# Appendix B — Programme Comparison Table This appendix is the working form of the comparison made in the body of the report. It sets the two components of the reference structure — the citizenship component examined in Chapter 6 and the European residence component whose qualifying property is examined in Chapters 7, 8 and 12 — against the principal alternatives, on official published figures only, and carries every qualification the chapters attach to those figures. It is not a ranking and not a recommendation. The two components are complementary parts of one coordinated position and are never assessed against each other (see §5.7); Table 1 compares the citizenship component with other citizenship programmes, and Table 2 compares the €250,000 change-of-use category with the other Greek investor-residence tiers. Read a row across, then read §B.3 before drawing any conclusion from it: the variables that matter most to a client are the ones a price table cannot hold. Where the report's fact base contains no verified figure for a cell, the cell reads "not verified" and no approximation is substituted. ## B.1 Table 1 — Citizenship-by-investment programmes | Programme (route) | Contribution or donation, single applicant | Contribution or donation, family of four | Real-estate route minimum | Due-diligence and processing fees | Capital contributed or invested | Stated processing time | Programme age | Status and notes as at 2 August 2026 | Body reference | |---|---|---|---|---|---|---|---|---|---| | **São Tomé and Príncipe** — contribution to the National Transformation Fund (Decree-Law 07/2025, Anexo I) | US$90,000 | US$95,000 (application of two to four members); each additional qualified dependant US$5,000 | None — the programme provides no real-estate route | US$5,000 per application, non-refundable after submission; the official programme channel publishes a further US$750 per applicant for citizenship documents, which is official-site content and requires confirmation at the date of application | Contributed (spent). Non-refundable by law, but payable only after approval and within 90 days of it, failing which the process lapses | The official channel states approximately 1.5 to three months to decision and about three months from approval to passport; a statement of that channel, not an audited figure, and no processing time is assured | Approximately one year — the decree entered into force on publication, 1 August 2025 | Operational. Nationals are visa-required for the Schengen Area (Regulation (EU) 2018/1806, Annex I), so the passport is never the source of European mobility. Nationality may not be granted to a person already holding more than two foreign nationalities; acceptance of applications from holders of three or more foreign nationalities, and passport issuance to adult dependent children, are reported to have been placed on hold by memorandum of 10 April 2026, with no evidence located that either hold has been lifted. Dependant categories published administratively (children to 30; parents and grandparents 55+) have no basis in either gazetted text and are not treated as statutory anywhere in this report. Parliamentary elections are scheduled for 27 September 2026 | §6.2, §6.3, §6.4, §6.5, §6.9, §6.12, §12.1 | | **St Kitts and Nevis** — Sustainable Island State Contribution | US$250,000 | US$250,000 (single or family up to four); additional dependant +US$25,000 (under 18) / +US$50,000 (18 and over) | US$325,000 (approved development or private condominium) / US$600,000 (private single-family dwelling), with a seven-year no-resale condition; floors reduced from US$400,000 / US$800,000 by SRO 43 of 2024 (25 October 2024) | Due diligence US$10,000 principal / US$7,500 dependant aged 16 and over; a main-applicant interview is mandatory; application and processing fees beyond due diligence: not verified | Contribution route: contributed (spent). Real-estate route: invested (retained), subject to the seven-year no-resale condition; §12.12 treats it as not a retained-asset equivalent | Stated decision within 120 to 180 days | Decades of operating history; commencement date not verified in this report | Operational. Visa-exempt for the Schengen Area (Regulation (EU) 2018/1806, Annex II, consolidation of 30 December 2025), an exemption now structurally conditional on programme character under Article 8a(1)(e) inserted by Regulation (EU) 2025/2441. COM(2025) 792 (19 December 2025) describes such schemes as a "potential ground" for suspension and asks the states concerned to vet applicants "pending the discontinuation of those schemes". Reported unpublished Commission letters of 25 June 2026 are said to seek phase-out by 1 June 2028; that demand is reported correspondence and is not in COM(2025) 792 | §12.12, §14.1 | | **Dominica** — Economic Diversification Fund | US$200,000 | US$250,000 (principal and up to three dependants); additional dependant +US$25,000 (under 18) / +US$40,000 (18 and over) | At least US$200,000 in an approved project, plus government fees of US$75,000–100,000 (+US$25,000 / +US$40,000 per dependant), with a three-year holding period, extended to five where resold to another programme purchaser | Processing US$1,000 per application; due diligence US$7,500 principal / US$4,000 dependant aged 16 and over; mandatory interview US$1,000 per applicant aged 16 and over; naturalisation certificate US$500 per person | Contribution route: contributed (spent). Real-estate route: invested (retained), subject to the statutory holding period; §12.12 treats it as not a retained-asset equivalent | "At least three months" to approval in principle | Decades of operating history; commencement date not verified in this report | Operational; Annex II visa-exempt on the same structurally conditional basis as the row above. COM(2025) 792 records a 2024 rejection rate of 6.5% | §12.12, §14.1 | | **Grenada** — National Transformation Fund | US$235,000 | US$235,000 (single or family up to four) | US$270,000 (share in an approved project) / US$350,000 (unit), plus a US$50,000 government fee | Application US$1,500; processing US$1,500 (aged 17 and over) / US$500 (under 17); due diligence US$5,000 (aged 17 and over); mandatory interview US$1,000 (aged 17 and over). The official page states "+US$25,000/50,000 per additional dependant after the third dependant" without the age split behind the two figures; the split is not verified | Contribution route: contributed (spent). Real-estate route: invested (retained); §12.12 treats it as not a retained-asset equivalent | Not published by the responsible unit; industry reporting of approximately four to six months is reported tier only | Decades of operating history; commencement date not verified in this report | Operational; Annex II visa-exempt on the same structurally conditional basis | §12.12, §14.1 | | **Antigua and Barbuda** — National Development Fund | US$230,000, plus processing US$10,000 | US$230,000 (single or family up to four), plus processing US$20,000; from the fifth dependant, processing +US$10,000 each and, on the published Schedule of Fees, an additional-dependant charge of US$10,000 (aged 0–5), US$25,000 (aged 6–17) or US$50,000 (18 and over). Whether that additional-dependant charge applies at application or only to post-grant additions is not resolved on the published schedule | US$300,000 (approved real estate). Business route US$1.5m sole / US$5m joint with a minimum of US$400,000 each | Due diligence US$8,500 principal / US$5,000 spouse / US$2,000 (aged 12–17) / US$4,000 (18 and over); passport US$300 per person | Contribution route: contributed (spent). Real-estate route: invested (retained); §12.12 treats it as not a retained-asset equivalent | Not published on the responsible unit's site; not verified | Decades of operating history; commencement date not verified in this report | Operational; Annex II visa-exempt on the same structurally conditional basis. COM(2025) 792 records a 2024 rejection rate of 1.7%. A separate University of the West Indies Fund route is priced at US$260,000 inclusive of processing fees for a family of six or more, with a minimum family size of six per application and +US$10,000 per additional dependant from the seventh. Deprivation of citizenship may follow a failure to spend five days in the country within five calendar years of obtaining it, with no refund | §12.12, §14.1 | | **Saint Lucia** — National Economic Fund | US$240,000 | US$240,000 (applicant alone or with up to three qualifying dependants); additional dependant +US$10,000 (under 18) / +US$20,000 (18 and over); newborn up to 12 months US$5,000 | US$300,000 plus administration fees of US$30,000–45,000 (+US$5,000 / +US$10,000 per dependant). Approved built real-estate project (apartment or villa) US$500,000 plus a US$30,000 administration fee, with a five-year no-sale condition. National Action Bond US$300,000 in non-interest-bearing bonds held five years, plus a US$50,000 non-refundable administration fee. Enterprise routes: US$250,000 for a Cabinet-approved enterprise project (Option 3); US$3.5m for a single applicant with at least three permanent jobs (Option 1); US$6m jointly with at least six permanent jobs and a minimum of US$1m each (Option 2). The three enterprise options are those of Schedule 2, paragraph 3 as replaced by Statutory Instrument No. 57 of 2026, regulation 12(b); the built real-estate minimum is Schedule 2, paragraph 2A, inserted by regulation 12(a) of the same instrument, and the US$300,000 route minimum is Schedule 2, paragraph 2 as replaced by S.I. No. 106 of 2024, in force 1 July 2024 | Processing US$2,000 / US$1,000; due diligence US$8,000 / US$5,000; interview and identity verification required since 4 September 2023 | Contribution route: contributed (spent). Real-estate and bond routes: invested (retained), the bond fee being non-refundable; §12.12 treats the real-estate route as not a retained-asset equivalent | Approximately 90 days from acceptance to grant, per the responsible unit's published questions and answers. The Board may approve a maximum of 1,500 applications annually (regulation 7(9), inserted by S.I. No. 57 of 2026); applications received in the 2024 and 2025 financial years and approved in 2024–2027 are excluded from the cap for 2025–2027 | Decades of operating history; commencement date not verified in this report | Operational; Annex II visa-exempt on the same structurally conditional basis. COM(2025) 792 records a 2024 rejection rate of 5.3%. Restructured by Statutory Instrument No. 57 of 2026 (gazetted 23 March 2026), which created the built real-estate route, closed applications for approval of new real-estate projects after 1 December 2025, introduced an annual approvals cap and a declared-financial-resources requirement, and required biometric data from successful applicants | §12.12, §14.1 | | **Türkiye** — investor citizenship (Art. 20(2) of the implementing regulation) | None — the programme provides no contribution or donation route | Not applicable: the threshold attaches to the investment, not to the applicant; no separate dependant charge verified | Real estate of at least US$400,000 with a three-year no-sale annotation. Alternatives: fixed capital of at least US$500,000; at least 50 employees; deposits, government debt, fund units or private pension contributions of at least US$500,000 each, held for three years | Not verified | Invested (retained), subject to the three-year no-sale annotation or holding period | Not verified | Not verified. The threshold history is the report's clearest illustration of decree-level instability: a lira amount, then US$250,000, then US$400,000, the last set by Karar 5554 (Resmî Gazete 31834, 13 May 2022) in force from 13 June 2022 | Operational. The grant is a discretionary Presidential decision under Article 12(1)(b) of Law 5901 and is never an entitlement. Turkish nationals are visa-required for the Schengen Area, so the passport carries no European mobility | §14.2, §12.12 | | **Vanuatu** — Development Support Programme | US$130,000 | US$180,000 (family of four); +US$10,000 per additional dependant. A separate Form D route is priced at US$260,000, which covers the applicant, spouse and one child under 18 only; each further child under 18 adds US$19,250 and each dependant aged 18 to 21 adds US$44,250, plus a US$250 application fee | Not verified — the located official schedule prices the contribution routes only | Financial Intelligence Unit due diligence US$5,000 | Contributed (spent) | Not verified | Not verified; more than 10,500 passports were estimated to have been issued by March 2021 (Council Decision (EU) 2022/366) | Operational and still selling, but the executed precedent for loss of mobility: the EU visa waiver was partially suspended from 4 May 2022, fully suspended for all nationals from 4 February 2023, and Vanuatu was permanently transferred to Annex I by Regulation (EU) 2025/11. Programme survival and mobility value are separate risks | §6.12, §14.1 | | **Nauru** — Economic and Climate Resilience Citizenship Programme (Act 2024) | US$90,000, published as a "limited time offer" with two conflicting expiry dates on the same official page (31 December 2026 in the body; 30 June 2026 in the footer) and no stated undiscounted base | Not verified — no family price is published; dependants aged 16 and over add US$2,000, US$2,000 and US$3,000 each | None — donation only | Principal fees US$5,000 and US$6,000 | Contributed (spent) | Three to four months | No operating history — the enabling Act dates from 2024 | Excluded from serious comparison in this report: sub-scale, promotional pricing in flux, minimal mobility and no operating history. The headline figure must never be quoted without the limited-time caveat | §12.12 | | **Egypt; Jordan; other jurisdictions occasionally proposed** | Not verified | Not verified | Not verified | Egypt: a US$10,000 administrative fee where the application is made from abroad. Jordan: not verified | Not verified | Egypt: three to six months, stated. Jordan: not verified | Not verified | Egypt operates a statutory investment-naturalisation mechanism (project, real-estate, treasury-payment and central-bank-deposit routes; minor children up to 21), but the route amounts are not published on the official page and were not verified. No official Jordanian source was reachable, so every Jordanian figure requires confirmation at the date of application. Cambodia and North Macedonia were not researched for this report and are carried unpriced | §12.12 | *Table 1 — Citizenship programmes on official published figures, as at 2 August 2026. Assumptions and derivation: all amounts are the official published figures of the enacting instrument or of the responsible unit's own fee schedule, in US dollars as published, and are exclusive of professional fees, taxes, translation, apostille, courier and acquisition costs and of any Kestrel Private engagement; no currency conversion is applied (the report's planning assumption of €1 = US$1.15 is governed by §10.2 and applied in Chapter 10). Every figure requires confirmation at the date of application. The "family of four" column reproduces each programme's published contribution or donation rule for a principal and three qualifying persons; it is not a family total, because due-diligence, processing, interview and document fees turn on age thresholds that differ between programmes (12, 16, 17 and 18 all appear above) — the fee rules are printed here and no family total is constructed anywhere in this report. Family composition is a legal question before it is a pricing question: for São Tomé and Príncipe the statutory dependant class is narrower than the class published administratively (§6.3, §11.5, §11.6). Contribution and fee figures for São Tomé derive from Decree-Law 07/2025, Anexo I; the US$750 document aggregate is official-site content, not gazetted law. Currency and trajectory: no amount above is a standing figure. The Saint Lucia, St Kitts and Nevis and Türkiye amounts are dated here to the instrument that set them — S.I. No. 106 of 2024 (in force 1 July 2024) and S.I. No. 57 of 2026 (gazetted 23 March 2026); SRO 43 of 2024 (25 October 2024); Karar 5554 (13 May 2022, in force 13 June 2022) — and the Saint Lucia row was re-verified against S.I. No. 57 of 2026, read in full, on 4 August 2026. The Antigua and Barbuda, Dominica, Grenada and Vanuatu amounts are those published by each responsible unit on 4 August 2026; no gazetted instrument fixing them was located, so the date from which each has applied is not stated, and each is one point in a schedule these states amend by statutory instrument, in several cases more than once a year. The São Tomé amounts may be altered by joint ministerial *despacho* under Article 22(1) of Decree-Law 07/2025, and the programme is one year old. A responsible unit's website is not a primary instrument: Saint Lucia's own unit publishes superseded pre-July-2024 figures on its questions-and-answers page while its gazette says otherwise, so every figure above that rests on a website rather than an instrument is identified as such. Sources and analysis: §6.2–§6.5, §6.9, §6.12, §12.1, §12.12, §14.1, §14.2. Rejection rates, the "potential ground" formulation and the discontinuation language are those of COM(2025) 792 (19 December 2025); the reported 1 June 2028 phase-out demand sits in unpublished correspondence of 25 June 2026 and is never attributed to that report.* Two arithmetical points, recomputed here from the published figures rather than carried across: - On the São Tomé figures, the identifiable government-side cost of a single application is US$90,000 + US$5,000 + US$750 = US$95,750, and of a family application of four within the statutory dependant class US$95,000 + US$5,000 + (4 × US$750) = US$103,000. Both totals rely on the US$750 document aggregate, which requires confirmation at the date of application, and both exclude every professional and ancillary cost (§6.4). - The reference structure's contribution for a family of two to four members, US$95,000, is US$135,000 to US$155,000 below the published family-of-four donation of the five Eastern Caribbean programmes (US$230,000 to US$250,000). That difference is a comparison of contributions only. The reference structure then deploys a further €250,000 into the retained property, plus acquisition friction of 5.9% to 13.1% of that sum, so its total outlay is materially larger; the difference is that the larger part is an asset rather than an expense, and an asset carrying its own risk (§12.4, §12.12). ## B.2 Table 2 — European investor residence: the Greek tiers | | **€250,000 — change of use** | **€250,000 — listed or preserved building** | **€400,000 tier** | **€800,000 tier** | |---|---|---|---|---| | **Threshold** | €250,000 minimum acquisition value at the time of purchase, by exception to the general tiers | €250,000 minimum acquisition value at the time of purchase, by exception to the general tiers | €400,000 | €800,000 | | **Property conditions** | One single property whose main spaces change use to residential; no minimum floor area; full ownership and possession; the change of use must be completed before the application is submitted. The requirement that completion fall after 5 April 2024 appears in the official administrative record (mitos), not in Law 5100/2024 itself, and is cited accordingly. Where the building is industrial, an engineer must certify that no industrial activity has been installed and in operation for at least the preceding five years. Circular 1/2026 (21 April 2026) provides that a property already residential on 5 April 2024 may not be cycled out of and back into residential use and that a building-permit paper amendment alone does not qualify. The threshold is in practice once-only per property, the notary being obliged to certify prior use for a permit; that once-only effect is reported rather than verified. The property may not be used as the seat or branch of a business | One single property, listed or preserved, being restored or fully reconstructed; no minimum floor area; full ownership and possession. Restoration is to be completed by the first renewal, and transfer of an unrestored listed building is void; fines of €150,000 attach to listed-building breaches, and the exact mapping of fine to breach is to be confirmed against the gazette text | One single property anywhere outside the €800,000 areas; where the property is built, or a building permit has been issued for it, at least 120 m² of main spaces; full ownership and possession | One single property in the Region of Attica; the Regional Unit of Thessaloniki (Region of Central Macedonia); the Regional Units of Mykonos and Thira (Region of South Aegean) — the Regional Unit of Thira comprising Thira (Santorini), Ios, Folegandros, Sikinos and Anafi; or an island with a population, according to the latest census, over 3,100. The statute fixes the zone by regional unit, not by island: the islands within the Regional Unit of Thira that fall below the 3,100 population limb — Ios, Folegandros, Sikinos and Anafi — are nonetheless in the €800,000 zone, and a property acquired on any of them at €400,000 does not qualify. Where the property is built, or a building permit has been issued for it, at least 120 m² of main spaces; full ownership and possession | | **Permit duration** | Five years, renewable for equal periods each time, provided the property remains in the holder's ownership and possession; the statute sets no cap on renewals. Periods of absence from Greece are no obstacle to renewal — there is no physical-presence condition | As left | As left | As left | | **Employment rights** | The permit does not establish a right of access to any form of employment (Article 100 §9 of Law 5038/2023) | As left | As left | As left | | **Letting restrictions** | Long-term letting is expressly permitted. Short-term (sharing-economy) letting and sub-letting are prohibited; breach carries revocation of the permit and a standalone administrative fine of €50,000. A primary-residence lease is reported to bind the landlord for a minimum of three years (reported tier; requires confirmation at the date of application). The property may not house a business | Long-term letting permitted on the same statutory terms; short-term letting and sub-letting prohibited, with the same revocation and €50,000 fine | Long-term letting permitted; short-term letting and sub-letting prohibited for properties acquired for the initial grant or renewal of an investor permit, with the same revocation and €50,000 fine | As for the €400,000 tier | | **Route to naturalisation** | The investor permanent residence permit is among the titles carrying a seven-year residence requirement under the official administrative record (last updated 30 July 2026); other conditions include the PEGP examination in Greek language, history, geography, culture and institutions, evidenced economic and social integration including Greek tax returns for the residence years, a €550 fee (€100 for EU nationals, stateless persons and refugees) and a €200 resubmission fee. A permit held without genuine relocation does not lead to Greek citizenship: the permit years count, but the examination, tax-return and genuine-residence requirements presuppose actual life in Greece. There is no investor fast-track to citizenship in Greek law | As left | As left | As left | *Table 2 — The Greek investor residence permit (type B.5) by investment tier, as at 2 August 2026. Assumptions and derivation: thresholds and conditions are those of Article 100 of Law 5038/2023 (Government Gazette A′ 81/01.04.2023) as amended by Article 64 of Law 5100/2024 (A′ 49/05.04.2024), with documentary requirements under Joint Ministerial Decision 214926/2025 (B′ 6014/11.11.2025) and the administrative content of the official record at mitos.gov.gr; Circular 1/2026 content is reported tier, the circular text not having been opened. The statute fixes the €800,000 zone by **regional unit**, not by island: Article 100(2)(a) reads «τις Περιφερειακές Ενότητες Μυκόνου και Θήρας». The Regional Unit of Thira extends well beyond Santorini, and the islands within it that fall below the 3,100 population limb — Ios, Folegandros, Sikinos and Anafi — are nonetheless in the €800,000 zone. The constitutive instrument for the regional units is Law 3852/2010, Article 3. The consequence is not curable after the event: Article 100(3) requires the price to be paid in full before the application is submitted. The 120 m² condition likewise attaches to a property that is built **or** for which a building permit has been issued (Article 100(2)(a) and (2)(b)); no minimum floor area attaches to either €250,000 category. The fee position is common to all four columns and is therefore stated here rather than in the table: €2,000 for issuance and again for renewal, plus a €16 electronic residence card, the change-of-use initial-issuance table totalling €2,016 (€2,000 + €16 = €2,016); family-member permits €150, the independent three-year permit of a child reaching 21 €450, minors exempt from permit fees. Two temporal qualifications travel with the table: the perimeter of the short-term-letting prohibition for acquisitions predating 5 April 2024 is contested in commentary and unresolved; and Law 5275/2026 (A′ 17/06.02.2026) is reported to alter card-validity mechanics, but its text has not been read and nothing in it is stated here as law. Whether a resold conversion property re-qualifies a new €250,000 application is an open administrative question. All four columns require confirmation at the date of application. Sources and analysis: §7.4, §7.12, §7.14, §12.2, §12.5, §12.10, §14.1, §14.3, §14.6, §14.12, §14.15.* **Both tables carry the same reservation.** Every amount above is the official published figure of the enacting state or of the responsible unit, exclusive of professional fees, taxes, acquisition costs, translation, legalisation and any advisory engagement, and each is current only at its stated date. Published schedules change, and several of the instruments above were amended within the last 24 months. Every figure requires confirmation against the schedules in force at the date of application (§10.1, §14.2). ## B.3 What this table cannot show A comparison table makes price look like the decisive variable because price is the variable a table holds well. On the report's own findings it is the least important of the variables in play, and four matters that decide outcomes do not appear in any column above. - **Programme integrity and institutional capacity.** Due-diligence standards, the independence of each screening layer, the standing of the application channel, the grounds on which a file may be refused, the treatment of a file after approval and the transparency of published reporting are what separate one programme from another. None is a number. The assessment set out at §6.12 — operational status at the date of application, current processing and issuance experience, refund provisions, post-approval legal risk and banking treatment — is the working test, and it applies to every row in Table 1. - **Operating history.** The reference structure's citizenship component has existed in law for approximately one year; the Caribbean programmes have decades of operating history, and a young programme's activity data are programme-supplied rather than audited. An approvals record showing no refusals among a small number of files is not evidence of due-diligence rigour in either direction (§6.12). - **The EU's visa-suspension lever.** The Schengen access of the five Eastern Caribbean programmes is now structurally conditional on programme character, following Article 8a(1)(e) inserted by Regulation (EU) 2025/2441 and the Commission's Eighth Report; Vanuatu is the executed precedent, having moved from visa-exempt to visa-required in three steps on citizenship-by-investment grounds. That lever cannot be applied to São Tomé and Príncipe, which is already in Annex I and holds no exemption to suspend — which is not an advantage but a statement of where the exposure lies. Short-stay Schengen movement within the reference structure arises from the Greek residence permit and from nothing else, so the analogous failure mode attaches to the continuity of that permit, not to the passport (§14.1, §6.9, §7.14). - **What "invested" is worth.** The contributed-or-invested column records a legal character, not a recoverable amount. Retained capital is retained at risk: acquisition friction of 5.9% to 13.1% of the €250,000 is consumed on day one; the letting regime restricts what the asset can earn; a sale during the permit's validity revokes the permit; and the verified Greek record includes a nominal fall of 42.4% nationally between 2008 and 2017 with years of effective illiquidity. Capital preservation, appreciation, rental income and resale liquidity cannot be guaranteed (§12.3, §12.4, §12.9, §12.11, §14.14). Two further limits are stated for the avoidance of doubt. No probability is assigned to any legislative change recorded above, because none can be evidenced (§14.1). And a lower price is not a reason to prefer one component over another, or one programme over another: each is assessed on its own legal terms, against a client's own objectives, and where a component fails that assessment the correct outcome is to decline it rather than to substitute something cheaper (§5.7, §6.14, §13.11).