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1,800+ applications since 2016 · 19 client nationalities · the desk closes at 30 concurrent files
The five Eastern Caribbean CBI programmes are aligning under one regional regulator. New physical-stay, civic orientation and due-diligence rules are months away. Files logged before each island's enabling act will almost certainly be assessed under today's terms.
The five Eastern Caribbean citizenship-by-investment programmes signed off in early 2026 on a framework that ends roughly two decades of independent rulemaking. The Eastern Caribbean Citizenship by Investment Regulatory Authority, EC-CIRA, is the body that will sit above the individual island CIUs and police a common standard. The agreement is done. What isn’t done is the local legislation on each island that puts the new rules into force, and that gap is the entire reason we are writing this note.
Once each parliament passes its enabling act (the working expectation across our practice is summer to autumn 2026), the file you submit will look very different from the file we are filing this week. The honest read is that current applicants are likely to be assessed under the rules that existed on the day their file was logged, not the rules that exist when the file is decided. New regulations of this kind are rarely retroactive in our experience, and the regional language so far supports that.
That window is months, not years. Here is what we are telling clients.
The five programmes (Antigua & Barbuda, Dominica, Grenada, Saint Lucia, St. Kitts & Nevis) have always operated under their own CIUs, with their own due-diligence agents, pricing floors, application forms, and oath ceremonies. EC-CIRA doesn’t replace the CIUs; it sits above them. Its job is to publish minimum standards (price floor, due-diligence depth, residency obligation, post-citizenship monitoring) and to audit each island’s compliance with those minimums.
Three of the new minimums matter to a private client deciding whether to file now or wait.
Today, four of the five programmes require zero days of physical presence to apply, qualify, and hold the citizenship indefinitely. The exception is Antigua & Barbuda, which already asks for five days in-country across the first five years after naturalisation. Light by any measure.
Under the EC-CIRA framework, every one of the five will move to thirty days in-country across the first five years. The thirty days can be split into shorter trips; the wording leaves room for flexibility. It doesn’t leave room for opting out. The travel itself isn’t the friction. The friction is the diary entries it imposes on principals who already structure their year tightly, the coordination cost with a second residency (UAE for most of our clients), and the fact that thirty days of hotel receipts and arrival stamps become an item in any future revocation conversation. Today there is nothing to argue about. After EC-CIRA there is.
For families with school-age dependants, the practical answer is usually to fold the thirty days into a single annualised visit. For founders and operating principals, the number is small but the calendar coordination is real.
Today the file is paperwork. Source-of-funds documentation, due-diligence questionnaires, biometrics-light, an oath. No learning component, no test, no interview about the country itself.
The new framework introduces a mandatory orientation programme covering the history of the country and how the constitution works. Each island will run the curriculum its own way (some have signalled an online module, others a half-day in-country session bundled with the residency week), but the orientation requirement is uniform across all five.
This isn’t difficult content. It is one more gate the file has to clear and one more line item on the case timeline. A file that today closes in sixteen to twenty-two weeks gate-to-gate will, under the new regime, add three to six weeks for orientation scheduling alone during the early rollout period while the islands work out delivery logistics. The early rollout is always the messiest part. Files cleared before the rollout begins skip that queue entirely.
This is the change that will reshape the cost curve more than the other two combined. The EC-CIRA framework imposes:
The interview is the most consequential addition. Today, very few of our family files involve any face-to-face appearance until the oath ceremony, which is itself often conducted at an embassy or consulate. Under EC-CIRA the interview happens during the assessment phase, before approval-in-principle. Scheduling alone will add weeks. The interview content (source-of-funds rationale, intended use of citizenship, ties to the country) is the kind of conversation that needs preparation for principals who aren’t in the habit of being questioned by a government officer.
The per-adult due-diligence fee is also expected to rise meaningfully. Our working budget across the five programmes today is USD 7,500 to USD 10,000 per adult. We expect the post-EC-CIRA floor to sit closer to USD 12,000 to USD 15,000, with St. Kitts at the high end given its existing fee structure.
A family-of-four file lodged today, at any one of the five programmes, lands under the current rules:
The same file lodged the day after each respective enabling act passes:
The financial delta on a family-of-four file is somewhere between USD 15,000 and USD 30,000 in additional fees, plus the time cost of the orientation and travel. The non-financial delta is the orientation gate itself, the interview, and the standing residency obligation.
A short read of each, with the link to the working file for clients ready to engage:
Antigua & Barbuda is the workhorse for family files. NDF contribution from USD 230,000 for a family of four. The five-day residency is already in place; the move to thirty days is the smallest delta of the five but still meaningful. The CIU’s outsourced due-diligence pipeline is the most consistent in the region, which is why most of our family files actually close here.
Dominica is the price floor. EDF contribution from USD 200,000 single, around USD 215,000 for a family of four. Today’s zero-residency rule is the largest delta against the EC-CIRA target, so Dominica clients have the most to lose by waiting. The 2024 UK visa shift is a real consideration; the file path itself is fast and clean.
Grenada carries the US E-2 treaty, which is the single feature that overrides every other comparison for founders building US operating presence. NTF contribution from USD 235,000 for a family of four. The CBI Unit has been politically stable through multiple administrations, and the file path is one of the cleanest in our office.
Saint Lucia is the small, responsive CIU. NEF contribution from USD 240,000 for a family of four. UK visa-required since 2024, which narrows the audience. For clients where direct CIU engagement is part of the structuring strategy, this is the file we open.
St. Kitts & Nevis is the institutional benchmark, operating since 1984. SISC at USD 250,000 single, around USD 295,000 for a family of four. The strongest passport in the Caribbean Five alongside Antigua. The 2024 SISC re-issue stabilised pricing through 2027; the post-EC-CIRA due-diligence fee uplift will land hardest here given the existing floor.
We compare the five in working detail in our Caribbean Five compared note, which sits next to this one on the strategy shelf.
Every advisor in this market reads the same regulatory tea leaves. The result is the same in every cycle of major rule change: a rush of files in the months before the rules harden, and a noticeable lengthening of CIU response times during that rush.
We are already seeing it. Files we expected to clear in eighteen weeks are running closer to twenty-two. New intakes for the second half of 2026 are being told the window is real but the queue is real too. Submitting in late August doesn’t protect you the way submitting in early July does. The date that matters is the day the CIU logs and accepts the file, not the day you signed an engagement letter.
For principals who have been thinking about a Caribbean second citizenship over the past year and haven’t yet acted, this is the moment that decision becomes pricier and slower if deferred.
If you are within ninety days of being ready to file (passport copies in hand, source-of-funds documentation organised, family unit confirmed), engage now. The week of work it takes to assemble the file is the dominant cost relative to the legislative timing risk you are carrying.
If you are six months out, the conversation we need to have is whether to compress your preparation window. For most clients, yes. For a smaller number, the answer is to plan around the new regime and pay the additional cost as the price of getting it right rather than getting it fast.
If you are still deciding which of the five programmes fits, that decision needs to happen in days, not weeks. We can run a short qualification call and have a recommendation back to you within forty-eight hours.
If a Caribbean passport is on your mobility plan for the year, the next move is direct. Email us at [email protected] with your family unit, your preferred programme (or "we should decide together"), and your target filing date. We will respond the same business day with a structured qualification call and a target submission window.
If you aren’t yet sure which programme fits your file, our strategy call is the right starting point. Thirty minutes is enough to put a clear recommendation on the table, alongside the budget, the timeline, and the work your file needs from you to be in front of a CIU before the EC-CIRA legislation arrives.
The window is months, not years. The files that go in before each island’s enabling act passes will almost certainly be assessed under today’s rules. The files that go in after will not.