How Big Is the Citizenship-by-Investment Industry?

Ask a Bitcoiner how big Bitcoin’s market cap really is, and the answer arrives in seconds: sourced, timestamped, checkable against a dozen exchanges in real time. Ask the same person how big the citizenship-by-investment industry really is, and the answer is usually a headline pulled from whichever article loaded first, a figure with no denominator attached, repeated because it sounds plausible rather than because anyone checked where it came from.

That gap is worth noticing. The people who buy passports through citizenship-by-investment programs are frequently the same people who would never buy an asset without first checking its supply schedule, its custody arrangement, and its verifiable transaction history. Most CBI buyers never run that same discipline on the industry itself.

Here is the range as it actually exists in print. The Council on Foreign Relations cites outside estimates putting the broader investment-migration industry, citizenship and residency programs combined, at “nearly $22 billion annually.” A market-sizing report from research firm MarketIntelo scopes the citizenship-by-investment segment specifically; its own current report page states $9.5 billion for 2025, projecting growth to $35.8 billion by 2034, while press coverage as recently as February 2026 cited the same publisher at a different figure, $5.2 billion for 2024, a number that no longer appears anywhere on MarketIntelo’s own site. When a single publisher’s own number will not hold still across a few months, it is not a reliable anchor for anyone else’s citation either. Lead-generation sites circulate a combined figure of $50 billion, $20 billion in CBI plus $30 billion in golden visas, that traces to no named primary report anyone can point to. None of these numbers describes the same activity, and none of them reconciles into one true figure. That is not a rounding problem. That is the finding.

The Headline Number Depends On What You Count

Three different things get called “the CBI market,” and each produces a different total. The first is citizenship-only government intake: the actual contribution a sovereign fund collects when it grants a passport, nothing else attached. The second is combined investment-migration revenue, which folds in residency-by-investment and golden-visa real estate flows alongside citizenship, a much larger and more diffuse category. The third is professional and advisory fees layered on top of either, legal work, agent commissions, and due-diligence processing that never touches a government treasury at all. CFR’s $22 billion is scoped to the second category. MarketIntelo’s $9.5 billion does not map cleanly onto any single category: the publisher’s own methodology blends citizenship donations with real estate, government bond, and business-investment amounts, capital that mostly flows to developers and issuers rather than a sovereign treasury. That makes it a fourth, differently blended number, not a clean stand-in for citizenship-only government intake. Neither figure is wrong. They are answering different questions, and MarketIntelo is arguably answering more than one at once.

The Investment Migration Council, the industry’s own trade body, is instructive here precisely because of what it does not say. Its public materials describe investment migration as a form of legal migration used by over 80 sovereign states, a country-count claim, not a revenue claim. No single audited global dollar figure appears on the IMC’s own pages. The trade association closest to the data declines to publish the number every press release assumes exists. It hosts third-party research, Henley’s Private Wealth Migration Report, the CBI Index, the Worldwide Immigration Trends Report, without endorsing any one of them as the industry total. Anyone who cites “the IMC says the market is worth this much” should be asked which report they mean.

The third category, professional and advisory fees, is the hardest to see from outside because it rarely appears in any government’s public accounts at all. Government contributions across the roughly dozen active programs cluster between about $90,000 and $400,000 for a single applicant across the Caribbean and Pacific programs, depending on the jurisdiction and the route. El Salvador’s Freedom Passport is priced well above that band, the clear outlier at the top of the range rather than the norm. Either way, that government figure sits before legal fees, due-diligence processing, and agent commissions, which route through law firms and licensed agents rather than a national treasury and rarely appear in the same disclosure. A market-size estimate that quietly folds them in will run larger than one that does not, without either estimate announcing which choice it made.

Why Even The Governments Disagree With Themselves

The clearest illustration of why a single number cannot be trusted comes from a government describing its own program to itself. OCCRP’s investigation into Dominica’s citizenship-by-investment program found that Dominica’s government reported $170 million in citizenship-sale revenue to its own Parliament for the period between June 2018 and July 2019, while national budget records for the same period showed $80 million, a discrepancy of more than double from the same government describing the same year to two different audiences. The same investigation cites a cumulative $1.2 billion in CBI revenue claimed for the years 2017 through 2020, alongside two further red flags: gazette publication of new citizens’ names was quietly halted in March 2019 and had still not resumed as of December 2022, and separate gazette tallies list only about 7,700 new citizens from 2007 through 2022 against budget figures implying more than 19,000 for mid-2016 through mid-2022 alone, a gap of well over 10,000 names.

If a single government’s disclosures to its own parliament and its own budget office do not agree with each other, no outside analyst averaging press releases across a dozen jurisdictions is going to produce a number worth trusting to the dollar. This is also why the most durable figure in the field is not a dollar amount at all. Kristin Surak’s research, published as The Golden Passport (Harvard University Press, 2023), puts the number of people naturalizing through investment programs worldwide at roughly 50,000 a year, including family members. That estimate has become the industry’s standard citation through repetition across scholarly and press coverage alike, not because a central registry counted every passport issued. It is a serious scholarly estimate. It is still an estimate.

What Holds Steadier Than The Dollar Figure

The shape of the market is more reliable than its price tag. Roughly a dozen sovereign citizenship-by-investment programs are actively processing applications today, depending on where the count is drawn. Five sit in the Caribbean: St. Kitts and Nevis, the oldest, dating to 1984; Dominica; Grenada; Antigua and Barbuda; and St. Lucia. Outside the Caribbean, Vanuatu, El Salvador, Nauru, and Türkiye operate programs with real government statutes behind them. Trade press also reports active programs in Jordan, Egypt, and North Macedonia, reasonably well corroborated but resting on secondary sourcing rather than a government-primary source in every case. A broader definition that sweeps in residency-linked hybrid schemes reaches into the low twenties; the dozen-program count is the tighter, citizenship-specific definition.

That count, and the roughly 50,000-passports-a-year figure, are the two facts that show up consistently across sources with different methodologies and different incentives. The dollar total does not survive that consistency test. The program count and the applicant volume do, which is itself informative: it suggests the wide dollar range is a function of accounting choices and disclosure quality, not of genuine uncertainty about how many programs exist or how many people use them.

A handful of small states set the pricing norms for an entire global industry, and when one of them tightens due diligence or loses a visa waiver, the market-size headline moves with it inside a single fiscal year.

The Concentration That Doesn’t Show Up In The Headline

For several of these states, CBI is not a side revenue line. It is close to the whole budget. IMF Article IV consultation data shows St. Kitts and Nevis CBI revenue falling from 22% of GDP in 2023 to 8% of GDP in 2024, more than half in a single year, following the country’s own 2023 due-diligence tightening and price increase (the broader five-country regional agreement came a year later, in 2024). The IMF projects this lower level is now structural rather than cyclical, contributing to a forecast of public debt exceeding 70% of GDP by 2030. Dominica’s CBI program provided an estimated 58% of total government revenue in its 2025/26 budget.

When one revenue line accounts for more than half of a sovereign government’s budget, a single regulatory shock, a due-diligence tightening, a threshold increase, a visa-waiver suspension, reshapes that country’s fiscal picture within a single year, and reshapes the industry’s aggregate market-size headline right along with it. A market size quoted for 2023 and a market size quoted for 2025 can differ by billions without anyone involved being wrong. The underlying market moved because a handful of small economies, not a distributed global industry, carry most of the weight.

The same dynamic shows up wherever a small state publishes its own numbers. In Vanuatu, CBI activity contributed an estimated 18% of government revenue in the first half of 2024, generating roughly $60 million for the year, down from $68 million the year before, a decline tracking the EU’s 2022 partial suspension of Vanuatu’s Schengen waiver over due-diligence concerns. The EU’s later, permanent revocation of that same waiver, effective February 2025 and covered below, is a separate, more recent escalation, not the cause of the 2023–2024 dip. A double-digit swing in one country’s annual CBI intake, driven by a single regulatory decision made on another continent, is exactly the kind of variance that makes one global dollar figure a poor tool for understanding what is actually happening inside any given jurisdiction.

The Supply Side Has Been More Volatile Than The Price Tag Suggests

The past five years have been unusually rough on the supply side of this market, and the trend has not been in one direction. Cyprus terminated its program on November 1, 2020, after Al Jazeera’s “Cyprus Papers” investigation exposed due-diligence failures, including passports issued to individuals with criminal records. Bulgaria’s parliament voted 218 to 0 to end its investor-citizenship program, effective April 2022, after nine years of operation, citing European Union pressure tied to Russia sanctions-evasion concerns following the invasion of Ukraine, along with corruption and money-laundering risk. Malta’s investment-citizenship program was ruled contrary to EU law by the Court of Justice of the European Union in Case C-181/23, decided April 29, 2025; the Grand Chamber held that citizenship “cannot result from a commercial transaction.” Separately, the EU brought its multi-year suspension of Vanuatu’s Schengen visa waiver to a permanent end, effective February 2025 (covered above): one of two major EU enforcement actions against CBI jurisdictions inside the same eighteen-month window.

The Caribbean states responded collectively rather than individually. A 2024 regional agreement roughly doubled minimum investment thresholds across the five Caribbean programs, from about $100,000 to $200,000 or more. In September 2025, all five signed a regional agreement establishing the Eastern Caribbean CBI Regulatory Authority, targeting October 2025 for each to enact it into national law. That target slipped: St. Kitts and Nevis and Dominica passed their enabling legislation in mid-October 2025, but Saint Lucia had not ratified by then, and a December 1, 2025 general election that dissolved and reconstituted its parliament pushed that timeline out further, so the five-state rollout was not actually complete on the original schedule. The regulator itself, with mandatory escrow accounts, biometric collection, and a shared applicant database to stop a rejected applicant from refiling in a neighboring island, is not expected to be fully operational until 2026.

Set against all of that contraction, the industry has still added supply. Nauru launched a new program, the Economic and Climate Resilience Citizenship Program, in early 2025, with promotional pricing of $90,000 for a single applicant now extended through December 31, 2026, before the contribution reverts to a standard $115,000. The same eighteen months that saw a founding-scale EU member state’s program struck down by its own high court also saw a brand-new sovereign entrant open its doors. Contraction in the older markets and expansion at the margins are happening at the same time, which is one more reason a single trend line for “the CBI market” obscures more than it reveals.

Judge The Program, Not The Industry’s Aggregate

Treat a headline market-size figure the way you would treat a promoter’s price target for an unfamiliar asset: interesting context, not a basis for a decision. What actually matters when evaluating a specific program is its own statute, its own due-diligence record, and its own processing history, not the number the industry claims for itself in a press release. That distinction is the entire premise behind the Bitcoin Passport Index, 21 CBI’s editorial ranking of jurisdictions on the criteria that matter specifically to a Bitcoin holder. Its inaugural 2026 edition scores each program on its own record, not on how large the aggregate market happens to be that year; a high rank reflects a jurisdiction’s statute and track record, never a market-size claim.

That is also why 21 CBI productizes only two of the roughly dozen active programs and treats every other jurisdiction as bespoke advisory, scoped after the paid Sovereignty Strategy Session. El Salvador, serviced through passport.sv, and Vanuatu, serviced through cbi.vu, each stand on their own legislative record and their own processing history. Neither one needs an industry-wide dollar figure to make its case, and neither should be evaluated against an aggregate that, as the sections above show, cannot even get its own components to agree with each other.

The honest answer to “how big is the CBI industry, really” is this: big enough that a dozen sovereign governments run it as formal policy, small enough that no single number describes it without a footnote, and unstable enough that the figure you read this year will not match the one you read next year. Size the industry if it interests you. Size the program before you fund it. That decision comes down to one statute, one due-diligence file, one program.

This article is general information, not legal, tax, or immigration advice. Figures cited here are current as of the sources cited and the publication date of this piece, and are subject to change without notice.