Grenada CBI Bill: 30-Day Residency Requirement May Be Applied Retroactively

The Parliament of Grenada has begun considering a bill that could change the rules for obtaining citizenship by investment. In particular, for new applicants under Citizenship by Investment (CBI), the proposal would introduce a requirement for physical presence in the country—at least 30 days. The draft also states that the new norms “may be applied retroactively” to applications already submitted.

The Grenada Citizenship by Investment (Amendment) Bill, 2026 was tabled in the House of Representatives on 28 July, and then discussed in the Senate on 31 July. As of the time of publication, the provisions are not yet in force: paragraph 1(2) provides that they will take effect on a date to be appointed by the Minister through an official Order, published in the Gazette. No such document has been published so far.

The bill amends the core CBI law—Grenada Citizenship by Investment Act, No. 15 of 2013. In total, it introduces 16 amendments, adding 23 new sections. The explanatory (interpretive) notes are signed by the Attorney General Claudette Joseph.

The release also says the bill is intended to align Grenada’s domestic legislation with the agreement establishing a regional CBI regulator, the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA). The ECCIRA agreement was signed by five governments on 18 September 2025, and the ECCIRA Agreement Act, No. 19 of 2025 gave it legal force in Grenada.

Neither the “five-day threshold” in the first year nor the two-step passport logic is disclosed in the short description the government shared with a wider audience.

30-Day Residence: Family-Based Approach and a Separate 5-Day Minimum in Year One

The key requirement is set out in Section 7A. The applicant and their dependants must prove what the bill calls a “bona fide and effective link” to Grenada. In practice, this translates into 30 days of physical presence in the country—either during, or within the first five calendar years after the citizenship certificate is issued.

Days can be “pooled” together: if multiple family members are in Grenada on the same date, that date is counted once toward the family total.

However, the “family” framework includes an individual baseline that the release does not mention: each person listed in the application must be in Grenada for at least 5 days within the first 12 months after receiving citizenship. Any remaining days can then be “made up” through shared family participation.

There is also another important point: the obligation is tied to the people included in the application through which citizenship was granted. The bill does not clarify how the rule will work for dependants added later (for example, a spouse or a newborn). This leaves an open question: must such a person meet the five-year/30-day minimum independently, or can their days be included in the family’s overall count?

My Grenada Solutions CEO Nisha McIntyre expects most elements of the bill to follow the ECCIRA agreement’s logic, but highlights uncertainty: how exactly the residence and integration rules will be implemented.

In her view, the real model resembles a “family residence” approach rather than a fully individual one: a family may satisfy the 30-day requirement collectively. At the same time, she considers this approach controversial because each family member experiences the island “individually” as a citizen.

A similar question is raised by Savory & Partners CEO Jeremy Savory: if the main applicant has already met the 30-day minimum and later adds a spouse or a newborn, must the new dependant separately complete 30 days—or can they rely on the main applicant’s status?

Savory believes that, in any case, the physical requirements will inevitably create “friction” and may reduce demand for the program, while also affecting expectations among applicants, developers, and international agents. He is not fundamentally opposed to residence requirements, but argues that the rules should be balanced and reflect applicants’ real-life circumstances.

Section 7B also introduces the possibility of “front-loading”: applicants and dependants may demonstrate residence before citizenship is granted, and the verified time will be credited. However, after citizenship is issued, the remaining portion of the requirements would still need to be completed.

Integration Program and Exemptions

The integration program becomes mandatory, but the bill leaves its content open. Possible elements under consideration include civic education (Grenada’s laws, history, constitutional principles), cultural adaptation, or participation in public initiatives. The bill also provides for a separate interview by a competent authority in Grenada, or by a delegated third party.

Exemptions are allowed in exceptional and humanitarian circumstances. The text lists two examples, but the list is not closed—for instance, significant economic, social, or family ties, or documented inability to enter/travel (conflict, medical reasons, age, or security risks).

Grenada’s committee must notify ECCIRA of every exemption granted and the reasons for the decision.

Passport: Shorter Validity if Conditions Are Met

The bill introduces a two-tier model for passport validity. Under Section 7A(11), the initial passport will be issued for 5 years. A renewal for the full period of 10 years is possible only if the committee confirms that the holder has met the residence and integration requirements.

McIntyre notes that this is the part of the bill with the least uncertainty: “the passport will be issued, but its validity will be cut in half.”

As she explains, currently all Grenadian citizens receive a 10-year passport when citizenship is granted (the change took place about a year and a half ago), though it could vary depending on the application submission date. Under the new logic, if an application is filed after the bill enters into force, the passport would be 5 years.

Before renewal, the holder submits a Declaration of Presence to ECCIRA, and the regulator may cross-check the information with immigration records. Failure to comply without reasonable grounds under Section 7A(12) could trigger procedures to revoke citizenship and the passport (a reference is made to Section 12(5) of the principal act).

Who Will Be Affected: The Risk of Retroactive Application

The targeting of changes is governed by Section 7B(6). Residence provisions would apply to applications submitted after the ECCIRA Agreement Act comes into force (the bill does not specify the date).

The same provision then states that the requirements “may be applied retroactively” to applications currently under review—at the Minister’s discretion, provided that transitional guidelines exist.

At the same time, neither the bill nor the principal act explains what counts as a “pending application.” By intent, it could include applications already filed but not yet decided, but the text does not define it unambiguously.

McIntyre believes the core problem is the broad discretion given to the Minister. She points to two issues with no public criteria: for example, whether time spent before citizenship is issued will be credited, and whether humanitarian/economic contributions will be considered when shaping residence requirements.

“What benchmark will determine that Applicant A can credit their economic and humanitarian contributions toward residence, while Applicant B with similar contributions cannot?” she emphasizes.

The transitional guidelines have not yet been published either, meaning it is unclear how the Minister will implement the discretion.

Co-founder and Managing Partner of Immigrant Invest Elena Ruda frames the situation as “not time to judge yet,” because an Order will still be required for the changes to take effect, and the decisive document will likely be the transition guidelines. She adds that in past “cutoff” changes, the threshold has typically been tied to the document submission date.

Savory, meanwhile, considers retroactivity fundamentally risky: even if the bill is ultimately applied correctly, changing the rules after applicants have already made commitments undermines predictability and trust. He also notes that legal disputes are possible, but the reputational impact may be even more significant.

Agent Licensing and Activity: “No Objection” Clearance from ECCIRA Required

Section 5 reshapes the licensing chain through a new Section 3H. Agents, promoters, due diligence providers, developers, and escrow agents will have to undergo checks by a Grenada committee, which then forwards the dossier to ECCIRA.

The committee assesses candidates against “fit and proper” criteria under Article 15 of the agreement, and then transfers the materials to the regulator.

ECCIRA must decide within 30 days from submission of a complete documentation package. The decision is valid for three years, unless ECCIRA suspends or revokes the confirmation earlier. If a marketing license is issued or renewed without such confirmation, it will be void.

The rule also extends “voiding” to any registrations, licenses, permits, or approvals issued after an ECCIRA refusal—specifically to the extent that allows a participant to take part in the program.

If ECCIRA suspends or revokes confirmation, the Minister must suspend/revoke the corresponding local agent’s license on the regulator’s recommendation. In such a case, the Grenada committee will stop accepting applications from that agent for the duration of the decision.

Due diligence providers face an additional filter: ECCIRA must ensure the company is a reliable international provider with verified experience in investigations. A similar assessment applies to the ability to work with international databases and in multiple languages.

Conflict-of-interest screening also applies to the applicant: there must be no financial connection between ECCIRA officers, board members, parliamentary representatives, licensees, or other regulated persons.

McIntyre says the idea of regional licensing makes sense to her, but the mechanics remain unclear: will agents have to pay for licensing both at IMA and at the regulator, and will the sub-agent model remain in place?

Based on her logic, the sub-agent model may be questioned: if all agents working on the program must receive regulator approval, how will sub-agents be handled, and will they be required to register separately?

Interviews: Mandatory for Dependants Over 18, and for Those 12+ When Risks Exist

Section 7 repeals and replaces the previous interview rules. Now personal interviews become a mandatory part of due diligence for both the applicant and dependants over 18.

For dependants, the threshold is lowered to 12 years if due diligence identifies “material concerns.” Interviews may be conducted in person or in a secure virtual environment.

Exemptions from interviews are provided only for dependants and only with written permission from ECCIRA. If the applicant fails to attend without reasonable cause, the committee may suspend or reject the application. Grenada is also required to retain interview records and control access to them for 7 years.

McIntyre notes that the 12-year threshold is below current practice: previously, due diligence and interviews typically covered individuals aged 17 and above. In her view, this could affect pricing, as rules for younger dependants may increase workload.

A Refusal in One Country Closes the Path in Others

New Section 8B requires maintaining a register for all applications that were refused, citizenship was withdrawn, approval was denied, or applications were not approved for other reasons—along with the grounds. Notifications must be sent to ECCIRA and to the head of the relevant department of each participating state within three working days.

Section 8C introduces a ban: Grenada will not be able to accept, process, or approve applications from persons whom a participating state has refused. The only way to bypass the ban is through direct written approval from ECCIRA, based on evidence of a substantial change in circumstances or a procedural error in the original refusal.

The definition of “withdrawal” in Section 8B(6) is broad and could cover cases where an applicant withdraws after being notified of an adverse finding or a high likelihood of refusal, as well as cases where the applicant stops engaging instead of responding to due diligence requests.

ECCIRA Gets Priority: Regional Rules Will Prevail

Section 3 introduces a supremacy rule: if there is a conflict between Grenada’s CBI law and the ECCIRA Agreement Act, the ECCIRA agreement prevails. The committee must also exercise its powers in accordance with ECCIRA’s regulatory requirements, standards, directives, timelines, and protocols.

If Grenada fails to meet its obligations, the mechanism under Section 13G applies: ECCIRA issues a Notice of Non-Compliance, and the committee has 30 days to respond. Repeated violations would lead to public notice and a sanction recorded in ECCIRA’s annual report.

Additionally, ECCIRA’s Board of Directors may approve a mandatory action plan with timeframes. If the plan is not followed, the Board may recommend limiting the annual maximum number of approved applications for Grenada. Financial measures are also possible—penalties in a Compliance Fund or a combination of sanctions.

After six months of continuing non-compliance, the issue may be referred to arbitration by other participating states. All measures automatically lapse once full compliance is certified by ECCIRA.

Audits: Reports Will Be Published Within 30 Days

Section 3B provides for an annual independent financial audit and an independent operational audit every two years. The audit can be performed by the Director of Audit or an independent external auditor appointed/approved by ECCIRA. The auditor must have no real or perceived conflict of interest.

Within 180 days after the end of the financial year, Grenada’s committee submits the report to ECCIRA. Publication on Grenada’s website must follow within 30 days after the report is transmitted. A separate annual audit applies to escrow accounts.

ECCIRA may initiate a special audit based on four triggers: repeated violations across multiple cycles; receipt of credible information about systemic governance or corruption problems; significant security/financial/reputational risks to the regional framework; and the Minister’s failure to submit a biannual report to the House of Representatives within 6 months without reasonable cause.

Biometrics and Source of Funds: A Single Regional Database

Sections 13A–13F establish the Eastern Caribbean Citizenship by Investment Database, a regional repository as the core record-keeping system. Grenada must upload biographical data, citizenship decisions, passport records, documents on source of funds, and the results of post-approval checks. Biometrics are also included, aligned with ICAO requirements and ISO standards.

Data will be transmitted through a secure web portal maintained by the Joint Regional Communications Centre (JRCC), a unit of CARICOM IMPACS. Access will be limited to three categories: authorized JRCC staff, designated competent authorities, and persons authorized through bilateral/multilateral agreements for security or law enforcement purposes.

No Mention of EU Sanctions Lists in the Bill Text

According to the government of Antigua and Barbuda, the European Commission sent letters to all five Eastern Caribbean states on 25 June, requesting a phased withdrawal by 1 June 2028. Grenada has not published the correspondence it received.

Antigua’s report states that during the transition period there are interim measures, including full exclusion of individuals subject to EU restrictive measures by September 2026.

At the level of vetting, the Grenada bill partially addresses the Commission’s requests: due diligence includes standards to counter money laundering, terrorist financing, and financing the proliferation of weapons. It also includes politically exposed persons (PEPs) and source-of-funds information.

Ruda views the package as “work on checks,” not as a concession: in her view, it aligns with measures referenced when discussing Schengen zone concerns.

Savory, on the other hand, believes Grenada should stay the course on sovereignty and not “bow” to external demands. He argues that European internal access is already “shifting” due to border restrictions among EU countries, and he cites the experience of Vanuatu, where citizenship by investment can generate high returns even without visa-free access to Europe.

The bill text itself does not directly mention EU sanctions measures. Whether this gap will be closed via ECCIRA regulations, directives, or further amendments remains an open question.

Antigua and Barbuda moved first: on 14 July, Gaston Browne tabled a similar bill that raises residence from 5 days to 30 and introduces the same audit cycle. All five governments met in Roseau on 10 July and issued a joint response to the Commission, emphasizing negotiations rather than accepting the premise of a phased withdrawal.

What Still Needs to Happen Before Practical Implementation

The version of the bill published by Parliament contains blank fields: the act number and passage dates. ECCIRA is expected to begin operations in September, after Saint Lucia makes a ratification payment/contribution that the other four states have already completed.

Savory doubts the regulator will be able to handle the administrative burden of tracking renewals and residence requirements across all five countries without creating bottlenecks.

McIntyre is waiting for clarifying documents: “the bill was submitted recently—we’re waiting for circulars that explain how everything will be applied.”

The published text also keeps internal inconsistencies. For example, the explanatory notes describe Section 3C as corrective measures, but the operational rule in 3C actually concerns changing the auditor’s report. There is also a cross-reference in Section 8C to a subparagraph of Section 8A, not to Section 8B.

At the same time, the minimum investment thresholds under the citizenship by investment program do not change: the current requirements are US$235,000 to the National Transformation Fund for families of up to four, or US$270,000 in approved real estate. The new rules shift key parameters toward regulations rather than changing the headline minimums.

If you’re considering citizenship by investment and want to anticipate how requirements may shift (including the possibility of new rules being applied to already submitted applications), it’s crucial to monitor legislative updates and effective dates. The team at Digital Nomad helps you assess risks and plan your CBI/golden visa path so your documents and expectations stay aligned with the latest regulations.

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