Compare programmes: a lawyer’s comparison.
Cost, mobility, tax, family coverage and regulatory risk compared from a private-client advisory perspective.
Dominica and St Kitts and Nevis are both established Caribbean citizenship-by-investment programmes, but they are not interchangeable. Dominica is usually the more cost-efficient route. St Kitts and Nevis is usually the more premium route. The right answer depends on the client’s nationality, family composition, travel priorities, tax residence, source-of-funds profile and tolerance for regulatory risk.
Last reviewed:
Applications are subject to eligibility, due diligence, authorised-agent submission, investment completion and final approval by the relevant government authority.
The wider field, compared.
Dominica and St Kitts and Nevis are the two routes Moore Law most often advises on, but they sit within a wider field. This table summarises the investment-migration programmes at a glance before the detailed Dominica-versus-St-Kitts comparison that follows.
| Programme | Region | Principal routes | Indicative minimum (single) | Indicative timeline | Notable features |
|---|---|---|---|---|---|
| Dominica | Caribbean | Fund / Real estate | USD 200,000 | ~6 months | Most economical; long track record; UK now requires visa |
| St Lucia | Caribbean | Fund / Real estate / Bonds / Enterprise | USD 240,000 | Longest of the five | Recoverable bond option |
| Grenada | Caribbean | Fund / Real estate | USD 235,000 | ~6 months | US E-2 eligibility; visa-free China |
| St Kitts & Nevis | Caribbean | Contribution / Real estate | USD 250,000 | 3–6 months (accelerated available) | Oldest programme (1984); Dubai biometrics |
| Antigua & Barbuda | Caribbean | Fund / UWI / Real estate / Business | USD 230,000 (family of 4) | ~6 months | Best family value; 5-day presence required |
| Türkiye | Eurasia | Real estate / Deposit | USD 400,000 | ~8 months+ | Recoverable property; US E-2; not Schengen |
| Egypt | North Africa | Contribution / Real estate / Deposit / Business | ~USD 250,000 | Several months | US E-2; regional access |
| Jordan | Levant | Contribution / Deposit / Bonds / SME | ~JOD 350,000+ | Several months | Stability; regional standing |
| Vanuatu | Pacific | Contribution | ~USD 130,000 | 1–2 months | Fastest; lost EU & UK visa-free access |
| São Tomé & Príncipe | Gulf of Guinea | Contribution | ~USD 90,000 | Several months | Newest (2025); lowest cost; unproven |
| Malta | EU | — | Discontinued 2025 | — | Investor route ended by ECJ; merit/residence only |
| Austria | EU | Exceptional contribution | Discretionary | No fixed timeline | Not a programme; rare discretionary grant |
All figures are indicative minimum contributions and exclude government, due-diligence, legal and processing fees. Programme terms change frequently; we confirm current requirements at the point of engagement.
The short answer.
Dominica is usually the cost-efficient route.
Dominica normally has the lower single-applicant entry point and can be attractive for clients who prioritise contribution cost, family efficiency and current China access, provided that US travel is not the central objective.
St Kitts is usually the premium route.
St Kitts and Nevis carries the stronger programme-age narrative and a higher contribution. It is also not listed in the current Dominica-specific partial US visa suspension, although no US visa or entry outcome should be assumed.
The correct route depends on the client.
The better programme is not determined by the lowest headline price. It depends on family structure, travel priorities, source of funds, tax residence, biometric logistics and regulatory risk.
Choosing well is a question of judgement, not a comparison chart.
The two programmes compared.
Last reviewed:
| Criterion | Dominica | St Kitts and Nevis | Moore Law view |
|---|---|---|---|
| Programme age | Established in 1993 | Established in 1984 | St Kitts has the stronger programme-age narrative. |
| Fund contribution | From US$200,000 single applicant; US$250,000 for main applicant plus up to three qualifying dependants | US$250,000 for main applicant or family of up to four | Dominica is cheaper for a single applicant. For a family of up to four, the headline contribution gap narrows. |
| Real-estate route | From US$200,000 in an approved project, plus government fees | From US$325,000 for approved development or private condominium/share; from US$600,000 for single-family private home | Dominica has the lower real-estate threshold, but all transaction and government costs must be modelled. |
| Typical planning timeline | Approximately 6–9 months for a clean file | CIU decision window 120–180 days from acknowledgement; planning assumption approximately 4–6 months | St Kitts is usually positioned as the faster route. |
| Residence to qualify | None under the current CBI route | None under the current CBI route | Neither should be confused with tax residence. |
| Authorised-agent route | Required; direct submissions are not accepted | Required | Moore Law supervises the authorised agent; the agent submits the file. |
| Interview | Mandatory for applicants aged 16 and over | Main applicant required; dependants aged 16 or over may be required if necessary | Both require interview planning. |
| Biometrics | Passport/document process should be checked at the time of application | Biometric enrolment mandatory for new applications submitted from 14 April 2026 onwards; existing Citizenship Programme citizens must enrol by 31 July 2027 | St Kitts has a clear, fee-bearing biometric-enrolment logistics point that must be budgeted from the start. |
| China access | Current China–Dominica mutual visa exemption for eligible ordinary passport holders, subject to verification before travel | No equivalent current ordinary-passport China advantage identified in this review | Dominica is stronger where China access is genuinely relevant, but the benefit should be checked before advice is relied upon. |
| UK/Schengen access | Current access subject to review and change | Current access subject to review and change | Treat all visa-free access as volatile. |
| US position | Subject to a current Dominica-specific partial US visa suspension affecting certain categories | Not listed in the current Dominica-specific partial US visa suspension | St Kitts is not named in the Dominica-specific position, but no US visa or entry outcome should be assumed for either programme. |
| Tax position | Citizenship is not tax residence | Citizenship is not tax residence | Tax must be structured separately. |
| Family cost efficiency | Strong for families under the EDF route | Strong for families up to four under SISC | Model the exact family, especially adult dependants. |
| Best suited for | Cost efficiency, current China access, contribution route where US travel is not the central objective | Programme standing, speed, and clients who value not being named in the Dominica-specific US position | The choice turns on priorities, not on a single headline figure. |
| Main caution | Current Dominica-specific US visa suspension | Higher cost and fee-bearing biometric-enrolment logistics | Both remain subject to EU/Schengen review and wider CBI scrutiny. |
The comparison is a planning summary only. Programme rules, fees, travel access and regulatory positions can change.
Which route fits which client?
Choose Dominica if…
Dominica is usually the better starting point if the client wants the lower established Caribbean entry route, prefers a straightforward contribution option, has a family profile that keeps the EDF route efficient and values current China access.
- Cost efficiency is a major priority.
- China access is commercially relevant.
- The client does not rely on the passport for US visitor, study or immigration planning.
- The client wants a contribution route rather than real estate.
Choose St Kitts if…
St Kitts and Nevis is usually the better starting point if the client values programme age, premium positioning, current US profile and speed more than the lowest possible entry contribution.
- Programme reputation matters.
- Current US positioning matters.
- A family of up to four is applying under SISC.
- The client accepts biometric-enrolment logistics.
Pause before choosing either if…
The client has prior visa refusals, unclear source of funds, sanctions or PEP exposure, adverse media, complex family-dependant issues, unresolved tax residence questions or a travel objective that depends on a benefit likely to change.
- The source-of-funds file is not ready.
- There is a prior refusal from a visa-waiver partner country.
- US or Schengen access is the only reason for applying.
- The client is treating citizenship as an automatic tax outcome.
Cost by family composition.
The contribution route is usually the cleanest way to compare Dominica and St Kitts. The figures below are rounded planning estimates for clean files and must be confirmed before funds are committed.
Dominica — Economic Diversification Fund
| Applicant profile | Contribution | Due diligence | Approx. government/admin | Indicative all-in |
|---|---|---|---|---|
| Single adult | US$200,000 | US$7,500 | approx. US$3,250 | approx. US$210,750 |
| Couple, no children | US$250,000 | US$11,500 | approx. US$4,000 | approx. US$265,500 |
| Couple + 1 child under 16 | US$250,000 | US$11,500 | approx. US$4,500 | approx. US$266,000 |
| Couple + 2 children under 16 | US$250,000 | US$11,500 | approx. US$5,000 | approx. US$266,500 |
St Kitts and Nevis — Sustainable Island State Contribution
| Applicant profile | SISC contribution | Due diligence | Biometrics / passport-modernisation | Indicative government-file total before professional fees |
|---|---|---|---|---|
| Single adult | US$250,000 | US$10,000 | approx. US$2,500 | approx. US$262,500 |
| Couple, no children | US$250,000 | US$17,500 | approx. US$4,500 | approx. US$272,000 |
| Couple + 1 child under 16 | US$250,000 | US$17,500 | approx. US$5,800 | approx. US$273,300 |
| Couple + 2 children under 16 | US$250,000 | US$17,500 | approx. US$7,100 | approx. US$274,600 |
How to read the numbers.
For both programmes, the contribution route can be efficient for a family of up to four. Young children usually add modest administrative cost. Adult dependants are materially more expensive because they add contribution amounts and due-diligence requirements.
Dominica is clearly cheaper for a single applicant. For a family of up to four, the headline contribution difference narrows because both routes are around US$250,000 before fees. The St Kitts figures now also include mandatory biometric-enrolment and passport-modernisation charges, which apply per applicant and should be budgeted from the start rather than treated as an afterthought. St Kitts may still justify its higher all-in cost where programme standing, processing speed and the fact that it is not named in the Dominica-specific US position matter to the client.
The government contributions, due-diligence fees and administrative charges shown are not Moore Law fees. Moore Law’s professional fees are quoted separately.
Travel access and the moving value of a passport.
Mobility is usually the most marketable part of citizenship by investment. It is also the most volatile. Visa-free access is not owned by the citizen in the same way that citizenship is. It depends on diplomatic relations, immigration policy, document security, information-sharing and the issuing country’s ongoing standing.
Dominica currently has a notable China-access advantage through the China–Dominica mutual visa exemption, which should be verified before any travel is planned. St Kitts and Nevis is not named in the current Dominica-specific partial US visa suspension, but that is not the same as guaranteed US entry, and no US visa or entry outcome should be assumed. Both programmes must be assessed against EU/Schengen review risk and the wider direction of CBI regulation.
Treat mobility as a current planning assumption, not a permanent guarantee.
A passport is not a tax plan.
Both Dominica and St Kitts and Nevis are commonly marketed by reference to favourable tax features. The practical distinction is more important: holding the passport does not, by itself, make the client tax-resident there, and it does not sever tax obligations in the client’s current country of residence.
The tax value of any citizenship depends on the client’s residence, domicile, source of income, company structures, reporting obligations and exit from previous tax systems. That work sits outside ordinary passport broking. It belongs in legal and tax advice.
Citizenship is a legal status. Tax residence is a separate analysis.
Current regulatory issues.
| Issue | Dominica | St Kitts and Nevis | Why it matters |
|---|---|---|---|
| US visa restrictions | Subject to a current Dominica-specific partial US visa suspension affecting certain categories | Not listed in the Dominica-specific suspension, though no US visa or entry outcome is guaranteed | Critical where US visitor, study or immigration optionality matters |
| EU/Schengen scrutiny | Relevant | Relevant | The EU can use its visa-suspension mechanism where investor citizenship schemes create concern |
| OECS minimum pricing | Relevant | Relevant | Caribbean CBI discounting below agreed minimums is a serious red flag |
| Authorised-agent route | Required | Required | Applications must be handled through proper authorised channels |
| Biometrics | Check at time of application | Mandatory, fee-bearing biometric enrolment for new applications from 14 April 2026; existing CBI citizens must enrol by 31 July 2027 | Document integrity is becoming central to programme credibility, and the fees must be budgeted |
| Tax residence | Not automatic | Not automatic | Citizenship does not create or replace tax residence |
How we would approach the choice.
We would not choose between Dominica and St Kitts by passport ranking, marketing brochure or headline contribution. We would first ask what the citizenship is supposed to achieve.
If the client wants a lower-cost established route and current China access matters more than US travel optionality, Dominica may be the better starting point, provided the China benefit is verified rather than assumed. If the client wants the original programme, a more premium route and the comfort of a programme that is not named in the Dominica-specific US position, St Kitts and Nevis may justify the additional cost and its fee-bearing biometric logistics — without anyone treating US entry as guaranteed.
In either case, the route should be selected only after eligibility, family composition, tax residence, source of funds and regulatory risk have been reviewed.
The right question is not “Which passport is stronger?” It is “Which citizenship belongs in this client’s structure?”
This comparison should be read with the official programme and regulatory sources in mind.
- Dominica CBIU
- Dominica EDF
- St Kitts and Nevis CIU
- St Kitts SISC
- St Kitts Biometrics
- China–Dominica Mutual Visa Exemption
- OECS CBI Memorandum implementation
- EU visa suspension mechanism
- US State Department visa suspension note
- White House Proclamation 10998
External government and institutional sources. Programme figures and regulatory positions should be verified against these before they are relied upon.
Common questions.
Is Dominica better than St Kitts?
Dominica is usually better for cost efficiency and current China access, which should be verified before travel. St Kitts is usually better for programme age, premium positioning and speed, and it is not named in the current Dominica-specific partial US visa suspension. Neither point guarantees any US visa or entry outcome, and the correct answer depends on the client’s facts.
Is St Kitts worth the higher cost?
It can be. The premium may be justified where programme standing, speed and the fact that St Kitts is not named in the current Dominica-specific US visa suspension matter to the client. It may not be justified where the client is primarily cost-sensitive and does not need those advantages. The higher cost now also includes mandatory biometric-enrolment charges.
Which is cheaper for a family?
For a single applicant, Dominica is usually cheaper. For a family of up to four, the contribution gap narrows because both programmes have a contribution route around US$250,000 before fees. Adult dependants can materially increase the cost under either programme.
Which passport is better for travel?
That depends on the destinations that matter to the client. Dominica currently has a China-access advantage, which should be verified before travel. St Kitts is not named in the current Dominica-specific partial US visa suspension, although that does not guarantee US entry. UK and Schengen access must be treated as subject to change.
Can Moore Law tell me which one to choose?
Yes, after reviewing the client’s nationality, residence, family composition, source of funds, travel objectives, tax position and regulatory risk. Moore Law’s role is to give a suitability recommendation, not simply present two brochures.
Can approval be guaranteed?
No. Approval is always subject to eligibility, due diligence, investment completion and final government decision.