Three issues with the Maltese citizenship by merits and the Bulgarian alternative
The Maltese citizenship for special merits comes with three main issues. The first is the extreme difficulty of obtaining it, along with the rigorous due-diligence checks every applicant must pass. The second is the banking risk: anyone with this status may face serious problems when dealing with banks in the European Union. The third and most serious issue is that the new citizenship by merits from Malta can be cancelled at any time. Even after it has already been granted. In this article, we will examine this problem in more detail.
Bulgaria vs Malta – virtually identical citizenship legislation, but completely different approaches
To start with, let’s compare the Bulgarian and the Maltese legal texts, that define how citizenship for special merits is granted by each country:
Bulgaria – citizenship for special merits
According to art. 16 of the Bulgarian Citizenship Law:
A person who is not a Bulgarian citizen may obtain Bulgarian citizenship without the conditions under Art. 12 if the Republic of Bulgaria has an interest in his naturalisation or if the person has special merits for the Republic of Bulgaria in the social and economic sphere, in the field of science, technology, culture or sport.
Malta – citizenship by merit
According to art. 10 (9) of the Maltese Citizenship Act:
Notwithstanding the provisions of this Act or any other Act, the Minister may grant a certificate of naturalisation as a citizen of Malta by merit to an alien or stateless person, namely to a person who renders exceptional services1 or who makes an exceptional contribution, including through job creation, to the Republic of Malta or to humanity, or whose naturalisation is of exceptional interest to the Republic of Malta:
Differences and similarities
Both Bulgaria and Malta allow their governments to grant citizenship to a foreigner who has provided or can provide exceptional services. The idea is the same: to reward individuals who significantly benefit the state.
The Maltese legislation provides an extensive interpretation of what counts as “exceptional”. Malta lists categories such as scientists, technologists, artists, entrepreneurs, philanthropists, researchers, sports figures, and others. It even includes contributions that benefit humanity, not only Malta itself.
Malta also adds a new category. People whose skills and profile are of “exceptional interest” to Malta. This means that in theory, even without a proven contribution, a candidate may qualify if the Minister sees strategic value in granting him a citizenship. The Bulgarian legislation allows that too, but doesn’t specify it so openly.
The main difference between Malta and Bulgaria
The key difference is that Malta actively promotes its new citizenship by merits program, while Bulgaria keeps low profile. Chances are you have never heard of the Bulgarian special merits program. At the same time, the Maltese program, in its current shape, exists only since 2025. In contrast, the “less known” Bulgarian special merits citizenship program exists since 1998. So which program do you think is more “established”.
Malta actively uses its citizenship by merit clause as part of a government-controlled scheme that welcomes ultra-high-net worth applicants.
Although the country claims it is not investment-based, the system is clearly designed to attract primarily extremely wealthy or very influential individuals.
No marketing in Bulgaria
Bulgaria, in contrast, uses this provision with caution. Citizenship by merit is granted silently, without any marketing at all. As result, Malta’s program operates under constant scrutiny from the European Union, which argues that it resembles the former citizenship by investment model. This creates huge legal and political risk for all applicants.
Maltese citizenship by merits can be revoked even after it is granted
Because all of the above, the Maltese law is so drafted that in fact, citizenship by merits is reversible. This is done so on purpose, so the Maltese authorities can “fix an error” if the EU authorities get overly concerned about certain person, who has been naturalised. The new Maltese citizenship for special merits can be legally revoked even after it is granted. This is so, because the entire framework is designed to give Malta broad discretion and to protect the interests of the European Union.
Since the program closely resembles the old investment citizenship scheme, Malta must demonstrate that each case is genuinely based on “exceptional contribution,” not financial payment. This creates several legal vulnerabilities for the applicant. If the authorities later conclude that the justification for granting citizenship was insufficient, misleading, or not truly merit-based, they can legally cancel the decision. Citizenship can also be revoked if information provided during the application is found to be incomplete, inaccurate, or inconsistent, even years later. Having in mind the subjectivity of the merit based citizenship, we expect cancellation of citizenship to occure frequently.
Finally, EU pressure plays an important role too. If the European Commission challenges Malta’s decisions, the government may revoke individual cases to avoid infringement procedures. For applicants, this means that Maltese citizenship obtained through the special merits route is not fully secure and remains exposed to future legal or political scrutiny.
What to do if you can provide exceptional value and want an EU passport
If you can provide exceptional value and want an EU passport, Malta is an attractive option. Its citizenship by merits program is well known and actively promoted, making it accessible to ultra-high-net-worth individuals and global talent. However, it comes with significant risks. The process is expensive, your citizenship could be revoked in the future, and you may face serious difficulties with EU banking.
For a safer alternative, consider Bulgaria. Its special merits citizenship program is little known but provides a legitimate route to an EU passport. While it is more discreet and less actively marketed, it avoids many of the risks associated with Malta, making it a good choice for those who prefer security over publicity.
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