Malta’s Citizenship-by-Investment scheme, known as the Golden Passport, allowed wealthy individuals to obtain Maltese – and, therefore, EU citizenship – in exchange for a substantial financial investment.

But the ECJ found it violated EU law by reducing the acquisition of citizenship to a mere commercial transaction, dependent on predetermined payments or investments.

It required no genuine link or ties to Malta, no requirement of residency of any length of time, and, in the words of the ECJ, represented a “commercialisation of the grant of the nationality of a member state”.

Malta’s government has already said it will comply with the judgment and review its citizenship regulations accordingly.

Portugal’s Golden Visa scheme remains completely unaffected by the ruling, with a host of more stringent requirements which legal experts say will raise no concerns with the ECJ.

Paul Stannard, chairman and founder of Portugal Pathways which assists in facilitating Golden Visa applications, and the Portugal Investment Owners Club, said: “It is good the EU is supportive of individual countries' residency rules, but wants to close the door to citizenship schemes that have no links or connection with the country whatsoever.

“Unlike Malta’s scheme, which granted citizenship directly, Portugal’s Golden Visa requires applicants to spend time in the country each year and achieve a basic level of the Portuguese language. Citizenship is only available after five years if all criteria are met. It is completely different in terms of why the ECJ stopped the Maltese scheme.”

He added: “Portugal has evolved its Golden Visa residency-by-investment programme, and this will continue as demand to invest in Portugal’s future remains high.

“It is bringing a lot of new talent and investment to Portugal, especially with the recent introduction of the IFICI tax regime, often referred to as NHR 2.0, which is aimed at bringing professionals, academics, entrepreneurs, and value creators to Portugal.”

Portugal’s Golden Visa programme was changed in 2023 to exclude real estate and capital transfer routes, focusing instead on investment in key growth sectors through regulated alternative investment funds in Portugal.

These include the likes of healthcare, technology, tourism, hospitality, renewable energy, media and international events.