Argentina cancels master agent tender for its CBI program after complaints from two companies

The Argentine Ministry of Economy has scrapped an international tender to appoint a master agent for launching the country’s first citizenship by investment (CBI) — citizenship for investment — program.

Resolution 522/2026, signed by Minister Luis Caputo on 14 April 2026, fully annulled tender 34-0001-CPU25. No contract has been awarded, payment obligations to bidders will not arise, and the bid maintenance guarantees will be returned.

The cancellation came six weeks after, on 5 March 2026, the commission recommended awarding a four-year contract to a consortium of four companies operating under the name Asesorías Legal Advisor Limitada. However, that recommendation was never converted into a formal award.

What triggered the renewed review

After the dictamen was communicated to participants via the COMPR.AR procurement system, two bidders filed impugnaciones — official challenges — within the statutory deadline.

The complaints were submitted within the three-day window provided for by Article 73 of Decree 1030/2016. One of the challengers was Henley & Partners, which finished second in the evaluation results.

The other bidder was Latitude Consultancy. At the outset, it had been deemed not admitted due to failing to meet the financial solvency indicators.

The decision lists the impugnación documents filed in the ministry’s registry: IF-2026-23119614, IF-2026-24886582, and IF-2026-25220209. However, the substance of the objections is not disclosed in the annulment.

To address the complaints, the ministry’s legal and administrative service Secretaría Legal y Administrativa (the requesting unit) prepared a new technical report (IF-2026-28784861-APN-SLYA#MEC). It analyzed both the challenges themselves and the underlying bid documentation.

According to the report, even though both bids were formally admitted, there were “material discrepancies” in the approaches and in how well the proposed solutions aligned with the public-policy objectives that must be implemented under the program.

“Continuing the procedure under the current conditions,” the conclusion states, did not guarantee the required “consistency, integrity, and strategic alignment” necessary for the program to be implemented correctly. For that reason, it was deemed advisable to conduct a reassessment of the operational appropriateness of the ongoing procurement process.

The ministry justified the cancellation by citing Article 20 (in fine) of Decree 1023/2001 and Article 9 of Decree 1030/2016.

How the tender reached cancellation

The Ministry of Economy announced tender 34-0001-CPU25 on 5 December 2025. The contract covered comprehensive advisory services: developing, implementing, launching, and promoting Argentina’s CBI program over a four-year period.

Initially, 11 companies showed interest, and by 20 January 2026 6 bidders submitted applications.

During the March evaluation stage, four bidders were found not admitted:

• Hong Kong Qian Cheng Business Co., Ltd. and Salzburg International for Law LLC — due to defects in the bid maintenance guarantee (a procedural shortcoming that cannot be remedied, per Article 66 of Decree 1030/2016);
• Latitude Consultancy — due to failure to meet the financial solvency indicators;
• Ancova Associates FZCO — because its response to a clarification request effectively changed the original submission, violating the principle of inmodificabilidad de las ofertas under Article 15 of the General Terms and Conditions.

The final shortlist included two candidates: the consortium and Henley & Partners. On the technical portion, both received the same 48 points. The split occurred at the economic stage, which carries 40% weight.

The consortium proposed $10,000 per tranche across five tranches of 1,000 applications each — totaling $50,000 for the entire contract. Henley proposed tranches increasing from $2 million to $8 million, summing to $25 million. Final overall scores were: 88.00 for the consortium and 48.09 for Henley.

What has been cancelled—and what remains in force

The annulment ends the procurement of the master agent, but it does not “zero out” the regulatory framework on which the CBI program is built. Decree 366/25 remains in effect, having amended the citizenship law: naturalization is now allowed through “substantial” investments without tying it to the length of residence.

Decree 524/25 also continues to apply. It established the Agencia de Programas de Ciudadanía por Inversión (APCI) and set out the inter-agency procedure for evaluating applications.

In addition, the program logic remains that CBI citizens do not automatically receive tax resident status.

At the same time, an important point remains: there is no operational “fill-in” of the program yet—investment thresholds, permitted sectors, application-processing routes, a global promotion mechanism, and the interaction infrastructure with agents have not been put in place. The master agent tender was intended to be the key tool for building that practical component.

Specialists who have been working on program parameters over the past year are now waiting to see whether the ministry will issue a new tender, change the procurement model, or build operational capacity inside APCI directly. The decision does not specify which option has been chosen.

One procedural window remains open. Participants have 20 business days from notification to file a request for reconsideration (motion for reconsideration) with the Ministry of Economy. If reconsideration is denied, the case automatically moves to a higher level of appeal.

Alternatively, participants may file an appeal to the higher authority immediately within 30 business days, bypassing the reconsideration stage.

Whether challenges will be filed specifically by the companies that were excluded from the process—or displaced by the outcome—remains unknown.

The resolution was signed on the same day Argentina published its March inflation data, which President Javier Milei called “bad,” and one day before Minister Caputo met in Washington with the IMF Managing Director Kristalina Georgieva to push a second review of Argentina’s program with the IMF.

For applicants, potential agents, and observers who have been expecting concrete program parameters since the framework was formed in mid-2025, the immediate effect is effectively a “reset to zero” at the procurement level. The legal path remains, but the route to practical program launch is still not defined.

If you’re considering citizenship by investment or other investment-based residency options, it’s crucial to track not only the eligibility criteria, but also how a country’s processes and approvals evolve. The Argentina case highlights how tenders and the selection of agents can be reviewed following complaints from applicants. Want to understand what’s required in your specific situation? Contact the experts at Digital Nomad — we’ll help assess risks, prepare your documents, and move forward with confidence and full legal compliance.

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