Argentina’s Citizenship-by-Investment Program: Executive Policy Meets Constitutional Constraints

Argentina’s announced citizenship-by-investment program promised foreign investors a potential pathway to citizenship. Two developments in 2026 have made its future increasingly uncertain.

In April 2026, the Government suspended the international tender that had been launched to engage a consulting firm to design, implement and promote the program.

According to the Ministry of Economy, the proposals received differed significantly in their strategic approaches and raised concerns regarding their alignment with the Milei Administration’s broader policy objectives. Unofficial sources say the Government had skewed the process to favor a single bidder and was forced to reset when the other bidders threatened to go public with a complaint.

The Administration has moved away—at least for now—from the original tender-based strategy. It appears instead to be directly shaping and implementing the program. This change has slowed implementation.

The Government has created the Agency for Citizenship by Investment (APCI), an agency reporting to the Ministry of Economy and responsible for administering the program, reviewing applications, conducting eligibility assessments, and issuing recommendations on citizenship applications. So far, however, only APCI’s Executive Director, Aixa Granara, has been appointed; many other positions critical to the agency’s operational ability have yet to be filled. Moreover, the Ministry of Economy has yet to issue regulations defining the type or amount of investment that will qualify, or how the Government proposes to enforce compliance with the law.

In June of this year, the Administration’s hopes for enactment suffered a grave setback when the National Electoral Chamber declared the executive order (Decree No. 366/2025) creating the citizenship-by-investment program unconstitutional. The court ruled that the Government was unable to confer citizenship without legislative involvement. An executive order alone was an unlawful exercise of executive power. The ruling presages  a potential showdown between the executive and the judiciary on the executive’s power to create a citizenship-by-investment program.

For now, implementation of a citizenship-by-investment program appears to be a long way off. Any unilateral attempt by the executive will likely be blocked by the courts. A more enduring framework would require congressional enactment.

Legislation, however, would face practical obstacles in cobbling enough votes. The Administration’s current legislative agenda focuses on other economic and structural priorities. As Argentina approaches the 2027 election cycle, the president’s political agenda will become increasingly narrow.

The program is best described as in limbo. The official APCI website continues to describe the program as being in a “launch phase.” No portal exists, however, to file an application.

For investors interested in Argentina, five developments will determine whether the initiative can mature from a policy proposal to a functioning program:

• Settlement of the constitutional challenge to Executive Order 366/2025.
• Congress’s interest in legislating citizenship by investment.
• Release of regulations defining qualifying investments and minimum thresholds.
• APCI becoming an operational agency.
• The creation of an application and review procedure.

Argentina does not yet offer an operational or legally settled citizenship-by-investment pathway. Until the judicial, legislative and regulatory issues outlined above are resolved, prospective investors should treat the program as a policy initiative rather than an available route to citizenship.

We will continue to monitor the program and update you on significant legal and regulatory developments.