Second Passport for German Citizens in 2026: New Dual Nationality Rules and Your Best Investment Options

For decades, Germany's strict single-nationality rules made citizenship by investment an unattractive option for German high-net-worth individuals. The old §25 Staatsangehörigkeitsgesetz (StAG) was unambiguous: voluntarily acquire a foreign citizenship, and you automatically forfeit your German one. The trade-off was too steep for most investors to contemplate.

That barrier was removed on 26 June 2024, when Germany's Gesetz zur Modernisierung des Staatsangehörigkeitsrechts came into force. German nationals can now freely acquire a second or even third citizenship — including through investment — without losing their German passport. This single legislative change opened the full global CBI and Golden Visa market to Germany's approximately 1.4 million high-net-worth individuals.

The timing is particularly relevant because Germany simultaneously tightened its exit tax regime. From 1 January 2025, the Wegzugsbesteuerung (§6 AStG) was extended to cover ETF shares and investment fund units — meaning unrealised gains on these assets are now taxed as if liquidated on the day of emigration, even without an actual sale. For German investors holding significant fund portfolios, planning a second citizenship well in advance of any tax residency change has moved from optional to strategically prudent.

Mirabello Consultancy — IMC member, ACAMS-certified, Swiss-based in Zurich with offices in Dubai, 250+ successful citizenship cases and a 99% approval rate — advises German-speaking investors on exactly this intersection of citizenship law and investment migration planning. To discuss your profile with our Swiss-based team, book a free consultation today.

Can German Citizens Now Hold a Second Passport?

Yes. Since 26 June 2024, German nationals can hold dual or multiple citizenship without restriction. The reform removed §25 StAG's automatic-loss clause, which previously stripped German citizenship from anyone who voluntarily acquired a foreign nationality. German nationals who obtain a second citizenship by investment today keep their German passport unconditionally.

Before this reform, the picture was more complicated. The old §25 StAG had limited exceptions: EU and Swiss nationals had been exempt since a 2007 ruling, and naturalisations for specific hardship cases or where German citizenship could not reasonably be renounced were also protected. However, citizens of non-EU countries — including the Americas, Asia, Africa, and the Middle East — who obtained a German naturalisation were routinely required to give up their original citizenship. Those who acquired a foreign citizenship voluntarily (for example, through CBI) faced automatic German citizenship loss.

The 2024 reform aligns Germany with most other developed democracies — the United Kingdom, France, Australia, Canada, and Switzerland among them — in accepting multiple nationality as a normal feature of modern, mobile life. For an estimated 5.7 million German nationals living abroad and many more HNWIs with international interests, this is a structural change that reshapes the entire landscape of personal citizenship planning.

One important note: the reform applies prospectively. Germans who previously lost their citizenship under §25 StAG between 2000 and 2024 may apply for reinstatement under transitional provisions in the new law. If you believe you may have been affected, legal advice from a German nationality law specialist is recommended before pursuing any new CBI application.

What Exactly Changed in the June 2024 StAG Reform?

The core change was the deletion of §25 StAG's automatic-loss clause for voluntary foreign citizenship acquisitions. Additionally, the 2024 reform reduced the standard naturalisation residency period from eight to five years (three years for exceptional integration), introduced the concept of multiple citizenship as a default right, and formally recognised dual citizenship acquired through descent or birth as permanent and unconditional. The reform was part of a broader modernisation of German nationality law that had been debated since 2021.

For investment migration purposes, the two most directly relevant changes are:

• Free acquisition of a second citizenship: German nationals can now obtain CBI passports (Vanuatu, Caribbean, Pacific, African programmes) or citizenship through long-term naturalisation in another country without any risk to their German passport.
• Free acquisition of a second EU citizenship: Germans can now obtain, for example, Portuguese, Maltese, or Cypriot citizenship (where those routes are legally open) while retaining their German passport. This was already largely the case within the EU, but is now codified without any ambiguity.

The reform also has significant implications for foreign nationals who naturalise as German citizens. Since June 2024, they are no longer generally required to renounce their original citizenship as a condition of German naturalisation. This expands the naturalisation-eligible pool within Germany and creates reciprocal interest from non-German HNWIs who want German residency and eventual citizenship while keeping their original passport. Mirabello Consultancy also advises on German residency pathways for foreign nationals — visit our Golden Visa programmes guide for an overview of investor residency options across Europe.

Why Are German HNWIs Considering Second Passports in 2026?

German high-net-worth investors cite five primary motivations for second citizenship in 2026: advance Wegzugsbesteuerung planning, geopolitical risk diversification, enhanced global business mobility, a personal Plan B for themselves and their family, and the ability to structure international assets more efficiently. The June 2024 StAG reform removed the principal legal barrier to acting on all five.

The Wegzugsbesteuerung (exit tax) motivation deserves particular attention. Germany's §6 AStG has historically applied to shares in corporations, but the 2025 extension to ETF units and investment fund shares materially broadened its impact. A German HNWI who has accumulated a portfolio of broadly diversified index funds or equity ETFs over the past decade may now face a substantial notional tax liability simply by relocating — even temporarily — to another tax jurisdiction. The tax is assessed on unrealised gains as if the assets were sold on the day of departure from German tax residency.

Importantly, a second citizenship does not trigger the Wegzugsbesteuerung. Only a change of tax residency (moving your primary residence out of Germany) triggers the liability. This means that obtaining a CBI passport now — while still tax-resident in Germany — is a cost-free preparatory step. It gives the investor a fully operational second citizenship in reserve, available whenever a future relocation decision is made, without triggering any current tax event.

Beyond tax planning, the Henley Private Wealth Migration Report 2026 estimates that Germany is among the top three source countries for HNWI emigration, with an estimated 5,000+ millionaires relocating internationally in 2026 alone. Drivers include rising income and wealth taxation, regulatory complexity, geopolitical concerns, and the desire for better quality of life in lower-cost jurisdictions. Second passports and European Golden Visas are the two most common legal structures these investors use to prepare their move. To explore the full set of programmes Mirabello recommends, see our citizenship by investment hub.

Which CBI Programmes Are Best for German Citizens?

German nationals already hold one of the world's strongest passports, granting access to over 190 countries visa-free — placing them among the top five globally. The value of a CBI passport for a German national is therefore not primarily additional visa-free access, but rather: a standalone legal identity in a second jurisdiction, US E-2 treaty access (Grenada), specific Commonwealth benefits, and a political insurance policy independent of Germany's domestic future. Cost, processing speed, and programme stability are the key selection criteria.

* Nauru introductory pricing ($90K contribution, ~$101K all-in) expires 30 June 2026. Post-June price increases to $115K contribution (~$126K all-in).

For German investors, three specific programmes deserve attention beyond the cost table:

Grenada is the only Caribbean CBI programme with a US E-2 treaty investor visa agreement. The Grenada passport allows its holders to apply for an E-2 visa at a US embassy — a non-immigrant visa that permits a US business presence without the $800,000 EB-5 minimum or the US immigration process. For German entrepreneurs with US commercial interests, Grenada's $235,000 investment plus E-2 access creates a pathway that no other Caribbean programme matches. Learn more about Grenada citizenship by investment.

Vanuatu is the fastest programme in the world at 30–60 days. However, EU Schengen visa-free access was suspended for Vanuatu passport holders in December 2024. For a German national who already holds a German passport for Schengen travel, this suspension is less significant than for investors from third countries. Vanuatu nonetheless provides strong Asia-Pacific and Commonwealth access, and remains a compelling option for German investors who prioritise speed and minimum cost above passport reach.

Dominica at $200,000 offers a no-residency-requirement Caribbean passport with 145 visa-free countries and ECCIRA-regulated programme integrity. Its real estate route starts at $200,000 — the most affordable Caribbean real estate CBI threshold. Explore Dominica citizenship by investment for the full programme details.

How Does Wegzugsbesteuerung Interact with Second Citizenship Planning?

A second passport does not trigger Wegzugsbesteuerung. Germany's §6 AStG exit tax is activated only by a change of tax residency — specifically, when an individual ceases to be unlimited tax liable in Germany (unbeschränkte Steuerpflicht ends). Holding a second citizenship whilst remaining tax-resident in Germany has zero impact on Wegzugsbesteuerung. The passport and the tax domicile are independent legal concepts.

This is the central insight for German HNWI planning: obtaining a second citizenship by investment now — whilst still residing and paying tax in Germany — incurs no exit tax liability, creates no new German filing obligations, and does not accelerate any existing ones. It simply establishes a second legal identity, available to be activated at any future point.

When an investor eventually decides to relocate — whether to Malta, Portugal, Greece, UAE, or a Caribbean island — the following sequence matters:

1. Obtain second passport first — typically 4–6 months for Caribbean CBI, 30–60 days for Vanuatu. No tax consequence.
2. Establish new residency — in a chosen jurisdiction (Malta non-dom, Portugal NHR, UAE free zone, etc.).
3. Deregister from Germany — this triggers §6 AStG on any unrealised gains in the portfolio at that date.
4. Manage the exit tax liability — via the 7-year instalment plan (available under certain conditions), portfolio restructuring in advance, or the Rückkehrerregelung (7-year return window if intent to return to Germany).

The practical implication: every month an investor waits to obtain their second passport whilst still tax-resident in Germany is a month during which they remain exposed to future Wegzugsbesteuerung on any further appreciation of their ETF or fund portfolio. The passport application period (4–6 months) is a fixed minimum lead time — there is no reason to start it later than necessary.

For complex situations involving large ETF portfolios, GmbH ownership, or participation in asset management partnerships, Mirabello Consultancy recommends working in parallel with a German tax adviser specialised in §6 AStG and a Mirabello citizenship specialist. Our Swiss base in Zurich and fluency across seven languages means we are well-positioned to coordinate with your existing advisers.

What Are the Best Golden Visa Options for German Investors?

Golden Visas (residency by investment) serve a different function for German nationals than citizenship by investment. Germans already have full EU freedom of movement — they can live, work, and invest anywhere in the EU without restriction. The value of a European Golden Visa for a German investor is therefore primarily about establishing a formal tax residency base in a lower-tax jurisdiction, not about travel access. The right Golden Visa for a German investor is the one that best supports their planned tax residency transition.

Three programmes stand out in 2026:

Malta MPRP (Malta Permanent Residence Programme) offers EU permanent residency for a government contribution of €68,000–€98,000 (depending on property rental vs purchase), plus a philanthropic donation of €2,000 and ongoing property requirements. Malta's non-domiciled resident programme offers a €15,000 flat annual tax on foreign-source income — highly attractive for German investors who will retain substantial international income post-relocation. Processing is approximately 4–6 months. Malta has a stable legal and regulatory environment, English as an official language, and direct flights from every major German city.

Greece Golden Visa offers EU residency from €250,000 (startup investment, commercial conversion, or heritage restoration) to €800,000 (Athens, Thessaloniki, major islands). The new startup route — investing in a National Startup Registry company — requires 2 jobs created in Year 1 and maintained for 5 years, making it best suited for entrepreneur-investors. Property routes remain the most popular. Greece has no mandatory residency requirement — a single annual visit suffices to maintain the permit. For German investors who want EU residency without relocating, Greece is a structurally efficient choice. See our Greece Golden Visa guide for full details.

Portugal Golden Visa remains open via the fund investment route (€500,000 minimum in qualifying investment funds). Portugal's Non-Habitual Resident (NHR) tax regime — extended and restructured in 2024 — offers favourable treatment for pension income, foreign-source income, and qualifying professional categories at a flat 20% tax rate for 10 years. Portugal is the only EU Golden Visa programme that provides a direct pathway to full EU citizenship after 5 years of residency (even non-continuous). A note: the Portuguese Constitutional Court is currently reviewing the April 2026 law that would have extended the citizenship timeline from 5 to 10 years — that law is suspended pending a ruling expected in May–June 2026. The 5-year citizenship pathway remains active. Explore our Golden Visa comparison guide for the full picture.

What Does the CBI Application Process Look Like for German Nationals?

German nationals face no additional barriers or heightened scrutiny in Caribbean or Pacific CBI programmes. Germany is a low-risk source country for all major due diligence frameworks. Applications follow the standard process: document preparation, criminal background checks, bank reference, source-of-funds documentation, and the investment transaction. Virtual interviews are accepted by most programmes for German applicants.

The typical documentation required includes: certified copy of German passport, birth certificate, marriage certificate (if applicable), police clearance certificate from German federal authorities (Bundeszentralregister), bank statements (12 months), proof of source of funds (company accounts, investment statements, or asset sale documentation), and a professional reference letter. All documents require notarised translation if not in English.

Mirabello Consultancy manages the full application process from our Zurich office — document preparation, due diligence review, submission, and follow-up. Our German-speaking team communicates in your language throughout the process. With 250+ successful cases and a 99% approval rate, we have refined the process to minimise delays and maximise certainty of outcome.

Processing timelines by programme: Vanuatu (30–60 days), Caribbean programmes (4–7 months), São Tomé and Nauru (3–6 months). All programmes issue physical passports at the end of the process. Citizenship is typically granted in perpetuity and is inheritable by future children born after naturalisation.

To begin your application, the first step is a free consultation with Mirabello Consultancy to assess which programme best fits your profile, timeline, and Wegzugsbesteuerung planning horizon. Our Swiss team speaks German natively and understands the specific tax and legal context that German investors face.

For official information on the German dual nationality reform, see the Bundesministerium des Innern (Federal Ministry of the Interior). For independent research on investment migration programmes, refer to the Investment Migration Council.

Frequently Asked Questions

Can German citizens hold dual citizenship after the 2024 reform?

Yes. Since 26 June 2024, German nationals can hold dual or multiple citizenship without restriction. The 2024 Staatsangehörigkeitsgesetz (StAG) reform removed the general automatic-loss clause in §25 StAG, which previously stripped German citizenship when a national voluntarily acquired a foreign one. German passport holders can now obtain a second citizenship by investment without any risk to their German passport.

Does getting a second passport trigger Germany's exit tax (Wegzugsbesteuerung)?

No. Obtaining a second citizenship does not trigger §6 AStG (Wegzugsbesteuerung). Germany's exit tax is activated only by a change of tax residency — when an individual ceases to be unlimited tax-liable in Germany. Holding a second passport whilst remaining German-tax-resident has zero effect on exit tax liability. The passport and tax domicile are independent legal concepts.

Which is the cheapest second passport for German citizens?

São Tomé and Príncipe offers citizenship by investment for approximately $90,000, making it the most affordable CBI programme globally in 2026. Nauru is similarly priced at $90,000 contribution (~$101,000 all-in) but this introductory rate expires on 30 June 2026. Vanuatu costs approximately $130,000 net and processes in 30–60 days, though EU Schengen visa-free access has been suspended since December 2024.

Is the Vanuatu passport still worthwhile for German citizens after losing Schengen access?

Yes — for German nationals specifically. Because German passport holders already have Schengen access through their own passport, the suspension of Vanuatu's Schengen visa-free travel in December 2024 is largely irrelevant. German investors can still use the Vanuatu passport for strong Asia-Pacific and Commonwealth access, while retaining their German passport for Schengen travel. Vanuatu's 30–60 day processing speed remains unmatched globally.

What is the best Caribbean CBI programme for a German investor who wants US business access?

Grenada is the only Caribbean citizenship by investment programme with a US E-2 treaty investor visa agreement. Grenada passport holders can apply for a US E-2 visa at any US embassy, which allows a US business presence at a substantially lower investment threshold than the EB-5 programme ($800,000). For German entrepreneurs with US commercial interests, the Grenada programme at $235,000 offers a unique and highly strategic advantage.

How Do I Start with Mirabello Consultancy?

Mirabello Consultancy offers a free initial consultation to review your profile and recommend the right programme for your citizenship and tax planning goals. Our Swiss-based team in Zurich advises German-speaking investors with full fluency in the Wegzugsbesteuerung and StAG reform context. With 250+ successful citizenship cases, a 99% approval rate, IMC membership, and ACAMS certification, Mirabello is the Swiss standard in investment migration. Book your free consultation today and receive a personalised recommendation within 48 hours.