Golden Visa and Investment Citizenship Programs Have Closed: What Happens to Your Documents and Yandex-Reality Investments?

Digital Nomad
08.04.2026 Residence by investment (Golden Visa)
Программа ВНЖ или гражданства закрылась: что будет с вашими документами и инвестициями в Яндекс-реальности

Programs end. Rules change “overnight.” You invested a significant amount to obtain a residence permit, and now the news sends a clear signal: the door is closed. If you’re already in the process—or you’ve already received a status—your first reaction is often panic.

But in most cases, that reaction is unnecessary.

Over the past years, at least several major investment migration programs have been shut down across Europe and the Middle East: Spain, Ireland, Cyprus, Malta, the UK, and also the UAE—though there, the model was more targeted. After each cancellation, investors asked the same question: what will happen to my money, my residence permit, and my further path to citizenship?

For “insiders,” the short answer is almost always the same: nothing critical happens. Typically, the “grandfathering” approach applies—your existing status remains valid, and renewals are considered under the rules that were in effect at the time you applied or received the permit.

But there are nuances: the consequences differed from country to country. Below is a breakdown by key cases.

Spain: closed “by the book” and protections for current applicants

When Spain closed its Golden Visa program on April 3, 2025 (Organic Law 1/2025), the government codified the transitional provisions in the official bulletin BOE. There was no room for interpretation.

What this meant for investors:

— existing holders keep their residence permit for the full term for which it was issued;
— renewal is possible under the criteria of the original 2013 law;
— applications submitted before the deadline are assessed under the rules that applied at the time of filing.

This approach aligns with Spain’s constitutional principle: laws should not retroactively strip rights that have already been granted. In practice, the program stopped for new applications, while the system kept running for those already “inside.”

Ireland: the program ended, but processing continued for years

Ireland’s Immigrant Investor Programme (IIP) was closed on February 15, 2023. At the time, Justice Minister Simon Harris said the closure would not affect existing projects and applications.

It turned out that this wasn’t just “nice words.” Thousands of cases were still pending: 3,127 applications with potential investments exceeding €2 billion. Even two years later, Ireland approved new decisions: in 2024, 538 applications were approved—more than double the previous year, and the highest figure in the program’s history.

Bottom line: the program no longer exists, but the “queue” and processing under older rules kept going. For those who filed before February 2023, the closure usually didn’t change their personal scenario.

Malta: the program was canceled, but existing investors’ passports didn’t vanish

Cyprus, Ireland, Spain—different stories. But Malta stands out. In April 2025, the European Court of Justice ruled that Maltese Exceptional Investor Naturalization (MEIN) violated EU rules by using a model of naturalization for fixed payments. The court required the program to stop.

Malta complied: MEIN was revoked in July 2025 and replaced with citizenship based on a “merit” approach.

At the same time, official guidance emphasized that decisions made under the current and previous legal framework remain valid. Experts also confirmed that the court ruling did not affect passports already issued.

Practical takeaway: if citizenship was obtained through investment before the court decision, it stays. The program ended—but citizenship didn’t.

United Kingdom: a “zombie visa” instead of a clean shutdown

In the UK, Tier 1 (Investor) was closed on February 17, 2022. Authorities cited money-laundering risks and political reasons—against the backdrop of tougher sanctions sentiment after events surrounding Ukraine.

But the uniqueness here is different: the category is officially closed, yet in practice it keeps serving those who are already inside the system.

The official gov.uk page still contains instructions: existing applicants can extend the visa for two years, apply for Indefinite Leave to Remain (similar to permanent residence), and arrange family reunification.

So the pathway remains for “insiders.” New applicants—cannot. Existing ones—can. In that sense, the UK setup looks like a “zombie visa”: closed on paper, operational in reality.

Cyprus: the program was canceled, but there wasn’t a mass “clean sweep” of existing citizens

Cyprus ended its Citizenship by Investment (CBI) on November 1, 2020 after an investigation exposed influence schemes involving high-ranking individuals. The shutdown was abrupt.

Next is an important detail that headlines often distort: Cyprus revoked 360 citizenships, including 101 investors and 259 family members. That sounds alarming, but it’s important to understand the scale: between 2007 and 2020, 6,779 citizenships were granted.

The revocations didn’t happen simply because the program was closed. They were based on grounds tied to violations: fraud, false statements, concealment of material facts, and subsequent serious criminal offenses. Public commentary indicated that the legal logic was built around three groups of reasons: fraud to obtain citizenship, criminal convictions for serious crimes, and actions seriously harming the public interest (for example, terrorism or violations of the sanctions regime).

If citizenship was obtained lawfully and without “red flags,” it usually remains. But for those who hadn’t yet been processed, the situation could be harder: at the time of closure, there were 1,417 pending applications, and roughly 72% were rejected. Later, a decision of the Administrative Court (July 2024) made it possible to challenge refusals, opening a path to review hundreds of cases.

Cyprus takeaway: those who already received citizenship were, in most cases, still citizens. Those who were in the queue entered a zone of uncertainty.

Portugal: the program isn’t closed, but rules can “move”

Portugal has not closed Golden Visa—applications continue to be accepted through investments in funds. But this is a different type of risk: even if the program remains, the state can change timelines and conditions for citizenship.

In October 2025, parliament voted to increase naturalization periods to 10 years for non-EU and non-CPLP citizens, while EU and CPLP citizens would have up to 7 years. In December 2025, the Constitutional Court struck down part of the rules on equality grounds, and the president vetoed the decree.

On April 1, 2026, parliament approved an updated version of the law (152 votes to 64) following a political agreement. However, no transitional clause was included for those who had already invested.

Meanwhile, investors filed constitutional lawsuits, arguing the state changed the conditions of the promises on which capital was attracted. More than 20,000 applicants expected appointments with AIMA (the migration authority)—sometimes dating back to 2021.

An important nuance: permanent residence after 5 years, as described, was not expected to be affected. But for those banking on a shorter path to citizenship, the “horizon” has indeed shifted.

When geopolitics starts “hitting citizenship”

A similar risk appeared in cases where the program wasn’t formally closed, but a specific group was effectively blocked.

After the war in Ukraine began (February 2022), Portugal and Greece suspended Golden Visa processing for Russian citizens. In Portugal, this was done without passing a separate law—applications were simply left without movement. Courts took the position that this violated fundamental constitutional rights, including non-discrimination by nationality. In August 2024, AIMA resumed processing Russian applications—without public notice.

Greece went further: in February 2022, via a ministerial order, it suspended issuance and renewals of Golden Visas for Russian citizens “until further notice.” At the same time, according to the agency, the number of renewals could be increasing, suggesting uneven practice.

These stories show that between “grandfathering” and full cancellation there is an intermediate zone—when the state doesn’t formally close the program, but restricts access for a particular group. In such situations, case law can correct imbalances.

UAE: the scenario that scares investors the most

While Europe often relies on judicial protection, constitutional guarantees, and codified procedures, in the UAE the main reliance is on broad administrative discretion.

In late March 2026, media reports said the UAE began revoking residence permits for Iranian citizens who were outside the country. Reports suggested that the cancellations could also affect decade-long Golden Visas obtained through real estate investment.

As described, residents who left after tensions intensified on February 28, when trying to return, could find their status annulled. At the same time, it was reported that Iranians physically located in the UAE might be affected differently.

The UAE government did not officially confirm or deny the reports. However, if the information is accurate, it would become one of the first publicly described cases of mass revocation of investment-linked Golden Visas in the country’s history.

Experts also highlight a structural vulnerability: the UAE Golden Visa, as noted, is not a “Plan B” and does not automatically lead to permanent residence or citizenship. It is a renewable 10-year residence permission operating within a framework of administrative discretion.

Loss of status can have cascading effects: freezing bank accounts, problems with lease contracts, and even difficulties enrolling children in schools—this is how lawyers describe such cases.

Can a country close a program and refuse to allow renewals?

The most alarming hypothetical scenario for an investor sounds like this: the state says the program is closed, renewal is not allowed, and you’re “out of the game.”

In countries governed by the rule of law, this scenario is indeed extremely unlikely: principles against retroactive removal of rights, doctrines of legitimate expectations, and administrative law norms tend to apply. In the European examples reviewed above, closing the program was generally accompanied by protections for existing holders.

But “unlikely” is not the same as “impossible.” The UAE has already demonstrated that with sufficient discretion and limited judicial oversight, it may be possible to cancel investment-linked statuses for certain groups during a geopolitical crisis. The technical infrastructure and digital systems that help people return after disruptions (for example, due to airspace closures) could also contribute to fast “backward” revocations of decisions.

Key difference: Europe’s Golden Visa typically exists in a legal environment with courts, appeals, constitutional guarantees, and stable practice. A UAE-style Golden Visa may be structured so that the core principle is administrative discretion.

Therefore, when planning investment migration, it’s important to assess not only whether a program is “closed or not,” but also how protected your rights are when policy changes.

If you invested in Golden Visa / investment residency or citizenship and worry that the program has been closed or rules changed overnight, the key is to rely on your specific legal status: transitional provisions, renewal terms, and the documents tied to your application. At Digital Nomad, we help investors understand what happens to their rights after a program ends—and what to do next with clarity.

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