The Cyprus Investment Programme was terminated on 1 November 2020, and in December 2025 the Cypriot Parliament deleted the section of law it ran under. The first step closed the program. The second removed the Council of Ministers’ power to naturalise investors at all, which is why there is now nothing left to reopen and no discretion left to petition.
Two things do still exist in Cyprus and are routinely presented as the program’s successor. One is an immigration permit for investors, which confers residence and not citizenship. The other is ordinary naturalisation, which is reached by years of residence and a language examination rather than by an investment. Neither is a citizenship by investment route, and treating them as one is the mistake that costs a buyer the most time.
The termination in 2020
The Republic of Cyprus states the position on the Ministry of Finance’s own register of program service providers: the Cyprus Investment Programme has been terminated since 1 November 2020, by decision of the Council of Ministers dated 13 October 2020. No naturalisation application could be submitted under the program after that date. The same source records that the Committee for Supervision and Control has not defined procedures for registering new service providers and does not accept new registration applications.
That left an unusual situation for five years. The program was shut, but the statutory power under which the Council of Ministers had granted citizenship to investors remained on the books, and applications submitted before the cut-off continued to be litigated.
The deletion in 2025
The Civil Registry (Amending) (No. 2) Law of 2025, Law 224(I) of 2025, was published in the Official Gazette of the Republic of Cyprus, Part I(I), No. 5066, on 12 December 2025. Its second section amends article 111A of the Civil Registry Law, and it does four things.
- It deletes subsection (2) of article 111A. That is the subsection under which the Cyprus Investment Programme operated.
- It inserts a new subsection (2A) providing that where, following a court decision, an administrative act on a naturalisation application issued under the deleted subsection (2) is re-examined, the provisions of that deleted subsection apply only to applications submitted up to 30 October 2020.
- It strikes the words “and the naturalisation of foreign entrepreneurs and investors and/or members of their family” from subsection (4), and confines subsections (3) and (4) to subsection (1) alone.
- It adds a proviso keeping the Regulations made under subsection (4) in force despite the deletion, but only as regards honorary naturalisations in the public interest under subsection (1), and applications under the Cyprus Investment Programme submitted up to 30 October 2020.
Section 4 of the same Law amends the First Schedule, under the heading of fees for acquiring Cypriot citizenship, replacing the reference to article 111A(2) with a reference to the new article 111A(2A) and deleting the line reading “Submission of application M127, EUR 2,000”.
The surviving reference points are all backward-looking. The only applications the deleted subsection still touches are those filed on or before 30 October 2020, and only where a court has ordered a re-examination. There is no forward gate.
What exists now, stated as what it is
An immigration permit for investors, which is residence
The Migration Department publishes the criteria for granting an immigration permit under the expedited procedure to third country nationals who invest in Cyprus. The legal basis is Regulation 6(2) of the Aliens and Immigration Regulations, exercised by the Minister of the Interior after notifying the Council of Ministers. The policy text carried on the Department’s page is the fourth revision, dated May 2023.
The investment threshold is at least EUR 300,000 in one of four categories:
- Purchase of a house or apartment from a development company, which must be a first sale, worth at least EUR 300,000 plus VAT.
- Purchase of other real estate such as offices, shops, hotels or related developments, or a combination, with a total value of EUR 300,000. These may be resales.
- An investment of EUR 300,000 in the share capital of a newly registered Cypriot company, or an increase of EUR 300,000 in the share capital of an existing one, based and operating in the Republic with proven physical presence and at least five employees.
- An investment of EUR 300,000 in units of a Cyprus investment organization of collective investments in the form of AIF, AIFLNP or RAIF, whose investments are held in the Republic.
Beyond the investment, the applicant must show a secure annual income of at least EUR 50,000, increased by EUR 15,000 for a spouse and by EUR 10,000 for each dependent minor child. Where the investment is in a house or apartment, that income must derive from abroad and be evidenced by a tax return from the country of tax residence. The funds for the investment must be proved to have been transferred to Cyprus from abroad, from the applicant’s or the spouse’s own bank account. The applicant and spouse must produce clean criminal record certificates, hold health insurance covering inpatient and outpatient care, and confirm that they do not intend to take up employment in the Republic, save as directors of the company they invested in.
Disposing of the investment without immediately replacing it with another of the same or greater value that meets the same conditions results in cancellation of the permit under Regulation 6.
Naturalisation, which is reached by residence
Since the Civil Registry (Amendment) Law of 2023 came into force on 19 December 2023, an adult applying for Cypriot citizenship by naturalisation must meet the following cumulatively, as the Ministry of the Interior sets them out:
- Legal and continuous residence for the 12 months immediately before the application, with absences not exceeding 90 days in total not interrupting that period.
- In the 10 years preceding that 12-month period, legal residence for cumulative periods of not less than 7 years.
- Good character.
- Knowledge of Greek at level B1 of the Common European Framework of Reference, proved by a certificate from the Greek Language Centre examinations or from the School of Modern Greek of the University of Cyprus.
- Knowledge of the basic elements of the contemporary political and social reality of Cyprus, proved by a certificate of success with a grade of 60 per cent or more in the examination run by the Ministry of Education, Sports and Youth.
- Suitable accommodation and stable, regular financial resources sufficient to maintain the applicant and family.
- Intention to reside in the Republic.
A shorter track exists under article 111B(2) for people residing in Cyprus for the purpose of highly qualified employment in companies falling within the categories fixed by Council of Ministers Decision No. 92.018 of 15 October 2021, covering foreign interest companies with independent offices, shipping companies, high technology and innovation companies, pharmaceutical and biotechnology companies, companies already on the Register of Foreign Companies, and accredited international higher education institutions. For those applicants the 7 year requirement falls to 4 years or 3 years, depending on whether Greek is proved at A2 or B1.
What this is not
- The investor permit is not a stage of a citizenship program. It confers residence under immigration regulations, and the citizenship provision it would have connected to no longer exists.
- Holding the permit does not shorten naturalisation. The reduced residence periods attach to highly qualified employment in listed company categories, and the permit’s quality criteria require the holder to confirm he does not intend to take up employment in the Republic.
- There is no discretionary back door left. The Council of Ministers’ power to naturalise investors was deleted, and what survives of it reaches only applications filed by 30 October 2020 that a court has sent back for re-examination.
- The EUR 2,000 fee line is gone. Parliament deleted it from the First Schedule in the same Law, which is a small detail that tells you the deletion was worked through rather than symbolic.
- A 2026 offer of Cypriot citizenship for an investment corresponds to no provision in force. The program closed in 2020 and its statutory foundation went in 2025.
Where independent counsel is useful, and where it is not
Nobody can file for Cypriot citizenship by investment, so any firm offering to is describing something that does not exist. What can be done is narrower and more useful. Where a client submitted a Cyprus Investment Programme application on or before 30 October 2020 and it was refused or left undecided, the new subsection (2A) is drafted specifically around that population, and the question is whether the file is one a court would send back. That is a live question with a short answer in most cases and it is worth getting early.
Where the objective is residence rather than a passport, the investor permit is a document discipline problem: source of funds evidenced from the applicant’s own account abroad, income evidenced by a tax return from the right jurisdiction, and an investment structured so that a later disposal does not silently void the permit. Serka acts as independent counsel on those files and is not an agent, representative or licensed intermediary of the Republic of Cyprus or of any Cypriot authority.
Sources
Every figure, date and quotation on this page comes from the Republic of Cyprus’s own publications, retrieved on 23 August 2026.
| What it supports | Source | Retrieved |
|---|---|---|
| Termination of the Cyprus Investment Programme on 1 November 2020 by Council of Ministers decision of 13 October 2020, and the closed service provider register | Republic of Cyprus, Ministry of Finance, Registry of Service Providers of the Cyprus Investment Programme, cipregistry.mof.gov.cy | 23.08.2026 |
| Deletion of article 111A(2), the new subsection (2A), the 30 October 2020 cut-off, the amendment of subsections (3) and (4), and the First Schedule fee change | Law 224(I) of 2025, Civil Registry (Amending) (No. 2) Law of 2025, Official Gazette of the Republic of Cyprus, Part I(I), No. 5066, 12 December 2025, published via the legislation repository linked by the Ministry of the Interior at gov.cy | 23.08.2026 |
| Regulation 6(2) legal basis, the EUR 300,000 investment categories, the EUR 50,000 income test with the EUR 15,000 and EUR 10,000 increments, the quality criteria and the cancellation rule | Republic of Cyprus, Migration Department, Immigration Permits for Investors, criteria under the expedited procedure, fourth revision May 2023, gov.cy | 23.08.2026 |
| Naturalisation qualifications in force since 19 December 2023, the 12 month and 7 year residence tests, Greek B1, the civics examination, and the article 111B(2) highly qualified employment track | Republic of Cyprus, Ministry of the Interior, Acquisition of Cypriot Citizenship by Naturalization, form M127, gov.cy | 23.08.2026 |
Related pages
- Citizenship by investment: the global overview
- Malta: the framework was repealed after the 2025 EU judgment
- Montenegro: applications closed on 31 December 2022
- Greece: the Golden Visa is a residence permit, not citizenship
- Austria: there was never a program to close
Serka Law Firm advises internationally on investment migration files, wherever the file is. If a Cyprus file of yours predates 30 October 2020, send us the refusal and the filing date, by e-mail to info@serkalaw.com or on WhatsApp to +90 530 127 59 35; whether anything in the 2025 Law reaches it depends on those two documents.