UPDATE · 2 OCTOBER 2026
The program enters its operational phase.
On 2 October 2026, during Argentina Week in Paris, Minister of Economy Luis Caputo and Chief of Cabinet Diego Santilli announced the launch of the Citizenship by Investment Program. According to the official communiqué, it will be operational to receive applications during the fourth quarter of 2026. [6]
The two routes are not economically equivalent. The contribution is a permanent, non-refundable transfer to the National Treasury: from the applicant’s balance sheet, it is not an investment. The bond keeps the capital represented by an asset issued by the Argentine State, but its real cost depends on term, rate, currency, amortisation, governing law, custody, transferability and any holding period. The communiqué does not set those terms; press coverage attributed to the Minister a seven-year, zero-coupon bond.
Spouses and children may apply with additional contributions: US$100,000 for a spouse, US$100,000 for each unmarried child aged 18 to 25 without children, and US$25,000 for each child under 18. A family with two minor children would total US$500,000 via the contribution route. The communiqué frames these as Treasury contributions and does not say how they apply when the main applicant chooses the bond.
The announcement confirms two positions this guide has held: the April 2026 cancellation of International Tender No. 34-0001-CPU25 (Resolution 522/2026) ended a procurement procedure, not the legal regime; and naturalisation by investment does not, by itself, create Argentine tax residence.
01. Why Argentina?
For investors considering a business or a long-term connection with Argentina, investment migration belongs within a broader legal strategy. Corporate structure, ownership, source of funds and family objectives should be assessed together. Citizenship is a legal status granted by the State; it cannot be guaranteed by a private contract.
DNU 366/2025 amended the Citizenship Law and introduced naturalisation through relevant investment, irrespective of the duration of residence. It also established APCI. This statutory wording should not be marketed as a guarantee that every procedural step can be completed remotely. [1]
02. Residence and citizenship are separate routes.
RBI concerns permission to reside in Argentina on the basis of an investment project. CBI concerns an application for nationality. A residence permit, a company registration or a property purchase should not be treated as interchangeable with citizenship approval.
The ordinary naturalisation route in the text of DNU 366/2025 refers to two years of legal, continuous residence, rather than a general three-year citizenship requirement. The applicable procedure and the effect of judicial decisions require a current, case-specific assessment. Permanent residence should not be presented as an automatic preliminary step for every naturalisation case. [1]
Explore Argentina investor residence ↗03. What counts as a relevant investment?
Law 346 still provides for the naturalisation of foreigners who make a relevant investment, and Decree 524/2025 leaves its definition to the Ministry of Economy, including through specific projects. [2]
The October 2026 announcement introduces two standardised instruments: the US$350,000 contribution and the US$800,000 bond. The implementing rules must clarify whether these are the only operational routes, whether they coexist with productive projects, or whether productive investment is in practice moved to investor residence. [6]
Energy, mining, agribusiness, infrastructure, manufacturing and technology are areas investors may wish to explore, but only under a rule that expressly accepts them. Market figures circulated before the announcement — such as a US$500,000 to US$1 million range — should no longer be used as references, and a US$100,000 RBI estimate should not be represented as a statutory threshold. Property, securities and crypto-assets are not assumed to qualify.
04. Institutions and compliance
APCI leads the assessment. According to the communiqué, the State Intelligence Secretariat (SIDE), the Financial Intelligence Unit (UIF), the Ministry of Security and the Ministry of the Interior take part. APCI then sends its recommendation to the National Migration Agency (DNM), which approves or rejects the application — the same architecture set by Law 346 and Decree 524/2025. [2] [6]
The review covers identity, the traceability and lawful origin of funds, wealth and financial profile, jurisdictional risk, criminal and reputational background and immigration history. All funds must move through the formal financial system under anti-money-laundering, counter-terrorist-financing and financial-transparency rules; the communiqué refers to standards aligned with OECD and FATF recommendations.
Practical preparation should therefore start before any transfer: beneficial ownership, source of wealth, source of funds and a consistent corporate and banking record.
05. Timing and implementation
The Government has announced that applications will be received during the fourth quarter of 2026. At this review, the official form, filing channel, document requirements, payment accounts and bond terms had not been published. [6]
The decree provides 30 business days for DNM to decide after receiving APCI’s report. That is not a deadline for the entire process, nor a passport guarantee. [2]
Nothing published ties the program to the current presidential term. A future administration could amend it within the constitutional and legal framework; citizenship validly granted is an individual status that does not lapse with a change of government. Figures such as a 5,000-case cap or a four-year closing window are not established by the cited rules.
06. Court rulings on DNU 366/2025.
Two appellate rulings, with different scopes, must be read alongside the announcement. On 18 June 2026, Chamber III of the Federal Civil and Commercial Court of Appeals invalidated Articles 37 to 43 of DNU 366/2025, which cover both the transfer of the citizenship certificate to DNM and the introduction of naturalisation through relevant investment. [7]
On 30 June 2026, the National Electoral Chamber, in the Liping Yang case, declared the decree null for transferring the citizenship certificate to DNM and for regulating electoral matters, which Article 99(3) of the Constitution excludes from emergency decrees. [8]
These are decisions in specific cases, not a general repeal: the Executive treats the regime as in force and the announcement relies on it. Law 27,802, passed by Congress, expressly refers to the investment naturalisation provision of Law 346. The extraordinary appeal route has been filed or is pending concession; the Supreme Court is expected to have the final word. Investors should weigh this risk before transferring funds.
07. Tax residence deserves its own analysis.
Article 194 of Law 27,802 amended Article 116 of the Income Tax Law: naturalisation through relevant investment does not, by itself, make the person an Argentine tax resident. The foreign-national residence rules continue to apply for this purpose; existing permanent residents retain their resident treatment. [3]
A generic “183 days” test is insufficient. The statutory rules include permanent residence and, for foreign nationals, a twelve-month period under temporary immigration authorisations, subject to the rules on temporary absences. Treaty questions need separate analysis. [4]
Argentina should not be described as a generally territorial tax jurisdiction: residents are generally taxed on Argentine and foreign-source income. Citizenship does not guarantee exemption, treaty access or confidentiality from reporting obligations. [5]
08. Seven questions the implementing rules must answer.
- Productive investment
Will capital placed in a company or in an energy, mining, agribusiness, technology or infrastructure project qualify without the contribution or the bond — or will it be channelled to investor residence?
- Authorised agents
Will there be a mandatory agent register, exclusive operators, or ordinary professional representation before APCI?
- Payment sequence
Are funds transferred before or after personal clearance? A pre-approval or conditional approval stage — and clear rules if an application is rejected after payment — would protect applicants.
- Fraud prevention
Contributions should go only to an official Treasury account published by the State and APCI; bond subscriptions only through official channels or regulated, expressly identified intermediaries.
- The bond
Term, coupon, currency, governing law, custody, listing, transferability and minimum holding period remain unpublished. Some holding requirement is a reasonable expectation, not a published rule.
- Duration
Nothing published makes the program expire with the current presidential term.
- A change of government after 2027
An expectation, a pending file, an approved application and granted citizenship are different positions; for pending files, the transitional provisions of any reform will matter most.
09. Professional support, in stages
Falivene & Asociados can define an engagement around your investment, documentation and family circumstances.
- Assessment and strategic design
Eligibility review, preliminary due diligence, source-of-funds assessment, investment structure and tax coordination.
- Preparation and submission
Document preparation, professional coordination and representation once a legally available filing route is confirmed.
- Decision and documentation
Follow-up and, if citizenship is granted, assistance with subsequent identity and passport procedures.
Fees, payment milestones and any success component are agreed in writing. Government charges, notarial work, translations, external accounting and the investment itself are separate unless expressly included. No outcome or processing time is guaranteed.
Post-naturalisation support can address continuing corporate, contractual and administrative needs in Argentina.
Request a preliminary assessment ↗ARGENTINA · FREQUENT QUESTIONS
Short answers, with their limits.
Is Argentina’s citizenship by investment program open?
Announced, not yet open. The Government announced that applications will be received during the fourth quarter of 2026. Until the implementing rules, the official filing channel and the payment accounts are published, no funds should be transferred.
How much does Argentine citizenship by investment cost?
The official communiqué sets two routes: a non-refundable US$350,000 contribution to the National Treasury or the subscription of a dedicated US$800,000 government bond. Family contributions: US$100,000 for a spouse, US$100,000 for each eligible child aged 18 to 25 and US$25,000 for each minor child. Government charges, due diligence and professional fees are separate.
Who decides an Argentine citizenship by investment application?
APCI leads the assessment with input from SIDE, UIF, the Ministry of Security and the Ministry of the Interior; it recommends approval or rejection to the National Migration Agency (DNM), which decides.
Has the investment citizenship decree been annulled?
Not generally. In June 2026, two appellate rulings in specific cases invalidated provisions of DNU 366/2025 or the decree itself, on different grounds. The extraordinary appeal route has been filed or is pending concession; the Supreme Court is expected to have the final word.
Can a business, property or securities investment qualify?
The announcement describes only the contribution and the bond. The implementing rules must clarify whether productive projects can still qualify as relevant investment; until then, property, securities and crypto-assets are not assumed to qualify.
Does citizenship by investment make me an Argentine tax resident?
Not by itself. Article 194 of Law 27,802 amended Article 116 of the Income Tax Law: naturalisation through relevant investment does not, on its own, create Argentine tax residence.
How long does the DNM decision take?
The decree gives DNM 30 business days to decide after receiving APCI’s report. That is not a deadline for the entire process, nor a passport guarantee.
PRIMARY SOURCES
Read the governing texts.
- DNU 366/2025 · Citizenship Law amendments ↗
- Decree 524/2025 · Investment citizenship procedure ↗
- Law 27,802 · Article 194 · Tax residence ↗
- Income Tax Law · Article 116 ↗
- ARCA · Income subject to tax ↗
- Official communiqué · Program launch, 2 October 2026 (Argentina Week, Paris)
- Federal Civil and Commercial Court of Appeals, Chamber III · Ruling of 18 June 2026 (Articles 37–43, DNU 366/2025)
- National Electoral Chamber · Liping Yang case, ruling of 30 June 2026
This guide explains the cited framework and the official announcement of 2 October 2026. It does not certify that applications are open or resolve the scope of litigation. Individual advice requires checking the implementing rules and relevant judgments before acting.