: From Products to Strategies
The investment-migration industry is evolving. Instead of offering isolated “products” like a single passport or visa, advisers will increasingly focus on strategy-driven solutions that combine citizenship, residency, and tax-residence options, tailored to each client’s short-, medium-, and long-term risk profile, business interests, and family goals.
As regulatory pressure, data-sharing, and algorithmic screening intensify, the market will naturally weed out opportunistic actors, leaving a smaller, more specialized cohort capable of navigating the complex intersection of migration rules, tax residence, and data-driven risk assessment. In this environment, an adviser’s value depends less on knowing “which program is open” and more on constructing and defending a coherent, sustainable mobility strategy that withstands both human scrutiny and algorithmic evaluation.
The emphasis will shift from transactional advice toward long-term stewardship, where mobility solutions become an integral part of global wealth and lifestyle planning. Advisers who integrate scenario planning, predictive risk modelling, and careful documentation will offer clients a decisive competitive advantage.
Troubles Ahead, and Where the Opportunities Lie
Challenges in 2026 are clear: sudden visa-free suspensions, increasing border scrutiny for economic citizens, retroactive questions from CBI states managing budget shortfalls, and more complex tax-residence and reporting requirements. Some programs may close entirely, while others survive only on paper, losing practical value as their passports become harder to use internationally.
Yet opportunities remain. Jurisdictions that anchor citizenship and residence in genuine presence, clear economic contribution, and transparent pricing can emerge stronger, even if slower and more costly. For globally mobile families who plan carefully—aligning mobility, taxation, and succession—2026 can still be a year of opportunity: fewer options, but far more durable and strategically sound solutions. Strategic foresight and careful documentation will become as important as capital, making professional guidance more critical than ever.