Schengen At Risk: EU Puts Caribbean Citizenship Visa-Free Access On The Line

In December 2025, the European Commission released its 8th annual Visa Suspension Mechanism Report, stating that it now views the existence of Caribbean citizenship-by-investment (“CBI”) programs as sufficient grounds to suspend Schengen visa-free access for those countries, representing a material shift in the risk profile of access to the Schengen area. Individuals holding more than one passport may continue to access the Schengen area in accordance with entry rules applicable to their second nationality, notwithstanding the restriction on certain Caribbean passports.

What Has Changed

Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia are explicitly singled out due to their consistently low CBI rejection rates and a combined total of more than 100,000 CBI passports issued to date. The Commission's report states that operating a CBI program “in itself” can justify suspending visa-free status. This statement marks a departure from earlier scrutiny focused on individual program elements, such as requiring each government vet applicants for CBI programs to ensure they demonstrate a genuine link to the country.

The report urges these five states to tighten security vetting as an interim step “pending the discontinuation” of their CBI schemes, signaling that program closure—not just reform—is the long-term expectation. Failure to show “measurable progress” could trigger the strengthened visa‑suspension mechanism, potentially following the phased template now being applied to Georgia (starting with suspension of official/diplomatic passports and then extending to wider populations).

Implications for Mobility Advisors

Schengen access obtained through Caribbean citizenship by investment can no longer be viewed as a stable, long-term foundation for mobility planning and should instead be treated as a conditional benefit dependent on evolving policy conditions. The impact of any potential change is likely to fall most heavily on dual nationals whose non-Caribbean passport requires a visa for entry into the Schengen area. Individuals may wish to explore EU‑anchored options such as residence‑by‑investment and eventual naturalization by residence, prioritizing jurisdictions whose policies are closely aligned with EU expectations.

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