Recent Policy & Legal Developments

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The Italian investment migration landscape has undergone several significant policy adjustments in recent years, driven by global competition for capital, EU-aligned regulatory compliance, and domestic reform agendas. Most notably, Italy has enhanced its Investor Visa for Italy (IVI) framework while maintaining a clear pathway from temporary residence to permanent residency and citizenship. These changes have made Italy an increasingly attractive jurisdiction for ultra-high-net-worth individuals (UHNWIs) seeking European residency with long-term strategic benefits.

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2023–2025: Refinements to Investment Thresholds and Efficiency

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Since 2023, the government has taken targeted measures to streamline the IVI process and increase its attractiveness. Key changes include:

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• Digitalization of the application portal through Invitalia (the official national agency for inward investment), allowing fully online submission, preclearance, and document review.
  
• Maintenance of the reduced investment thresholds introduced in 2020: €250,000 for innovative startups and €500,000 for Italian limited companies, which have remained competitive compared to other EU programs.
  
• Faster issuance of Nulla Osta (no objection certificate)—currently averaging 30–45 days, down from 90+ days pre-reform.

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No substantial legislative amendments have been made to the Citizenship Law (Law No. 91 of 1992) in the context of the IVI program. However, the authorities have issued new administrative circulars emphasizing the importance of AML/KYC compliance and requiring stricter documentation of investment execution, particularly in the real estate and corporate acquisition tracks.

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EU Alignment and AML Compliance Pressure

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The Italian program continues to face scrutiny from the European Commission, which has discouraged “golden passport” regimes while tolerating investment residency programs that require genuine ties and long-term integration. As such, the IVI is increasingly framed as a strategic business migration route rather than an expedited naturalization channel.

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In 2024, the Ministry of Interior issued Circular No. 318/2024, requiring all investor applicants to file enhanced documentation under EU AMLD6 provisions, including proof of beneficial ownership, cross-border banking certifications, and declarations of politically exposed person (PEP) status. While these measures have raised compliance burdens, they have simultaneously enhanced the reputation and durability of the Italian investor residency program.

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Grace Periods and Retroactive Application

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Notably, changes to procedural requirements have not been applied retroactively. Applicants approved under prior regulatory frameworks retain the right to renew and convert permits under the original conditions. However, any upgrade in investment route (e.g., increasing from startup to company shares) is treated as a new application and must meet current standards.

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