North Macedonia’s law still carries the investor citizenship clause

North Macedonia’s law lets a foreigner naturalise on the ground that admitting them serves a particular national interest — scientific, economic, cultural, sporting or otherwise. The European Commission calls the economic limb of that provision an investor citizenship scheme, and in December 2025 it told Skopje to “abolish the scheme and repeal its legal basis”. Nine months later the provision is where it was: the Ministry of Interior’s published consolidation of the citizenship law still carries it, and the ministry’s legislation page lists no amendment after 2022.

That distance between what the Commission has asked for and what the statute book shows is what an investor weighing this route has to price.

What Article 11 actually requires

The Law on Citizenship of the Republic of North Macedonia, in the editorially consolidated text the Ministry of Interior publishes, runs to the base law of 1992 and six sets of amendments, the last of them in 2022. Article 11 is short. A foreigner who meets the conditions in Article 7(1), items 1 and 8, may naturalise if doing so represents a particular scientific, economic, cultural, sporting or other national interest. The Government sets the criteria for that interest by decree. The Government gives an opinion on whether the interest exists in a given case. A spouse may come in alongside, on the conditions Article 9 sets for spouses.

Two features of that drafting decide what the route is.

The first is that the law fixes no sum of money. The words for euro and for investment, and the figure 400, appear nowhere in the consolidated text. The criteria are delegated to a Government decree — an instrument the Government makes, not one the Assembly votes on. This check did not read the decree now in force, so nothing here establishes what, if anything, it requires in cash.

The second is the cross-reference. Article 11 is a naturalisation provision and sits in the same part of the law as the ordinary route. Article 7(1) sets out ten conditions for that ordinary route. Article 11 incorporates two.

The eight conditions this route does not incorporate

Article 7(1) condition for ordinary naturalisation	Incorporated by Article 11
1) has reached 18	yes
2) seven years’ lawful, continuous residence before applying	no
3) secured housing and a permanent source of subsistence	no
4) no prison sentence of at least a year, at home or in the state of nationality	no
5) no criminal proceedings pending, at home or in the state of nationality	no
6) command of Macedonian sufficient to be easily understood	no
7) no residence-ban measure in force	no
8) admission must not endanger the security and defence of the state	yes
9) signs an oath of loyalty	no
10) release from the previous citizenship, or proof it will follow	no

Read down that column and the shape of the route is plain. Article 11 does not pick up the residence qualification, the language test, the subsistence test, the oath or the release-from-citizenship requirement. The absence of an incorporated residence condition is what makes sense of the Commission’s description of North Macedonian law as allowing citizenship “without prior residence requirements”.

What remains is not only the security condition in item 8. Article 11 sets a substantive requirement of its own — that the admission represent a particular national interest — and puts two further steps around it: criteria fixed by Government decree, and a Government opinion on whether the interest exists in the case at hand. The statute names all three. What it does not contain is the decree’s detailed criteria, or any indication of how an individual opinion is arrived at.

Items 4 and 5 are not incorporated either. Read them precisely: item 4 bars a prison sentence of at least a year for offences prosecuted ex officio, and item 5 bars pending criminal proceedings — two specified restrictions, not a general clean-record test. Their non-incorporation does not tell a reader that criminal history goes unexamined, since it may be weighed under the security condition or under criteria in the unread decree. It tells a reader that the statute does not impose those two restrictions on this route.

One more limit is worth stating rather than glossing. Article 7 contains paragraphs requiring a refusal on security grounds to be reasoned and setting time limits for the decision; the law does not say whether those paragraphs govern an Article 11 case, and this article does not assume they do.

What the European Commission has asked for

The Commission’s report under the Visa Suspension Mechanism, published on 19 December 2025, puts North Macedonia among the neighbouring countries where such programmes “persist”, and describes the provision as national legislation allowing citizenship “without prior residence requirements to individuals deemed to represent a ‘special economic interest’ for the country.”

Its recommendation is not a request to tighten criteria. It reads: “Investor citizenship scheme: North Macedonia must abolish the scheme and repeal its legal basis, provide information on the applications already submitted under the ‘special economic interest’ provision and ensure that all such applications undergo rigorous background checks.”

Two things follow. The first is that under the revised mechanism, operating such a programme is in itself a ground on which the Union may suspend a third country’s visa-free status — the mechanism this publication set out in July. The second is that the recommendation asks for abolition and repeal, in those words. Whether any particular redraft would satisfy it is a question about the redraft, and this check is not in a position to answer it.

The Commission’s enlargement report on North Macedonia, published six weeks earlier on 4 November 2025, states a narrower position: that the law’s implementation “should not lead to the systematic granting of citizenship in return for investment”, because it may be used to bypass the short-stay visa procedure and the assessment of individual migratory and security risks that goes with it. A warning against systematic granting and a demand for abolition are not the same instruction, and the December document is the later one.

The reports record few grants

The two documents count over different periods and should be read separately rather than added. The visa-suspension report records one citizenship granted under the provision in 2023 and two in 2024. The enlargement report records two in 2024, both to Turkish nationals, and one in 2025, to a national of Bosnia and Herzegovina — a figure published on 4 November and therefore not a full year.

Neither document gives a figure for applications made under the provision. The same visa-suspension report does carry application counts for other schemes it examines, so the omission is particular rather than a rule the document follows throughout; and the Commission’s recommendation separately asks Skopje to “provide information on the applications already submitted”. What a prospective applicant can read, then, is the number of grants, and not the number of people who asked.

What is not established

Trade and general press reported that a draft amendment to the citizenship law entered public consultation in June 2026, and reporting on 14 September said the Union does not regard it as going far enough. This publication has not read that draft. ENER, the register where those reports say the consultation was opened, did not answer a connection today from either of the two networks used for this check — so the original record was not read, and nothing above describes what the draft would change.

Three further points stay open. The Government decree carrying the criteria, and any figure in it, was not read in its current text. The Assembly’s register of materials received shows no citizenship bill among the entries for the ten days to 10 September 2026, which is the most recent page of that register and supports nothing wider. And whether the Government has settled a bill without yet sending it to the Assembly is not something either register answers.

What to watch

Three developments would move the position. An amended criteria decree would change the operative criteria without an Assembly vote. A bill tabled in the Assembly would give a text against which any proposed change, repeal included, could be read. And the Commission’s next report under the visa suspension mechanism is where its assessment of whatever Skopje does would next appear. Until then, the published provision is what the consolidated text shows: two incorporated conditions, a national-interest requirement whose criteria are set by decree, and a Government opinion on whether that interest exists.