Sources, scope and matters requiring professional review.
Editorial review:
Documented legislation
DNU 366/2025 amended Citizenship Law 346 to include relevant investment as a naturalization pathway. Decree 524/2025 sets out the roles of the Agency and the National Migration Directorate. Check the text applicable to each case.
Announcements and opening
The announcement dated 2 October 2026 describes a non-refundable USD 350,000 contribution or a USD 800,000 public bond, with applications planned for Q4 2026. This source does not confirm an effective opening date. Announced amounts exclude legal fees and other costs.
Family and due diligence
The announcement includes spouses and children subject to conditions and separate contributions. Family ties, age and route require review. Announced checks cover identity, wealth and funds tracing and background records; documents belong in an agreed private channel.
Case law and scope of the decisions
Volosh, Yana · Chamber III · 18 June 2026
In case 17.978/2025/CA1, the Federal Civil and Commercial Court of Appeals reversed the rejection of the constitutional challenge to DNU 366/2025 in citizenship matters and ordered the lower court to reassume jurisdiction over the application. It examined the absence of necessity and urgency and safeguards for review. It did not grant citizenship by investment or decide an investor application.
Electoral jurisdiction · official MPF report · 2 July 2026
The Public Prosecutor’s Office reported that the National Electoral Chamber reversed rejection of a naturalization application, confirmed electoral jurisdiction and declared DNU 366/2025 null. Its report distinguishes citizenship from migration status. It does not establish an approval of citizenship by investment.
Finality, appeals and applicable scope must be checked in the case file before recommending a strategy. These sources alone do not establish current procedural status or a general legislative repeal. Bronstein: the full judgment and procedural status remain pending; it is not presented as a guarantee of admissibility or citizenship.
Risks and limits
Review implementation rules, third-party costs, bond risks, tax matters and family circumstances before committing funds. An inquiry does not reserve a place or guarantee approval. New rules or decisions may change a case assessment.
Review log
23 October 2026: editorial check of the three official links below. Scope: original decree texts and the 2 October announcement. Additional review: the full Volosh judgment and the official MPF report of 2 July 2026. Pending: operational opening confirmation, finality and appeals in the case files, and the full Bronstein judgment. This date does not certify individual legal review.