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For high-net-worth individuals and their families, the answer may be particularly significant.
The move toward merit-based citizenship does not necessarily make wealthy individuals less attractive to governments.
In many respects, it may make the relationship more sophisticated.
A high-net-worth individual may bring substantially more to a country than the minimum financial contribution required under a traditional citizenship-by-investment program.
For example, an internationally successful entrepreneur might:
From a government’s perspective, this type of individual may represent considerably greater long-term value than a one-time financial contribution.
Citizenship by merit creates a framework through which that broader value can potentially be recognized.
This may ultimately be the most important conceptual change.
Traditional CBI programs tend to focus on investment.
Merit-based citizenship focuses more broadly on contribution.
Investment is relatively easy to measure.
A government can establish a minimum contribution of a specified amount and determine whether the applicant has satisfied the requirement.
Contribution is more difficult to quantify.
An entrepreneur who creates 100 jobs may arguably contribute more to a country than someone who makes a passive financial investment.
A scientist who develops important technology may provide enormous long-term value without making a traditional investment at all.
Likewise, a philanthropist who establishes a major charitable foundation may contribute to society in ways that cannot easily be captured by a standardized investment threshold.
Merit-based citizenship therefore gives governments the ability to consider the quality and nature of an applicant’s contribution, rather than simply its monetary value.
The RCBI industry itself has matured considerably.
Early investment migration programs were often marketed primarily around financial thresholds, processing times, and visa-free travel.
Today’s sophisticated applicants are increasingly looking at a much broader range of issues:
Governments are responding to the same evolution.
A citizenship program that is internationally respected must increasingly demonstrate that citizenship is being granted for legitimate and defensible reasons.
Merit-based frameworks potentially address this concern by placing greater emphasis on the individual rather than simply the transaction.
This does not mean that investment becomes irrelevant.
Rather, investment may become one element of a broader assessment of the applicant’s relationship with, and potential contribution to, the jurisdiction.
For prospective applicants, the shift toward merit-based citizenship has both advantages and disadvantages.
The principal advantage is potentially greater selectivity.
If a jurisdiction is genuinely seeking individuals who can make a meaningful contribution, applicants with strong professional backgrounds, entrepreneurial achievements, philanthropic records, international reputations, or significant economic resources may be particularly attractive.
However, the principal disadvantage is uncertainty.
Traditional CBI programs are generally designed to provide applicants with clearly defined eligibility criteria.
A discretionary merit-based framework may not provide the same level of predictability.
An applicant may satisfy a number of objective criteria but still face a discretionary assessment of whether their circumstances justify citizenship.
This means that applicants considering a merit-based route should pay close attention not only to the financial aspects of the process but also to their overall profile, proposed contribution, reputation, and the legal framework governing discretionary decisions.
The changing nature of citizenship programs is especially relevant to clients from the United States, Canada, Western Europe, Australia, and other developed jurisdictions.
These individuals often already possess strong passports.
Their objective is therefore not necessarily to replace their existing citizenship.
Instead, they may be seeking:
For these clients, the quality and long-term credibility of the second citizenship may be more important than simply obtaining a passport as quickly or inexpensively as possible.
A merit-based framework may therefore appeal to a different segment of the market: individuals who are willing and able to demonstrate a broader connection or contribution in exchange for access to a highly credible citizenship.
This is particularly relevant because many Western investors are not looking for a replacement passport.
They already have one.
Instead, they are looking for optionality.
A second citizenship can form part of a broader strategy involving family security, international business, succession planning, mobility, and long-term diversification. As with other significant planning decisions, the passport itself should not be viewed in isolation.
This is perhaps the biggest question surrounding the emerging model.
Critics may argue that if wealthy individuals continue to be the primary beneficiaries of discretionary citizenship, the distinction between CBI and citizenship by merit is largely semantic.
There is certainly an overlap.
Financial capacity can be relevant to an individual’s ability to contribute to a country, and wealthy investors are naturally more likely to have the resources to make substantial economic or philanthropic contributions.
However, the legal distinction can still be significant.
A genuine merit-based framework does not guarantee citizenship simply because an applicant meets a financial threshold.
The decision remains discretionary and depends on the individual’s overall circumstances.
This is an important distinction in Malta’s current framework, which expressly treats citizenship by merit as a discretionary, case-by-case process rather than a conventional citizenship program.
The distinction therefore lies not simply in the amount of money involved, but in the legal basis upon which citizenship is granted.
It is too early to say that citizenship by merit will replace citizenship by investment globally.
Different jurisdictions have different economic realities, constitutional structures, and political objectives.
For smaller states, structured investment programs can provide significant development capital, and there may continue to be strong economic reasons for maintaining them.
At the same time, countries seeking to attract highly successful individuals while minimizing the political and regulatory criticism associated with traditional CBI may increasingly favor discretionary frameworks.
This could produce a more segmented global market.
Some jurisdictions may continue to offer highly structured CBI programs.
Others may emphasize residence before citizenship.
Some may develop merit-based or exceptional-contribution frameworks.
And increasingly, jurisdictions may combine elements of these approaches, offering investors residence while reserving citizenship for individuals who demonstrate a deeper connection or exceptional contribution.
A Potential New Model for Investment Migration
The future may therefore be less about choosing between CBI and citizenship by merit and more about creating a continuum of pathways.
At one end are highly structured investment programs where an applicant’s financial contribution is the principal qualifying factor.
In the middle are residence-by-investment programs, where an investor initially obtains residence and may later qualify for citizenship after meeting requirements relating to residence, integration, language, or other connections.
At the other end are discretionary citizenship pathways, where the government assesses an individual’s exceptional achievements or contribution and determines whether citizenship is justified.
This creates a more nuanced investment migration landscape.
For governments, it provides different tools for attracting different types of international individuals.
For investors, however, it means that the old approach of simply comparing investment thresholds may become increasingly inadequate.
The right question may instead be:
What Could the Future Look Like?
The next generation of RCBI programs may place greater emphasis on quality rather than quantity.
Governments may become less interested in simply maximizing the number of successful applicants and more interested in attracting individuals who can provide long-term economic, social, cultural, or strategic value.
That could mean greater emphasis on:
It could also mean more sophisticated due diligence and a greater willingness to exercise discretion.
This would represent a significant change from the early days of investment migration.
The industry could increasingly resemble other areas of high-net-worth planning, where the focus is not simply on whether an individual can meet a financial threshold but on whether a particular structure is appropriate for that individual’s broader circumstances.
For prospective applicants, the changing landscape means that citizenship programs should be evaluated on more than headline investment amounts.
Investors should consider:
This is particularly important for HNW and UHNW clients.
A second citizenship is often a long-term family asset rather than a short-term travel solution.
The decision should therefore be evaluated in the same way as other major international planning decisions: by considering the client’s broader objectives rather than focusing on a single feature of the program.
The Bigger Picture
The emergence of citizenship by merit should not necessarily be viewed as the end of citizenship by investment.
Rather, it may represent the next stage in the evolution of the RCBI industry.
Governments are increasingly recognizing that attracting international capital is only one part of the equation.
They also want to attract entrepreneurs, investors, professionals, philanthropists, innovators, and families who can contribute to the country over the long term.
At the same time, international scrutiny means that governments must increasingly be able to explain why a particular individual was granted citizenship and demonstrate that the process is credible, transparent, and consistent with applicable legal and international standards.
Merit-based citizenship provides one possible answer to that challenge.
For investors, however, the evolution creates a new consideration.
The strongest citizenship opportunity may not necessarily be the one with the lowest investment requirement or the fastest processing time.
It may be the one where the applicant’s profile, objectives, contribution, and relationship with the jurisdiction make sense over the long term.
Citizenship by merit reflects a broader transformation taking place across the residence and citizenship by investment industry.
The traditional model of citizenship being granted after a defined financial contribution is facing greater scrutiny from governments, courts, and international institutions. The 2025 judgment of the Court of Justice of the European Union concerning Malta’s former investor citizenship scheme is one of the clearest examples of this changing environment.
At the same time, countries continue to recognize the significant economic and strategic value that internationally mobile investors, entrepreneurs, and high-net-worth families can bring.
Merit-based frameworks seek to balance these competing interests.
They allow governments to remain open to international talent and capital while retaining greater discretion over who ultimately receives citizenship.
For applicants, this creates both new opportunities and new considerations.
The future of RCBI is unlikely to be defined by a single model. Instead, the industry may increasingly differentiate between investment, residence, connection, and merit—with each jurisdiction determining the combination that best serves its national interests.
As the industry continues to mature, the strongest citizenship options are likely to be those that combine credible due diligence, transparent legal frameworks, responsible government oversight, and a clear rationale for why citizenship is being granted.
For prospective applicants, understanding this evolution is essential.
Citizenship should not be viewed simply as a financial transaction or travel document. It is a long-term relationship with a country—and the jurisdictions that recognize this distinction are likely to play an increasingly important role in the next generation of global investment migration.
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