Croatia has no citizenship-by-investment program. No sum of money, property purchase, or company formation entitles a foreign investor to a Croatian passport. Online articles, often produced to attract clients, nevertheless claim otherwise. They describe a "program launched in 2019" or a minimum investment of EUR 200,000 in a company with at least ten employees, or they speak of a "golden passport" and list all sorts of conditions for obtaining one. Unfortunately, many of our clients come to us wishing to apply for Croatian citizenship based on such an investment, relying on this incorrect information. This is precisely why we have prepared this expert legal article: to dispel the myth and provide accurate information on the subject.
The Croatian Citizenship Act does not allow citizenship to be acquired based on investment. The Ministry of Foreign and European Affairs states this expressly in its consular information: Croatia does not grant citizenship based on investment or on ownership of real estate.
The only provision sometimes misread as an "investment route" is Article 12 of the Act. Under it, a foreigner whose admission to citizenship would be in the interest of the Republic of Croatia may acquire citizenship even without meeting the ordinary naturalization requirements. This is an exceptional, discretionary ground. It sets no investment threshold, confers no right to a positive decision and is not a publicly available programme. In practice, it applies mainly to athletes, artists, and others whose contribution to the state has been specifically established. During earlier legislative amendments, the Ministry of the Interior expressly stated that it did not intend to amend Article 12 to ease the acquisition of citizenship for foreigners whose sole motive is investment.
The Administrative Court in Rijeka confirmed in judgment 2 Us I-2113/2023-15 of 16 January 2024 that even a successful business in Croatia does not open the way to citizenship. The Ministry of the Interior had refused an application for Croatian citizenship on grounds of special state interest. The applicant was a foreign national who co-owned a tourism company that had run a travel portal with more than 100,000 monthly visitors for four years. The Ministry of Tourism and Sport checked his claims and requested a statement from the Croatian National Tourist Board. It concluded that it could not establish beyond doubt an interest of the Republic of Croatia. It stressed that the court must establish the state's interest, not the applicant's personal interest. The court dismissed the claim. It held that Article 12 is the most privileged form of naturalization, which gives a foreigner no subjective right and involves a very high degree of administrative discretion. The threshold of an interest beyond doubt is very strict, and the business activities described did not meet it. The court added that a foreigner does not need Croatian citizenship to reside, work, and do business in Croatia.
More generally, acquiring citizenship in this way would not be permissible in EU Member States today. On 29 April 2025, in Case C-181/23, European Commission v Republic of Malta (OJ C/2025/3238), the Court of Justice of the European Union, sitting as the Grand Chamber, held that Malta's "golden passport" scheme breached EU law. The Court found that Union citizenship cannot be acquired through a commercial transaction. Granting nationality in exchange for predetermined payments or investments, without a genuine link to the state, infringes Article 20 TFEU and the principle of sincere cooperation under Article 4(3) TEU. The case concerned Malta's "Citizenship by Naturalization for Exceptional Services by Direct Investment" scheme, introduced in 2020 under Article 10(9) of the Maltese Citizenship Act and the accompanying regulations. In the operative part of the judgment, the Court declared that by establishing and operating such an institutionalized scheme, Malta had commercialized the grant of a Member State nationality and, by extension, Union citizenship—the scheme provided a transactional naturalization procedure in exchange for predetermined payments or investments. Malta thereby failed to fulfill its obligations under Article 20 TFEU and Article 4(3) TEU, and the Court ordered it to pay the costs.
The judgment matters for Croatia too. Granting nationality remains a competence of the Member States, but they must exercise it in compliance with EU law. Any future investment scheme modeled on Malta's would face the same objection. Investing in Croatia may therefore help regularise a foreigner's residence, for example for work or business. Citizenship can then be acquired only through the ordinary route, once the statutory conditions are met.
We caution that services promising "fast" or "guaranteed" Croatian citizenship for a fee have no legal basis. Before making any payment or investment for that purpose, we recommend consulting a lawyer who practices citizenship law.


