Three changes, three different signals

São Tomé and Príncipe's Citizenship Investment Unit (CIU) has issued a memorandum to licensed marketing agents announcing three simultaneous changes to the country's citizenship-by-investment programme. Dated 10 April 2026 and signed by CIU Director Disney Leite Ramos, the document covers a legislative restriction on multi-nationality applicants, a significant operational improvement in passport issuance, and a temporary freeze on adult dependent applications. The three changes do not point in the same direction, and understanding each one separately matters for investors currently evaluating the programme.

The three-nationality hold: a legislative gap, not a policy reversal

The most immediately restrictive change concerns applicants who already hold three or more foreign nationalities. Citing Nationality Law No. 07/2022, which prohibits the granting of São Toméan nationality to individuals in that category, the CIU confirmed that new applications from such individuals are suspended.

"Effective immediately, acceptance of new applications from individuals holding three foreign passports or more will be placed on hold," the memorandum states.

The hold does not reflect a deliberate change in programme direction. An amendment to this restriction had been anticipated but has not yet been finalised by parliament. Ramos told IMI Daily that "the legislative amendment regarding individuals holding three nationalities or more will be addressed soon upon the completion of the requisite parliamentary procedures."

Philippe May, Founder and CEO of EC Holdings, described the restriction as "regrettable, as there is a certain demand from people holding three passports," but added that the practical impact is limited. "Not very important," he said — a view that reflects the reality that most qualifying investors currently hold fewer than three nationalities.

Remote biometric issuance: a meaningful operational improvement

The more consequential shift for the majority of applicants is on the operational side. Until 9 April, passport issuance required in-person biometric capture — fingerprints and signature — either in São Tomé and Príncipe itself or at one of only two designated embassies, in Lisbon or Brussels. For an internationally mobile investor base, that geographic constraint was a meaningful friction point.

A legislative amendment has now resolved it. The national ID can be issued remotely through video verification with the Civil Registry and Notary Office.

Ramos framed the change around compliance as much as convenience: "STP wishes to ensure full compliance and proper identity verification, confirming that each applicant is genuine and in good standing. The government of STP has put a team in place to assure smoothness for this process."

May described the shift as "rather positive," noting that "very few find it convenient to travel to Lisbon or Brussels" for biometric capture. For a programme targeting high-net-worth individuals across multiple time zones, the removal of that requirement is a substantive improvement.

Adult dependent freeze: another legislative gap under review

The third change concerns adult dependents above the age of 18. Passport issuance for this category is on hold while a revised dependency framework is being finalised. Ramos confirmed that the revised law "is already underway and expected to be implemented in due course."

As with the three-nationality restriction, this hold reflects an unresolved gap in the programme's underlying legislation rather than a fundamental shift in policy intent.

Programme context: still the most affordable CBI on the market

São Tomé and Príncipe launched its CBI programme in September 2025 with a US$90,000 donation to the National Transformation Fund — the lowest entry point of any citizenship-by-investment programme currently available. The programme attracted over 200 applications in its first few months and had issued its first passport by January 2026. In February 2026, the CIU revoked a licensed agent's authorisation for underselling the programme, signalling that the government intends to manage the programme's market positioning actively.

For HNWI investors who hold fewer than three existing nationalities and are not seeking to include adult dependents, the programme remains open and materially more accessible now that remote biometric enrolment is available. For those who fall under either of the two active holds, the appropriate response is to monitor parliamentary developments and maintain close contact with a licensed agent familiar with the programme's evolving framework.

FAQ

What is the three-nationality hold and who does it affect?

São Tomé's Nationality Law No. 07/2022 prohibits granting São Toméan nationality to individuals already holding three or more foreign nationalities. The CIU has confirmed that new applications from such individuals are on hold effective immediately, pending a parliamentary amendment that has not yet been finalised.

How does São Tomé's new remote passport issuance process work?

A legislative amendment now allows the national ID to be issued remotely through video verification with the Civil Registry and Notary Office, replacing the previous requirement for in-person biometric capture in São Tomé, Lisbon, or Brussels. The CIU has a dedicated team in place to manage the process.

Can adult dependents over 18 still apply under the São Tomé CBI programme?

Not at present. Passport issuance for adult dependents above 18 is on hold while a revised dependency framework is being finalised. The CIU Director has said the revised law is underway and expected to be implemented in due course.

Is the São Tomé CBI programme still worth considering for HNWI investors?

For qualifying applicants — those holding fewer than three foreign nationalities and not relying on adult dependent inclusion — the programme remains the most affordable CBI option on the market at US$90,000. The remote biometric change is a meaningful operational improvement. The current holds reflect legislative gaps rather than a change in the programme's fundamental direction.

Source: IMI Daily — São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule