Argentina's New Citizenship by Investment Program: Sound Foundation, Unwritten Rules and EU Questions, Says Sam Bayat

South America's first CBI program starts at $350,000. Sam Bayat backs the design but flags unwritten agent rules, a shaky legal footing and the EU blind spot.

DUBAI, UNITED ARAB EMIRATES, October 8, 2026 /EINPresswire.com/ -- Argentina has become the first country in South America to announce a citizenship by investment (CBI) program. Economy Minister Luis Caputo and Chief of Cabinet Diego Santilli presented it on October 2 during Argentina Week in Paris, and applications are expected to open in the fourth quarter of 2026. Once active, Argentina will become the second G20 economy, following Türkiye, to offer a citizenship by investment.
There are two routes. The main applicant can make a non-refundable contribution of US$350,000 to the National Treasury or invest US$800,000 in a government bond created specifically for the program. Early reports indicate that there will be a seven-year holding period without accrued interest. A spouse adds US$100,000, as does each unmarried child aged 18 to 25. Each child under 18 adds US$25,000, so a family of four on the contribution route pays US$500,000.
Applications will be assessed by the Agency for Citizenship by Investment Programs together with the State Intelligence Secretariat, the Financial Information Unit, and the Ministries of Security and Interior. The National Migration Directorate takes the final decision, and the government says the checks will follow OECD and FATF standards.
Sam Bayat, founder and managing director of Bayat Group, gave the design a largely positive assessment.
“There is no passive real estate route, so developers are not gatekeepers of citizenship. Vetting was built in from the first day, rather than added years after,” said Bayat. “The foundation is sound. What follows, the implementing rules, will decide whether this becomes something new.”

The Missing Third Pillar
Days before the announcement, Bayat argued in Investment Migration Insider (IMI) that Argentina should not copy Türkiye or the Caribbean but build a third model. In the following article, he proposed three components: a non-refundable public contribution, a recoverable government investment, and direct equity in Argentine operating companies. The announced program includes the first two.
"A contribution funds the Treasury. A bond funds the Treasury for longer. Neither builds the economic connectivity that Argentina needs most," Bayat said. "An investor with a stake in an Argentine business brings customers, suppliers, technology, and access to their home market. The measure of a program is not how many passports it issues. It is how much economic value each one creates."
He cautioned that direct equity carries its own risks: inflated valuations, related-party transactions, hidden buybacks, and other ways of manufacturing compliance. In his view, independent valuations, arm's-length rules, controlled fund flows, minimum holding periods, and ongoing monitoring are essential.
Bayat also proposed that provinces pool capital from groups of 50 or 100 investors in ring-fenced vehicles, funding projects too large for any single investor, provided each project first qualifies on its own merits.

The European Question
The official announcement did not address the European Union's position. Under the EU's revised visa suspension mechanism, in force since December 2025, operating an investor citizenship program can itself be grounds for suspending visa-free travel to the Schengen area, a privilege Argentine citizens currently enjoy. This summer, five Caribbean states with CBI programs were told to phase out their schemes by June 2028 or risk losing the same access.
“Argentina should expect to be read against the same standard,” said Bayat. “The test is whether a new citizen has a genuine link to the country, and that should mean substance, not hotel nights. An investor who owns part of a company, develops exports, pays tax and keeps a home in the country has the stronger link.”
What Is Still Unwritten
Restricted nationalities, processing times, and the criteria for accrediting agents have not yet been published. Bayat said the agent framework matters most.
“The greatest long-term risk to any program is not the applicants. It is the intermediary industry,” he said. “Argentina needs no exclusive concessionaire, only an official portal and a small accredited network, with due diligence kept apart from the commercial side. The government must control the industry. The industry must never control the program.”
He also recommended a finite citizenship window of four or five years, with residence and productive investment routes continuing after it closes, so that the program brings in capital early without creating permanent fiscal dependence.

The Legal Footing
Legal certainty is a further consideration. On June 30, 2026, Argentina’s National Electoral Chamber declared null Decree 366/2025, the emergency decree that reformed the Citizenship Law and opened the investment route. The government has filed an extraordinary appeal with the Supreme Court.
The program is also being challenged in Congress. On the day of the Paris announcement, opposition MPs filed a bill to prohibit citizenship by investment, following a similar bill filed by a senator in August. Both remain in committee.
“Investors acquiring a lifelong status will want to know the ground beneath it is settled,” said Bayat. “A statute passed by Congress would provide that certainty in a way no decree can.”
He concluded, "Argentina has done the hard part. It chose the state over developers, priced for families, and put vetting at the center. That is a foundation, not a finished model.”

About Bayat Group
Founded in 1993 by Sam Bayat Esq., a Canadian lawyer, Bayat Group is a law firm specializing in residency, citizenship, investment migration, and cross-border legal matters. Based in Dubai, with an office in Istanbul and a network of offices and partner locations in North America, the Caribbean, and Australia, the firm advises private clients, families, and businesses on available citizenship and residency pathways. Bayat Group also offers services related to business and corporate immigration, offshore trust, and tax planning.

Sam Bayat
Bayat Group
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Sam Bayat, Esq.,reviews what the Argentine CBI design gets right, where it leaves exposure to European scrutiny, and how it can create lasting economic value