Official · 02.10.2026Argentina announces South America's first Citizenship by Investment Programme→
A long empty conference table in a Buenos Aires ministry with tall windows, stacks of blank papers and brass desk lamps, morning light
  1. Home
  2. Insights
  3. Regulations: open questions

The Programme

What the rules must still answer

Argentina has published its prices but not its rulebook. When the implementing rules appear, read them against this checklist. A programme that answers all twelve questions clearly is ready for your money. One that leaves several open is not.

Updated 8 min readSourced from official announcements

Key facts

  • The legal procedure exists: DNU 366/2025 and Decreto 524/2025.
  • Article 6 of Decreto 524/2025 lets the Agency issue complementary rules. As of 10 October 2026 we have found none on fees, forms or a portal.
  • The Agency has had an executive director, Aixa Granara, since 22 April 2026 (Decreto 285/2026).
  • The legal basis is before the Supreme Court. The government's appeal was granted on 24 September 2026.

On 2 October 2026 Argentina told the world what its citizenship by investment programme costs. It did not say how it works. The two decrees behind the programme set out who evaluates and who decides. Almost everything an investor needs to plan a file, from fees to the bond’s small print, is left to rules not yet written.

Article 6 of Decreto 524/2025 gives that job to the Agencia de Programas de Ciudadanía por Inversión. Since 22 April 2026 the Agency has had an executive director, Aixa Granara, appointed ad honorem by Decreto 285/2026. The government says applications open in Q4 2026. The rules should appear before then.

Use the twelve questions below as a reading guide when they do.

1. What are the government fees?

Neither decree mentions fees. The official release gives only the investment amounts. Every established programme charges at least an application fee and a due-diligence fee per person. As a benchmark, St Kitts and Nevis charges a non-refundable US$10,000 due-diligence fee for the main applicant and US$7,500 for each dependant aged 16 or over, plus post-approval fees.

Look for: a fee per applicant, a separate due-diligence fee, whether fees are refundable, and whether third-party checks are billed on top. Our cost guide will be updated when amounts appear.

2. How and where do you apply?

There is no portal yet. The rules should say whether you file online, at a consulate or in Argentina, and whether you may file yourself or only through an authorised representative.

Look for: the filing channel, the document list, translation and apostille rules, and the language of the forms. Our how-to-apply guide follows the published procedure step by step.

3. How long will it take?

The only deadline in force is in Article 4 of Decreto 524/2025: Migraciones must decide within 30 business days of receiving the Agency’s report. No deadline governs the Agency’s own review or the inter-agency checks by SIDE, the UIF, RENAPER, the criminal records registry and the Ministry of Security.

Look for: a target time for the Agency’s review, what counts as a complete file, and whether a delay “for cause” is possible. St Kitts, for comparison, must tell the applicant within 120 to 180 days whether the file is approved in principle, refused or delayed for cause.

4. When does the money move?

This may be the most important open question. Article 1 of Decreto 524/2025 refers to a foreigner who “hubiere realizado” (has made) a relevant investment. Read literally, that suggests the investment is made before the application is filed.

Caribbean programmes usually do the reverse. In St Kitts, the main contribution is paid only after an approval-in-principle letter. In Dominica, due-diligence fees are paid when the file is submitted, and the investment follows approval in principle.

Look for: whether payment comes before filing, after approval in principle, or into a holding account. See our guide to refunds and escrow.

5. What are the bond’s terms?

The official release confirms a US$800,000 programme bond. Press reports add a seven-year hold (AP) and zero interest (Infobae). Nothing official yet covers maturity date, currency of repayment, governing law, transfer, inheritance or ranking in a future restructuring.

Look for: a prospectus or decree that creates the bond, with those terms in full. Our contribution vs bond analysis shows why they matter.

6. Is there any residence or presence requirement?

DNU 366/2025 allows naturalisation for a relevant investment regardless of time of residence. No post-grant residence rule has been published. The rules may still require at least one visit, for example for biometric capture, an interview or an oath.

Look for: any visit before or after approval, any minimum stay, and where biometrics are taken.

7. Who counts as family?

The official release prices a spouse at US$100,000, single children aged 18 to 25 without children of their own at US$100,000 each, and children under 18 at US$25,000 each. One press report gave the band as 18 to 24; the official text says 18 to 25.

Look for:

  • whether the age is fixed at filing or at decision, so that a child does not “age out” during processing;
  • whether unmarried partners (uniones convivenciales) count as spouses;
  • whether parents or grandparents can be included;
  • how children born or adopted after approval are added, and at what cost.

The last point matters because the nationality “option” route covers children of native Argentines, not children of naturalised ones. See our family guide.

8. What happens if you are refused?

No refund rule has been published. The contribution is described officially as non-refundable, but that does not tell you what happens if Migraciones rejects the application.

Look for: a refund rule for refusals, any deduction for fees, the timeline for repayment, and whether a refused applicant can reapply.

9. Will there be licensed agents?

The official agent framework is not yet published. The government cancelled its master-agent tender in April 2026, and no firm has been publicly appointed as an official operator. See tender, consortium and advisers.

Look for: whether agents must be licensed or registered, a public list, rules on fees and marketing, and sanctions. Our guide to choosing an agent explains what to check in the meantime.

10. Can citizenship be revoked?

It has been reported, but not confirmed, that DNU 366/2025 adds grounds to annul a naturalisation, such as concealing facts. The programme rules should make the grounds and the procedure explicit.

Look for: the list of grounds, who decides, whether there is an appeal, and whether revocation of the main applicant affects family members.

11. How do the rules deal with the court case?

On 30 June 2026 the Cámara Nacional Electoral declared DNU 366/2025 unconstitutional and sent citizenship cases back to federal electoral judges. The government’s extraordinary appeal was granted on 24 September 2026, and Infobae reported on 7 October that the file has entered the Supreme Court for study.

Look for: any statement on whether applications will be accepted before the Court rules, and what happens to pending files and paid funds if the Court confirms the ruling. Our legal status briefing sets out the scenarios.

12. What will be published afterwards?

Good practice, as set out in the 2023 FATF/OECD report on investment migration, includes public reporting of approvals and revenue. A programme that publishes statistics is easier to trust and harder to capture.

Look for: a commitment to publish annual figures, and an independent audit of how the money is used.

How to use this checklist

When the rules appear, mark each question as answered, partly answered or open.

Result What it suggests
10–12 answered The programme is ready for serious applications
6–9 answered Prepare documents, but keep funds in place
Under 6 answered Wait for clarification or the Supreme Court ruling

Questions 4, 8 and 11 carry the most weight. They decide whether your capital is exposed before the outcome is known. We will report each new rule on our news page.

Note. This checklist is general information, not legal or investment advice. Speak to a qualified adviser in Argentina before you commit funds.

Sources

Frequently asked questions

Have Argentina's CBI implementing regulations been published?

Not as of 10 October 2026. Decreto 524/2025 sets the basic procedure and lets the Agency issue complementary rules, but we have found no Agency resolution with fees, forms or a portal.

Who will write the detailed rules?

Article 6 of Decreto 524/2025 empowers the Agencia de Programas de Ciudadanía por Inversión to issue complementary and clarifying rules on the application procedure and the evaluation of applications.

Do I pay before or after approval?

This is not yet published. Article 1 of Decreto 524/2025 refers to a foreigner who has made the investment, which suggests payment could come before the application, unlike Caribbean programmes that collect the main payment after approval in principle.

Is there a physical presence requirement?

None has been published. DNU 366/2025 allows naturalisation for a relevant investment regardless of time of residence, but the rules may still require a visit for biometrics or an interview.

Next stepPrivate Briefing

Be first when the doors open.

Applications open in Q4 2026. Join the priority list for a confidential briefing, early access to the official regulations, and a file prepared before the first day.

  • Strictly confidential
  • No obligation
  • Response within one business day