Dominica’s citizenship threshold is US$200,000 before further fees

The figures Dominica’s citizenship-by-investment programme runs on are not a price list published at the regulator’s discretion. They sit in a gazetted instrument.

The Commonwealth of Dominica Citizenship by Investment Regulations, 2024 were made under section 20 of the Citizenship Act, Chapter 1:10, and gazetted on 28 June 2024 as Statutory Rules and Orders No. 8 of 2024.

Schedule 1 sets the qualifying investment amounts and the government fees. Since then one instrument has amended that Schedule, and a second has brought a different Act into operation over the top.

What Schedule 1 sets, by family size

Both routes begin at US$200,000, and after that they diverge sharply.

On the contribution route, paragraph 1(3)(a) sets a direct monetary investment of US$200,000 for a main applicant alone, US$250,000 for a main applicant and up to three qualifying dependants, US$25,000 for each additional dependant under eighteen, and US$40,000 for each additional dependant of eighteen or older.

The Unit adds on its own contribution page that no separate government fee arises on this route: those, it says, are “only relevant to applicants who invest in real estate.”

On the real estate route, paragraph 2(1) requires the purchase of a unit in an Approved Project worth at least US$200,000 for each main applicant.

Paragraph 2(3) then adds government fees on approval in principle: US$75,000 for a main applicant alone, US$100,000 for a main applicant and up to three dependants, US$25,000 for each additional dependant under eighteen and US$40,000 for each additional qualified dependant of eighteen or older.

Set the two side by side for a family of four — a main applicant, a spouse and two children under sixteen — and the difference the shared headline figure conceals becomes visible.

Family of four	Contribution route	Real estate route
Contribution, or property purchase	250,000	200,000
Government fees on approval in principle	—	100,000
Due diligence, interviews, processing, certificates	16,500	16,500
Total of the amounts above	266,500	316,500
Of which buys no asset	266,500	116,500

United States dollars, assuming no enhanced due diligence and that the two adults alone are aged sixteen or over. The sums do not fall due together: the real estate government fees arise on approval in principle, and the certificate fee is payable before each certificate issues. Neither column includes what an Authorised Agent charges for its own work, because the Regulations price the agent’s licence and not the agent’s services.

Nor does the second row say what the property is worth later. Regulation 7(3) forbids resale until three years have elapsed from the grant of citizenship, and regulation 7(4) blocks the same unit from supporting another application for five years. What a buyer will pay when those periods run is not settled by any instrument, and this article does not estimate it.

The charges that are not the contribution

Four charges apply on both routes, at paragraph 1(3)(b) and paragraph 2(3): due diligence of US$7,500 on the main applicant and US$4,000 on each dependant, US$1,000 per interview, US$1,000 per application in processing, and US$500 for each certificate of naturalisation.

The two paragraphs are not worded alike on the dependant limb — the real estate list says “each dependant sixteen years of age or older”, the contribution list says only “each dependant” — but regulation 4(13) requires due diligence on applicants aged sixteen and over, and the Unit publishes the contribution figure with that age limb.

Interviews are compulsory: regulation 4(10) requires that “every applicant shall attend an interview virtually or in person”, and the Unit adds that this means applicants aged sixteen and over, usually remotely.

Enhanced due diligence fees replace the standard due diligence fees; the interview, processing and certificate charges stand whatever happens.

Where an applicant or dependant is a citizen of a country or region specified by the Minister in a Gazette notice, regulation 11(4)(b) sets US$25,000 for the main applicant, US$15,000 for the spouse and for each dependant of sixteen or over, and US$10,000 for each dependant aged twelve to fifteen — payable, under paragraphs 1(4) and 2(4), in replacement of the standard due diligence figures.

Which nationalities that catches is harder to state than it looks: no notice under regulation 11(6) was found on the Government of Dominica register of laws on 9 September 2026, and the Unit’s own page lists Belarus, Iran, Northern Iraq, North Korea, Russia, Yemen and Sudan as subject to “explicit bans, limitations or enhanced due diligence requirements” without saying which country falls under which.

The money is committed before the decision. Regulation 7(5) allows an application to be considered only after two things have happened: all monies have been placed in an irrevocable escrow account, and an Approved Project has been deemed to have commenced.

What becomes of that money if the answer is no is less clear than it should be. Regulation 7(7) provides that where an application is denied the fees paid “in accordance with paragraph 1(3)(c) of Schedule 1” are not refundable — but paragraph 1(3), as printed by the Unit, contains only subparagraphs (a) and (b), and regulation 4(4) points to the same missing subparagraph.

Deprivation is drafted without that gap: where citizenship is withdrawn under regulation 6(1), regulation 6(2) provides that no refund is made of any fees, investments or other sums.

What the holder owes afterwards

The Regulations impose no residence obligation, and the Unit’s published answers say so twice: an applicant does not have to reside in Dominica before or after citizenship is granted, and is not required to reside there to keep it. Whether the regional agreement now adds one for families applying today is a separate question, and the last section of this article takes it up.

Three obligations do bind. Regulations 4(1)(c) and 5 prohibit a change of name, otherwise than by marriage, for five years from the certificate of naturalisation, and regulation 6(4) makes a breach a ground for deprivation.

The holding periods run from the grant, and regulation 7(6) answers a breach not with a fine but with revocation of citizenship, possible disqualification from the programme, and a sale that is null and void — or, where it cannot be nullified or voided, damages payable to the Government.

And regulation 6(5) is drafted in the mandatory: a person who “has after becoming naturalised been sentenced in any country to imprisonment for a term of not less than 12 months shall be deprived of citizenship of Dominica”.

One amendment, and one commencement

The amendment removed a limit. The Citizenship by Investment (Amendment) Regulations, 2025, gazetted on 27 November 2025 as Statutory Rules and Orders No. 46 of 2025, amend Schedule 1 by deleting from paragraph 3(1) the words “not more than five years after the main applicant obtained citizenship”.

Those words had confined the post-citizenship route to a child born or adopted within five years of the grant. Without them, a main applicant may apply to register a child under eighteen whenever the child was born or adopted, on payment of US$2,000 processing, US$4,000 due diligence where the child is sixteen or over, and US$500 for the certificate.

The Unit’s guidance now describes the position as carrying “no time restriction”.

The commencement concerns a different Act. On 22 July 2026 the Minister responsible for the programme made a Commencement Order, gazetted the following day, deeming Dominica’s Eastern Caribbean Citizenship by Investment Regulatory Authority Agreement Act, 2025 to have come into operation on 1 July 2026.

Section 5(1) gives that Act priority over any inconsistent enactment, and section 5(2) requires the country’s citizenship-by-investment law and everything made under it to “be construed and applied to conform with this Act”.

The Act also puts every agent, promoter, developer and due diligence provider on notice: under sections 25 to 29, those authorised immediately before commencement are deemed provisionally prequalified from 1 July 2026 for up to nine months, subject to earlier revocation, and must apply to the Unit within that period. The application does not extend the provisional standing, which ends on confirmation, on refusal, or on expiry, whichever comes first.

What the regional Act does not settle

The documents read on 9 September 2026 do not establish whether the regional agreement’s presence requirements have become applicable to new applications. That obligation lives in its Article 48, read here in the copy scheduled to Antigua and Barbuda’s implementing Act, Dominica’s own printed schedule being an image scan.

Under Article 48, each applicant and named dependant commits to being physically present “for an aggregate of at least thirty (30) days during or up to any of the first five (5) calendar years after the date of the grant”, with at least five of those days falling in the first twelve months.

Section 4 of Dominica’s Act keeps two things apart: the Agreement has the force of law in Dominica, but it “shall enter into force in accordance with Article 95”, which sets that date at the thirtieth day after the fifth instrument of ratification is deposited.

Article 95.2 then applies the Agreement to applications made after entry into force, or after provisional application under Article 96, which three Participating States may trigger by declaration.

No notice of a fifth deposit and no declaration of provisional application was found on the Unit’s news index, the register of laws, the OECS Commission pressroom or the Eastern Caribbean Central Bank news feed on 9 September 2026. Unsuccessful searches do not establish that neither trigger has occurred.

One thing Article 95.2 does settle. It reaches applications made after the trigger, so a grant already made is outside it either way, and the open question is confined to families applying now. For them, the Unit’s own guidance is no help: read the same day, it still makes no mention of the Authority, of a presence requirement or of an integration programme.

The two routes are therefore not two prices for the same thing. A family of four on the contribution route commits US$266,500 and holds no asset at the end of it. The same family on the real estate route commits US$316,500, of which US$116,500 is fees and US$200,000 is a unit that regulation 7(3) forbids it to resell for three years from the grant.

Neither figure includes what the Authorised Agent charges for its own work, because the Regulations set the agent’s licence fee and say nothing about the agent’s bill.