Changes to the Cyprus Investment Program

Introduction

The Cyprus Investment Program (CIP) was one of the leading citizenship-by-investment schemes in the world, allowing foreign nationals to obtain Cypriot — and therefore EU — citizenship through qualifying investments starting from €2,000,000. On 15 May 2019, the Cypriot government introduced significant amendments to strengthen due diligence, increase government donations, and extend investment holding periods. The program was ultimately discontinued in November 2020.

This article examines the full program requirements, the 2019 changes, and the current alternatives available to investors seeking Cyprus residency and citizenship.

Overview of the Cyprus Investment Program

The Cyprus Investment Program offered a straightforward route to EU citizenship. Applicants needed to make a qualifying investment, contribute a government donation, and satisfy anti-money laundering criteria. Cyprus imposed no residency or language requirements for applicants, the application was typically approved in approximately 6 months, and the entire family could obtain a Cyprus passport.

Cypriot citizens enjoy the ability to travel, live, and work anywhere in the European Union without restrictions. Cyprus itself is one of the safest countries worldwide with excellent education and healthcare, functioning as an international business hub.

Qualifying Investment Options

The applicant could invest in real estate, a business in Cyprus, or an alternative investment fund. The permissible investment categories and minimum thresholds were:

Investment Type	Total Investment	Details
Residential Property	€2,000,000	Must include at least one property worth minimum €500,000
Commercial Property	€2,500,000	€2,000,000 in commercial/tourism property + €500,000 residential property
Cyprus Businesses	€2,500,000	€2,000,000 in business + €500,000 residential; business must employ at least 5 EU/Cypriot citizens with 5+ years legal residency
Alternative Investment Funds	€2,500,000	€2,000,000 in AIFs + €500,000 residential property

The applicant was required to retain investments for 5 years from obtaining citizenship but had to permanently maintain ownership of a residence valued at least €500,000, or replace it with one of equal or higher value.

Cyprus citizenship could be applied for provided the applicant concluded the investments during the three years preceding the application date (the purchase of a privately-owned home was exempted from this requirement).

Non-Financial Criteria

The non-financial criteria were essentially anti-money laundering requirements:

• Clean criminal record
• Enhanced Due Diligence clearance
• Copy of a valid Schengen Visa (unless the applicant's nationality did not require a visa for the Schengen Area)

Family Eligibility

Cyprus extended citizenship eligibility to family members of the primary applicant:

• Spouse: Included in the main application at no additional investment.
• Minor children: Included in the family application.
• Dependent children up to 28: Those studying for an undergraduate or master's degree, or having a severe physical or mental disability, could also obtain a passport.
• Parents or parents-in-law: Could apply for citizenship with an additional €500,000 investment in either a separate house of €500,000 or a shared house with the applicant worth at least €1,000,000.

What Did Not Change

The 2019 amendments preserved the core structure of the program. The main areas of investment remained real estate and Cypriot businesses or Alternative Investment Funds (AIFs). Cyprus continued to impose no residency or language requirements and still permitted dual citizenship. The spouse, parents, and children up to 28 could obtain a Cypriot passport on the basis of the initial investment.

Key Changes Introduced on 15 May 2019

Government Donation

The updated Cyprus Investment Program required a mandatory donation consisting of two components:

1. €75,000 to the Cyprus Land Development Corporation (to support housing for the less fortunate)
2. €75,000 to the Research and Innovation Foundation

The €75,000 donation to the Research and Innovation Foundation could be avoided if the investment included a €400,000 investment in either:

1. A certified innovative enterprise; or
2. A company whose operations fall within the primary or secondary sectors of the economy (excluding construction); or
3. A company in the sectors of research and development, education, health, and renewable energy sources.

Exit Strategy

The government guidelines increased the investment holding period by 2 years. Successful applicants could sell their investment after 5 years instead of the previous 3 years. This change did not affect the residential property requirement — investors had to always maintain a €500,000 or higher residence in Cyprus, or replace it with one of equal or greater value.

Enhanced Due Diligence

The government introduced an enhanced due diligence process for applicants. The Cyprus Authorities would obtain an Enhanced Due Diligence report from an independent international company prior to approving any citizenship application. This appeared to be the government's response to pressures from the EU and the US regarding transparency standards.

Schengen Visa

After 15 May 2019, applicants for Cypriot citizenship under the CIP were required to hold a valid Schengen visa. This measure responded to EU concerns about the citizenship-by-investment scheme.

Rejection of citizenship application from another country

The Cyprus government would not approve a citizenship application if the applicant had been rejected in another European country. The applicant was required to provide a declaration to this effect.

Post-Approval Monitoring

Under the amended rules, the government monitored successful applicants for 10 years after citizenship approval and reserved the right to cancel citizenship of individuals convicted of a serious criminal offense carrying an imprisonment sentence of 10 years, or who were wanted by Interpol for such an offense.

The government also sought annual confirmation that applicants maintained their investments for the required 5 years (or replacements approved by the authorities).

Application Procedure

The procedure to obtain citizenship under the Cyprus Investment Program followed these steps:

1. Choose a qualifying investment from the approved categories.
2. Conduct legal due diligence on the investment and prepare contracts.
3. Prepare citizenship application documents — all documents had to be officially translated into English or Greek and double certified/apostilled.
4. Open a bank account in Cyprus and transfer the investment funds.
5. Submit applications for both Permanent Residency and Citizenship (both filed simultaneously). An appointment at the Ministry of Interior was required for biometric data.
6. Permanent Residency issued within 5-7 working days.
7. Citizenship approval in approximately 6 months from filing.
8. Passport issuance in another 3 months (approximately 9 months total). The applicant signed the naturalization certificate within 3 months of approval and provided biometrics again.
9. Family member applications submitted separately. Minor children processed in approximately 3-4 weeks; adult children and parents in approximately 2-3 months.

Program Discontinuation in November 2020

The Cyprus Citizenship by Investment Program was officially discontinued in November 2020 following an investigation that raised concerns about the integrity of the scheme. Investors seeking Cyprus residency and a pathway to citizenship must now follow the residency-by-investment route, which grants permanent residency and can lead to citizenship through naturalization after the required period of lawful residence.

For further information on current Cyprus immigration programs, you can look at our residency by investment guide or contact us for a consultation.