Malta vs Bulgaria – citizenship for special merits

In the good old days, when investment citizenship was still a good thing, Malta and Bulgaria were competing fiercely. At many international seminars, we often highlighted the advantages of the Bulgarian golden passport program over the Maltese one. Of course, the Maltese program had its own strengths, which we were always happy (or not quite so) to acknowledge. Little did we know that in 2026, Bulgaria and Malta will again cross swords on the citizenship stage. This time however, with their own and distinctive Citizenship for merits programs.

A fundamental flaw

In this article, we will focus primarily on the new Maltese citizenship for merits program. Without underestimating its advantages, we will highlight and explain its drawbacks and most importantly its fundamental flaw:

Malta’s current citizenship for merits legislation did not appear out of nowhere. Long before the major reform in 2025, Malta already had a small, rarely used legal provision that allowed the government to grant citizenship for exceptional services. This early mechanism, however, was never a structured or accessible program. It existed quietly alongside the well known Maltese Citizenship for investment. The special merits path to citizenship was only applied in rare cases involving athletes, cultural contributors, scientists, or individuals who had rendered special services to the nation. To our knowledge, nobody has ever obtained Maltese citizenship for special merits, based on investment or financial contribution.

The major turning point came in 2025, when the European Court of Justice ruled against Malta’s investment based citizenship. This forced a complete reshaping of national citizenship policy. To comply with EU requirements while preserving Malta’s sovereign right to grant citizenship, the government shifted from a transactional, investment driven model to a merit driven naturalisation framework. In July 2025, amendments to the Maltese Citizenship Act transformed the old, vague merit clause into a fully developed, regulated program formally referred to as citizenship by naturalisation on the basis of merit.

In all honesty, we admire Malta for having tried to save its CBI program. Malta did everything it could to keep its program alive. Unfortunately however, the EU bureaucrats won and the program had to close. Malta didn’t give up even then and it revamped its citizenship by merits legislation to be able to continue granting Maltese citizenship to rich foreigners.

So far, so good. But what Malta did next was striking: it amended its citizenship by merits legislation only a few months after its CBI program was shut down. It was absolutely clear that the new merit citizenship was intended to replace the “illegal” CBI program. All other EU countries, who closed their CBI programs (ie Cyprus and Bulgaria), did it voluntarily. They didn’t make any legal amendments, suggesting they intend to continue providing citizenship against financial contribution.

All this means that Malta is now under exceptionally close supervision by EU institutions. This oversight comes not only from the European Commission, but also from various EU-level AML supervisory bodies. For all of them, it is perfectly clear that Malta has not fully closed its doors to non-EU citizenship “buyers” – despite the EU’s explicit expectations.

Obtaining Maltese citizenship for merits – only for selected few

The first problem with the new Malta merits-based citizenship is that it will be accessible only to the crème de la crème of those seeking to become citizens. With all the attention and EU oversight, Malta cannot afford to grant citizenship by merits to just anyone willing to invest a seven-digit sum in exchange for an EU passport. The companies that facilitate the Maltese merits citizenship will need to cover their costs from the very few eligible candidates. They will also need to make sure that the background of any candidate is crystal clear. By crystal clear we don’t mean the standard KYC and AML regulation to be fully observed. We mean much more. Even the slightest deviation from what the government’s expectation are and the candidate will be turned down.

Foreign nationals who obtain Maltese citizenship through the new special merit program should be aware that they are likely to face increased scrutiny from banks across the European Union. In many cases, EU financial institutions are expected to reject applications for opening new bank accounts from clients who have acquired citizenship by investment. And for most banks the new Maltese merits citizenship is equal to an investment citizenship. In more serious situations, banks may even close existing accounts, as they are required to conduct regular due-diligence checks. Once a bank discovers that a client now holds citizenship granted through this program, the banking relationship may be terminated.

We are not writing this to discourage prospective applicants for Maltese citizenship. This is rather to provide a realistic picture of what is already being discussed informally within the European banking community. Before becoming a member of the European Union, Malta was considered an offshore financial centre. Now it is the smallest EU member state. Banks in the EU clearly understand that most new Maltese citizens under the merit program acquired their status through some form of financial contribution. This profile is precisely what EU banks aim to avoid due to strict AML (Anti-Money Laundering) and compliance requirements.