Introduction
The Egyptian Citizenship by Investment Program has become one of the routes used by the State to attract foreign capital and link the granting of nationality to investment or direct cash inflows into the Egyptian economy. The program has passed through several legislative and regulatory stages since the introduction of the naturalization system linked to investment, before 2023 witnessed the most significant amendments that shaped its current form.
As for 2025, based on the legislative framework and general decisions that could be verified, it did not witness any new reduction in the financial thresholds or the introduction of new investment routes comparable to those introduced in 2023. Rather, the year saw the continued implementation of the program and the issuance of actual decisions granting nationality to a number of applicants after their applications had been examined by the Citizenship Applications Examination Unit.
This study reviews the legal status of the program as applied during 2025 and still in force through September 2026, while explaining the four routes, application procedures, and the most important legal and financial risks that investors should consider before selecting the appropriate route.
The Legal Framework of the Citizenship by Investment Program
The program is not based on a single administrative decision, but rather on an integrated legislative framework headed by Egyptian Nationality Law No. 26 of 1975, as amended.
Law No. 140 of 2019 was one of the key milestones in establishing the modern form of the program. It replaced Article 4 bis of the Nationality Law and authorized the Prime Minister – upon recommendation of the Citizenship Applications Examination Unit – to grant Egyptian nationality to a foreign national who purchases real estate, establishes an investment project, deposits a sum of money in foreign currency as direct revenue to the State Treasury, or places a deposit in a special account with the Central Bank of Egypt, in accordance with the rules issued by decision of the Prime Minister.
Prime Ministerial Decree No. 3099 of 2019 was then issued to regulate the investment cases, followed by Decree No. 647 of 2020 regulating the work of the Citizenship Applications Examination Unit and the procedures for submission and examination of applications.
In 2023, a highly significant package of amendments was issued, particularly Law No. 28 of 2023 and Prime Ministerial Decrees Nos. 876 and 3562 of 2023. These measures established most of the financial thresholds and procedures currently governing the program.
What Actually Changed in 2023?
It is important to correct a common perception that the main facilitations appeared in 2024 or 2025. The fundamental transformation occurred during 2023.
In March 2023, Prime Ministerial Decree No. 876 of 2023 was issued, reducing a number of the financial thresholds required under the investment programs.
Then, in May of the same year, Law No. 28 of 2023 was issued and removed from Article 4 bis the restriction requiring the property to be owned by the State or by a public legal person. As a result, the statutory provision came, in principle, to permit the purchase of real estate without limiting its source to the State, thereby opening the route to privately owned properties where the requirements of the program and the legal rules governing ownership are satisfied.
In September 2023, Prime Ministerial Decree No. 3562 of 2023 aligned the executive framework with this amendment. The wording governing the real estate route became simply “purchase of real estate,” without the previous restriction concerning State ownership, and the Decree also introduced documents and requirements for proving the property and the investment.
The Four Current Routes to Citizenship by Investment
First: Direct Revenue to the State Treasury – USD 250,000
An applicant for naturalization may deposit USD 250,000 as direct revenue in foreign currency accruing to the State Treasury on a non-refundable basis.
This route requires the lowest amount among the citizenship-by-investment programs, but it does not create an investment asset that can later be sold by the investor, because the amount becomes final revenue to the State Treasury.
The USD 250,000 may be paid in installments over a period not exceeding one year, and nationality is not granted before full payment of the amount.
Second: Purchase of Real Estate Valued at No Less Than USD 300,000
The real estate route allows the purchase of property for an amount of no less than USD 300,000, provided that the investment value is brought into Egypt in foreign currency in accordance with the applicable rules.
The real estate investment amount may be paid in installments over a period not exceeding one year, provided that the decision granting nationality is not issued before completion of the required amount.
The current documents issued by the Citizenship Applications Examination Unit indicate that the property may be purchased from the State or the private sector, subject to satisfaction of the legal documents required for the property, including matters relating to the purchase contract, licensing, the legal status of the property, and proof of the source and transfer of the investment value.
In this route, merely signing a sale contract for USD 300,000 is not sufficient. The investor must be able to establish the validity of the transaction, the legality of the property, and payment of the price through a method accepted by the Unit.
Third: Establishment of or Participation in an Investment Project
A foreign national may establish an investment project or participate in an existing project with an amount of no less than USD 350,000, transferred from abroad in accordance with the applicable rules, together with an additional deposit of USD 100,000 as direct non-refundable revenue to the State Treasury.
Accordingly, the minimum total financial commitment under this route is USD 450,000, of which USD 350,000 is invested in the project and USD 100,000 constitutes a non-refundable contribution to the State Treasury.
The project is subject to Investment Law No. 72 of 2017 and the related incorporation, operation, and licensing rules depending on the nature of the activity.
Fourth: Cash Deposit of USD 500,000
The program allows a deposit of USD 500,000 into a special account with the Central Bank of Egypt for a period of three years.
The deposit is refunded after expiry of that period in Egyptian pounds at the exchange rate announced by the Central Bank at the time of repayment, without interest.
Accordingly, the investor must carefully assess exchange-rate risk. Although the deposit is refundable in principle, it is not a USD-denominated investment with a guaranteed value at the end of the period, nor does it generate a return during the three years.
Citizenship Application Review Fee: USD 10,000
Regardless of the investment program selected by the applicant, the naturalization applicant must pay a non-refundable fee of USD 10,000 or its equivalent in foreign currencies in accordance with the applicable payment rules.
This fee is separate from the foregoing investment amounts. Selecting the USD 250,000 route, for example, means that the program amount is payable in addition to the application review fee.
Law No. 28 of 2023 amended the mechanism for payment of this fee, allowing the amount to be brought in from abroad or proving its entry through customs points and subsequently depositing it in accordance with the prescribed rules.
Purchase from the Private Sector: A 2023 Amendment, Not 2024
Some writings stated that the ability to purchase properties from developers and the private sector began through amendments issued in October 2024.
Legally, the more accurate position is that the legislative basis for this development dates back to Law No. 28 of 2023, which removed from Article 4 bis the wording restricting purchases to properties owned by the State or public legal persons.
Decree No. 3562 of 2023 subsequently replaced the previous executive wording with the general expression “purchase of real estate.”
Accordingly, reliance may be placed on privately owned property where both the property and investor satisfy the applicable legal and documentary requirements.
Must the Property Be Registered with the Real Estate Registration Office?
This point requires precise wording.
The instructions and documents governing the real estate route require evidence of the legal status of the property. Decree No. 3562 of 2023 included among the required documents evidence that the property is registered with the Real Estate Registration Office or subject to the supervision of one of the State-owned authorities exercising jurisdiction over the property.
Accordingly, it is incorrect to establish an absolute rule that every property must have final registration with the Real Estate Registration Office. Conversely, it is also incorrect to assume that a mere preliminary contract unsupported by any recognized legal status is automatically sufficient.
This is one of the most important legal due diligence issues to be examined before purchasing property for citizenship purposes.
The Five-Year Property Holding Requirement
The real estate route imposes an important consequence that should be considered from the outset of the investment.
If the naturalized person disposes of the property before five years have elapsed from the date of acquiring it, retaining Egyptian nationality requires the deposit of USD 250,000 as direct non-refundable revenue to the State Treasury.
Accordingly, selling the property before the end of the five-year period does not mean that nationality is automatically withdrawn at that exact moment. The system provides a specified financial alternative for retaining nationality.
However, early disposal may in practice make the real estate route substantially more expensive than the investor originally planned. Accordingly, the intended property holding period should be assessed before selecting this route.
The Investment Project Is Also Subject to a Five-Year Restriction
The issue is not limited to real estate.
If the naturalized person liquidates, suspends, or disposes of the investment project or the person’s share therein before five years have elapsed from the date of its operation, retaining nationality likewise requires the deposit of USD 250,000 as direct non-refundable revenue to the State Treasury.
This makes the investment-project route principally suitable for persons who have a genuine project and a medium- or long-term operating plan, rather than those seeking to create a temporary entity merely to complete citizenship procedures and then exit it quickly.
Joint Ownership of Property: Generalization Should Be Avoided
During 2024 and 2025, some sources circulated information suggesting that more than one citizenship applicant could share ownership of a single property, provided that each person’s share amounted to USD 300,000.
However, upon reviewing the general officially published provisions and the current pages of the Citizenship Applications Examination Unit, the confirmed rule that can be relied upon is that an applicant under the real estate route must establish a qualifying real estate investment of no less than USD 300,000.
Accordingly, we do not recommend structuring a multi-buyer transaction specifically for the purpose of acquiring nationality before obtaining official confirmation from the Unit regarding acceptance of the ownership structure, the value of each applicant’s share, and the method of documenting it.
Is a Personal Bank Account in Egypt Required?
This requirement should not be generalized to all cases under the program without reference to the instructions governing the specific transaction.
The fundamental rule under the governing provisions is the ability to establish that funds entered Egypt from abroad in accordance with Central Bank rules, or that they entered through a customs point and were declared and subsequently deposited in accordance with legal procedures.
The detailed banking implementation may vary depending on the type of investment, the selling entity, and the bank used. It should therefore be determined before transferring funds to avoid difficulties in proving that the amount satisfies the requirements of the program.
Steps for Obtaining Nationality
1. Preparing the Application and Documents
The file begins with completion of the naturalization application and preparation of the required documents, which, according to the Unit’s current guide, include the passport, birth certificate, personal photographs, information on other nationalities, details of the spouse and children, criminal record, movement certificates, medical examination, and other documents required by the Unit.
The Unit provides a location for receiving citizenship applicants, and there is also a system of accredited intermediaries. The Nationality Law also permits submission of applications through electronic mechanisms made available under the legislation.
2. Payment of the Application Fee
The USD 10,000 fee is paid in accordance with the Unit’s instructions before the application review is completed.
3. Preliminary Examination
The current official procedures state that the Citizenship Applications Examination Unit examines the application and issues a preliminary determination within a period ranging from three to six months from the date on which the application is fully completed.
The examination is conducted in light of national security considerations and after consultation with the competent security authorities.
Accordingly, the period does not in practice begin from the applicant’s first contact with the Unit if the file is incomplete, but is linked to completion of the required information and documents.
4. Temporary Six-Month Residence to Implement the Program
Upon issuance of preliminary approval, the applicant is granted the right to temporary residence in Egypt for six months to complete actual implementation of the selected investment route.
During this period, the applicant submits evidence of the property purchase, implementation of the project and payment of the required commitments, or placement of the deposit or direct revenue, depending on the selected program.
5. Final Decision
After completion of the investment program and submission of the required information and documents, the Citizenship Applications Examination Unit completes its review and submits its recommendation to the Prime Minister in light of national security considerations.
The official guide states that the final decision is issued within a maximum period of three months from the date on which the program, information, and required documents have been fully completed.
Does the Process Take 6 to 12 Months?
The official website of the Citizenship Applications Examination Unit indicates an estimated timeframe ranging from 6 to 12 months.
However, this period should be understood together with the preceding stages. Preliminary examination depends on completion of the file, followed by the program implementation stage and then final review.
Accordingly, investors can reduce delays attributable to them by submitting a complete file, preparing the financial transfer route in advance, and conducting legal due diligence on the property or project before linking it to the citizenship application.
Is the Program Open to All Nationalities?
The official FAQs published by the Citizenship Applications Examination Unit state that persons of all nationalities may apply to the program.
However, approval remains subject to legal and security screening, and nationality does not arise merely because the required financial amount is available.
Accordingly, investment represents one of the conditions of the legal route to nationality, rather than an automatic purchase of nationality.
Are Arabic Language Tests Required?
According to the officially published FAQs, the Citizenship by Investment Program does not impose an Arabic-language test on the naturalization applicant.
This distinguishes this route from certain ordinary naturalization cases in which the Law requires knowledge of the Arabic language.
Do the Spouse and Children Automatically Obtain Nationality?
The common statement that “nationality automatically includes the investor, the investor’s spouse, and children” requires correction.
The position is more nuanced.
Minor children: Article 6 of the Nationality Law regulates the effects of naturalization of the father or mother on minor children. The 2023 amendment expanded the rule to include the children of a foreign woman who acquires Egyptian nationality, while taking into account cases where ordinary residence is abroad and the original nationality is retained under the applicable law.
The wife: A wife does not automatically acquire Egyptian nationality merely because her husband becomes naturalized. Article 6 instead establishes an independent route based on notification of her desire to acquire nationality and continuation of the marriage for two years, subject to the possibility of a reasoned decision depriving her of acquisition.
The foreign husband of a woman who becomes naturalized as Egyptian: The Law does not provide an equivalent route making him Egyptian automatically through his wife.
Accordingly, the legal status of each family member must be examined separately.
Acquired Nationality Does Not Mean Immediate Enjoyment of All Political Rights
One point rarely mentioned in promotional material concerning the program is that Article 4 bis of the Nationality Law provides for application of the provisions contained in Article 9 to persons who acquire nationality through investment.
Under Article 9, a foreign national who acquires Egyptian nationality may not exercise political rights until five years have elapsed from the date of acquisition, and may not be elected or appointed as a member of a representative body until ten years have elapsed, unless an exemption is granted in the cases permitted by law.
Accordingly, describing the nationality as “fully effective immediately upon issuance” requires qualification by this important statutory restriction.
Sector-Specific Restrictions May Also Apply to Naturalized Persons
Acquisition of nationality removes the person from the legal status of a foreign national in many matters, but it does not automatically eliminate every special condition contained in other legislation.
Certain activities, geographical areas, or legal statuses may impose special conditions relating to the period elapsed since naturalization, dual nationality, or the nature of the activity.
Accordingly, an investor planning to enter a regulated activity – rather than merely obtain nationality – should examine the legislation governing that activity independently.
Dual Nationality
The Egyptian legal system permits, in principle, the holding of more than one nationality, and the Citizenship Applications Examination Unit states that acquisition of Egyptian nationality through investment does not in itself require relinquishment of the original nationality.
However, investors should review the law of their country of origin, because certain States do not permit dual nationality or impose specific conditions for retaining it.
Risks of the Real Estate Route That Should Be Examined Before Purchase
The real estate route may be attractive because it combines nationality with retention of an investment asset, but it requires careful legal due diligence before contracting.
The following should be reviewed:
- The seller’s ownership and title to dispose of the property.
- The legal status of the land and property.
- The building permit, where required.
- The area and unit corresponding to the contract.
- The existence of mortgages, attachments, or disputes.
- The developer’s authority to dispose of the property.
- The status of the project before the relevant land authority.
- The method of payment and proof of transfer in foreign currency.
- The ability to retain the property for five years without adversely affecting the investor’s financial plan.
Risks of the Cash Deposit
The principal advantage of the deposit is that it is not linked to operation of a project or fluctuations in the real estate market, but it carries a different type of risk.
The amount remains frozen for three years without return and is then repaid in Egyptian pounds at the exchange rate applicable at the time of repayment.
Accordingly, the opportunity cost and currency risk should be compared with the benefits the investor obtains from this route.
Risks of the Investment Project Route
The project is not merely a formal means of satisfying a citizenship condition. It must operate under the Investment Law and remain in existence in accordance with the applicable restrictions.
The investor should examine:
- The legal form of the company.
- The nature of the activity and required licenses.
- Taxation and employment matters.
- Partners and ownership percentages.
- Exit mechanisms and sale of the ownership interest.
- The effect of suspension or liquidation during the first five years on the investor’s nationality status.
What Happened During 2025?
The Official Gazette shows continued implementation of the naturalization system during 2025 and the issuance of decisions by the Prime Minister approving the granting of nationality to a number of foreign nationals after consultation with the Citizenship Applications Examination Unit and pursuant to the Nationality Law and the decisions regulating the program.
Examples include Prime Ministerial Decisions Nos. 835 and 836 of 2025, followed by Decisions Nos. 2799 and 2800 of 2025, which granted nationality to groups of applicants of different nationalities.
The significance lies not in the names of the naturalized persons, but in the fact that the program remained active and was actually implemented during 2025, while the principal financial thresholds in force continued to derive from the 2023 amendments.
Are There Official Figures Confirming More Than One Thousand Applications?
Reports and articles have circulated different figures concerning the number of program applications and the level of demand for certain real estate projects.
However, it is preferable not to present any specific figure as an official fact unless it is issued by the Citizenship Applications Examination Unit or another competent government authority and is tied to a clear date.
Accordingly, evaluation of the program’s success should rely on official data and published granting decisions, rather than marketing figures alone.
Selecting the Most Suitable Route for the Investor
There is no single route that is best for every applicant.
The USD 250,000 contribution is simpler in terms of managing an investment asset, but it is non-refundable.
Real estate, by contrast, gives the investor an asset that may be retained and later sold, but it requires real estate due diligence and is subject to a time restriction on disposal.
The deposit is simpler than an operating project, but it freezes USD 500,000 for three years without return and exposes the investor to exchange-rate risk upon repayment.
The investment-project route may be most suitable for a person who already intends to conduct economic activity in Egypt, but it requires management, operation, and a longer-term commitment.
Legal Recommendations Before Submitting the Application
- Select the route before transferring funds: because the transfer method and proof of entry of foreign currency form part of the legal file.
- Conduct full real estate due diligence: if the selected route is property purchase, particularly when buying from a private developer.
- Do not rely on marketing promises: neither a developer nor an intermediary can guarantee issuance of a nationality decision.
- Review the law governing the original nationality: to determine the effect of acquiring Egyptian nationality on the current nationality.
- Calculate the effect of early exit: whether from the property or the project during the first five years.
- Prepare the security and documentary file early: including criminal-status certificates, movement certificates, foreign documents, and authentications.
- Verify the intermediary: the Unit provides a list of accredited intermediaries authorized to deal with the program.
- Examine the legal status of family members separately: and do not assume that the husband or wife acquires nationality automatically.
The Role of the Office of Dr. Mostafa El Rouby – Attorneys and Legal Consultants
The Office of Dr. Mostafa El Rouby – Attorneys and Legal Consultants believes that a citizenship-by-investment file should be treated as a single legal and investment transaction, rather than merely an administrative application.
A decision that appears economic – purchasing real estate, establishing a project, or freezing a deposit – creates long-term legal consequences. Weak initial due diligence may result in the investor’s funds being tied up in an unsuitable asset or may delay completion of the citizenship file.
Legal support in this field includes:
- Assessing the most suitable investment route.
- Reviewing eligibility requirements before submission.
- Legal due diligence on properties and developers.
- Establishing and reviewing investment projects.
- Reviewing transfer documents and source of funds.
- Preparing and reviewing the naturalization file.
- Following up the application before the Citizenship Applications Examination Unit.
- Examining the legal status of the spouse and children.
- Assessing the effects of disposing of the investment after obtaining nationality.
Conclusion
The Egyptian Citizenship by Investment Program became more flexible following the 2023 package of amendments, which reduced the minimum real estate investment to USD 300,000, set the project investment threshold at USD 350,000 plus USD 100,000 to the State Treasury, reduced the deposit to USD 500,000 for three years, and maintained the direct-revenue route at USD 250,000.
The ability to purchase privately owned real estate also resulted from a statutory amendment issued in 2023, rather than an amendment introduced in 2024 or 2025.
During 2025, implementation of the program continued and actual decisions granting nationality were issued, while the principal structure of the program remained based on the Nationality Law, the 2019 and 2020 decisions, and the 2023 amendments.
However, financial investment alone does not result in nationality. The application remains subject to legal and security screening, and the Prime Minister retains authority to issue the final decision based on the recommendation of the Citizenship Applications Examination Unit.
Selection of a property or project should also not be based solely on the value of the investment, but rather on the soundness of the asset’s legal status, the ability to retain it for five years, the correctness of the funds-transfer route, and the consequences of early exit.
Accordingly, the optimal decision is not always to select the least expensive program, but rather to select the route that achieves the nationality objective without creating an investment or legal risk greater than its value.
Written and Prepared by: Dr. Mostafa El Rouby