REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the suspension of the visa exemption for nationals of Vanuatu
Date: 2024-05-31
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU visa policy, Schengen Agreement, Vanuatu, admission of aliens, agreement (EU), external border of the EU, foreign national, revision of an agreement, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 31.5.2024  COM(2024) 366 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the suspension of the visa exemption for nationals of Vanuatu  
 
 
1.  Introduction 

Investor  citizenship  schemes  (or  citizenship-by-investment/CBI  programmes,  also  commonly 
referred to as “golden passports”) run by third countries with visa-free access to the EU present a 
number of potential security risks for the EU and its Member States. In particular, these schemes 
can be used to bypass the regular EU short-stay visa procedure and the in-depth assessment of 
individual  migratory  and  security  risks  it  entails,  including  a  possible  evasion  of  measures  to 
prevent  money  laundering  and  financing  of  terrorism1.  This  is  especially  problematic  as  the 
passports  issued  to  beneficiaries  of  such  schemes  cannot  be  differentiated  from  other  ordinary 
passports.   

The  Commission  has  been  engaging  with  all  visa-free  countries  operating  investor  citizenship 
schemes with  a view to  preventing and mitigating possible security risks  for the EU2. Vanuatu 
has been the first – and so far, only – country for which the visa suspension mechanism has been 
activated,  based  on  the  public  policy  and  security  suspension  ground  of  Regulation  (EU) 
2018/1806 (the ‘Visa Regulation’) 3.  

Vanuatu  is  listed  in Annex  II  to  Regulation  (EU)  2018/1806  among  the  third  countries  whose 
nationals  are  exempt  from  the  requirement  to  be  in  possession  of  a  visa  when  crossing  the 
external borders of the Member States for stays of no more than 90 days in any 180-day period. 
The  exemption  from  the  visa  requirement  for  nationals  of Vanuatu  is  applicable  since  28  May 
2015,  when  the Agreement  between  the  European  Union  and  the  Republic  of  Vanuatu  on  the 
short-stay visa waiver (‘the Agreement’)4 was signed and started to apply. 

Since  25  May  2015,  Vanuatu  has  been  operating  investor  citizenship  schemes  allowing  visa-
required  third-country  nationals  to  easily  obtain    the  Vanuatu  citizenship  and  passport,  thus 
enabling them to  gain  visa-free  access  to  the EU, bypassing the Schengen visa procedure. The 
Commission started investigating Vanuatu’s citizenship schemes in 2017, as these raised serious 
concerns, including on account of failures in the security screening of applications.  

Based  on  the  assessment  of  the  relevant  data  and  information  collected,  the  Commission 
concluded  that  Vanuatu’s  investor  schemes  presented  serious  deficiencies  and  security  failures 
that had the potential to create a risk to the internal security of the EU and its Member States, and 
activated the suspension mechanism set out in Article 8 of the Visa Regulation.  

1   Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions  of  23  January  2019  on  Investor  Citizenship  and  Residence 
Schemes in the European Union (COM(2019) 12 final), p. 23. 

2   Report  from  the  Commission  to  the  European  Parliament  and  the  Council,  Sixth  Report  under  the  visa 

suspension mechanism, COM(2023) 730 final. 

3  Regulation  (EU)  2018/1806  of  the  European  Parliament  and  of  the  Council  of  14  November  2018  listing  the 
third  countries  whose  nationals  must  be  in  possession  of  visas  when  crossing  the  external  borders  and  those 
whose nationals are exempt from that requirement (OJ L 303, 28.11.2018, p. 39). 

4  Agreement between the European Union and the Republic of Vanuatu on the short-stay visa waiver (OJ L173, 

3.7.2015, p. 48). 

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The suspension has been articulated in three phases, as detailed below. The present report to the 
European Parliament and the Council describes in  detail  the different  phases of the suspension 
mechanism  and  the  dialogue  the  Commission  held  with  Vanuatu.  The  report  is  submitted  in 
compliance with Article 8(7) of the Visa Regulation. 

2.  Phase  1  –  activation  of  the  suspension  mechanism  (Article  8(6)(a)  of  the  Visa 

Regulation) 

Between 2017 and 2021, the Commission had a number of meetings and written exchanges with 
the authorities of Vanuatu to collect information on Vanuatu’s investor citizenship schemes5. In 
that context, the Commission expressed serious concerns and warned the government of Vanuatu 
of  the  possibility  of  the  visa  requirement  being  reintroduced.  These  concerns  were  related  in 
particular to: 

• 

• 

• 

• 

• 

the high number of passports issued to nationals that would otherwise have to apply for a 
visa  to  travel  to  the  EU  (more  than  10  000  between  2015  and  2021),  with  a  very  low 
rejection rate; 

the  absence  of  any  requirement  for  the  applicants  to  have  previously  resided  or  even 
visited  Vanuatu,  as  the  application  process  is  managed  by  specialised  agencies  located 
outside Vanuatu (e.g., in Dubai, Thailand, Malaysia, etc.) whereby the applicant does not 
need to have any direct contact with Vanuatu’s authorities; 

the absence of a requirement for a physical interview, reducing the opportunities for the 
authorities of Vanuatu to properly assess the applicant or to corroborate the information 
provided in the application, including its veracity and credibility;  

the  fact  that  the  schemes  were  commonly  advertised  as  a  way  to  by-pass  the  Schengen 
visa procedure and easily obtain visa-free access to the EU; 

the fact that the applications were processed within very short deadlines, not allowing for 
a proper security screening and exchange of information with the applicants’ country of 
origin or main past residence before the granting of the citizenship. Due to this, Vanuatu 
had granted citizenship to persons subject to  a criminal investigation,  including persons 
listed on Interpol’s databases6; 

• 

the  lax  legislation  on  name  changes,  as  successful  citizenship-by-investment  applicants 
can also apply for an identity change. 

5   As explained in detail in the Proposal for a Council Decision on the partial suspension of the application of the 
Agreement between the European Union and the Republic of Vanuatu on the short-stay visa waiver, COM(2022) 
6 final. 

6   In  particular,  in  July  2019,  it  came  to  the  Commission's  attention  that  applicants  had  been  granted  citizenship 
under  Vanuatu's  investor  citizenship  schemes  despite  them  being  listed  in  Interpol's  databases  and  that  some 
applicants  had  presented  forged  documents  (in  particular  forged  clean  criminal  records)  that  the  relevant 
authorities of Vanuatu failed to detect. 

2 

 
 
 
 
 
Furthermore,  Vanuatu  is  also  classified  as  potentially  posing  a  high  risk to  the  integrity  of  the 
Common  Reporting  Standard  by  OECD,  raising  suspicion  of  possible  tax  evasion  and  money 
laundering activities 7.  

As the explanations provided by Vanuatu in the above-mentioned exchanges were not sufficient 
to mitigate those concerns, the Commission decided that the increased risk to the public policy 
and internal security linked to the nationals of Vanuatu having obtained the citizenship under the 
investor  citizenship  schemes  could  be  mitigated  only  by  means  of  a  suspension  of  the  visa 
exemption. 

To this aim, the Commission adopted on 12 January 2022 a proposal for a Council decision8 to 
suspend  partially  the  visa  waiver  agreement  with  Vanuatu.  The  decision  was  adopted  by  the 
Council9 on 3 March 2022. 

In parallel, on 27 April 2022, the Commission adopted an implementing regulation10 having the 
effect of activating the suspension mechanism set out in Article 8 of the Visa Regulation, for a 
first period of nine months (4 May 2022 - 3 February 2023).  

Following  the  activation  of  the  suspension,  and  in  accordance  with  Article  8(6),  last  sub-
paragraph  of  the  Visa  Regulation,  the  Commission  engaged  in  an  enhanced  dialogue  with 
Vanuatu, with a view to identifying appropriate solutions which could remedy the circumstances 
having led to the temporary suspension of the visa exemption.  

In  the  kick-off  meeting  of  the  dialogue,  on  12  May  2022,  the  Commission  expressed  its 
willingness to find a solution and, to this end, proposed to hold monthly technical meetings. The 
parties agreed that the authorities of Vanuatu would appoint a contact point and communicate it 
to  the  Commission,  in  order  to  proceed  with  the  subsequent  technical  meetings.  Vanuatu 
informed the Commission of the decision of the Government of Vanuatu to set up a Task Force to 
review  the  investor  citizenship  schemes.  It  was  agreed  that  the  authorities  of  Vanuatu  would 
transmit to the Commission a progress report prepared by the Task Force. 

However,  Vanuatu  did  not  subsequently  engage  in  a  meaningful  way.  Vanuatu’s  investor 
citizenship schemes remained in operation, and the Commission, during this first phase did not 
receive any information  from  the authorities of Vanuatu  with  regard to  possible legislative and 
non-legislative  actions  aiming  to  remedy  the  circumstances  having  led  to  the  temporary 
suspension. 

7  https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/residence-citizenship-by-

investment/  

8   Proposal  for  a  Council  Decision  on  the  partial  suspension  of  the  application  of  the  Agreement  between  the 

European Union and the Republic of Vanuatu on the short-stay visa waiver (COM/2022/6 final). 

9   Council Decision (EU) 2022/366 of 3 March 2022 on the partial suspension of the application of the Agreement 
between the European Union and the Republic of Vanuatu on the short-stay visa waiver (OJ L 69, 4.3.2022, p. 
105).  

10   Commission Implementing Regulation (EU) 2022/693 of 27 April 2022 on the temporary suspension of the visa 

exemption for nationals of Vanuatu (OJ L 129, 3.5.2022, p. 18).  

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3.  Phase 2 – extension of the suspension (Article 8(6)(b) of the Visa Regulation) 

As the circumstances that led to the suspension persisted, the Commission adopted a delegated 
Regulation extending the suspension for a period of 18 months, until 3 August 202411. At the 
same time, the Council adopted a Decision on the full suspension12 of the Agreement.  

During this second suspension phase, the Commission continued the dialogue with Vanuatu, with 
four  meetings  held  between  February  2023  and  April  2024,  and  numerous  information 
exchanges in writing. 

The  first  of  these  meetings  took  place  on  15  February  2023,  where  Vanuatu’s  designated 
contact point for the enhanced  dialogue, the National Security  Advisor to the Prime Minister’s 
Office, informed the Commission of the policy and legislative measures put in place by Vanuatu 
to address the concerns of the Commission: new standards of procedures to manage the schemes, 
including  the  appointment  of  a  new  Head  of  the  Citizenship  Office;  the  reduction  and  better 
scrutiny  of  private  agents  handling  citizenship  applications  that  would  lead  to  the  direct 
termination  of  their  professional  license  in  case  of  malpractice;  and  draft  amendments  to  the 
Citizenship Act that would introduce a new stringent screening process. The Commission on this 
occasion asked to be provided with detailed explanations of these measures and how they would 
address the circumstances that led to the suspension. 

On  4  April  2023,  Vanuatu  submitted  to  the  Commission  the  Citizenship  Amendment  Act, 
adopted  on  21  March  2023.  The  main  novelty  introduced  by  this  new  legislation  is  the 
replacement of the institutions and procedures for the screening and due diligence checks of the 
applications.  In  particular,  the  previous  Internal  Screening  Committee  appointed  by  the  Prime 
Minister  has  been  replaced  by  three  institutions:  the  Vanuatu  Police  Force,  the  Financial 
Intelligence Unit and the Vanuatu Immigration Services. Those institutions carry out the checks, 
including  on  Interpol  databases,  and  report  to  the  Secretary  General  of  the  Citizenship 
Commission.  This  new  process  includes  the  automatic  banning  of  applicants  whose  names 
correspond to a hit in the Interpol database, the exclusion of applications submitted by citizens 
from  countries  placed  on  the  UN  sanctions  list,  and  the  extension  of  the  vetting  process  for  a 
period  of  14  to  a  maximum  of  30  days.  However,  Vanuatu  did  not  submit  any  accompanying 
document to explain the legislative changes and how they would address the circumstances that 
led to the suspension. 

On  13  July  2023,  the  second  meeting  of  this  phase  took  place,  during  which  the  Commission 
expressed to Vanuatu’s  representatives the need to receive a detailed explanation of  the  above-
mentioned Citizenship Amendment Act. In that context, the Commission expressed its concerns 
about the legislative changes, especially in relation to the methodology used for processing the 

11   Commission Delegated Regulation (EU) 2023/222 of 1 December 2022 on the temporary suspension of the visa 

exemption for all nationals of Vanuatu (OJ L 32, 3.2.2023, p. 1). 

12   Council Decision (EU) 2022/2198 of 8 November 2022 on the suspension in whole of the application of the 

Agreement between the European Union and the Republic of Vanuatu on the short-stay visa waiver (OJ L 292, 
11.11.2022, p. 47). 

4 

 
 
 
applications that did not sufficiently address the issues identified as risks for the internal security 
of Member States, such as the lack of exchange of information with the applicants’ countries of 
origin about criminal records and the origin of the funds. 

On  5  December  2023,  the  third  meeting  took  place.  Vanuatu  was  represented  by  a  newly 
designated  Contact  point,  the  Secretary-General  of  Vanuatu  Citizenship  Commission.  In  that 
context, the Commission  regretted that  the long  reaction time of the Vanuatu  authorities to  the 
Commission’s  requests  for  information  was  slowing  down  the  dialogue,  and  recalled  the 
approaching  legal  deadline  set  out  by  the  suspension  procedure  of  3  August  2024.  Hence, 
Vanuatu  was  invited  to  use  the  following  weeks  to  provide  the  missing  information  and 
explanation of the policy and legislative changes, for the Commission to conclude its assessment.  

Following the meeting, a list of follow-up questions were sent to Vanuatu on 15 December 2023 
with  a  one-month  deadline,  to  which Vanuatu  responded  only  on  22  March  2024,  with  replies 
that failed to convincingly address the concerns of the Commission. 

The  Commission  also  informed Vanuatu  on  the  newly  adopted  proposal  on  the  revision  of  the 
suspension  mechanism13,  which  introduces  the  operation  of  investor  citizenship  schemes  as  a 
new autonomous suspension ground, and on the ongoing legislative process.  

The fourth and last meeting of this phase took place on 5 April 2024 between the Commission 
and  the  Secretary  General  of  the  Vanuatu  Citizenship  Commission.  The  Commission  invited 
Vanuatu  to  clarify  and  elaborate  on  the  replies  submitted  on  22  March  2024  regarding  the 
screening  and  vetting  procedure,  the  independence  of  the  institutions  involved  in  the  schemes, 
and  the  impact  of  the  suspension  on  citizenship  applications  in  2022  and  2023.  The  existing 
concerns were not addressed adequately and several factual and statistical inconsistencies in the 
data previously provided to the Commission remained unanswered (see point ii under ‘Phase 3’ 
below).  At  that  point,  the  Commission  was  informed  by  Vanuatu’s  representatives  that 
possibilities  for  exchanges  at  technical  level  had  been  exhausted  and  that  Vanuatu  would 
consider outreach to the Commission at the political level. 

4.  Phase  3  –  Commission’s  final  assessment  and  proposal  to  terminate  the  visa 

exemption (Article 8(7) of the Visa Regulation)  

As set out in Article 8(7) of the Visa Regulation, before the end of the period of validity of the 
delegated act, the Commission has to submit a report to the European Parliament and to the 
Council with its final assessment, which may be accompanied by a legislative proposal to amend 
the Regulation in order to transfer the reference to the third country concerned from  the list of 
visa-free countries to the list of visa-required countries.  

The present report is submitted in compliance with this requirement, with the Commission’s final 
assessment presented in detail below. 

13   Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2018/1806 

as regards the revision of the suspension mechanism, COM/2023/642 final. 

5 

 
 
 
i.  Economic reliance on the schemes 

Before  the  suspension,  Vanuatu’s  economy  heavily  relied  on  the  revenues  generated  from 
the investor citizenship schemes (i.e., 33% of total revenues in 2020 and 2021,14 or 12.3% of 
the GDP in 2020 and 10.2% in 2021). The introduction of the visa waiver suspension, in 2022, 
triggered a decline in revenue collected under the schemes of 27%(15) leading the schemes to 
account for about half of what they amounted to in 2021 in terms of GDP, i.e., 5.3% in 2022 and 
5.5% in 2023. 

ii. 

Statistics: applications received, passports issued, and rejection rate 

Statistics  show  a  high  number  of  successful  applicants,  with  the  vast  majority  from 
nationalities that would otherwise require a visa to enter the EU. Table 1 below shows statistics 
received from Vanuatu’s authorities concerning the period 2015 until 2021.  

Statistics 2015 - 2021 

Total applications received  

14 504 between 2015 and 2021 

Total number of citizenships 
awarded  

13 489 between 2015 and 2021 

Total passports issued 

10524 between 2015 and 2021  

Rejections/citizenship 
revoked 

1 015 (Rate ~9.6%) between 2015 and 2021 

Successful applicants – main 
nationalities 

China (6 628), Nigeria (430), Libya (292), Iraq (276), 

Syria (276), Russia (247), Lebanon (222), Iran (154), 

Republic of Korea (88), Yemen (74), Sudan (29) 

Table 1: Vanuatu’s statistics submitted in January 2022 related to the period 2015-2021 

However,  there  are  numerous  inconsistencies  in  the  data  submitted  by  Vanuatu  to  the 
Commission over the years.  

Statistics  on  the  number  of  successful  applications  shows  discrepancies.  Data  received  from 
Vanuatu  in  2020  indicated  around  4  000  as  the  total  number  of  successful  applications  for  the 
period  2015  -  August  2020,  while  the  above-mentioned  statistics  from  2022  indicate  a  total  of 
around 13 500 citizenships awarded. Similarly, the number of applications refused and revoked 
provided  in  2022  (1  015)  differs  from  previous  statistics  (submitted  in  2020),  which  indicated 
that the number of applications refused for the period 2015 – August 2020 was only one, while 
15 citizenships granted were subsequently revoked.  

As regards statistics concerning the years 2021-2023, Vanuatu provided different sets of data on 
three  different  occasions.  On  12  July  2023,  Vanuatu  indicated  682  as  the  total  number  of 
applications  received  in  2022  and  676  as  total  number  of  applications  received  in  the  first  six 
months  of  2023.  On  23  October  2023,  Vanuatu  provided  data  that  seemed  to  show  that  the 

14  Vanuatu: 2023 Article IV Consultation-Press Release; Staff Report; and Statement by the Executive Director for 

Vanuatu (imf.org), International Monetary Fund, Country Report No. 23/115, March 2023 

15  Ibid. 

6 

 
 
 
 
 
number  of  successful  applicants  dropped  drastically  in  the  last  three  years  compared  to  the 
previous years: (144 in 2021, 127 in 2022, 130 in 2023). However, on 23 March 2024, following 
the reiterated request of the Commission to provide clear and consistent statistics, Vanuatu sent 
yet another different set of data, indicating 1072 total applications received in 2021, 875 in 2022, 
and 1113 in 2023, with respectively 4, 5 and 22 rejections.  

These  inconsistencies,  besides  making  the  data  provided  difficult  to  assess  and  compare,  also 
indicate  a  general  lack  of  reliability  in  the  internal  control  process  of  the  schemes  by  the 
competent authorities of Vanuatu. 

iii.  Amendment of the Citizenship Act 
In March 2023, Vanuatu  introduced an  amendment  to  its  Citizenship Act16, aiming to  mitigate 
the risks identified by the Commission. The main changes introduced are the following: 

-  Screening  of  the  applications  and  due  diligence  checks  are  now  carried  out  by  three 
institutions:  i)  Vanuatu  Police  Force,  ii)  Financial  Intelligence  Unit  (FIU)  and  iii) 
Immigration Services who refer to the Secretary General and replace the Internal Screening 
Committee appointed by the Prime Minister17; 

-  Applications from applicants listed on the Interpol database are refused; 

-  The duration of the screening procedure by the three institutions should not take more than 

14 days and, in any case, if more time is needed, it should not take more than 30 days; 

-  Applications submitted by citizens from a list of ‘restricted countries’ or countries included 

under (unspecified) UN sanctions lists are disregarded; 

-  The deadline for a decision on whether to grant citizenship by the Citizenship Commission is 

set in three months. 

The impact that these changes have had in view of remedying the circumstances that led to the 
suspension are addressed in the sections below. 

iv. 

Sensitive and banned nationalities  

As  shown  in  Table  1,  the  countries  of  origin  of  successful  applicants  mostly  include  countries 
whose nationals must be in possession of visas when crossing the external borders of the Union.  

In 2023, Vanuatu introduced a legislative change aiming to restrict the possibility for nationals of 
some countries to apply for its citizenship. In particular, the amended Citizenship Act establishes 
that the Citizenship Commission must not accept an application if that applicant is a resident or 
citizen of a country that has been listed by the Citizenship Commission as a restricted country or 

16   Amendment n.1 of 2023 of the Citizenship Act (CAP 112), published on the Official Gazette of the Republic of 

Vanuatu on 21 March 2023. 

17  The Internal Screening Committee consisted of the Secretary general as the Chairperson, the Compliance Officer 
of the Citizenship office; the Director of Immigration Services, the Principal Passport Officer, one legal officer 
from  the  State  Law  Office  nominated  by  the  Attorney  general  and  a  Police  Officer  nominated  by  the 
Commissioner of Police. 

7 

 
 
 
listed  under  an  unspecified  list  of  United  Nations  sanctioned  countries  (such  as  Yemen,  Syria, 
Sudan,  North  Korea  and  Iran)18,  unless  the  applicants  show  that  they  have  not  resided  in  the 
restricted country for the last 5 years and provide evidence of permanent  residency abroad. As 
Russia and Belarus are not part of these lists, Vanuatu has continued accepting Russian and 
Belarusian applicants also after the Russian aggression against Ukraine.  

v.  Fees 

According to the latest information provided, four investment options are currently available in 
Vanuatu19.  Vanuatu’s  investor  citizenship  schemes  are  among  the  cheapest  in  the  world  for 
individual investors and families (for a single applicant the fee amounts to USD 130 000). The 
fee  per  person  strongly  decreases  according  to  the  number  of  applicants  under  the  same 
application (USD 180 000 for a married couple with two children). 20  

During  the dialogue, Vanuatu  has not shown any concrete intention to  increase the investment 
fees as a possible way to reduce the number of citizenships granted. 

vi.  Residence requirements 

Residence or physical presence in Vanuatu is not required before citizenship is granted, or even 
during  the  application  process.  In  March  2024,  Vanuatu  informed  the  Commission  of  ongoing 
interinstitutional  discussions  to  ‘address’  the  issue  of  residence  requirements.  However,  no 
further  information  has  been  submitted  on  the  content  and  timeline  of  possible  legislative 
amendments.  

vii.  Application process  

The programme is administered by the Citizenship Office. The office neither interacts with the 
applicants nor with the country of origin. Interested investors submit their applications through 
designated agents, who are solely responsible for all interaction with the applicants. Agents must 
be  Vanuatu  citizens  (citizenship  must  not  be  acquired  through  the  investor  schemes)  and  have 
their main registered office in Port Vila, Vanuatu. They are required not to sell below or above 
the set price by law, and they are not remunerated for marketing the schemes. Vanuatu provided 
to the Commission a list of 71 designated agents. In April 2024, the official website of Vanuatu’s 
Citizenship’s Office included a list of 60 designated agents. 21  

Agents are also in charge of marketing and promotion of the schemes. Most of them, on their 
websites,  have  been  promoting  Vanuatu’s  schemes  as  allowing  visa-free  entry  to  the  EU,  as 
providing a faster application process compared to other schemes, and explicitly mentioning the 
possibility  to  change  name  after  acquiring  the  citizenship.  Agents  participate  partly  in 
processing applications. They carry out the first stage of due diligence checks of applications 
before  submitting  them  to  the  Citizenship  office,  which  then  transmits  them  to  the  three 
institutions for clearance and due diligence checks.  

18   According to the statistics provided by Vanuatu’s authorities for the period 2016-2021, nationals from the five 
restricted countries applied and obtained Vanuatu’s citizenship. Syria (276), Iran (154), Republic of Korea (88), 
Yemen (74) Sudan (29). 

19   Development  Support  Program  (DSP), Vanuatu  Contribution  Program  (VCP),  Capital  Investment  Immigration 

Plan (CIIP), Real Estate Option Program (REO). 

20   https://vancitizenship.gov.vu/index.php/citizenship/fees-and-charges  
21  https://vancitizenship.gov.vu/index.php/about-us/designated-agents 

8 

 
 
 
viii. 

Screening/vetting procedures  

After receiving the applications from the agents, the Citizenship Office checks each applicant’s 
documents  against  a  checklist  before  they  are  submitted  to  the  decision  body  (the  Citizenship 
Commission).  

As  mentioned  above,  Vanuatu  adopted  a  number  of  legislative  changes  in  2023,  though  it  has 
failed to provide satisfactory proof that these changes are being implemented and are sufficient 
to  mitigate  the  security  risks  of  its  investor  schemes.  As  mentioned  above,  the  amendments 
introduce a new screening process, with a Screening committee consisting of three institutions: 
i)  the  Vanuatu  Police  Force,  ii)  the  Financial  Intelligence  Unit  (FIU)  and  iii)  the  Immigration 
Services,  which  amongst  others  check  the  applicants’  details  against  Interpol  and  other 
international databases. The vetting process is also extended for a period from 14 to a maximum 
of 30 days. 

While on the one hand this new procedure appears to mitigate the risk of granting the citizenship 
to  persons  who  are  listed  in  Interpol  databases,  on  the  other  hand  it  does  not  include  other 
necessary  elements  to  properly  assess  the  absence  of  security  risks  of  the  applicants.  In 
particular, there are no adequate means for the authorities of Vanuatu to verify the veracity 
of the documents issued by the applicant’s country of origin or residence, including identity 
documents  and  criminal  records,  since  these  authorities  do  not  exchange  information  with  the 
applicants’ country of origin or residence. 

During  the  dialogue,  Vanuatu  merely  indicated  the  references  to  the  legislative  changes, 
without providing sufficient accompanying explanation and  information on the reliability 
and  robustness  of  this  screening  process.  It  is  therefore  not  possible  for  the  Commission  to 
assess  whether  the  security  risks  flagged  at  the  time  of  the  suspension  decision  have  been 
mitigated by these changes.  

Furthermore,  contrary  to  other  third  countries  operating  investor  citizenship  schemes,  Vanuatu 
does not seem to rely on international due diligence firms for identity, reputational and security 
screening.  This,  coupled  with  the  fact  the  Vanuatu’s  authorities  have  no  contacts  with  the 
authorities of the countries of origin of the applicants, makes it  highly unlikely that Vanuatu is 
able  to  thoroughly  assess  the  authenticity  and  veracity  of  the  applicants’  documents  and 
information. 

ix.  Name change 

Before  2021,  persons  who  acquired  the  citizenship  of  Vanuatu  through  an  investor  citizenship 
programme  could  also  subsequently  apply  for  an  identity  change  in  Vanuatu.  During  the 
dialogue,  Vanuatu  informed  the  Commission  that  in  2021  the  relevant  legislation  the  Civil 
Registration Act 28 of 2021 under section 24(1A) was amended providing that persons holding 
dual citizenship could not have a change of name registered in Vanuatu. However, Vanuatu also 
informed  the  Commission  that  it  does  not  hold  any  records  of  the  name  changes  that  were 
registered  until  2019,  so  it  could  not  provide  any  information  on  the  number  of  persons  who 
acquired  the  citizenship  through  investment  and  subsequently  changed  their  name,  or  on  any 
follow-up checks on those persons. 

x.  Commission of enquiry - review of passports granted under the previous screening 

process 

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In February 2023, Vanuatu  established a Commission of enquiry tasked with  investigating any 
alleged wrongdoings committed during the operation of the schemes since their establishment. In 
April 2024, Vanuatu informed that the Commission of enquiry’s investigation were still ongoing 
and that it could not provide a clear date on the delivery of its findings. 

Furthermore,  Vanuatu has  not implemented any structural  ex-post monitoring mechanism 
to address the potential security loopholes of the more than 10 000 passports issued before the 
change of legislation  and allegedly  more robust  screening procedure. While Vanuatu  informed 
the Commission that, based on case law, it is  possible to revoke the citizenship where this has 
been obtained with fraud or against the law, it has not provided information on actual cases of 
revocation  of  citizenship  acquired  through  the  investor  schemes.  The  fact  remains  that  the 
existing  volume  of  passports  issued  under  the  citizenship  scheme  since  2015,  under  the  same 
conditions that made possible the issuance of passports to individuals that should not have been 
granted  the  citizenship  due  to  their  Interpol  listing  and  falsified  applications  continue  to 
constitute a potential risk or threat to the security of the Member States.   

5.  Conclusion 

In  light  of  the  above  updated  assessment,  the  Commission  considers  that  Vanuatu  has  not 
provided  satisfactory  remedies  to  the  circumstances  that  led  to  the  suspension  of  the  visa 
exemption.  In  particular,  the  quality  of  the  responses  to  the  Commission’s  requests  and  the 
numerous  inconsistencies  in  the  data  provided,  as  well  as  the  lack  of  sufficient  explanations 
regarding the new legislation and its implementation, led the Commission to the conclusion that 
the  operation  by  Vanuatu  of  investor  citizenship  schemes  would  continue  to  pose  substantial 
risks  to  the  public  policy  and  internal  security  of  the  Member  States  if  holders  of  Vanuatu’s 
passports would be able to resume visa-free travel to the EU. 

Therefore, in accordance with Article 8(7) of the Visa Regulation, the Commission has decided 
to  propose  an  amendment  to  that  Regulation,  transferring  Vanuatu  from  the  list  of  visa-free 
countries  to  the  list  of  visa-required  countries22.  To  allow  the  necessary  time  for  the  European 
Parliament  and  the  Council  to  examine  the  Commission  proposal,  the  Commission  has  also 
extended the period of suspension of the visa exemption by six months23, until 3 February 2025. 

22   Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2018/1806 

as regards Vanuatu, COM(2024)365. 

23   Commission Delegated Regulation (EU) …/… amending Regulation (EU) 2018/1806 as regards the extension of 

the temporary suspension of the visa exemption for nationals of Vanuatu, C(2024)3650. 

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