São Tomé: 350 citizenship files approved, 29 passports in year one

A first-year report on São Tomé and Príncipe’s citizenship-by-investment programme, dated 1 September 2026 and issued in the name of the Citizenship by Investment Unit, records 548 applications submitted, 350 approved, 12 rejected and 186 still in process. It also records 117 citizenships granted and 29 passports issued. The document does not appear on the unit’s own website; the copy reviewed here was obtained from the trade publication that circulated it. For anyone weighing a contribution that starts at 90,000 US dollars, the space between an approval and a passport in hand is the part worth reading closely.

Numbers the report does not put on a common basis

The application figures reconcile exactly: 350 approvals plus 12 rejections plus 186 files in process account for all 548 submissions. Of the 362 files decided, 12 were refused — a rejection rate of 3.3%.

The next two figures cannot be measured against those. An application is a file, and the report states that 256 of the 548 were family applications covering two to four people each. The report does not say whether “117 citizenships granted” and “29 passports issued” count people or files, and it gives no as-of date for either count. A reader therefore cannot calculate a conversion rate from approval to citizenship, or from citizenship to passport.

What the unit does state, in its own words, is the direction of travel. The report says: “The Unit acknowledges that the issuance of citizenship documents has not progressed at the same pace as application approvals.” It goes on to describe work with national authorities to streamline the post-approval process and expand the capacity of its São Tomé office.

That candour is worth something. It also sits against a payment sequence set by the statute. Under Decree-Law 07/2025, which regulates nationality by investment or donation and took effect on 1 August 2025, delivery of the approval certificate is conditional on the applicant depositing the contribution within 90 days, failing which the file lapses. The instrument also gives the unit 15 days to approve or refuse an application once the Public Prosecutor’s prior opinion is in or its period has run, and five days to send a completed file to the Central Registry Office after the oath of allegiance. It sets no deadline for the issue of the passport itself.

A revenue figure that cannot be reconciled exactly

The report gives one figure for money reaching the National Transformation Fund. It states: “Of the 350 applications approved during the reporting period, approximately 50% completed their qualifying contribution payments, generating over USD 9,800,000 for the National Transformation Fund.”

Neither limb of that sentence is exact. “Approximately 50%” is not a payer count, and a figure given as “over” 9.8 million dollars has no upper bound — it is as true of eleven million as of sixteen. Annex I of the decree-law fixes the minimum contribution at 90,000 US dollars for a single applicant and 95,000 for a family of two to four, plus 5,000 for each additional dependent, so roughly 175 contributions at the floor would come to at least 15.75 million dollars. That is not a contradiction; the report’s phrasing accommodates it. It is the limitation: the document does not allow a reader to establish exactly how much money reached the fund, or exactly how many applicants paid.

The contrast is with the counts the report does give precisely. The application figures sum to 548, the six nationality counts sum to 548, and the nationality shares are stated to two decimal places. Applications received across the first year came from 72 nationalities: China 159, Russia 122, Iran 50, Germany 28, ten stateless applicants and 179 others.

What the decree-law asks for, and what this document is not

The decree-law sets out accounting duties of two different kinds, and a document of this kind discharges neither.

The first has named institutional recipients and no stated public-release requirement. Article 21 requires the unit to produce a report every quarter, within 30 days of the quarter’s end, setting out applications submitted, approved and rejected, the identity of applicants and dependents, amounts invested, projects financed and the balances of the National Transformation Fund. That report goes to the Minister of Justice, the Public Prosecutor and the National Assembly. Nothing follows from the absence of a public copy: a quarterly report may have been filed with all three and never published, and the statute does not ask for more. Article 19(6) works the same way, requiring a detailed annual report on supervision and audit work to reach the Court of Auditors, the Central Bank and the Financial Intelligence Unit by 31 March each year.

The second kind is audit, and the decree-law provides for it in two places that it does not expressly link. Article 7(5) subjects the fund to a mandatory annual audit by an independent auditor and to oversight by the Court of Auditors and the Central Bank. Article 8(4) separately requires the concession contract to ensure that detailed monthly reports of inflows, outflows and balances go to the unit, the Central Bank and the Court of Auditors, and to ensure “submission to independent annual audit, selected under the law, whose results are made public”. The decree-law does not say when the first such results fall due.

The six-page document dated 1 September is not any of those things. It carries no fund balance, no auditor’s name, no audit opinion and no schedule of financed projects with amounts against them; it describes new power generators and upgraded ministry IT equipment in narrative form. Nor do any audit results appear on the unit’s website, where the report itself is also absent. That is a statement about what a reader can find, not a finding about the unit’s compliance.

How the programme is organised

The report describes the structure it operates through. São Tomé and Príncipe, it says, “is the first country to establish its Citizenship by Investment Unit outside its own country, operating through a Government-authorized structure with offices in Dubai and Sao Tome and Principe.” The Dubai head office, on the report’s account, manages application processing, due diligence and compliance, document verification and coordination with licensed marketing agents, while the São Tomé office works with government institutions.

The decree-law provides for part of that and is silent on the rest. Article 4 allows a Managing Entity, public or private, to be designated to support the administration, promotion and execution of the programme, acting under a public service concession contract when private, and permits the unit to contract external due diligence services. It does not say where the unit itself may sit.

The report names no private entity in its six pages. Separately, the Portuguese news agency Lusa reported in August 2025 that the government had awarded a ten-year public service concession to Passport Legacy, a company incorporated under Dubai law, with revenues divided 56% to the government and 44% to the company. That contract is not public, and the reporting does not establish which revenues the split applies to, nor that Passport Legacy is the structure the report describes. The unit’s website carries a testimonial from Passport Legacy’s chief executive commending the programme’s governance standards.

Two provisions to check before wiring funds

Two rules in the primary statute bear on people who already hold several passports. Article 11 of the Nationality Law of 2022 bars the grant of São Toméan nationality to anyone holding more than two foreign nationalities, and provides that a naturalised citizen who later acquires a fourth nationality loses São Toméan nationality immediately. An applicant already holding two other citizenships is at the statutory limit, and one further nationality acquired afterwards removes this one by operation of law. The trade publication that circulated the first-year report has also reported a memorandum of 10 April 2026, signed by the unit’s director, putting acceptance of applications from holders of three or more foreign passports on hold, and says parliament has not amended the restriction.

Separately, article 14 of the decree-law preserves the Public Prosecutor’s right to bring judicial opposition to an acquisition of nationality for six months after it is declared, before the administrative court, and provides that such opposition has no suspensive effect on the acquisition. Article 18 lists revocation of nationality among the sanctions the decree-law makes available.

What to watch

In August 2025 the opposition ADI announced, in reporting carried by Forbes África Lusófona and SAPO, that a group of its deputies had asked the Constitutional Court to declare the decree-law unconstitutional in successive and abstract review, arguing that it inverts nationality from a consequence of investment into a means of obtaining it. No ruling was located as at 4 September 2026, which establishes nothing about how the request has been disposed of.

Article 17 of the decree-law lets the government, for reasons of national security or diplomatic reciprocity, predetermine the inadmissibility of candidates from countries under international sanctions ratified by São Tomé and Príncipe, or from countries lacking effective judicial cooperation. Such a list takes the form of a Council of Ministers resolution published in the official gazette. No such resolution was located.

An approved applicant has 90 days to deposit the contribution or lose the file. What this report tells that applicant about the fund receiving the money is that receipts passed 9.8 million dollars in the first year. The quarterly report the decree-law directs to the Minister of Justice, the Public Prosecutor and the National Assembly would carry the balance, and the audit the concession contract must provide for would be published. Neither is among the documents a prospective applicant can read today.