ESG Considerations in Citizenship by Investment Programs

Published: 4 April 2025

In a world where people and capital are more mobile than ever, Citizenship by Investment (CBI) programmes have become a gateway to global mobility and opportunity.

But as these schemes grow in popularity, so does the scrutiny surrounding them. That’s where Environmental, Social, and Governance (ESG) considerations come in.

ESG isn’t just a buzzword anymore—it’s a vital framework that ensures investment migration doesn’t just benefit the wealthy, but supports long-term, sustainable development for everyone involved.

In this article, we’ll explore how ESG principles are reshaping CBI programmes and why it matters more than ever.

What is ESG and Why Does It Matter for CBI?

Let’s start with the basics. ESG stands for:

• Environmental – How programmes impact the planet

• Social – How they contribute to the wellbeing of communities

• Governance – How they’re managed, including transparency and accountability

In the context of CBI, ESG considerations can turn a transactional process into a powerful tool for national development.

They help ensure that funds from new citizens are used in ways that are ethical, impactful, and future-focused.

Environmental: Investing in a Greener Future

One of the strongest arguments for ESG-aligned CBI programmes is their potential to support environmental resilience. Many small island nations vulnerable to climate change have used CBI funds to invest in sustainable infrastructure.

Take Dominica, for example. The country has built more than 2,000 hurricane-resistant homes, funded by CBI contributions. These homes aren’t just about shelter—they’re about helping communities survive and thrive in the face of natural disasters.

By directing CBI funds into renewable energy, conservation, and green construction, countries can build a more sustainable future—while offering investors the opportunity to support meaningful, eco-friendly change.

Social: Building Stronger Communities

CBI programmes also have the potential to make a real difference in people’s lives.

Funds are often used to improve public services like healthcare and education, as well as build affordable housing.

In Grenada, for instance, revenue from the programme has helped upgrade hospitals and schools. Similarly, Antigua & Barbuda has invested in new healthcare infrastructure and university facilities.

These are tangible benefits that help foster social stability and economic inclusion—creating a more equitable society for locals, and a more appealing environment for responsible investors.

Governance: Trust is Everything

Let’s be honest—CBI programmes haven’t always had the best reputation. That’s why strong governance and transparency are critical to their success.

Programmes that implement strict due diligence help protect national security and attract higher-quality applicants. Again, Dominica sets a strong example here: the government rejected over 800 applications between 2019 and mid-2024 due to concerns arising during the vetting process.

But it’s not just about who gets in—it’s about where the money goes. Clear reporting on how CBI funds are used builds trust with citizens and investors alike, and shows the programme is being run responsibly and ethically.

ESG in Action: Case Studies Worth Noting

A few countries are already setting the standard when it comes to ESG-led CBI.

• St. Kitts and Nevis has launched the Sustainable Island State Contribution Fund (SISC), which targets economic growth through seven strategic pillars—including health, education, and sustainable industries. It’s an innovative approach that integrates CBI funds into the country’s long-term development strategy.

• Dominica again shines as a case study, not just with climate-resilient housing, but also by fully financing a $320 million international airport through CBI contributions. This infrastructure boosts both tourism and economic opportunities for the local population.

These examples show how well-managed CBI programmes can serve both the interests of investors and the needs of the nation.

The Risks of Ignoring ESG

Of course, when ESG is ignored, the consequences can be serious.

A cautionary tale comes from Vanuatu, which lost its visa-free access to the EU due to concerns about weak screening processes in its CBI programme. The message is clear: without proper governance, even well-intentioned programmes can backfire—damaging a country’s reputation and hurting long-term viability.

Balancing economic gains with ESG values isn’t always easy, but it’s essential. Investors are increasingly prioritising ethical, responsible opportunities—and governments that align with those values will stay ahead of the curve.

Aligning with Global Standards

To future-proof their CBI initiatives, countries are beginning to align with international ESG frameworks, such as the United Nations Sustainable Development Goals (SDGs).

This creates a win-win: applicants gain access to global mobility while contributing to impactful national development. And countries gain a reputation for responsible leadership and sustainable growth, which attracts better investors.

Advisory firms and financial service providers (like us!) play a key role in this process—guiding investors toward programmes that align with their values and helping countries design policies that stand the test of time.

Final Thoughts

ESG considerations aren’t just a “nice to have” in today’s world—they’re essential to the long-term success of any CBI programme.

By integrating ESG into their core strategy, countries can ensure that citizenship by investment isn’t just about economic gain, but about building stronger, greener, and more inclusive societies.

For investors, it’s an opportunity to be part of something bigger—to gain global access while making a positive impact. For countries, it’s a chance to turn economic migration into a catalyst for lasting development.

As the world evolves, so too must investment migration—and ESG is leading the way.