The Caribbean’s new citizenship regulator has no published start date

Five Eastern Caribbean states have written the treaty creating a common regulator for their citizenship-by-investment programmes into national law, but no commencement order and no announced ratification trigger could be found in the official record on 27 August 2026.

Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia signed an agreement in September 2025 placing their citizenship-by-investment programmes under a single regional regulator, and by 1 December 2025 all five had enacted it. Eleven months on, an investor cannot establish from the public record when the new standards begin to apply to an application, because the two events that would start them have not been announced.

What the five parliaments actually did

Signature ran over six days, not one: the witness block in the agreement records Antigua and Barbuda, Dominica and Saint Kitts and Nevis signing on 18 September 2025, Saint Lucia on 22 September and Grenada on 23 September. The OECS Commission announced it on 24 September and set a deadline of October 2025 for enabling legislation.

They came close. Dominica’s Parliament passed its bill on 14 October and Saint Kitts and Nevis followed on 17 October. Antigua and Barbuda’s became Act No. 18 of 2025 on assent on 6 November, Grenada’s Act No. 19 of 2025 on 24 November.

The Eastern Caribbean Central Bank confirmed on 1 December that all five had enacted the agreement, and that the authority was “expected to become operational in 2026” — without naming a date.

Enactment is not the switch, and there are two of them

Antigua’s act does not commence on assent. Section 1(2) reads: “This Act shall come into force on a date to be appointed by the Minister by Order published in the Gazette.” Grenada’s section 1(2) is word for word the same.

The Antigua and Grenada statutes were read in full; the equivalent provisions in the Dominica, Saint Kitts and Nevis and Saint Lucia acts were not obtained and are not described here. The Antigua memorandum makes the sequencing explicit, noting that ratifying the agreement and appointing technical staff to the authority’s offices are steps that “can be taken before the legislation comes into force”.

The second switch sits in the treaty. Section 4(1) provides that, “subject to this Act”, the agreement has the force of law, and section 4(2) adds that it “shall enter into force in accordance with Article 95”.

Article 95.1 sets that trigger at the thirtieth day after the fifth instrument of ratification is deposited with the Director General; Article 96 offers an earlier route, under which the agreement applies provisionally once three states declare that they will apply it so. Article 95.2 then confines the regime to applications “made after its entry into force or after its provisional application”.

Neither switch has left a public trace.

No commencement order under section 1(2), no announcement of a fifth deposit and no declaration of provisional application was located on the legislative sites of Antigua and Barbuda and Grenada, in the OECS Commission pressroom, in the central bank’s news feed, or on the five national citizenship unit news pages, searched on 27 August 2026. That is an absence in the sources reviewed, not proof that nothing has been done.

The clearest official account of where the project stood is the central bank’s statement of 28 April 2026: an Interim Regulatory Commission was still establishing the authority, and “recruitment for a Chief Executive Officer for ECCIRA and other positions is progressing, in preparation for its operationalisation later this year”.

The statement describes institutional readiness in April. It settles nothing about the legal position in August, and the two are not the same question.

What the standards will require once they apply

The agreement is not a statement of principle. Article 48 requires every main applicant and every named dependant to commit to being physically present in the granting state for an aggregate of at least 30 days across the first five calendar years after the grant.

Each of them is required to be present for not less than five days in the first twelve months; the balance of the 30 may be shared across the family. A mandatory integration programme sits alongside the presence requirement.

Article 56 makes a personal interview a mandatory component of due diligence and requires a unit to suspend or reject an application where the applicant fails to attend without just cause.

The requirement reaches dependants aged 18 and over, and those aged 12 and over where due diligence has raised a material concern; recordings are held for 15 years. Under Article 47, on the board’s recommendation, the Council of Ministers determines the maximum number of applicants who may be granted citizenship in each state in a financial year.

Biometrics show how much is still undecided. Article 51.1 obliges national units to collect and protect biometric data, but the categories, the security measures and the retention periods are all matters on which “the Authority shall issue standards and guidelines”.

No such standards were located on the central bank or OECS Commission sites on 27 August 2026, and open search reached no separate website or document register for the authority. On the domestic side, the Antigua memorandum envisages that data-protection and biometric detail will come in regulations.

What binds today is national

Saint Kitts and Nevis has not waited for the region. Its citizenship unit says the National Biometric Enrolment and Passport Modernisation Programme launched on 14 April 2026, and that “biometric enrolment is a mandatory component of all new citizenship applications submitted from 14 April 2026 onwards”.

Every citizen who acquired citizenship through the programme, dependants and children included, must enrol by 31 July 2027, after which only biometric-enabled passports are accepted for travel.

Enrolment costs USD 2,500 for a main adult applicant aged 16 or over, USD 2,000 for a second adult and USD 1,300 for a child under 16, reduced by 10 per cent where enrolment is completed between 20 July and 31 December 2026. The unit publishes the requirement and the deadline; the instrument imposing them is not identified on that page.

The distinction matters to anyone costing a family file. A regional standard that has not been shown to apply carries no charge yet. A national requirement with a 2027 deadline and a published fee schedule is a present obligation on families who already hold these passports — and at standard rates a couple with two children under 16 pays USD 7,100 to comply.

The exposure sits in the pending file

Grenada shows how the two layers are meant to meet. The Citizenship by Investment (Amendment) Bill, 2026 would amend the 2013 programme act to recognise the authority, make its prequalification a precondition of any local agent’s licence, and write the 30-day presence requirement into domestic law.

Grenada’s Ministry of Legal Affairs records that the bill was debated in the Senate on 31 July 2026. It does not say the bill was passed, and that could not be established.

Its commencement clause is again a ministerial order. Its proposed section 7A(6) states that the residency provisions “apply to applications submitted on or after the coming into force of the ECCIRA Agreement Act and may be applied retroactively to pending applications at the discretion of the Minister, subject to transitional guidelines”.

Enacted and commenced in that form, the clause would let a file already lodged in Grenada be pulled under the new presence obligations by ministerial decision rather than by the date it was filed. The transitional guidelines that would frame that decision have not been published.

Antigua and Barbuda has been reported to be moving its own amendment. No such bill and no corresponding act appeared on the government’s published legislative index when it was checked on 27 August 2026, so its contents are not described here.

What to watch

Three developments would move this from expectation to obligation, and each answers a different question. A commencement order in a national gazette brings that state’s act into force, and only that state’s. Confirmation that a fifth instrument of ratification has been deposited, or that three states have declared provisional application, starts the agreement itself.

The authority’s first standards and guidelines under Article 51.3 settle what biometric data is collected and how long it is kept. Until at least the first two are on the record, an application filed in the Eastern Caribbean is governed by the national programme it was filed under — and, in Grenada’s case, by a discretion that has still to be written down.

Updated 4 September 2026. The Authority has published a commencement window on its own website: a window rather than a date, and one that says nothing about whether the Agreement has entered into force.

The Authority publishes a window, and it is not a date

Every statement in this update about the Authority’s website describes what those pages carried when they were read on 4 September 2026.

The About page of the Eastern Caribbean Citizenship by Investment Regulatory Authority carried a timeline whose final entry read “LATE 2026”, against the line “ECCIRA will commence operations in Grenada”.

That is a window rather than a date, and the page offered nothing narrower.

The two earlier steps on the same timeline are also placed in periods rather than on single dates: the Agreement was signed by the Heads of Government “18 TO 23 SEPTEMBER 2025”, and “OCTOBER TO NOVEMBER 2025” the enabling bill “was passed in the national parliaments of the five participating states to give effect to the ECCIRA Agreement in domestic law”.

Commencing operations is not the same as entering into force

Article 95.1 of the Agreement, read for the 27 August article, provides that the Agreement enters into force on the thirtieth day following the date of deposit of the fifth instrument of ratification.

Commencing operations and entering into force are two different events. The first is an operational milestone the Authority sets for itself, and it has now stated one.

The second is governed by the treaty provision above, whose trigger is the deposit of the fifth instrument of ratification. Nothing on the pages read for this update links the two, gives a date for that deposit, or states that it has occurred.

The Media Releases page carried four items, the most recent dated 2 July 2025, all issued by the Interim Regulatory Commission through the Eastern Caribbean Central Bank: draft legislation, in-country consultations, the appointment of a legal drafting consultant, and the establishment of the Commission itself.

None of the four mentions ratification, a deposit, or entry into force. The Updates page — described on the site as the place for “Operationalisation updates, stakeholder notices, and general public information” — stated “No updates published yet”.

What is still open

The About page stated that the Authority “is led by five key executive and management positions” and that “Recruitment is ongoing and appointments will be announced on this website”.

The five are a Chief Executive Officer, a Legal Counsel and Corporate Secretary, a Chief Corporate Services Officer, a Chief Licensing and Compliance Officer, and a Chief Research and Complaints Officer. The Recruitment page carried no vacancy documents, and said they “will be published here once approved by the Authority”.

So the information published by the Authority has moved on one point and not on the other. The 27 August article found no published start date; the Authority’s site now publishes a window, which is not a date.

Whether the Agreement has entered into force is a separate question, and the pages read for this update do not resolve it — which is a statement about those pages, not about the legal position.