CBI ambitions in Argentina outpace institutions: tender cancellation and the risks of “citizenship by investment”

Paula Carello, a former technical adviser to Argentina’s National Immigration Office, believes that cancelling the procurement exposed systemic problems that won’t be solved by simply launching a new tender. In her view, Argentina currently lacks the institutional safeguards needed for a citizenship by investment (CBI) program. As an alternative, she points to a residency by investment (RBI) framework: citizenship should reflect a genuine connection to the Republic—not be reduced to buying a passport.

On 14 April 2026, Argentina’s Ministry of Economy effectively annulled, with little public notice, international public tender No. 34-0001-CPU25. The contest was meant to deliver a four-year contract (or until the CBI Agency approved 5,000 positive recommendations) to a consulting firm—or consortium—to develop, implement, launch, and promote the citizenship by investment (CBI) program.

Resolution RESOL-2026-522-APN-MEC was not published in the Official Gazette, and the wording of the document—at best—was unclear.

In Article 1, it stated “the conduct of procedures,” while Article 2 cancelled the tender itself. The logic hidden in the preamble referred to a technical report: continuing “under current conditions” allegedly would not ensure the necessary “consistency, completeness, and strategic coordination” for the program to be implemented correctly. In essence, it was a bureaucratic “the approach needs to be rethought.”

The decision to cancel the tender looks reasonable. But what the tender revealed—institutional and procedural vulnerabilities—should become the subject of public discussion, which has not yet happened.

A tender no one talked about

The procurement began on 5 December 2025. No Argentine media outlet reported it. Interest came from 11 foreign companies (none from Argentina). Six of them submitted bids before the deadline of 20 January 2026.

The evaluation report was published on 5 March: it recommended awarding the contract to a consortium. Two losing bidders filed formal objections. A month later, the Ministry stopped the process.

Some documents from the procurement file remain inaccessible via the official COMPR.AR portal—contradicting principles of transparency and accountability. Missing items include the bids (some elements may be justifiably withheld due to commercial confidentiality, but key parts should be public), the technical report that led to the cancellation (IF-2026-28784861-APN-SLYA#MEC), the text of the objections, and comments related to the bidders’ proposals.

The author’s team submitted two requests: a formal request for access to the case file materials and a request for information. The first received a vague reply referring to COMPR.AR. The second request remains unanswered.

The silence continues outside the portal as well. The government has not discussed the situation in political speeches, press conferences, or sector-focused expert forums. Meanwhile, no local specialists or academic institutions were brought in—and, according to the author, even international bodies that have repeatedly highlighted the risks of CBI programs: from money laundering and terrorist financing to corruption, evasion of financial sanctions, and passport misuse as a tool for concealing assets (including by avoiding international tax reporting and OECD/G20 CRS standards).

Based on what is happening, close attention to the topic appears to come mainly from international companies operating in the CBI segment: they are already generating a flow of leads through their websites.

In this context, it cannot be ruled out that market players lobbied for regulatory changes at the executive level and that the program may ultimately have been set in motion.

Both sides of the counter

The problem with the cancelled tender was not purely procedural. It was structural.

In the Specific Terms and Conditions, among other requirements, the winning firm had to help the Agency create an information system to accept online applications and evaluate them. At the same time, the company was expected to advise the government on what would count as a “substantial investment” under the new Article 2 of Citizenship Law No. 346—and, in parallel, to maintain its own international client pipeline that would use the system.

This is not a theoretical conflict of interest. Any company bidding for such a contract operates in a B2C model: it collects and manages individual applicants through CBI programs worldwide.

The winner would be on both sides of the process: designing the rules and infrastructure, then “feeding” the system with its own clients. This kind of model requires strong institutional guarantees of impartiality and transparency. The tender did not include such guarantees.

Imagine launch day: the consortium that helped configure online intake and assessment would, within the first hour, submit 5,000 files from its clients. Which applications would be reviewed first, and according to what priority logic? Who would set that principle—the same company, or the state, with the company closely involved?

Another added risk concerns code ownership. If the contract had proceeded, the consortium could (or would have had to) retain rights to the system’s source code. Any subsequent updates and modernization would then create ongoing costs for the Argentine state—replicating the dependency pattern seen in outsourced e-government systems (for instance, visa solutions, border control, or electronic files across different jurisdictions).

In practice, Argentina’s Migration Office (DNM), which handles naturalization and citizenship, has already developed its own RADEX system for migration procedures using internal technical specialists. There was no operational need to hand over CBI application intake infrastructure to an external contractor with a commercial interest.

It is also telling to compare this with European Union practice. In EU-funded migration projects, experts are typically engaged through pre-existing framework agreements with firms and/or consortia that have already been assessed and selected. In Argentina, there was no comparable institutional “filter” between the state and competing companies seeking to build an exceptionally sensitive program.

Institutional problems that documents don’t fix

The legal structure for CBI in Argentina formally exists. DNU 366/2025 amended the Citizenship Law, and Decree 524/2025 created the Agency for Citizenship by Investment Programs.

The updated Article 2 of Law No. 346 provides that foreigners who make a “substantial investment” may obtain naturalization regardless of residency duration. But in practice, almost nothing is working behind that framework—at least for now.

The Agency had no director until recently. Last week, Decree 285/2026 appointed an official from the tax authority to the role—on a non-remunerated basis. For a position of this type, that is unusual.

It is also important to consider that President Milei, early in his mandate, said “no hay plata” (“there’s no money”) and since then dismantled parts of public structures. In that logic, creating new posts under CBI and/or bringing in an international company does not align well with the stated budget constraints.

The term “substantial investment” still has no regulatory definition. Article 2 bis delegates the clarification to the Ministry of Economy, which has not yet issued the relevant rule. The $500,000 threshold mentioned in 2025 press releases remains a media statement, not a binding legal instrument.

The tender terms themselves further highlight the issue: which specific investment types would be considered “substantial” were, in effect, expected to be defined through consultations with the winning foreign company. The tender anticipated that the firm would provide “consulting services” and analyze legislation. But how could a company without prior experience in Argentina—unfamiliar with the country’s legal, social, and cultural realities—reliably determine which investments are truly strategically useful?

Responsibility allocation between the Agency and the DNM is also unclear. The DNM already handles residence permits and—after powers were transferred via the DNU—naturalization based on residence.

If DNM’s workload expands to include CBI cases, a practical question arises: what happens to the existing queue? Residence permits are currently assessed in 4 to 12 months. Naturalization applications submitted in 2025 under the two-year residence track are allegedly not moving because implementing regulations for the Citizenship Law have not yet been issued.

When CBI cases begin arriving (expected to be decided by DNM within 30 days under Decree 524/2025), how will oversight priorities for cases be set? The institutional architecture is not yet in place. Scaling capacity requires additional staff and training—unless, as the author notes, the plan was to partially outsource case processing to a foreign firm, which would be unacceptable from an institutional standpoint.

Another complication is the “double e-system.” DNM uses RADEX, while the Ministry of Foreign Affairs works in GDE. If a case touches both platforms, coordination becomes a bottleneck and can lead to delays. For CBI applicants, this is almost inevitable when their cases involve competencies across multiple agencies.

Finally, there is still no mechanism for oversight and performance evaluation of the Ministry of Economy (through the Agency that receives applications, performs initial assessment, and conducts due diligence) and of the Ministry of Security (through the DNM that makes the final decision). Interagency alignment is also not provided—unlike other sensitive procedures, such as refugee status determination in CONARE.

In practice, the only real control mechanism remains judicial review—after a DNM refusal, which is not in the interest of investors seeking fast and predictable procedures.

What “substantial investment” really means

Argentina’s historical Citizenship Law (dating back to 1869) linked nationality to activities that benefited the Republic: creating a new industry, implementing a useful invention, or achieving other moral and material progress. The law’s purpose was to recognize the value of people who build, participate, and introduce innovations in the country.

These were individuals who lived in Argentina and left a mark: inventors, entrepreneurs, authors of a new production method—an early form of “citizenship for contribution.”

DNU 366/2025 replaced that approach with “substantial investment”—two words without a clear definition that now carry the full weight of deciding who becomes Argentine.

Previously, a “new industry” meant an industry that did not yet exist in the country, stimulating jobs and innovation. A “useful invention” meant an idea—patented or not—that someone wanted to implement. The focus was on productive benefit rather than commerce.

Now the emphasis narrows sharply to money. The author sees this as a mistake: some projects with high public, social, cultural, or economic value may require minimal—or even zero—capital, such as data processing solutions, innovations in the social sciences, or technology development. Under the new wording, someone with a transformative idea but without large capital may have far fewer chances to obtain citizenship.

The author also proposes broadening the concept of “merit” and recognizing contributions by scientists, artists, athletes, and other categories—through mechanisms that do not exclude them by the literal wording of the law. In this context, international experience analysis is important.

The issue of family ties is also highlighted: citizenship based on family grounds (parents and partners) in the new version has effectively been removed. This affects the right to family unity and family protection enshrined in international law.

Are donations investments?

This is not an abstract question. Even before DNU 366/2025, some members of communities tried to submit applications through “donations” to hospitals or educational institutions, framing them as a basis for naturalization via federal jurisdiction. In most cases, success was limited.

Under the new framework, donations could potentially take on new meaning. In Article 6 quater, subsection f) of the updated Law No. 346, the Agency for Citizenship by Investment Programs is authorized to accept “inheritances, gifts, and donations” as part of an investment scheme.

But the program itself does not exist yet. Even if, in the future, multiple “programs” are created, key questions remain: where would the funds be directed? Would they reach vulnerable groups, or would they be used to reduce external debt? Would NGO initiatives be financed—and which ones, and by whom would priorities be set? None of this is established, and it requires separate study.

The author recommends a whole-of-government and whole-of-society approach, in line with the Global Compact for Safe, Orderly and Regular Migration. This is especially important for donations and engagement with civil society.

In practice, CBI investment models are usually grouped into four directions: direct donations into public funds; business investments (injecting capital into local companies); real estate purchases; and investments in financial instruments (government bonds or approved funds).

Each model carries its own risks—for both the country and applicants. For example, real estate is among the most common formats worldwide, but its social and economic drawbacks are well known. In discussions about “golden visas” in Spain or Portugal, questions about housing affordability and market distortions repeatedly surfaced.

Real estate schemes are also vulnerable to overvaluation and weak oversight: in some cases, properties were deliberately priced higher so that the applicant “invested” more than the asset was actually worth, with the difference taken by intermediaries and developers.

Additionally, such schemes can facilitate money laundering—not only by foreign applicants, but also by domestic participants if due diligence, valuation standards, and source-of-funds controls are insufficient.

In the author’s view, when using CBI through real estate, investments should be distributed across regions of the country rather than concentrated mainly in Buenos Aires. What is attractive to investors does not always match the needs of the receiving communities.

To improve regulatory quality, direct knowledge-sharing with colleagues in other countries can help—rather than relying solely on international private intermediaries whose interests may not align with national priorities.

As for donations, the author personally would support contributions to local clubs and associations that often function as NGOs but are closed or threatened with closure due to funding shortages. Support for NGO programs working with vulnerable groups, science, arts, or animal protection could also be beneficial—provided funds are allocated fairly.

How to close the gap between “idea” and “institution”

In practice, there has often been a mismatch of interests: people had ideas or investments (in healthcare, industry, social sciences), but there was no institutional mechanism that would effectively connect them with those who can implement projects inside the country.

CONICET, NGOs, local entrepreneurs, and even government bodies were involved—but there was no public policy that systematically “bridged” the parties.

A future CBI program could create a partnership platform—for example, “sponsorship” arrangements where foreign investors support local entrepreneurs, NGOs, or even public institutions (especially local government bodies in less developed regions). However, given well-known transparency and administrative capacity problems in certain segments of the public apparatus, such an ambitious approach may be difficult to implement.

But, as the author notes, dreaming is not forbidden.

Who gets the passport: a family question

CBI marketing often describes citizenship as a “legacy.” If earlier families passed wealth to their children, today wealthy families think in terms of “passports.”

Argentina has not yet answered the key design question: does the investment benefit only the investor, or does it extend to family members?

If it extends, to whom exactly: children, grandchildren, the investor’s parents, and/or the spouse—and in what numbers? Some market participants openly state that if the program benefits only the applicant, it will not be commercially successful. The author cannot confirm that based on her own experience and consultations.

Article 2 of Law No. 346 did not change the minimum age for naturalization: it applies at age 18. Legally, the program cannot include minor children of investors.

Even if a mechanism existed to bypass the restriction, inequality and the risk of legal disputes would arise: children who obtain citizenship under the parents’ two-year residence track do not receive extensions. Why should the investor’s children—who may have no ties and roots in Argentina—receive more?

Comparative law shows different approaches: some jurisdictions consider only minors; others include adult children up to a certain age, and sometimes even the applicant’s parents. But a comparative analysis with Argentina’s concept of “family reunification” in migration law has not yet been conducted.

The threshold for family members’ investment also requires study: in many jurisdictions, dependent persons face lower requirements than the main applicant.

Money, “merit,” and services

Beyond family questions, there is the issue of whether Argentina should develop “citizenship for merit” (as it historically did), alongside CBI, or as an alternative.

Some countries (such as Austria and Malta) shift emphasis toward “exceptional services” rather than just the investment amount. Critics note that in practice the difference sometimes becomes a label for a financial contribution.

For Argentina, this generally fits the constitutional framework: under Article 20, foreigners may obtain naturalization after two years of continuous residence, but the term can be shortened if the applicant proves services rendered to the Republic.

The question is whether this model can be applied in the new context, considering institutional changes (creation of a new Agency and transfer of decision-making to a federal migration authority rather than federal judges). The author considers this direction promising: at minimum, it preserves the spirit of the Constitution, where contribution is not reduced to money alone.

At the same time, DNM’s discretionary powers may raise concerns—as in other countries where the process is not purely formula-based. In that scenario, the role of qualified local lawyers becomes important.

Constitutional questions: amendments and residency requirements for investors

DNU 366/2025 did not go through Congress. It amended the Citizenship Law (and also migration legislation, education law, and higher education law) through presidential intervention.

As already mentioned, Article 20 of the Constitution provides for naturalization based on residence after two years, but allows the term to be reduced for those who prove services to the Republic. In the previous version, the Citizenship Law interpreted “services” broadly, but always in the context of people living in Argentina.

The new logic explicitly allows naturalization regardless of residency duration. This creates a risk: a person could spend a few days in the country, make a contribution, and leave with a passport.

Constitutional compatibility of such a model is already becoming the subject of legal disputes. Several cases, in particular, concern the requirement for applicants under the residence track: they were not supposed to leave the country for even a single day during the two-year period.

Meanwhile, the mechanism for “residence under CBI” remains undefined: does it require a standard residence permit like other applicants? Can “transit” residence under special circumstances be used? Can naturalization occur without a single day of residence—for example through consulates?

There is also a deeper constitutional question: changes at this level should be subject to parliamentary debate. Amending the framework via an emergency decree, bypassing the legislative branch, undermines the legitimacy of the entire structure—a point the author fully agrees with.

And beneath the legal architecture lies a moral and human dimension: individuals with no connection to Argentina but with significant financial resources gain access to citizenship, while those who have lived in the country for years on modest incomes cannot even obtain permanent residence on an accelerated basis.

This asymmetry of unfairness should not go unnoticed.

What Argentina should learn from the EU trajectory

In the author’s view, Argentina is entering a market that countries with more advanced legal systems are increasingly moving away from. On 29 April 2025, the Court of Justice of the EU declared Malta’s program unlawful: selling citizenship without a genuine link to the state violates the principles of sincere cooperation.

The European Commission asked candidate countries to close CBI/RBI programs as a condition for starting membership negotiations (Moldova, Montenegro). For other countries with visa-free access for “Schengen” travelers, Brussels also increased pressure: retaining access could depend on revising CBI offers.

The risk of “passport devaluation” is not abstract. For decades, Argentina has built a visa-free profile based on trust in citizens’ compliance and the reliability of identification and security systems. A poorly governed CBI could lead to suspicious traces for passport holders in documents and travel patterns—prompting destination countries to tighten checks.

Over time, this could lead not only to individual border issues, but also to diplomatic frictions, stricter visa regimes, or enhanced scrutiny for all Argentines—regardless of how citizenship was obtained.

The United Kingdom case is illustrative: it recently removed Saint Lucia’s visa-free access. Fixing such situations later can be extremely difficult.

As a possible solution, the author sees value in dialogue with the EU delegation in Buenos Aires to reduce these risks in advance.

RBI as an alternative to CBI

Argentina already has a foundation for residency by investment under migration law No. 25,871 (Article 23, d)—in force for more than 20 years. However, in practice the path barely works due to institutional, economic, and operational barriers. Based on the author’s experience with a limited number of cases, implementation did not seem technically impossible, but it has occurred sporadically.

DNM granted residency to investors to a small number of people, but there is no structured program. The author believes this direction has not received enough attention.

Argentina is not a “passport country” like Caribbean islands. Many foreigners genuinely choose to live in the country. RBI would likely attract applicants with an intention to reside, bring capital inflows (potentially with lower individual thresholds but higher total volumes), and help avoid the constitutional, political, ethical, and reputational risks specifically tied to citizenship.

RBI would also strengthen institutional capacity: DNM would continue developing due diligence, internal expertise, and interagency coordination needed to assess investment applications before decisions reach the irreversible stage of granting citizenship.

The lessons from RBI would directly help with any future CBI design. In the government decision text referenced by the author at the beginning, there is a logic of “reassessing the operational significance of the current process”—which looks like an acknowledgment that the institutional base is not yet ready. RBI could be a way to build that base.

In 2024, in a request for access to public information, the author received from DNM data on RBI—specifically, investor requests, favorable decisions, and closed cases (2010–2024, as of September). One of the replies said: “regarding item 3, no regulatory administrative act was issued, and any regulatory update is under review.”

At the same time, according to the author, drafts of RBI regulatory rules were being developed for nearly three years—possibly longer.

Three (or four?) scenarios for next steps and recommendations

After the tender cancellation, Argentina has three scenarios, though a fourth could be emerging as unofficial practice.

First scenario: launch a new tender with revised conditions. But if the state chooses this path, the terms must explicitly address the conflict-of-interest issue and the other risks raised in the article.

The author proposes a B2B model: the consultant would act through registered local intermediaries rather than running its own client pipeline. Local experts, academia, and international organizations of which Argentina is a member (for example, the OAS, the UN, MERCOSUR; and also OECD, which the country plans to join) should also be involved in the design. It is not only about bringing in expertise, but also about setting proper participation frameworks.

Second scenario: develop the program internally. The federal migration authority has competent specialists who have already implemented the digital case-management and due diligence architecture. That institutional base can be expanded.

The author envisions a working group of local specialists (lawyers, economists, NGO representatives, sector experts in healthcare, education, science, and ecology), government representatives (including the Federal Investment Council), international experts in a consultative role, and public officials and academics from countries with CBI/RBI experience. A series of expert meetings could be organized, the experience of “players” studied, and best practices exchanged with states that have already launched or amended similar programs.

Before any action, a baseline assessment is needed (for example, using a Logical Framework methodology): feasibility, stakeholder analysis, risk analysis, IT system assessment, etc. The design should balance economic development and the human dimension—in terms of RIGI (Decree 749/2024) and in line with UNDP and the Sustainable Development Goals (SDGs). A monitoring and impact evaluation system is also required—for example, an interim review after the first 200 or 500 citizenship grants.

Third scenario: delay or fully abandon CBI. Formally, the legal basis exists, but the lack of implementing regulations and operational mechanisms is not unusual for Argentina. However, the political cost of CBI—considering EU criticism, the risk of “passport devaluation,” and constitutional litigation—may end up higher than the potential benefit.

Even if one focuses on figures from public discussions (for example, $500,000 per applicant for 5,000 grants—totaling $2.5 billion), that would only be comparable to a small fraction of the public debt, which in early 2026 exceeded $460 billion. But the author emphasizes: this is not only about arithmetic. The real question is who receives one of the country’s most significant institutions, why they are granted it, what risks materialize, and who the actual beneficiaries are.

Fourth scenario is sometimes mentioned in academic circles as a possible practice: the state could work directly with the companies that participated in the tender to design the future program. There is no official information about this, so the scenario remains unclear. If authorities do go down this path, the author’s recommendation is the second scenario (internal development), supplemented by a serious RBI pilot.

Conclusions

Granting citizenship creates irreversible consequences for investors and systemic consequences for the country. Therefore, CBI should not be designed with the key authors being companies whose main goal is to generate application volume and bill for services.

A large public tender is not mandatory. Nor is it necessary for the program to be managed by companies with a direct or indirect interest in its implementation. If CBI continues nonetheless, it should be built by Argentina—for Argentina—with the highest standards of transparency and institutional integrity. Only then can a system be created that generates fewer disputes and is less likely to be challenged.

There are also other ways to attract capital that carry fewer risks than CBI.

RBI is one such tool, and in Argentina it has hardly developed. Migration rules have existed for 20 years, but in their current form they effectively do not work. At the same time, the legal basis exists. DNM took initial steps by granting residency to a small number of investors who proposed investing and genuinely living in the country. This path should be developed—also for smaller investors—for the social and economic impact.

Finally, the author expresses deep concern about inequality and long-term harm that public policies without a coherent, inclusive, and strategic vision can create—especially when they are designed without meaningful participation from local stakeholders and implemented in a way that lets external interests outweigh national well-being and development. Such approaches can weaken local capabilities, increase dependency, and exclude the communities the program is supposed to help.

This contradicts the spirit of the Sustainable Development Goals, including the principle of “leave no one behind,” as well as the principles of the Universal Declaration of Human Rights. Sustainable progress cannot be built by ignoring local knowledge, institutions, and talent—and cannot be replaced by short-term gains that undermine society’s long-term interests.

What we dismantle, ignore, or weaken today in the name of urgency may come back tomorrow as greater inequality, social fragmentation, and lost opportunities for future generations. Let’s think together—responsibly, inclusively, and strategically—about building a better Argentina and a better world for everyone.

About the author: Paula Carello is a former technical adviser to Argentina’s National Immigration Office (the body that currently handles citizenship grants through naturalization) and to the Chamber of Deputies of the Province of Santa Fe. She teaches at a university and serves as an international consultant on migration, asylum, development, and human rights (including for the UN and the EU), and she also runs a practice at Lux Brumalis Law Firm & Consultancy in Argentina.

This article reflects only the author’s position and should not be understood as the position of IMI Daily or any organization with which the author is affiliated.

If you’re considering citizenship/residency by investment, don’t focus only on the benefits—assess the institutional reliability of the program: how tenders are handled, how transparently decisions are made, and whether there are real quality-control mechanisms. The Argentina case highlights the risks when “passport purchase” replaces genuine ties and when procedures shift without clear guarantees. To understand which investment-based options more often align with requirements for real connection and legal certainty, explore Digital Nomad’s guidance: https://digital-nomad.gr/en/goldenvisa

Our Telegram channel about various types of Greek residence permits, digital nomad programs, and the Greek Golden Visa: @digitalnomadgr