The citizenship crossroads

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The EU wants the Caribbean’s investment-citizenship programs wound down by 2028. Both sides hold a legitimate case. What happens next depends on whether the region chooses defense or proposal.

 

By Fletcher St. Jean, MBA

On June 25, 2026, EU Commissioner Magnus Brunner wrote formally to the governments of Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and St Lucia, asking them to phase out their Citizenship by Investment programs by June 1, 2028. The mechanism is the EU’s revised visa-suspension framework, under which operating such a program is now, in itself, a self-standing ground for suspending Schengen visa-free access. The deadline is firm. The stakes are considerable.

It would be easy to read this as a confrontation. That reading is not entirely wrong. But it is not the most useful one. The more accurate account is that two partners, each holding a legitimate position, need to reach the same table — and that the region’s best move is to arrive there with a plan rather than a plea.

Two legitimate cases

Begin with the region’s. CBI is not a line item for these states; it is a pillar of the public finances. In Dominica it reached roughly 37% of GDP. In St Kitts and Nevis, home to the world’s oldest such program, running since 1984, CBI has at times funded more than half of government revenue. That money built hospitals, airports, resilient housing, and debt reduction. As St Kitts and Nevis has already discovered, the cliff is not solely a 2028 possibility — its 2024 fiscal deficit widened to about 11 percent of GDP as CBI revenue fell. For small states with thin tax bases and constant storm exposure, this is not a policy disagreement. It is a question of fiscal survival.

Brussels’ case deserves equal candor. Visa-free access to the Schengen area is a shared asset the EU regards as its responsibility to protect. Across the five programs, an estimated 107,000 passports have been issued; application volumes remain high and rejection rates low, raising questions about due diligence depth. The Financial Action Task Force has cautioned that such schemes can be misused to alter identities and enable financial crime. And in 2025 the European Court of Justice found Malta’s program breached EU law. One may debate the deadline; the concern behind it is one reasonable partner could hold in good faith.

A good start, aimed at one question

What is less well known than it should be is that the region did not wait for the letter. In September 2025, after two years of consultation with the US, UK and European Commission, the five states signed a ninety-two-article agreement creating the Eastern Caribbean Citizenship by Investment Regulatory Authority — ECCIRA — headquartered in Grenada and operational this year. It sets binding standards across all five programs: uniform due diligence, mandatory interviews, biometrics, a genuine-link residency requirement, unified registries so a rejected file cannot resurface elsewhere, and powers to audit, sanction and revoke licenses. A partner that has already moved this far deserves to be met halfway.

And yet ECCIRA, admirable as it is, was built looking in a single direction. It asks how the programs might be made acceptable to Brussels, Washington and London. The letter of June 25 is itself the answer to that question: “regardless of how well it is managed.” Compliance, however rigorous, cannot resolve a concern that is no longer about administration. It is about principle. The region has built an excellent instrument for defending an asset it is being asked to surrender. What ECCIRA proves — and this is its real value — is that these five states can act collectively when the stakes are clear enough. The task now is to turn that same capacity toward a second question, and a wider lens: not “how do we keep this revenue?” but “what will replace it — and what will we ask of our partners in exchange?”

Arrive with a proposal, not a plea

The ECCU governments should convene a standing regional panel — under the OECS, drawing on ECCIRA, the ECCB, the CDB and the region’s trade negotiators — with one mandate: to carry a unified strategy into direct diplomatic engagement with the European Union and the United States, and to return with something binding. That engagement must run on two tracks. The first is the programs themselves: to test honestly whether a rebuilt CBI regime can satisfy Brussels. The second track matters more, because it survives whatever is decided about the first.

If these programs are to be wound down, the region should not arrive asking for compensation. It should arrive asking for trade. Consider the asymmetry plainly: if CBI ends, the EU and US secure their integrity objective; the Eastern Caribbean absorbs the entire fiscal cost. That is not a partnership outcome, and it need not be. The instruments already exist — the CARIFORUM–EU Economic Partnership Agreement, the Samoa Agreement, the Caribbean Basin preferences with the United States — but they remain under-used, because market access without productive capacity is a door into an empty room.

History is instructive here. European preferences once sustained a Windward Islands banana industry that clothed, schooled and housed a generation. When those preferences fell away, the region learned how quickly a single-crop economy can hollow out. That is a lesson to carry into this negotiation rather than to repeat. A serious compact would pair guaranteed, long-dated access to European and American markets for Caribbean agricultural and value-added produce with a firm regional commitment to build what such exports require — cold chain, packing capacity, phytosanitary certification, port infrastructure. The region invests; the partners open the door and keep it open. Revenue that once arrived as a fee for a passport would instead arrive as earnings from work — a more durable foundation, and a more dignified one.

One Caribbean, one table

This is not a moment for five separate conversations. No single Eastern Caribbean state has the scale to negotiate a trade compact with Brussels or Washington on favorable terms; together, they have a market, a diaspora, a strategic position in the western Atlantic, and a legitimate claim on partnership. The 2028 deadline is not only a threat. It is the strongest argument for regional unity the Caribbean has been handed in a generation, and it would be a waste of a hard moment not to use it.

The CDB’s “decade of decision” estimates a regional financing need of some US$65 billion to 2033 simply to prevent stagnation. The ECCB’s “Big Push” calls for doubling the currency union’s economy within a decade. Both frameworks assume the region can mobilize capital and sustain investment. A disorderly fiscal cliff makes both harder. A negotiated compact — trade, agriculture, energy, infrastructure — makes both more possible. The deadline is real. So is the opportunity. What this moment needs is a region that arrives at the table not to defend a position, but to propose a future. There is no one coming to save the Caribbean. There rarely is. But there is a table, and there is still time to shape what gets agreed at it.

About the author

Fletcher St. Jean, MBA, is a Caribbean financial services leader and strategist with over two decades in the sector, and a participant in the Wharton Executive Leadership Program. He advises governments, institutions, and investors on financial and economic strategy across the region through St. Jean & Company, established in 2017, and writes on Caribbean economics and finance through The Caribbean Ledger.

 

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