Greece vs Malta and Italy Residency Programmes (2026)

A historic court ruling in Malta on 30 April 2025 effectively ended the EU's "golden passport" era. It is a development that fundamentally changed the comparison between Greece, Malta and Italy. In this article we look at what actually happened in Malta, what remains and Italy's alternative position, in comparison with Greece.

A Historic Ruling: Malta's Golden Passport Is Dead

On 30 April 2025 the Court of Justice of the European Union (ECJ) declared Malta's citizenship-by-investment programme (MEIN) unlawful. The Court ruled that granting citizenship "in exchange for predetermined payments or investments" reduces citizenship to "a mere commercial transaction". Under the Case C-181/23 precedent, the ruling effectively makes it impossible for any EU member state to launch a Malta-style direct citizenship-by-investment programme in the future. It marks the end of the EU's last true "golden passport" programme.

After the ruling, Malta introduced a discretionary citizenship route for those making an "exceptional contribution to society" in science, innovation, the arts and culture; however, this is not an investment-based route and is not a practical option for most investors.

What Remains? The Malta Permanent Residence Programme (MPRP)

Malta's Permanent Residence Programme (MPRP) continues unaffected by the ruling; it provides only a residence permit, not citizenship. Investors can apply with a rented property (from ~€14,000 a year) or a purchased property (from ~€375,000-475,000), combined with a government contribution, an administrative fee and a charitable donation. The programme's standout features are that the status is permanent from day one and carries no minimum stay requirement; processing is also quite fast at 4-6 months.

There are, however, two important limitations: the MPRP does not grant the right to work in the EU — investors who want to be employed in Malta need a separate work-permit process. In addition, the path to citizenship is not accelerated; standard naturalisation via the MPRP still requires 5 years of real and substantial residence — meaning the "genuine link" requirement is monitored more strictly after the ECJ ruling.

Italy: Varied Investment Routes, Standard Citizenship Timeline

Italy's Investor Visa offers several distinct routes: a €250,000 investment in an innovative start-up, €500,000 in shares of an Italian company, a €1,000,000 philanthropic donation or €2,000,000 in government bonds. Italy's standout feature is its annual flat-tax Non-Dom regime, raised to €300,000 from 2026 (from €200,000 previously); this is a model similar to, but more expensive than, the approach we covered in our series' Greece Non-Dom article, covering all foreign income with a flat amount.

In terms of citizenship, however, Italy offers investors no special acceleration; the standard Italian naturalisation process generally requires around 10 years of legal residence for non-EU citizens. This makes Italy attractive not to investors seeking fast citizenship but mainly to high-net-worth individuals who want to benefit from the Non-Dom tax advantage.

Full Comparison Table

The Overall Citizenship Picture: Greece Leads in Southern Europe

After the ECJ ruling, direct citizenship by investment is no longer possible anywhere in the EU; all options are subject to standard naturalisation periods (usually 5-10 years). In this landscape, Greece's 7-year period stands out for investors seeking the fastest EU citizenship in Southern Europe — although Malta's 5-year MPRP route looks technically shorter, it is stressed that "genuine link" scrutiny has tightened after the ECJ ruling and token visits may no longer be enough. Italy's ~10-year standard period represents the longest in this three-way comparison.

Which Profile Should Choose Which?

• For those who want a tangible property investment, broad family coverage and a moderate Non-Dom tax regime: Greece.
• For investors who prioritise fast processing (4-6 months) and permanent status from day one and do not need the right to work: Malta MPRP.
• For high-net-worth individuals with very high foreign income who value the Italian lifestyle and can afford the €300,000 Non-Dom regime: Italy.
• For those aiming for fast EU citizenship: of the three, Greece's 7-year period stands out as the clearest and most predictable path in the tighter post-ECJ scrutiny environment.

Frequently Asked Questions

1. Can I still obtain citizenship by investment in Malta?
No. On 30 April 2025 the Court of Justice of the European Union declared Malta's citizenship-by-investment programme unlawful, marking the end of the EU's last true "golden passport" programme. Malta still offers a residence permit through its Permanent Residence Programme (MPRP), but this is not citizenship; the path to citizenship is subject to the standard 5-year naturalisation process and there is no accelerated route.

2. Can I work under Malta's MPRP?
No. The Malta Permanent Residence Programme does not grant the right to work in the EU. People who want to be employed in Malta or practise a profession regulated under EU rules must either hold EU citizenship or obtain a separate national work permit in the relevant member state. This is a restriction similar to the one we covered in our series' article on the spouse's right to work in Greece; the same logic applies to MPRP holders.

3. Why is Italy's Non-Dom regime more expensive than Greece's?
Italy's Non-Dom regime was raised to €300,000 a year from 2026 (from €200,000 previously), while Greece's Non-Dom regime remains at a flat €100,000 a year. This makes Greece one of the lowest-cost options in Western Europe among such regimes, while making Italy's regime mathematically meaningful only for individuals with very high foreign income (at the level of several million euros a year).

4. Which of the three countries offers the fastest EU citizenship?
In theory Malta's 5-year MPRP period looks the shortest, but it is stressed that "genuine link" scrutiny has tightened after the ECJ ruling and symbolic visits may not be enough, which somewhat reduces its practical reliability. Greece's 7-year period offers a more predictable path because it rests on a clear and explicit physical-residence requirement (183 days/year). Italy's ~10-year standard period is the longest of the three.

5. Does the ECJ ruling on Malta also affect Greece?
Not directly, because Greece does not offer a direct citizenship-by-investment programme — it provides only a residence permit (the Golden Visa) that can feed into the standard naturalisation process. The ECJ ruling targets Malta-style "citizenship in direct exchange for investment" models; Greece's model, based on a 7-year genuine-residence requirement, does not fall within the "commercial transaction" definition criticised by the ruling. Greece's current structure is therefore already in a more compatible position under EU law.

Note: The information in this article is based on general observations, and the programmes' legislation can change quickly; it does not constitute investment advice. Contact us to determine which of the Greek, Maltese and Italian options best suits your goals — we are with you from the beginning to the end of the Golden Visa process.