The world’s first citizenship by investment transparency index launched by IMI

citizenship by investment transparency

The world’s first citizenship by investment (CBI) transparency index has been launched by Investment Migration Insider (IMI). The transparency index aims to encourage integrity within the program, while also addressing criticism that the industry continues to receive regarding its lack of regularized reporting and transparency.

Importance of the CBI transparency index launched by IMI

With multiple countries offering citizenship by investment programs across the world, the lack of regularized reporting and data sharing for part of the programs have always been a concern – and this is one of the three basic aspects of the CBI industry that have continually received criticism over the years, alongside the industry being called ethically objectionable and a security threat.

The industry has the ability to display a great deal of transparency, which would negate one of the three main criticisms against it. As per IMI, CBI programs could improve by disclosing pertinent data in a timely manner; however, the industry is not currently open enough to public scrutiny.

Consequently, it is crucial to supply transparent, impartial, and concrete metrics by which the CBI programs can examine their progress, and that of other programs. IMI launched its index with the goal that a quantitative index measuring CBI program transparency will create public and private discussion, self-evaluation by program administrators and eventually result in long-term improvements to CBI program transparency.

Methodology and detailed results

As stated by IMI, the transparency index is based on evaluations of the performance of each of the world’s CBI programs on 33 distinct criteria. The criteria were further divided into five varying dimensions, which are:

  • Reporting frequency of the program data
  • Richness of the processing data being published
  • Richness of the financial data being disclosed
  • Richness of the historical program data
  • The extent to which integrity measures are in place to ensure equitable and open program management on the part of the government.

Reporting frequency

The programs were each given a score depending on their reporting frequency. Portugal’s golden visa program provides monthly reports, making it the best in class on this dimension. However, as Portugal’s golden visa is not a citizenship by investment program, it is naturally not included in the CBI transparency index. Meanwhile, Grenada provides quarterly reporting, giving it the highest score on this dimension among programs that are included in said Index. Monthly reports are not provided by any program.

Both Malta’s MEIN and Saint Lucia’s CIP report annually, and thereby achieved a 40% score. If it were not for the discontinuation of bi-annual reporting by the country’s CIU, Antigua & Barbuda would have scored 60% on this dimension. The program’s most recent half-year report covers the 2020 period, so it falls into the “ad hoc/occasional reporting” category. Consequently, it only received a 20% score.

The CIPs of Cambodia, Egypt, and North Macedonia have never shared any data, hence they each received a 0% ranking.

Processing data richness

A point value was assigned by IMI to each program based on the Processing Data Richness, with a possible maximum of 16 points. The following ten criteria were included in the evaluation:

  • Application volume – main applicants (2)
  • Application volume – dependents (1)
  • Application approval volume – main applicants (2)
  • Application approval volume – dependents (1)
  • Application rejection volume (2)
  • Application volume by country of origin (2)
  • Application approval volume by country of origin (2)
  • Application rejection volume by country of origin (2)
  • The average number of dependents per application (1)
  • The average number of dependents per application by country of origin (1)

For this dimension, Saint Lucia’s CIP outperforms that of Grenada and even Malta’s MEIN (which is usually cited as an example of best practice). Of the three countries, Saint Lucia provides the most comprehensive statistics, including data on the nationalities of its investors–something that neither Grenada nor Malta divulges, though Maltese officials do share “region of origin” information.

Disclosure of financial data

IMI additionally analyzed the amount of financial information made public by each program based on eight standards:

  • Total investment amounts published (2)
  • Total donation amounts published (2)
  • Total government fee amounts published (2)
  • Application volume by investment category (2)
  • Application volume by investment category and country of origin (1)
  • Average investment amounts (1)
  • Average investment amount by applicant country of origin (1)
  • Details of government disbursement/retention of program proceeds published (2)

Malta was found to be the most forthcoming disclosing financial flows into and out of its program, earning a score of 11 out of 13. However, it failed to receive full marks because it refused to disclose the investor’s nationality. Antigua & Barbuda came close as the country shared extensive financial details, at least during the years when its CIU was still publishing reports.

Historical data availability

Malta and Saint Lucia are the only countries with complete public records of their programs’ performance. Although Antigua & Barbuda, Grenada, and Dominica have nearly complete data sets, reports were unavailable for certain periods. Jordan, Saint Kitts & Nevis, Turkey, and Vanuatu only provide partial data for a few years.

Integrity safeguards

Crucial procedural measures prevent unequal representation, unfair preferential treatment, and public corruption. IMI’s citizenship by investment transparency index is based on the following five criteria, whereas each program received a point for each one they fulfilled:

  • Government payments to private sector entities disclosed
  • Names of agents published
  • Agent appointment terms are clearly defined and published
  • Reports compiled by an independent authority
  • Agent blacklists are published

Malta is well ahead of comparable countries in disclosing exactly how much it has paid to private sector companies during the MIIP. This progress is due partly to an independent program regulator that exists separate from the government and processing unit.

The verdict

Malta’s MEIN policy is the world’s most transparent CBI program. It is followed by Saint Lucia’s, Grenada’s, and Antigua & Barbuda’s Caribbean CIPs. However, by reverting to regular reporting and publishing a blacklist disclosing information on agent payments, among other things, Antigua & Barbuda could become the leading nation among its Caribbean peers.

If you wish to secure second citizenship and benefit from the privileges it offers, the team of experts at Passport Legacy can help. We are available to assess your case and help you determine the right CBI program as per your eligibility status.


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