In the final part of our three-part mini-series on the theme of "citizenship and identity", we'll talk about the small Mediterranean island of Malta and its battle with the European Union to continue selling citizenship.
While Malta argues that it's a matter of national sovereignty, the European Union views it as a concerning practice that reduces citizenship to a mere commercial transaction.
So, should a passport really be for sale?
[00:00:00] Hello, hello, hello, and welcome to English Learning for Curious Minds, by Leonardo English, the show where you can listen to fascinating stories and learn weird and wonderful things about the world at the same time as improving your English.
[00:00:21] I'm Alastair Budge, and today it’s part three of our three-part mini-series on the subject of citizenship and identity.
[00:00:30] In case you missed it, in part one, we talked about who can and can’t become an Italian citizen.
[00:00:37] In part two, we talked about the Windrush Scandal, where tens of thousands of people in Britain, who had lived in the country for decades and believed they were British, were suddenly told they were not.
[00:00:49] And in this episode, we are going to talk about the small Mediterranean island of Malta, and its battle with the European Union over its right to continue selling its passports.
[00:01:02] If you are a seriously dedicated listener to this show, you might remember us touching on this subject in episode number 42, back in 2020, but today we are going to go a lot deeper and talk about how things have evolved since then.
[00:01:18] So let’s not waste a minute, and get right into it.
[00:01:24] So far in this mini-series, we’ve explored some of the ways in which an individual becomes a citizen of a country.
[00:01:33] They can be born there, they can have parents or grandparents who are citizens of that country, they can marry someone from that country, they can live in and contribute to that country for a certain time, after which they can apply to become a citizen.
[00:01:49] For the vast majority of the world’s population, one or more of these will be the routes through which they have acquired citizenship or citizenships.
[00:02:00] But there are also countries that offer a shortcut, countries that offer their passports to people who don’t want to wait, people who want a citizenship now, and are prepared to pay handsomely for the privilege.
[00:02:16] These are the countries that sell their passports, or to give them their technical name, countries that offer “citizenship by investment” schemes.
[00:02:28] Typically, these are small countries, often islands, which will offer citizenship in exchange for a cash donation or some kind of investment in the country.
[00:02:40] The first country to start offering it was the Caribbean island nation of Saint Kitts and Nevis, which launched its scheme in 1984.
[00:02:51] It offered citizenship of Saint Kitts and Nevis, along with low tax rates, in exchange for a cash payment. You didn’t even have to set foot in the country, but, for a fee, of course, you could become a citizen.
[00:03:07] And if you’re wondering who was and is buying these passports, and for what reason, it’s typically wealthy individuals looking for three main things.
[00:03:20] Firstly, greater travel freedom. A passport from Saint Kitts and Nevis gives visa-free access to over 150 countries, including the UK and much of Europe, which is a big deal for someone from, say, China or Russia, where they might need visas, or they might not be allowed to enter at all.
[00:03:43] Second, tax advantages. Saint Kitts has no income or capital gains tax for citizens, so it can be a legal way for the very rich to reduce their tax bills.
[00:03:56] Third, a safety net. For people from unstable countries, places with shaky economies, or simply countries where the government can come along one day and seize all your assets, a second passport is like an insurance policy, a quick exit if things go south.
[00:04:16] And for the country that sold these passports, the benefit was clear: cold, hard cash.
[00:04:25] It costs practically nothing to print a passport and add a name to a database, and if there is no residency requirement, no need for the individual to come there or buy property, the effect on the local population is minimal: no complaints about foreigners increasing property prices or changing the local environment.
[00:04:48] And the fees paid by these foreigners, or I should say newly minted fellow citizens, these can be used for everything from schools to hospitals to pensions.
[00:05:00] Given this, after the first scheme in Saint Kitts and Nevis was launched in 1984, many other countries followed suit, offering their own citizenship by investment schemes.
[00:05:13] Soon enough, a wealthy person could choose from a suite of different countries, like wandering down a supermarket aisle and looking at the various offers on sale.
[00:05:25] And fast forward to 2014, the tiny Mediterranean island of Malta made a splash by launching its own scheme that didn’t just get you any passport, it got you a passport to a country in the European Union.
[00:05:43] Now, importantly, Malta wasn’t the first EU country to launch a CBI-type scheme; Ireland launched a similar scheme in 1988, but it was a little different, and it wasn’t a great success.
[00:06:00] Malta’s was different.
[00:06:03] Firstly, it was a question of timing. There were simply a lot more people who could afford and who wanted to buy passports in 2014 than there were in 1988.
[00:06:15] Whether we are talking about China or Saudi Arabia or India, or even Russia, the market for people who could spend six-figure sums on citizenship was considerably larger when Malta launched its scheme.
[00:06:30] What’s more, the EU element was more valuable in 2014 than in the 1990s. When Ireland launched its programme, there were only 12 countries in the EU; when Malta did, there were 28.
[00:06:46] And importantly, having a passport to an EU country means that you have visa-free travel to any other country in the EU, which is a large bonus for a wealthy individual who likes the idea of trotting between Milan and Paris and perhaps the odd weekend trip to Stockholm or Barcelona. You also have the right to live in any EU country, so by getting a Maltese passport, you can live somewhere more desirable, like the south of France or a Tuscan villa.
[00:07:20] And secondly, the Malta scheme had some very slick marketing behind it. A company called Henley and Partners went around the globe selling passports on behalf of Malta, and collecting a healthy commission in the process.
[00:07:38] A 4% commission, by the way, on the cost of a minimum of €700,000, which would typically rise to almost a million Euros by the time everything else was taken into account.
[00:07:51] Now, you might be thinking “who would pay a million Euros for a passport?”, but the answer is “a lot of people”.
[00:08:00] The scheme was officially capped at 1,800 main applicants, which is the classic marketing ploy of creating scarcity to encourage people to take action, and in 10 years, almost all of those places were sold.
[00:08:17] Including dependents–so partners and children–a total of 5,300 people were granted Maltese citizenship, which brought in an estimated €1.6 billion to the country.
[00:08:32] That might not be all that much for a larger country, but for a small country like Malta, with a population of less than half a million, it equated to more than €3,000 for every man, woman and child.
[00:08:48] Yes, not all of this money reached the average person in Malta, and there are widespread allegations of corruption and cronyism, with politicians and businesspeople siphoning off large chunks for themselves.
[00:09:01] But it did mean that the government was able to start offering things like free childcare and make improvements to the healthcare and education systems.
[00:09:12] Now, the scheme in Malta was slightly stricter than that of Saint Kitts and Nevis, for example.
[00:09:19] There was a theoretical requirement for you to “live” in Malta, but in practice this meant you either had a buy an apartment worth at least €350,000 or rent one for €1,300 a month.
[00:09:36] If you are already paying almost a million Euros for a passport, another €1,300 is pocket change, and what this meant was that there were and still are hundreds of apartments in Malta that were rented out purely for the purpose of meeting this “residency requirement”.
[00:09:57] I lived in Malta for 7 years, for reasons entirely unrelated to passports or citizenship, I should add, and my former landlord had two apartments that he rented out to foreigners.
[00:10:11] One was to us. We were pretty good tenants, I think, but there was the occasional problem: the dishwasher broke or something needed to be fixed. You know, normal stuff that happens in any rented apartment.
[00:10:27] But he preferred his other tenants, who rented the apartment opposite us. They were far less demanding because they didn’t actually live in the apartment.
[00:10:37] They had never even seen it; the place was completely empty, but they paid their rent every month, so they had the paperwork to “prove” their so-called residency in Malta.
[00:10:50] Now, you might think this is all perfectly fair, and that a country has the right to decide who it gives citizenship to, and under what conditions.
[00:11:00] You might think that it’s awful, and that citizenship should be about more than bank transfers and signatures in air-conditioned conference rooms.
[00:11:10] Someone, or rather something, that firmly took the latter position, was the European Union.
[00:11:18] The EU’s objection wasn’t immediate, and Malta wasn’t trying to hide this scheme, quite the opposite.
[00:11:27] But as Malta’s programme gathered pace after its 2014 launch, concerns started to grow in Brussels.
[00:11:36] From the EU’s perspective, the problem was simple: while every member state has the sovereign right to decide who gets its citizenship, EU citizenship is automatically attached to national citizenship.
[00:11:52] The moment someone becomes Maltese, they also become European, with the right to live, work, and travel freely across 27 other countries.
[00:12:04] So, when Malta was selling its passports, it wasn’t just selling access to Malta, it was selling access to the entire European Union.
[00:12:15] At first, the European Commission expressed what you might call gentle unease about the scheme, with the occasional politician making a passing comment about it or mentioning how it should be looked into.
[00:12:29] But as the number of applicants grew, and as questions were raised about how thoroughly applicants were being vetted, the concerns became more serious.
[00:12:41] In 2017, a particularly strong light was shone on Malta after the assassination of the investigative journalist Daphne Caruana Galizia, who was, among other things, looking into allegations of political corruption specifically related to sales of passports.
[00:13:01] In 2018, the European Parliament passed a resolution calling on member states to phase out both citizenship and residence-by-investment programmes, warning that they posed risks related to money laundering, tax evasion, and security.
[00:13:19] The pressure kept mounting, and in October of 2020, the European Commission formally launched infringement proceedings against Malta, accusing it of violating EU law.
[00:13:33] At this point, Brussels wasn’t just politely expressing its disapproval; it was starting legal action against a member state.
[00:13:43] Malta, for its part, pushed back. It argued that deciding who becomes a citizen is a matter of national sovereignty, something that EU treaties leave entirely up to member states.
[00:13:58] But behind the scenes, the government also began to make changes.
[00:14:03] In late 2020, Malta officially closed its original Individual Investor Programme and introduced a new version, the Maltese Exceptional Investor Naturalisation Programme.
[00:14:17] On paper, this new scheme was stricter. Applicants now needed to establish residency for either 12 or 36 months, depending on the size of their payment, and the government claimed to have strengthened its due diligence processes.
[00:14:34] But critics, including the European Commission, argued that these changes were largely cosmetic. After all, wealthy individuals could still buy their way to Maltese citizenship in just over a year, often without any genuine connection to the country.
[00:14:52] They were still selling passports, it was now just a little harder to buy them.
[00:14:57] And there were more leaks. In 2021, an investigation called the Passport Papers revealed that applicants to the Malta passport scheme said they only planned to spend an average of 16 days in the country, and that this was considered sufficient by the Maltese government to qualify for “12 months residency”.
[00:15:22] Clearly, the Maltese authorities had been well-advised when creating the scheme to add this “12-month residency requirement”, so as to be able to claim to the EU that these people were genuine residents, but these leaked emails showed that people didn’t really have to spend any significant time in the country, they just had to pretend they did.
[00:15:44] And so, pressure continued to build, and the legal battle continued.
[00:15:50] In 2022, the European Commission escalated the case by issuing what’s called a reasoned opinion, which is the next formal step in infringement proceedings, and warned Malta that if it didn’t shut the programme down entirely, the case would be referred to the European Court of Justice.
[00:16:11] And in mid-2023, that’s exactly what happened: the dispute landed at the EU’s highest court, and in April of 2025, the court gave its decision.
[00:16:24] The scheme is in violation of EU law, and–to quote directly–it "amounts to rendering the acquisition of nationality a mere commercial transaction".
[00:16:37] In other words, something that should be about true connection–whether that’s through blood, living in a country for an extended period, or through marriage–this is reduced to just another product with a price tag.
[00:16:51] So, what comes next?
[00:16:54] Well, as of the time of recording this episode, not much has changed.
[00:16:59] The Henley & Partners website currently reads, “The Malta Citizenship by Naturalisation for Exceptional Services by Direct Investment process is no longer accepting new applications”, but there has been no official announcement.
[00:17:15] Malta has said it’ll examine the findings, and most likely it will find a way to challenge the EU’s decision.
[00:17:24] The country may be forced to shut its programme down permanently, and this decision could also effectively block any other EU country from launching a similar scheme in future.
[00:17:38] And that, ultimately, gets to the heart of the entire controversy.
[00:17:42] Is citizenship something that countries should be able to sell?
[00:17:46] Is it simply another product in a global market, like real estate or stocks?
[00:17:52] Or, as the European Union argues, is it something much deeper, tied to rights, responsibilities, and the shared values of a political union?
[00:18:04] Malta’s case may seem small and insignificant–a tiny island selling a few thousand passports–but the questions it raises are ones that every country, and every union of countries, are being forced to confront.
[00:18:21] OK, then, that is it for today's episode on Malta’s battle with the EU to sell passports, and with that comes an end to this mini-series on the theme of citizenship and identity.
[00:18:33] I hope it's been an interesting one and that you've learnt something new.
[00:18:37] As always, I would love to know what you thought of this episode and of this mini-series in general.
[00:18:42] Do you think an EU country should have full control over who it grants passports to, and how?
[00:18:48] If you have become a citizen of another country, do you truly feel like you belong in that country, and what is your story?
[00:18:57] I would love to know, and I’ll be happy to share my own experience too.
[00:19:01] You can head right into our community forum, which is at community.leonardoenglish.com and get chatting away to other curious minds.
[00:19:09] You've been listening to English Learning for Curious Minds by Leonardo English.
[00:19:14] I'm Alastair Budge, you stay safe, and I'll catch you in the next episode.
[00:00:00] Hello, hello, hello, and welcome to English Learning for Curious Minds, by Leonardo English, the show where you can listen to fascinating stories and learn weird and wonderful things about the world at the same time as improving your English.
[00:00:21] I'm Alastair Budge, and today it’s part three of our three-part mini-series on the subject of citizenship and identity.
[00:00:30] In case you missed it, in part one, we talked about who can and can’t become an Italian citizen.
[00:00:37] In part two, we talked about the Windrush Scandal, where tens of thousands of people in Britain, who had lived in the country for decades and believed they were British, were suddenly told they were not.
[00:00:49] And in this episode, we are going to talk about the small Mediterranean island of Malta, and its battle with the European Union over its right to continue selling its passports.
[00:01:02] If you are a seriously dedicated listener to this show, you might remember us touching on this subject in episode number 42, back in 2020, but today we are going to go a lot deeper and talk about how things have evolved since then.
[00:01:18] So let’s not waste a minute, and get right into it.
[00:01:24] So far in this mini-series, we’ve explored some of the ways in which an individual becomes a citizen of a country.
[00:01:33] They can be born there, they can have parents or grandparents who are citizens of that country, they can marry someone from that country, they can live in and contribute to that country for a certain time, after which they can apply to become a citizen.
[00:01:49] For the vast majority of the world’s population, one or more of these will be the routes through which they have acquired citizenship or citizenships.
[00:02:00] But there are also countries that offer a shortcut, countries that offer their passports to people who don’t want to wait, people who want a citizenship now, and are prepared to pay handsomely for the privilege.
[00:02:16] These are the countries that sell their passports, or to give them their technical name, countries that offer “citizenship by investment” schemes.
[00:02:28] Typically, these are small countries, often islands, which will offer citizenship in exchange for a cash donation or some kind of investment in the country.
[00:02:40] The first country to start offering it was the Caribbean island nation of Saint Kitts and Nevis, which launched its scheme in 1984.
[00:02:51] It offered citizenship of Saint Kitts and Nevis, along with low tax rates, in exchange for a cash payment. You didn’t even have to set foot in the country, but, for a fee, of course, you could become a citizen.
[00:03:07] And if you’re wondering who was and is buying these passports, and for what reason, it’s typically wealthy individuals looking for three main things.
[00:03:20] Firstly, greater travel freedom. A passport from Saint Kitts and Nevis gives visa-free access to over 150 countries, including the UK and much of Europe, which is a big deal for someone from, say, China or Russia, where they might need visas, or they might not be allowed to enter at all.
[00:03:43] Second, tax advantages. Saint Kitts has no income or capital gains tax for citizens, so it can be a legal way for the very rich to reduce their tax bills.
[00:03:56] Third, a safety net. For people from unstable countries, places with shaky economies, or simply countries where the government can come along one day and seize all your assets, a second passport is like an insurance policy, a quick exit if things go south.
[00:04:16] And for the country that sold these passports, the benefit was clear: cold, hard cash.
[00:04:25] It costs practically nothing to print a passport and add a name to a database, and if there is no residency requirement, no need for the individual to come there or buy property, the effect on the local population is minimal: no complaints about foreigners increasing property prices or changing the local environment.
[00:04:48] And the fees paid by these foreigners, or I should say newly minted fellow citizens, these can be used for everything from schools to hospitals to pensions.
[00:05:00] Given this, after the first scheme in Saint Kitts and Nevis was launched in 1984, many other countries followed suit, offering their own citizenship by investment schemes.
[00:05:13] Soon enough, a wealthy person could choose from a suite of different countries, like wandering down a supermarket aisle and looking at the various offers on sale.
[00:05:25] And fast forward to 2014, the tiny Mediterranean island of Malta made a splash by launching its own scheme that didn’t just get you any passport, it got you a passport to a country in the European Union.
[00:05:43] Now, importantly, Malta wasn’t the first EU country to launch a CBI-type scheme; Ireland launched a similar scheme in 1988, but it was a little different, and it wasn’t a great success.
[00:06:00] Malta’s was different.
[00:06:03] Firstly, it was a question of timing. There were simply a lot more people who could afford and who wanted to buy passports in 2014 than there were in 1988.
[00:06:15] Whether we are talking about China or Saudi Arabia or India, or even Russia, the market for people who could spend six-figure sums on citizenship was considerably larger when Malta launched its scheme.
[00:06:30] What’s more, the EU element was more valuable in 2014 than in the 1990s. When Ireland launched its programme, there were only 12 countries in the EU; when Malta did, there were 28.
[00:06:46] And importantly, having a passport to an EU country means that you have visa-free travel to any other country in the EU, which is a large bonus for a wealthy individual who likes the idea of trotting between Milan and Paris and perhaps the odd weekend trip to Stockholm or Barcelona. You also have the right to live in any EU country, so by getting a Maltese passport, you can live somewhere more desirable, like the south of France or a Tuscan villa.
[00:07:20] And secondly, the Malta scheme had some very slick marketing behind it. A company called Henley and Partners went around the globe selling passports on behalf of Malta, and collecting a healthy commission in the process.
[00:07:38] A 4% commission, by the way, on the cost of a minimum of €700,000, which would typically rise to almost a million Euros by the time everything else was taken into account.
[00:07:51] Now, you might be thinking “who would pay a million Euros for a passport?”, but the answer is “a lot of people”.
[00:08:00] The scheme was officially capped at 1,800 main applicants, which is the classic marketing ploy of creating scarcity to encourage people to take action, and in 10 years, almost all of those places were sold.
[00:08:17] Including dependents–so partners and children–a total of 5,300 people were granted Maltese citizenship, which brought in an estimated €1.6 billion to the country.
[00:08:32] That might not be all that much for a larger country, but for a small country like Malta, with a population of less than half a million, it equated to more than €3,000 for every man, woman and child.
[00:08:48] Yes, not all of this money reached the average person in Malta, and there are widespread allegations of corruption and cronyism, with politicians and businesspeople siphoning off large chunks for themselves.
[00:09:01] But it did mean that the government was able to start offering things like free childcare and make improvements to the healthcare and education systems.
[00:09:12] Now, the scheme in Malta was slightly stricter than that of Saint Kitts and Nevis, for example.
[00:09:19] There was a theoretical requirement for you to “live” in Malta, but in practice this meant you either had a buy an apartment worth at least €350,000 or rent one for €1,300 a month.
[00:09:36] If you are already paying almost a million Euros for a passport, another €1,300 is pocket change, and what this meant was that there were and still are hundreds of apartments in Malta that were rented out purely for the purpose of meeting this “residency requirement”.
[00:09:57] I lived in Malta for 7 years, for reasons entirely unrelated to passports or citizenship, I should add, and my former landlord had two apartments that he rented out to foreigners.
[00:10:11] One was to us. We were pretty good tenants, I think, but there was the occasional problem: the dishwasher broke or something needed to be fixed. You know, normal stuff that happens in any rented apartment.
[00:10:27] But he preferred his other tenants, who rented the apartment opposite us. They were far less demanding because they didn’t actually live in the apartment.
[00:10:37] They had never even seen it; the place was completely empty, but they paid their rent every month, so they had the paperwork to “prove” their so-called residency in Malta.
[00:10:50] Now, you might think this is all perfectly fair, and that a country has the right to decide who it gives citizenship to, and under what conditions.
[00:11:00] You might think that it’s awful, and that citizenship should be about more than bank transfers and signatures in air-conditioned conference rooms.
[00:11:10] Someone, or rather something, that firmly took the latter position, was the European Union.
[00:11:18] The EU’s objection wasn’t immediate, and Malta wasn’t trying to hide this scheme, quite the opposite.
[00:11:27] But as Malta’s programme gathered pace after its 2014 launch, concerns started to grow in Brussels.
[00:11:36] From the EU’s perspective, the problem was simple: while every member state has the sovereign right to decide who gets its citizenship, EU citizenship is automatically attached to national citizenship.
[00:11:52] The moment someone becomes Maltese, they also become European, with the right to live, work, and travel freely across 27 other countries.
[00:12:04] So, when Malta was selling its passports, it wasn’t just selling access to Malta, it was selling access to the entire European Union.
[00:12:15] At first, the European Commission expressed what you might call gentle unease about the scheme, with the occasional politician making a passing comment about it or mentioning how it should be looked into.
[00:12:29] But as the number of applicants grew, and as questions were raised about how thoroughly applicants were being vetted, the concerns became more serious.
[00:12:41] In 2017, a particularly strong light was shone on Malta after the assassination of the investigative journalist Daphne Caruana Galizia, who was, among other things, looking into allegations of political corruption specifically related to sales of passports.
[00:13:01] In 2018, the European Parliament passed a resolution calling on member states to phase out both citizenship and residence-by-investment programmes, warning that they posed risks related to money laundering, tax evasion, and security.
[00:13:19] The pressure kept mounting, and in October of 2020, the European Commission formally launched infringement proceedings against Malta, accusing it of violating EU law.
[00:13:33] At this point, Brussels wasn’t just politely expressing its disapproval; it was starting legal action against a member state.
[00:13:43] Malta, for its part, pushed back. It argued that deciding who becomes a citizen is a matter of national sovereignty, something that EU treaties leave entirely up to member states.
[00:13:58] But behind the scenes, the government also began to make changes.
[00:14:03] In late 2020, Malta officially closed its original Individual Investor Programme and introduced a new version, the Maltese Exceptional Investor Naturalisation Programme.
[00:14:17] On paper, this new scheme was stricter. Applicants now needed to establish residency for either 12 or 36 months, depending on the size of their payment, and the government claimed to have strengthened its due diligence processes.
[00:14:34] But critics, including the European Commission, argued that these changes were largely cosmetic. After all, wealthy individuals could still buy their way to Maltese citizenship in just over a year, often without any genuine connection to the country.
[00:14:52] They were still selling passports, it was now just a little harder to buy them.
[00:14:57] And there were more leaks. In 2021, an investigation called the Passport Papers revealed that applicants to the Malta passport scheme said they only planned to spend an average of 16 days in the country, and that this was considered sufficient by the Maltese government to qualify for “12 months residency”.
[00:15:22] Clearly, the Maltese authorities had been well-advised when creating the scheme to add this “12-month residency requirement”, so as to be able to claim to the EU that these people were genuine residents, but these leaked emails showed that people didn’t really have to spend any significant time in the country, they just had to pretend they did.
[00:15:44] And so, pressure continued to build, and the legal battle continued.
[00:15:50] In 2022, the European Commission escalated the case by issuing what’s called a reasoned opinion, which is the next formal step in infringement proceedings, and warned Malta that if it didn’t shut the programme down entirely, the case would be referred to the European Court of Justice.
[00:16:11] And in mid-2023, that’s exactly what happened: the dispute landed at the EU’s highest court, and in April of 2025, the court gave its decision.
[00:16:24] The scheme is in violation of EU law, and–to quote directly–it "amounts to rendering the acquisition of nationality a mere commercial transaction".
[00:16:37] In other words, something that should be about true connection–whether that’s through blood, living in a country for an extended period, or through marriage–this is reduced to just another product with a price tag.
[00:16:51] So, what comes next?
[00:16:54] Well, as of the time of recording this episode, not much has changed.
[00:16:59] The Henley & Partners website currently reads, “The Malta Citizenship by Naturalisation for Exceptional Services by Direct Investment process is no longer accepting new applications”, but there has been no official announcement.
[00:17:15] Malta has said it’ll examine the findings, and most likely it will find a way to challenge the EU’s decision.
[00:17:24] The country may be forced to shut its programme down permanently, and this decision could also effectively block any other EU country from launching a similar scheme in future.
[00:17:38] And that, ultimately, gets to the heart of the entire controversy.
[00:17:42] Is citizenship something that countries should be able to sell?
[00:17:46] Is it simply another product in a global market, like real estate or stocks?
[00:17:52] Or, as the European Union argues, is it something much deeper, tied to rights, responsibilities, and the shared values of a political union?
[00:18:04] Malta’s case may seem small and insignificant–a tiny island selling a few thousand passports–but the questions it raises are ones that every country, and every union of countries, are being forced to confront.
[00:18:21] OK, then, that is it for today's episode on Malta’s battle with the EU to sell passports, and with that comes an end to this mini-series on the theme of citizenship and identity.
[00:18:33] I hope it's been an interesting one and that you've learnt something new.
[00:18:37] As always, I would love to know what you thought of this episode and of this mini-series in general.
[00:18:42] Do you think an EU country should have full control over who it grants passports to, and how?
[00:18:48] If you have become a citizen of another country, do you truly feel like you belong in that country, and what is your story?
[00:18:57] I would love to know, and I’ll be happy to share my own experience too.
[00:19:01] You can head right into our community forum, which is at community.leonardoenglish.com and get chatting away to other curious minds.
[00:19:09] You've been listening to English Learning for Curious Minds by Leonardo English.
[00:19:14] I'm Alastair Budge, you stay safe, and I'll catch you in the next episode.
[00:00:00] Hello, hello, hello, and welcome to English Learning for Curious Minds, by Leonardo English, the show where you can listen to fascinating stories and learn weird and wonderful things about the world at the same time as improving your English.
[00:00:21] I'm Alastair Budge, and today it’s part three of our three-part mini-series on the subject of citizenship and identity.
[00:00:30] In case you missed it, in part one, we talked about who can and can’t become an Italian citizen.
[00:00:37] In part two, we talked about the Windrush Scandal, where tens of thousands of people in Britain, who had lived in the country for decades and believed they were British, were suddenly told they were not.
[00:00:49] And in this episode, we are going to talk about the small Mediterranean island of Malta, and its battle with the European Union over its right to continue selling its passports.
[00:01:02] If you are a seriously dedicated listener to this show, you might remember us touching on this subject in episode number 42, back in 2020, but today we are going to go a lot deeper and talk about how things have evolved since then.
[00:01:18] So let’s not waste a minute, and get right into it.
[00:01:24] So far in this mini-series, we’ve explored some of the ways in which an individual becomes a citizen of a country.
[00:01:33] They can be born there, they can have parents or grandparents who are citizens of that country, they can marry someone from that country, they can live in and contribute to that country for a certain time, after which they can apply to become a citizen.
[00:01:49] For the vast majority of the world’s population, one or more of these will be the routes through which they have acquired citizenship or citizenships.
[00:02:00] But there are also countries that offer a shortcut, countries that offer their passports to people who don’t want to wait, people who want a citizenship now, and are prepared to pay handsomely for the privilege.
[00:02:16] These are the countries that sell their passports, or to give them their technical name, countries that offer “citizenship by investment” schemes.
[00:02:28] Typically, these are small countries, often islands, which will offer citizenship in exchange for a cash donation or some kind of investment in the country.
[00:02:40] The first country to start offering it was the Caribbean island nation of Saint Kitts and Nevis, which launched its scheme in 1984.
[00:02:51] It offered citizenship of Saint Kitts and Nevis, along with low tax rates, in exchange for a cash payment. You didn’t even have to set foot in the country, but, for a fee, of course, you could become a citizen.
[00:03:07] And if you’re wondering who was and is buying these passports, and for what reason, it’s typically wealthy individuals looking for three main things.
[00:03:20] Firstly, greater travel freedom. A passport from Saint Kitts and Nevis gives visa-free access to over 150 countries, including the UK and much of Europe, which is a big deal for someone from, say, China or Russia, where they might need visas, or they might not be allowed to enter at all.
[00:03:43] Second, tax advantages. Saint Kitts has no income or capital gains tax for citizens, so it can be a legal way for the very rich to reduce their tax bills.
[00:03:56] Third, a safety net. For people from unstable countries, places with shaky economies, or simply countries where the government can come along one day and seize all your assets, a second passport is like an insurance policy, a quick exit if things go south.
[00:04:16] And for the country that sold these passports, the benefit was clear: cold, hard cash.
[00:04:25] It costs practically nothing to print a passport and add a name to a database, and if there is no residency requirement, no need for the individual to come there or buy property, the effect on the local population is minimal: no complaints about foreigners increasing property prices or changing the local environment.
[00:04:48] And the fees paid by these foreigners, or I should say newly minted fellow citizens, these can be used for everything from schools to hospitals to pensions.
[00:05:00] Given this, after the first scheme in Saint Kitts and Nevis was launched in 1984, many other countries followed suit, offering their own citizenship by investment schemes.
[00:05:13] Soon enough, a wealthy person could choose from a suite of different countries, like wandering down a supermarket aisle and looking at the various offers on sale.
[00:05:25] And fast forward to 2014, the tiny Mediterranean island of Malta made a splash by launching its own scheme that didn’t just get you any passport, it got you a passport to a country in the European Union.
[00:05:43] Now, importantly, Malta wasn’t the first EU country to launch a CBI-type scheme; Ireland launched a similar scheme in 1988, but it was a little different, and it wasn’t a great success.
[00:06:00] Malta’s was different.
[00:06:03] Firstly, it was a question of timing. There were simply a lot more people who could afford and who wanted to buy passports in 2014 than there were in 1988.
[00:06:15] Whether we are talking about China or Saudi Arabia or India, or even Russia, the market for people who could spend six-figure sums on citizenship was considerably larger when Malta launched its scheme.
[00:06:30] What’s more, the EU element was more valuable in 2014 than in the 1990s. When Ireland launched its programme, there were only 12 countries in the EU; when Malta did, there were 28.
[00:06:46] And importantly, having a passport to an EU country means that you have visa-free travel to any other country in the EU, which is a large bonus for a wealthy individual who likes the idea of trotting between Milan and Paris and perhaps the odd weekend trip to Stockholm or Barcelona. You also have the right to live in any EU country, so by getting a Maltese passport, you can live somewhere more desirable, like the south of France or a Tuscan villa.
[00:07:20] And secondly, the Malta scheme had some very slick marketing behind it. A company called Henley and Partners went around the globe selling passports on behalf of Malta, and collecting a healthy commission in the process.
[00:07:38] A 4% commission, by the way, on the cost of a minimum of €700,000, which would typically rise to almost a million Euros by the time everything else was taken into account.
[00:07:51] Now, you might be thinking “who would pay a million Euros for a passport?”, but the answer is “a lot of people”.
[00:08:00] The scheme was officially capped at 1,800 main applicants, which is the classic marketing ploy of creating scarcity to encourage people to take action, and in 10 years, almost all of those places were sold.
[00:08:17] Including dependents–so partners and children–a total of 5,300 people were granted Maltese citizenship, which brought in an estimated €1.6 billion to the country.
[00:08:32] That might not be all that much for a larger country, but for a small country like Malta, with a population of less than half a million, it equated to more than €3,000 for every man, woman and child.
[00:08:48] Yes, not all of this money reached the average person in Malta, and there are widespread allegations of corruption and cronyism, with politicians and businesspeople siphoning off large chunks for themselves.
[00:09:01] But it did mean that the government was able to start offering things like free childcare and make improvements to the healthcare and education systems.
[00:09:12] Now, the scheme in Malta was slightly stricter than that of Saint Kitts and Nevis, for example.
[00:09:19] There was a theoretical requirement for you to “live” in Malta, but in practice this meant you either had a buy an apartment worth at least €350,000 or rent one for €1,300 a month.
[00:09:36] If you are already paying almost a million Euros for a passport, another €1,300 is pocket change, and what this meant was that there were and still are hundreds of apartments in Malta that were rented out purely for the purpose of meeting this “residency requirement”.
[00:09:57] I lived in Malta for 7 years, for reasons entirely unrelated to passports or citizenship, I should add, and my former landlord had two apartments that he rented out to foreigners.
[00:10:11] One was to us. We were pretty good tenants, I think, but there was the occasional problem: the dishwasher broke or something needed to be fixed. You know, normal stuff that happens in any rented apartment.
[00:10:27] But he preferred his other tenants, who rented the apartment opposite us. They were far less demanding because they didn’t actually live in the apartment.
[00:10:37] They had never even seen it; the place was completely empty, but they paid their rent every month, so they had the paperwork to “prove” their so-called residency in Malta.
[00:10:50] Now, you might think this is all perfectly fair, and that a country has the right to decide who it gives citizenship to, and under what conditions.
[00:11:00] You might think that it’s awful, and that citizenship should be about more than bank transfers and signatures in air-conditioned conference rooms.
[00:11:10] Someone, or rather something, that firmly took the latter position, was the European Union.
[00:11:18] The EU’s objection wasn’t immediate, and Malta wasn’t trying to hide this scheme, quite the opposite.
[00:11:27] But as Malta’s programme gathered pace after its 2014 launch, concerns started to grow in Brussels.
[00:11:36] From the EU’s perspective, the problem was simple: while every member state has the sovereign right to decide who gets its citizenship, EU citizenship is automatically attached to national citizenship.
[00:11:52] The moment someone becomes Maltese, they also become European, with the right to live, work, and travel freely across 27 other countries.
[00:12:04] So, when Malta was selling its passports, it wasn’t just selling access to Malta, it was selling access to the entire European Union.
[00:12:15] At first, the European Commission expressed what you might call gentle unease about the scheme, with the occasional politician making a passing comment about it or mentioning how it should be looked into.
[00:12:29] But as the number of applicants grew, and as questions were raised about how thoroughly applicants were being vetted, the concerns became more serious.
[00:12:41] In 2017, a particularly strong light was shone on Malta after the assassination of the investigative journalist Daphne Caruana Galizia, who was, among other things, looking into allegations of political corruption specifically related to sales of passports.
[00:13:01] In 2018, the European Parliament passed a resolution calling on member states to phase out both citizenship and residence-by-investment programmes, warning that they posed risks related to money laundering, tax evasion, and security.
[00:13:19] The pressure kept mounting, and in October of 2020, the European Commission formally launched infringement proceedings against Malta, accusing it of violating EU law.
[00:13:33] At this point, Brussels wasn’t just politely expressing its disapproval; it was starting legal action against a member state.
[00:13:43] Malta, for its part, pushed back. It argued that deciding who becomes a citizen is a matter of national sovereignty, something that EU treaties leave entirely up to member states.
[00:13:58] But behind the scenes, the government also began to make changes.
[00:14:03] In late 2020, Malta officially closed its original Individual Investor Programme and introduced a new version, the Maltese Exceptional Investor Naturalisation Programme.
[00:14:17] On paper, this new scheme was stricter. Applicants now needed to establish residency for either 12 or 36 months, depending on the size of their payment, and the government claimed to have strengthened its due diligence processes.
[00:14:34] But critics, including the European Commission, argued that these changes were largely cosmetic. After all, wealthy individuals could still buy their way to Maltese citizenship in just over a year, often without any genuine connection to the country.
[00:14:52] They were still selling passports, it was now just a little harder to buy them.
[00:14:57] And there were more leaks. In 2021, an investigation called the Passport Papers revealed that applicants to the Malta passport scheme said they only planned to spend an average of 16 days in the country, and that this was considered sufficient by the Maltese government to qualify for “12 months residency”.
[00:15:22] Clearly, the Maltese authorities had been well-advised when creating the scheme to add this “12-month residency requirement”, so as to be able to claim to the EU that these people were genuine residents, but these leaked emails showed that people didn’t really have to spend any significant time in the country, they just had to pretend they did.
[00:15:44] And so, pressure continued to build, and the legal battle continued.
[00:15:50] In 2022, the European Commission escalated the case by issuing what’s called a reasoned opinion, which is the next formal step in infringement proceedings, and warned Malta that if it didn’t shut the programme down entirely, the case would be referred to the European Court of Justice.
[00:16:11] And in mid-2023, that’s exactly what happened: the dispute landed at the EU’s highest court, and in April of 2025, the court gave its decision.
[00:16:24] The scheme is in violation of EU law, and–to quote directly–it "amounts to rendering the acquisition of nationality a mere commercial transaction".
[00:16:37] In other words, something that should be about true connection–whether that’s through blood, living in a country for an extended period, or through marriage–this is reduced to just another product with a price tag.
[00:16:51] So, what comes next?
[00:16:54] Well, as of the time of recording this episode, not much has changed.
[00:16:59] The Henley & Partners website currently reads, “The Malta Citizenship by Naturalisation for Exceptional Services by Direct Investment process is no longer accepting new applications”, but there has been no official announcement.
[00:17:15] Malta has said it’ll examine the findings, and most likely it will find a way to challenge the EU’s decision.
[00:17:24] The country may be forced to shut its programme down permanently, and this decision could also effectively block any other EU country from launching a similar scheme in future.
[00:17:38] And that, ultimately, gets to the heart of the entire controversy.
[00:17:42] Is citizenship something that countries should be able to sell?
[00:17:46] Is it simply another product in a global market, like real estate or stocks?
[00:17:52] Or, as the European Union argues, is it something much deeper, tied to rights, responsibilities, and the shared values of a political union?
[00:18:04] Malta’s case may seem small and insignificant–a tiny island selling a few thousand passports–but the questions it raises are ones that every country, and every union of countries, are being forced to confront.
[00:18:21] OK, then, that is it for today's episode on Malta’s battle with the EU to sell passports, and with that comes an end to this mini-series on the theme of citizenship and identity.
[00:18:33] I hope it's been an interesting one and that you've learnt something new.
[00:18:37] As always, I would love to know what you thought of this episode and of this mini-series in general.
[00:18:42] Do you think an EU country should have full control over who it grants passports to, and how?
[00:18:48] If you have become a citizen of another country, do you truly feel like you belong in that country, and what is your story?
[00:18:57] I would love to know, and I’ll be happy to share my own experience too.
[00:19:01] You can head right into our community forum, which is at community.leonardoenglish.com and get chatting away to other curious minds.
[00:19:09] You've been listening to English Learning for Curious Minds by Leonardo English.
[00:19:14] I'm Alastair Budge, you stay safe, and I'll catch you in the next episode.
