The Generational Trap: Which CBI Passports Can Actually Be Inherited

Sometime around 2045, the grandchild of a man who acquired a Caribbean passport in the 2020s may walk into a consulate seeking to claim citizenship, only to be told that there is nothing to claim. The grant reached his parents and stopped there.

Where that line falls varies considerably more than buyers may realize. A family that acquires citizenship in Dominica and has another child six years later will find that the later-born child has no automatic citizenship, no right to apply, and no route into the program at any price. A family that acquires citizenship in Grenada and has a child in the same year, by contrast, gives that child citizenship at birth, free of charge, only for the chain to end with the grandchild.

None of this is new. A 2020 opinion piece for IMI argued that, with the exception of Grenada, Caribbean programs did not permit investors to transmit citizenship to future generations at all: the grant extended to the applicant’s children and stopped there. Six years later, the underlying law has tightened in some jurisdictions and been clarified in others, while the marketing language of citizenship “for generations” continues largely unchanged.

The Ways Countries Determine Who Inherits Citizenship

When a child is born abroad to a citizen parent, every country effectively asks one of two questions. The question it asks determines how long an acquired passport can remain within a family.

The simpler question is: is your parent a citizen? If the answer is yes, the child is also a citizen, regardless of where the child was born or how the parent acquired citizenship.

The more complex question is: how did your parents become a citizen? This is the model embedded in the Caribbean constitutions drafted in London during the 1970s and 1980s, as well as in Maltese law. It distinguishes between citizens who acquired their status in their own right — by being born on the island or through naturalization — and those who merely inherited it. Only the former category can transmit citizenship onward.

That model then divides again depending on where legislators placed investors within that distinction. This is where the five Caribbean programs diverge.

Group One: No Generational Limit

Turkey is the clearest example in the market. Its citizenship law provides that a child born to a Turkish mother or father, whether inside or outside the country, is Turkish from birth. The provision does not ask how the parent acquired citizenship, nor does it impose a cut-off after one or two generations. In practice, the principal administrative step is registration of the birth at a Turkish consulate.

Murat Yüksel of Yüksel Law, the in-house law firm of CIP Turkey, says the most common misconception among clients is the assumption that citizenship acquired through investment constitutes “a special form of citizenship that is personal to the investor, limited in its transmission to future generations, or somehow weaker than citizenship acquired through other routes.”

It does not, he says: “What is transmitted to future generations is not a special ‘CBI status,’ but Turkish citizenship itself.”

At each generation, the sole substantive test is whether at least one parent is a Turkish citizen at the time of the child’s birth, with legal parentage established.

Egypt follows the same model. Since a 2004 amendment placed mothers and fathers on equal footing, a person born to an Egyptian parent is Egyptian regardless of where the birth takes place. Minor children of a person who naturalizes are generally included in the parent’s grant rather than required to submit separate applications.

Cambodia likewise provides for transmission without limit. Its 1996 nationality law treats any legitimate child of a Cambodian mother or father as Cambodian, regardless of the child’s place of birth, and makes no distinction between naturalized parents and those who were citizens by birth.

Nauru has the simplest rule among the five. Under its citizenship legislation, a child born outside Nauru is a citizen if either parent was a citizen at the time of the child’s birth. There is no provision limiting this rule to parents born on the island, nor any provision terminating the chain after a specified number of generations.

Vanuatu appears to operate under the same principle on the face of its law. Its constitution provides that anyone born after independence, whether in Vanuatu or abroad, becomes a citizen if at least one parent is a citizen. However, practitioners report that children born after an investor receives citizenship are subjected to a paid post-approval application rather than being recognized automatically.

Group Two: One Generation, Then It Stops

Grenada comes closest to matching the “for generations” sales pitch, based on a single constitutional provision. Its constitution grants citizenship at birth to a child born abroad where the parent did not inherit citizenship himself. An investor who obtained citizenship through the Grenada program acquired it rather than inheriting it. Accordingly, his child born in Dubai, London, or elsewhere abroad is Grenadian automatically from birth, without a fee or deadline.

That child, however, inherited citizenship. His own child, if born abroad, therefore receives nothing automatically. In practice, “for generations” means only two generations.

A grandchild excluded from automatic transmission is not entirely without recourse. Section 5A of Grenada’s Citizenship Act permits the minister to register a descendant of a citizen upon application. This is a discretionary mechanism rather than a right, and no CBI bloodline is known to have tested it to date.

Saint Lucia reproduces the Grenadian wording almost verbatim and produces the same result. Its program also permits a citizen to add a child born after the original application was filed through a post-grant application to the CBI Board. Dependants who were already eligible when the original application was submitted but were omitted from the file are subject to a five-year deadline instead.

Malta no longer sells citizenship. In April 2025, the EU’s top court ruled that the program had to close, and Malta replaced it that July with a discretionary merit-based route. The transmission rules nevertheless continue to govern the thousands of families that acquired citizenship under the former program.

Malta’s citizenship agency frames the issue around the status of the parent. A child born abroad is Maltese if, at the time of birth, the parent holds citizenship by virtue of having been born in Malta, having naturalized, or having registered.

An investor naturalized under the former program falls within the second category. His child born abroad is therefore Maltese. That child, however, inherited citizenship, and Malta does not permit inherited citizenship to be transmitted again. The grandchild born abroad therefore receives nothing.

It might appear reasonable to assume that the grandchild could instead rely on Maltese ancestry, since Malta permits individuals with Maltese roots to claim citizenship. That route is also unavailable. When Malta introduced the ancestry route in 2007, it limited it to persons descended from an ancestor born in Malta whose own parent had also been born in Malta — a bloodline that no investor family possesses.

Alex Hopkin, director of operations at Latitude Group, notes that no family has yet reached this point: “The IIP began in 2014 and MEIN in 2020, so this likely remains a prospective issue, as we are not aware of any investor family that has had two successive generations born after the original naturalization.”

There is, however, a way to prevent citizenship from being lost after the second generation. “For a family wishing to ensure that the grandchild acquires citizenship automatically, our recommendation would be to consider having the child born in Malta,” says Hopkin. A child born on the island to a citizen parent acquires citizenship by birth in Malta rather than by inheritance, thereby restarting the transmission chain.

Group Three: No Automatic Claim at All

St Kitts and Nevis operates the oldest program in the world and imposes its most restrictive transmission rule. A child born abroad acquires citizenship at birth only where a parent was born in St Kitts and Nevis and held British citizenship immediately before independence in 1983. This excludes every investor.

The fallback mechanism — a right to register any child of a citizen under 18 — is expressly restricted in the case of investors. The Citizenship Act gives the minister specific grounds to refuse an application where the applicant is the child of a person who obtained citizenship through investment.

In practice, what exists is a fee schedule rather than a legal right. Official guidance from the Citizenship by Investment Unit (CIU) sets the fee at $7,500 for a child under three born after the certificate is issued and $10,000 for a child born while the application remains pending, in addition to standard fees. Children who were eligible at the time of the original application but were simply omitted cannot use this route at all and must instead proceed through a new sponsored application.

The 18-year cliff is sufficiently significant that the government has publicly warned citizens abroad about it. In October 2025, a petition submitted to the National Assembly called on lawmakers to amend the provision limiting descent to the first generation born abroad.

Antigua and Barbuda likewise limits automatic citizenship by birth abroad to children of independence-era or island-born citizens. Its registration provision is more generous than that of St Kitts and Nevis: it gives an unqualified right to register any child under 18 of a citizen and contains no exception for investors. A disciplined family could therefore continue registering each generation, provided the registration takes place before the child reaches 18.

The CIU prices this right rather than excluding it. Licensed agents publish the post-citizenship schedule at $10,000 for a newborn or newly adopted child under six and $20,000 for a child aged six to 17. Antigua separately requires investors to spend five days in the country during their first five years as citizens.

Dominica imposes the strongest limitation of all. Both its automatic-descent provision and its registration provision are restricted to children of persons who were citizens when Dominica became independent or who were born there. An investor’s child therefore has no constitutional route to citizenship through descent.

The matter consequently falls entirely within the program’s own rules. Those rules permit a CBI citizen to register a child born or adopted no more than five years after the investor obtained citizenship, provided the child is still under 18. Beyond that period, there is no route.

North Macedonia reaches a similar result through a calendar-based rule rather than a categorical distinction. Where both parents are citizens, transmission is automatic. Where one parent is foreign and the child is born abroad, the child acquires citizenship only if registered before turning 18, if the child moves to the country with the Macedonian parent before that age, or by applying between the ages of 18 and 23.

The Odd Cases: Jordan and São Tomé

Jordan permits transmission without a generational limit, but only through fathers. A child born anywhere to a Jordanian father is Jordanian. A Jordanian mother married to a foreign national cannot transmit her nationality to her child at all. No brochure in the market states this, making it the sharpest gender-based inequality in CBI transmission anywhere.

São Tomé and Príncipe launched the market’s newest and cheapest program on August 1, 2025. Its constitution treats children of a São Toméan mother or father as citizens, and descent for children born abroad appears to operate through registration.

The complication is that, as of April 2024, the implementing regulation for the 2022 nationality law had still not been adopted. Until that regulation exists, the rules governing investor bloodlines remain unsettled. Anyone providing a definitive answer about generational transmission in São Tomé is therefore guessing.

Why This Is About to Matter More

Every other feature of a CBI program is subject to scrutiny. Pricing is compared line by line, processing times are monitored, visa-free access figures are repeatedly ranked and reassessed, and due diligence standards are reviewed by three governments and a regional regulator. The promise of multi-generational transmission, however, has not received the same level of scrutiny.

Two developments are now occurring simultaneously. Countries around the world are making citizenship increasingly difficult to inherit, with Italy providing the clearest example. It has restricted how far down a family line citizenship may pass, and its highest court upheld that limitation in March 2026. Inheritance was once largely assumed; it is now being rationed.

At the same time, citizenship acquired through investment is becoming less permanent. Turkey recently stripped 6,134 investors of their citizenship, Grenada is considering a residency requirement that could affect people who already hold its passport, and St Kitts and Nevis plans to require investors to spend time in the country.

Both trends increase the significance of the same underlying question. A passport that can be transmitted cleanly through successive generations is now materially more valuable than one that cannot. Conversely, a passport marketed on a promise of generational transmission that the law cannot ultimately support may generate a complaint 20 years later, when a client’s grandchild is turned away at a consulate.

Every family purchasing a Caribbean passport for the benefit of its grandchildren should therefore be told, in writing and before the wire transfer is made, whether that grandchild will have a claim, an application route, or nothing at all.

For three of the five Caribbean programs, the answer today is nothing.

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