# 11. Family Cost Models Chapter 10 built the single-applicant reference case from the bottom up; this chapter re-runs that model for the family shapes most commonly assessed. Two fee architectures govern the result: the contribution tiers of Anexo I to São Tomé and Príncipe's Decree-Law No. 07/2025,[^11-1] and the family-member eligibility and fee provisions of Articles 95 §2 and 171 of Greek Law 5038/2023.[^11-6] One structural fact shapes everything that follows: the €250,000 property component does not scale with family size, while the contribution tier, the government fees and the per-person soft costs do. Because the two components are legally separate (see §5.8), a family may also be included asymmetrically (a member may hold the Greek family permit without the São Toméan nationality, or the reverse), and the models below therefore price each component on its own rules. All currency conversions use the report's working planning assumption of €1 = US$1.15 (§10.2). That figure is a planning assumption set below the prevailing market rate, not a market rate and not a forecast: the European Central Bank's euro foreign exchange reference rate stood at 1.1535 on 3 August 2026, so a dollar charge converted at 1.15 yields a slightly higher euro cost than the market would.[^11-19] The dollar amounts govern; the euro figures are conversions of them. Two qualifications govern every figure in this chapter. First, each model assumes that every family member named in it is admitted on both sides. Admission is decided by the Greek and the São Toméan authorities in each case, on the conditions of their own instruments, and no approval can be guaranteed. Secondly, the €250,000 property component is capital committed to a single illiquid asset; nothing below should be read as indicating that this capital is preserved or recoverable through the structure (see Chapter 12, and §12.3 in particular). ## 11.1 Single applicant The single-applicant known base, built in §10.3–§10.7, is reproduced here as the baseline against which each family shape is measured. | Cost component | Amount | | --- | ---: | | Qualifying Greek property | €250,000 | | São Tomé contribution — single applicant, US$90,000 | €78,261 | | São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 | | Greek main-applicant permit fee | €2,000 | | Greek residence-card production charge | €16 | | **Known base subtotal** | **€334,625** | Assumptions: €1 = US$1.15, a planning assumption below the prevailing market rate (§10.2);[^11-19] contribution and fee per Anexo I, Decree-Law No. 07/2025;[^11-1] Greek fees per Article 171, Law 5038/2023 and the official administrative record, as at 2 August 2026.[^11-6][^11-7] These figures are as built in Chapter 10 and are not re-derived here; they exclude every allowance item itemised there (§10.6, §10.8–§10.15). The €250,000 line is capital committed to a single property and is not treated as preserved or recoverable (see Chapter 12). Within the approximately €375,000 single-applicant planning figure, this base leaves about €40,375 for all other costs. Two of those costs are Kestrel Private's own. The professional engagement fee is charged per application, and the reference case comprises two applications (the São Toméan citizenship application and the Greek residence application), so €18,000 of the €40,375 is committed to Kestrel Private's own charges before any third-party cost is counted (§10.11; the basis of the charge is set out at §11.9). A third commitment follows immediately: the retainer of the licensed submitting agent through which the citizenship application must be filed, carried at €4,348 — an allowance of US$5,000 in Kestrel Private's own cost model, and a charge distinct from the programme's own US$5,000 due-diligence and processing fee in the table above. That allowance is neither published nor gazetted and is not sourced to any instrument; it requires a written quotation before engagement and confirmation at the date of application (§10.4). The three commitments together account for €22,348 of the allowance, being 55.4% of it, and leave €18,027 for every remaining third-party cost. Re-footed on that basis, Chapter 10's allowance stress test gives allowance totals of €40,600 in the lean case, €62,463 in the heavy case and €76,263 in the top case (§10.14). Against the €40,375 available, all three exceed the allowance — by €225, €22,088 and €35,888 respectively — and the corresponding all-in totals are €375,225, €397,088 and €410,888. The €375,000 planning figure is therefore exceeded in the single-applicant case even where every controllable cost falls at the bottom of its band, and by a wider margin on any less favourable set. Every family shape below is measured from a single-applicant case that already exceeds the planning figure by €225 before any property-specific cost is known. ## 11.2 Married couple The contribution moves to the family tier: US$95,000 for a family application comprising two to four people (€82,609).[^11-1] The due-diligence and processing fee of US$5,000 is charged per application, not per person, and does not double.[^11-1] Eligibility of the spouse differs between the two components, and between the gazetted São Toméan law and the programme's published administration. The decree includes the spouse by reference to Article 10(5) of the Nationality Law (Lei n.º 7/2022), which in turn applies Article 6. The spouse acquires under Article 6(1), which requires cumulatively a marriage of more than five years **and** that the marriage be under the regime of community of acquired property (*comunhão de bens adquiridos*), or under Article 6(2) a de facto union of more than three years recognised by the Civil Court.[^11-2] The property-regime condition is on the face of the statute and has no counterpart in the programme's published spouse category; how it is applied to a foreign marriage contracted under a different matrimonial regime is not addressed in either instrument and requires São Toméan advice before a spouse is priced into an application. A couple married under separation of property (the ordinary choice in a material share of the families this report addresses) does not meet the Article 6(1) limb on the face of the text, and the model below should not be relied on for such a couple without that advice. The programme's official site publishes a broader class: a spouse in a monogamous marriage or a de facto partner; the site states neither a durational condition nor a property-regime condition.[^11-3] The two positions have not been reconciled in any published instrument; the inclusion of a recently married spouse, and of a spouse whose marriage is under separation of property, therefore rests on administrative practice and requires applicant-specific legal confirmation at the date of application (see §14.8, §16.2). On the Greek side the spouse (or cohabitation-agreement partner) is a statutory family member under Article 95 §2, and may receive a family permit (type O.1) expiring simultaneously with the sponsor's, at a fee of €150 plus the €16 card.[^11-6] | Cost component | Amount | | --- | ---: | | Qualifying Greek property | €250,000 | | São Tomé contribution — family application of two, US$95,000 | €82,609 | | São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 | | Greek permit fees — main applicant €2,000; spouse (type O.1) €150 | €2,150 | | Greek residence cards — 2 × €16 | €32 | | **Known base subtotal** | **€339,139** | | Increase over the single-applicant base | **+€4,514** | Assumptions: as the table at §11.1; spouse eligibility on both sides subject to the conditions described above, and inclusion subject to the decision of the competent authority on each side. Per-person scaling items (§11.8) excluded. ## 11.3 Couple with one child A child under 18 falls within the gazetted São Toméan dependant class — minor children may be included at the naturalisation act[^11-2] — and within the two-to-four-person tier, so the contribution is unchanged at US$95,000 (€82,609).[^11-1] In Greece an unmarried child under 21 is a statutory family member (Article 95 §2); minors are exempt from the permit fee under Article 171, leaving the €16 card charge as the child's only known government cost.[^11-6] | Cost component | Amount | | --- | ---: | | Qualifying Greek property | €250,000 | | São Tomé contribution — family application of three, US$95,000 | €82,609 | | São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 | | Greek permit fees — main applicant €2,000; spouse €150; minor child exempt | €2,150 | | Greek residence cards — 3 × €16 (minors' card charge requires confirmation) | €48 | | **Known base subtotal** | **€339,155** | | Increase over the single-applicant base | **+€4,530** | Assumptions: as the table at §11.1; child under 18 at application. The €16 card charge is modelled per person including minors: the Article 171 exemption concerns the permit fee, and the treatment of the card charge for minors requires confirmation at the date of application. The subtotal therefore contains one unconfirmed element, immaterial in amount. ## 11.4 Couple with two children A family of four remains within the two-to-four-person contribution tier: the contribution is identical to that of a childless couple.[^11-1] This is the tier structure's most visible family effect: the third and fourth members add no contribution, only fees, documents and the per-person items in §11.8. | Cost component | Amount | | --- | ---: | | Qualifying Greek property | €250,000 | | São Tomé contribution — family application of four, US$95,000 | €82,609 | | São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 | | Greek permit fees — main applicant €2,000; spouse €150; two minor children exempt | €2,150 | | Greek residence cards — 4 × €16 (minors' card charge requires confirmation) | €64 | | **Known base subtotal** | **€339,171** | | Increase over the single-applicant base | **+€4,546** | Assumptions: as the tables at §11.1 and §11.3; both children under 18 at application; the minors' card charge is the unconfirmed element noted at §11.3. ## 11.5 Family with adult dependent children Adult children are the family shape on which the two components diverge most, and the point at which published law and published administration must be read separately. On the São Toméan side, the gazetted class is narrow. The decree defines dependants as the spouse and/or children of the principal applicant under Articles 10(4)–(5) of the Nationality Law; Article 10(4) covers minor children, who may themselves request the nationality up to one year after reaching majority.[^11-1][^11-2] Neither gazetted instrument contains any provision for dependent children up to age 30. That category — children to 30 — appears only on the programme's official site,[^11-3] and its statutory basis is not visible in either text. The state's own administration has acknowledged the gap: by a memorandum of the programme unit's director dated 10 April 2026, reported in industry press and not itself published, passport issuance for adult dependent children aged 18 and over was placed on hold pending a revised dependency framework; no evidence that the revised framework has been enacted, or the hold lifted, had been located as at 2 August 2026.[^11-4][^11-5] This report accordingly does not price adult children as São Toméan dependants. A family wishing to include a child aged 18 or over must treat that inclusion as unconfirmed administrative practice, to be verified at the date of application, together with the status of the passport hold, on applicant-specific legal advice. On the Greek side the position is statutory and clearer, but time-limited. An unmarried child is includable until age 21 (fee €150 plus the €16 card between 18 and 20, since the minor exemption no longer applies).[^11-6] Article 95 §2 contains no exception for an adult child lacking legal capacity: the list of family members is closed (it is expressed as a derogation from Article 84 §1) and every limb of it is age-limited or relationship-limited. Whether such a child may be accommodated under the humanitarian category (residence permit type "Α.4") is a separate question on separate conditions and fees, decided by a different authority, and requires applicant-specific legal advice.[^11-6] A child who reaches 21 while included may receive an independent three-year residence permit (type O.2) plus the €16 card. Article 171 §1(β) sets the fee for types O.1 and O.2 at €150, reserving €450 specifically for the three-year independent permit granted under the *first* sentence of Article 90 §5; Article 95 §2 grants the investor's child that permit by analogous application of the *second* sentence. The fee applicable to this route is therefore €150 on the face of the Code, and the €450 figure circulating in practice requires confirmation against the administrative record at the date of application. On the second-sentence reading no further renewal is permitted, making the permit in practice a bridge to about age 24, after which any further residence must rest on a category of the Immigration Code for which the child qualifies in his or her own right (see §16.4).[^11-6] The asymmetry is worth stating plainly. A nationality granted to an included child is a personal status that is not time-limited, but it remains subject to the loss grounds of the Nationality Law (Articles 11(2) and 16), to the administrative sanctions of the decree, which include revocation of nationality (Article 18), and to judicial opposition by the Public Prosecutor before the administrative court within six months of the declaration of acquisition (Article 14(7)–(8) of the decree).[^11-1][^11-2] The fourth-nationality rule of Article 11(2) — immediate loss on acquiring a fourth nationality — bears directly on a child of a multi-national family, and is screened person by person (§11.8). The Greek family permit, by contrast, is a derivative status that expires with the sponsor's permit and, for children, ends on the age timetable above. Families planning around children aged roughly 17 to 21 at application face sequencing questions on both sides (the Greek 21-year limit and the São Toméan one-year post-majority window) that belong in the implementation plan (see §17.5), not in a headline price. ## 11.6 Family including dependent parents The two components are asymmetric in the opposite direction for parents. In Greece, Article 95 §2 makes the direct ascendants of the spouses or partners statutory family members: the inclusion of parents of either spouse is anchored in the law itself.[^11-6] Whether the provision is applied beyond parents in practice requires confirmation at the date of application (see §16.5). Each included ascendant may receive a type O.1 permit expiring with the sponsor's, at €150 plus the €16 card: | Greek-side items — two dependent parents | Amount | | --- | ---: | | Family-member permit fees — 2 × €150 (type O.1) | €300 | | Residence cards — 2 × €16 | €32 | | **Additional known Greek fees** | **€332** | Assumptions: Article 95 §2 and Article 171, Law 5038/2023; official fee schedule as at 2 August 2026;[^11-6][^11-7] inclusion subject to the conditions of Article 95 §2 and to the decision of the competent authority. Excludes insurance and the other per-person items in §11.8. In São Tomé and Príncipe, by contrast, parents and grandparents aged 55 and over are a category published on the programme's official site[^11-3] with no visible basis in either gazetted instrument: the decree's dependant class is the spouse and children only.[^11-1][^11-2] Were such an inclusion admitted in administrative practice, the published tier structure would price each parent as a family member (within the two-to-four band, or at US$5,000 (€4,348) beyond the fourth member); but this report cannot present that as a statutory entitlement, and the position requires confirmation at the date of application (see §16.5). One cost line deserves particular attention for older family members: the Greek private health insurance required of every applicant and family member (§11.8) is priced by age. Reported market indications place minimum-compliance cover at roughly €70–€300 per adult per year, materially more from age 65, with cover reported as potentially unavailable from age 75. The upper bound of that band is published by a golden-visa industry site and is carried as an indicative ceiling only, not as an authority for premium levels; written quotations are required before any family including parents is modelled.[^11-11] ## 11.7 Additional dependants Beyond the fourth family member, the contribution increases by US$5,000 (€4,348) for each additional qualifying dependant.[^11-1] For a couple with three minor children: | Cost component | Amount | | --- | ---: | | Qualifying Greek property | €250,000 | | São Tomé contribution — family of five, US$95,000 + US$5,000 (US$100,000) | €86,957 | | São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 | | Greek permit fees — main applicant €2,000; spouse €150; three minor children exempt | €2,150 | | Greek residence cards — 5 × €16 (minors' card charge requires confirmation) | €80 | | **Known base subtotal** | **€343,535** | | Increase over the single-applicant base | **+€8,910** | Assumptions: as the tables at §11.1 and §11.3; all children under 18 at application; the minors' card charge is the unconfirmed element noted at §11.3. A sixth member (US$105,000; €91,304) takes the known base to €347,898 (+€13,273 over the single-applicant base). For family members added after approval in principle, Anexo I publishes separate amounts: US$10,000 for the spouse of a citizen, US$5,000 for other qualifying dependants, and US$500 for a newborn child up to one year old.[^11-1] Those amounts are not the whole charge. The chapeau to Anexo I item 4 requires them to be paid *in addition to* the Anexo I due-diligence and processing fee of US$5,000 per application, and the US$750 document charge applies per applicant.[^11-1][^11-16] Stated as three lines and a total, a spouse added after approval in principle therefore carries US$10,000 + US$5,000 + US$750 = US$15,750, and another qualifying dependant US$5,000 + US$5,000 + US$750 = US$10,750. The programme's official channel publishes the same US$5,000 charge for post-approval inclusions, as a "Submission Fee (except newborns)", so a newborn addition is published at US$500 + US$750 = US$1,250; the gazette contains no newborn exemption, and on the gazetted text read literally a newborn addition is US$6,250. Which governs requires confirmation at the date of application.[^11-18] Future children and their treatment on both sides are addressed at §16.6. On the Greek side, each additional family member carries the O.1 fee (unless a minor), the €16 card, and the full set of per-person items in §11.8. ## 11.8 Documentation and due-diligence cost differences The headline São Toméan due-diligence fee is flat — US$5,000 per application[^11-1] — but the checks behind it are per person. Under the decree, due diligence is performed by independent qualified external entities engaged by the programme unit on every applicant and, where applicable, on those dependants who are criminally imputable under São Toméan law (Article 11(1)); interviews may be required, in person or by video (Article 11(2)).[^11-1] The age at which criminal imputability begins is not stated in either instrument and requires confirmation at the date of application. The fee line does not double for a couple; the screening does. Source-of-funds preparation likewise extends across the household (see Chapter 15). Two payment conditions attach. The US$5,000 fee is non-refundable after submission, and the contribution itself is payable only after approval: delivery of the approval certificate is conditional on deposit within 90 days, failing which the process lapses.[^11-1] The consequence for a family is that screening, not payment, is where the exposure sits: a refusal or withdrawal affecting any one member does not return the per-application fee, and a re-filed application bears it again. How a refusal affecting part of a family is handled on both sides is addressed at §14.8. The per-person cost lines that scale with family size are these: - **Civil and identity documents (São Tomé).** The programme's official site has published an aggregate charge of US$750 (about €652) per applicant for the citizenship certificate, passport and national identity card; the amount appears in no gazetted schedule and requires confirmation at the date of application.[^11-16] - **Police certificates.** Each applicant requires criminal-record certificates from every country of nationality and every country of residence during the previous five years, issued within the three months before submission — a timing rule that forces per-person sequencing where several states are involved; costs vary by issuing state.[^11-1] (See §16.8.) - **Medical certificates.** One per applicant under the decree's application requirements.[^11-1] - **Translations.** Certified translation into Portuguese or English for the São Toméan file,[^11-1] and into Greek for the Greek file — published Greek rates run at roughly €15–€60 per page plus 24% VAT, per person and per document.[^11-12] - **Apostilles and legalisation.** Charged per document: the United Kingdom's published schedule is £45 per document (£35 for an e-apostille);[^11-13] South Africa's DIRCO legalises public documents without charge, with notarial fees additional for private documents.[^11-14] - **Entry and biometrics (Greece).** Where the application is filed by proxy, the applicant and each family member must enter Greece within an exclusive 12-month period from filing and give fingerprints; a second failure to attend a summoned appointment results in rejection.[^11-8] Where the applicant is a national of a state listed in Annex I to Regulation (EU) 2018/1806,[^11-17] that entry itself requires a Schengen visa (€90 per adult; €45 per child aged six to below 12)[^11-15] or a national entry visa (an indicative consular charge of €180, requiring confirmation at the date of application),[^11-8] plus travel costs per person. - **Health insurance (Greece).** Every applicant and family member must hold a private policy meeting the coverage minimums fixed under the predecessor Code and still applied in practice (subject to confirmation);[^11-9][^11-10] reported premiums are roughly €70–€300 per adult per year for minimum-compliance cover, age-loaded as described in §11.6, and the policy must be renewed annually for as long as the position is held.[^11-11] Two further family-scaling mechanics are easily missed. First, the fees recur: the €2,000 main-applicant fee applies at issuance and at each five-year renewal; family permits expire simultaneously with the sponsor's and are renewed alongside it, at the fee schedule then in force; fresh insurance is required at each renewal; and new cards are produced.[^11-6][^11-9] Secondly, the Nationality Law's multiple-nationality cap — no grant to a person already holding more than two foreign nationalities — attaches on its face to each person acquiring the nationality, not only the principal applicant; the programme unit is reported to have placed acceptance of applications from persons holding three or more foreign nationalities on hold by a memorandum of 10 April 2026 that has not been published, and that position requires confirmation at the date of application. The cap falls to be screened family member by family member (see §13.2, §14.8).[^11-2][^11-4] The family-member documentary requirements on the Greek side (birth, marriage and dependency evidence, and their legalisation) are fixed by the common-documents decision carried forward under the current documentation JMD; Chapter 16 sets out the documentation architecture, and the exact per-member list must be confirmed at the date of application.[^11-9] ## 11.9 Why the headline reference figure cannot apply to every family The approximately €375,000 reference case is, by its own terms, an illustrative single-applicant planning model (§1.5, §10.1). It cannot be quoted to a family — of any shape — for four reasons visible in this chapter's tables. First, the contribution is tiered, not flat: it steps up at the second family member and again at each member beyond the fourth. Second, the Greek fees and cards accumulate per person. Third, the per-person soft costs in §11.8 — documents, certificates, translations, legalisation, visas, travel and insurance — scale with headcount, and some recur annually or at each renewal. Fourth, the €40,375 residual allowance inside the €375,000 figure was constructed around one applicant's costs, and €22,348 of it — 55.4% — is committed before the first variable cost is reached: €18,000 of Kestrel Private professional engagement fees, one for each of the two applications in the reference structure (§10.11), and €4,348 for the licensed submitting agent's retainer, an allowance of US$5,000 carried in Kestrel Private's own cost model, published in no instrument and requiring a written quotation before engagement (§10.4). That leaves €18,027 for everything else. On Chapter 10's allowance stress test, re-footed on those two fees and that retainer, the allowance items total €40,600 in the lean case against the €40,375 available — an overrun of €225 — and €62,463 and €76,263 in the heavy and top cases, exceeding the allowance by €22,088 and €35,888 (§10.14). The single applicant's lean all-in total is €375,225, which is already above the planning figure before a second person is considered. There is accordingly no headroom for an additional person to consume: a married couple's known-base delta of €4,514 is added to an overrun that already exists, taking the lean all-in to €379,739 before a single per-person item of §11.8 is added. | Family shape (children under 18) | Contribution (US$ → €) | Greek fees and cards | Known base | Increase over single | | --- | ---: | ---: | ---: | ---: | | Single applicant | 90,000 → 78,261 | €2,016 | €334,625 | — | | Married couple | 95,000 → 82,609 | €2,182 | €339,139 | +€4,514 | | Couple with one child | 95,000 → 82,609 | €2,198 | €339,155 | +€4,530 | | Couple with two children | 95,000 → 82,609 | €2,214 | €339,171 | +€4,546 | | Couple with three children | 100,000 → 86,957 | €2,230 | €343,535 | +€8,910 | | Couple with four children | 105,000 → 91,304 | €2,246 | €347,898 | +€13,273 | Assumptions: every row includes the fixed €250,000 property and the US$5,000 (€4,348) per-application due-diligence fee; €1 = US$1.15, a planning assumption below the prevailing market rate (§10.2);[^11-19] Anexo I, Decree-Law No. 07/2025;[^11-1] Articles 95 §2 and 171, Law 5038/2023 and the official administrative record as at 2 August 2026;[^11-6][^11-7] children under 18; card charges modelled per person, including minors, whose treatment requires confirmation (see the §11.3 caption). Every row assumes each member named in it is admitted on both sides, which is a matter for the two administrations. Known bases only — the per-person scaling items of §11.8 and all Chapter 10 allowance items are additional; the €250,000 is capital committed to a single property (see Chapter 12). Kestrel Private's professional engagement fee sits among those allowance items and is not carried in any row: it is €18,000 in every row alike, being €10,000 on the citizenship application and €8,000 on the residence application instructed alongside it, charged per application and not per person (§10.11). The licensed submitting agent's retainer, carried at €4,348, is likewise an allowance item charged per application rather than per person and is not carried in any row either (§10.4). Worked deltas make the point concrete. A married couple adds €4,514 of known base; adding the reported per-person items with published amounts — US$750 (about €652) in programme document charges and a first-year insurance premium of roughly €70–€300 — takes the identifiable first-year increase to approximately €5,200–€5,500, before police certificates, medicals, translations, legalisation, visas and travel, which vary with the second applicant's nationalities and residence history. A couple with two minor children adds €4,546 of known base; with three further sets of document charges (about €1,956) and the spouse's insurance band, the identifiable first-year increase is approximately €6,500–€6,900, before the children's insurance premiums and the same variable items. These are illustrative sums of the components stated, not quotations. Two conclusions follow, and they pull in opposite directions. The two largest components do not scale with family size: the property requirement is a single qualifying investment, and the due-diligence fee is charged per application. Kestrel Private's professional engagement fee does not scale with family size either, for the same reason — it is charged per application and not per person (§10.11, and the closing paragraph of this section). The family members shown in the tables above may be included on that single investment, subject to Article 95 §2 and to the decision of the competent authority on each side. That is the structure's family economics: a fixed capital base — capital committed to one illiquid asset, which the structure neither preserves nor makes recoverable (see §12.3) — with scaling contribution tiers and per-person soft costs around it. But the €375,000 formulation still cannot be reused as a family figure — a couple's known-base increase alone consumes about a ninth of the €40,375 allowance, and a family of six's about a third; and because the lean case leaves no headroom at all, exceeding the planning figure by €225 on the single applicant alone, those same increases are not partial consumption of an allowance but additions to an overrun already incurred. The recurring per-person costs continue for the life of the position; and for two family shapes (adult children, §11.5; parents, §11.6) the São Toméan inclusion cannot currently be priced from the published law at all. Chapter 1's own restriction stands: the reference figure is not a family price (§1.5). A family quotation exists only after the full Chapter 10 model has been re-run with the exact family composition, the current government schedules on both sides, the selected property, and written quotations from the relevant providers — the discipline set out at §10.1 and applied family-shape by family-shape in Appendix D. Kestrel Private's own engagement is addressed at §10.11 and does not vary the government schedules set out here. It is charged as a fixed professional engagement fee, agreed in writing before work begins, and it is charged per application. Each programme applied to is a separate application: a separate body of work, a separate set of counterparties, a separate schedule of disbursements, and a separate government making a separate decision. The reference structure comprises two such applications — the São Toméan citizenship application and the Greek investor residence application — and therefore carries two fees — €10,000 and €8,000, or €18,000 in the reference case. A client instructing only one of the two programmes pays one fee of €10,000. The optional company, banking and tax layer is not a programme application and carries no Kestrel Private fee at all; its cost is entirely third-party. It sits outside the €375,000 reference case and outside every table in this chapter. Because the fee attaches to the application and not to the person, it does not scale with family size: it stands at €18,000 for every family shape modelled above, from the single applicant to the family of six, and is one of the few lines in the model of which that is true. ### Notes [^11-1]: São Tomé and Príncipe, Decreto-Lei n.º 07/2025 ("Regulamentação da Nacionalidade por Investimento ou Doação"), Diário da República I Série N.º 33, 1 August 2025, pp. 429–440 (Portuguese), Articles 3.º, 9.º, 10.º, 11.º, 14.º, 18.º and Anexo I §§2–4; gazette facsimile via https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^11-2]: São Tomé and Príncipe, Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República I Série N.º 25, 10 March 2022 (Portuguese), Articles 6.º, 10.º(4)–(5), 11.º(1)–(2), 16.º and 19.º–20.º; gazette facsimile via https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^11-3]: São Tomé and Príncipe Citizenship by Investment Unit, "Become a Citizen", cip.gov.st, archived snapshot of 17 July 2026 (live site unreachable at the research date), https://web.archive.org/web/20260717032201/https://cip.gov.st/become-a-citizen (accessed 2 August 2026). [^11-4]: IMI Daily, "São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule" (reporting the CIU Director's memorandum of 10 April 2026; the memorandum itself is not published), 11 April 2026, https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/ (accessed 2 August 2026). [^11-5]: NTL International, "São Tomé and Príncipe CBI 2026 legislative updates" (industry press page corroborating the adult-dependant passport hold), 14 April 2026, https://ntlinternational.com/press/sao-tome-and-principe-cbi-2026-legislative-updates (accessed 2 August 2026). [^11-6]: Greece, Law 5038/2023 (Immigration Code, Government Gazette A′ 81/01.04.2023), Articles 84 §1, 90 §5, 95 §2, 100 and 171 §§1–2, consolidated text (codification through Law 5307/2026) via https://www.taxheaven.gr/law/5038/2023 (article views /90, /95, /100, /171), swept against the Government Gazette facsimile A′ 81/01.04.2023 (Article 95 §2 at p. 4171; Article 171 §1(β)) via https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf — the whole gazette text was searched for the legal-capacity wording formerly relied on at §11.5 and it does not occur (accessed 4 August 2026). [^11-7]: Greece, National Registry of Administrative Public Services (mitos.gov.gr), "Permanent golden visa (change of use) – Initial issuance", last updated 31 July 2026, https://en.mitos.gov.gr/index.php/ΔΔ:Permanent_golden_visa_(change_of_use)_–_Initial_issuance (accessed 2 August 2026). [^11-8]: Greece, Law 5038/2023, Articles 8, 10 §11 and 14 §7 (proxy filing; twelve-month entry-and-biometrics period; consequences of non-attendance), Government Gazette facsimile A′ 81/01.04.2023 via https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf, swept against the consolidated text (codification through Law 5307/2026) via https://www.taxheaven.gr/law/5038/2023 — Articles 8, 10 §11 and 14 match, and the two articles that diverge (11 §1, 17 §1) are not relied on here. The €180 national entry-visa charge derives from the same gazette read (the fee provisions read include Articles 171, 176 and 177) but is not pinned to a numbered provision; it is stated as indicative and requiring confirmation at the date of application (accessed 2 August 2026). [^11-9]: Greece, Joint Ministerial Decision 214926/2025 (Government Gazette B′ 6014/11.11.2025), Articles 1–2 (incorporation of the common documents of JMD 95391/2024 Article 2; insurance-policy document; renewal documents), FEK PDF via https://www.pomida.gr/assets/File/1236_20250206014.pdf (accessed 2 August 2026). [^11-10]: Greece, Joint Ministerial Decision οικ. 53821/2014 (21 October 2014, under Article 136 §3 of Law 4251/2014) — private-insurance coverage minimums, fixed under the predecessor Code and still applied in practice, subject to confirmation; signed text via https://migration.gov.gr/wp-content/uploads/2020/05/ΚΥΑ53821_2014.pdf (accessed 2 August 2026). [^11-11]: Residence-permit insurance premium market data (reported band; not primary or official sources): insurancemarket.gr (lower bound, "από 68€ ετησίως"), https://www.insurancemarket.gr/asfalisi-allodapon-adeia-diamonis ; soeasyinsurance.gr (product mirroring the coverage minimums), https://soeasyinsurance.gr/immigration-medical/ ; the "about €300 per person" upper bound is published by mygoldenvisa.io, a golden-visa industry site, https://mygoldenvisa.io/blog/greece-golden-visa , and is carried as an indicative ceiling only, not as authority for premium levels; written quotations are required (all accessed 2 August 2026). [^11-12]: Published Greek certified-translation rates: Athens Translation Centre, https://athenstranslations.gr/en/rates ; WordHub, "How much does an official translation cost in Greece?", 10 April 2025, https://www.wordhub.gr/en/blog/official-translation-cost-greece (both accessed 2 August 2026). [^11-13]: United Kingdom, FCDO, "Get your document legalised" (published fee schedule), https://www.gov.uk/get-document-legalised (accessed 2 August 2026). [^11-14]: South Africa, DIRCO, Legalisation Services (public documents legalised without charge; private documents via notary and High Court Registrar), https://dirco.gov.za/legalisation-services/ ; corroboration: Docassist, https://www.docassist.co.za/cost-of-apostille-services-in-south-africa/ (both accessed 2 August 2026). [^11-15]: Regulation (EC) No 810/2009 (Visa Code), Article 16(1)–(2), consolidated version of 28 June 2024, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R0810-20240628 (accessed 2 August 2026). [^11-16]: São Tomé and Príncipe Citizenship by Investment Unit, "Financial Layout" (US$750 per-applicant charge for citizenship documents), official programme site on the government domain cip.gov.st, https://cip.gov.st/donation-to-the-national-transformation-fund (accessed 4 August 2026). [^11-17]: Regulation (EU) 2018/1806, Annex I, consolidated version of 30 December 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^11-18]: São Tomé and Príncipe Citizenship by Investment Unit, "Post-Approval Inclusion Fees" (official programme channel, read live: "Submission Fee (except newborns) $5,000"; spouse $10,000; each additional dependent $5,000; newborn child up to 1 year $500; stated to apply "exclusively to dependents added after the issuance of approval-in-principle"), https://cip.gov.st/post-approval-inclusion-fees (accessed 4 August 2026). [^11-19]: European Central Bank, euro foreign exchange reference rates (EUR/USD), daily series, rate of 3 August 2026 = 1.1535, https://www.ecb.europa.eu/stats/policy_and_exchange_rates/euro_reference_exchange_rates/html/eurofxref-graph-usd.en.html (accessed 4 August 2026). The report's €1 = US$1.15 is a planning assumption set below that reference rate; it is not a market rate and not a forecast (§10.2).