By JUAN PABLO ROJAS PASCUAL – ROJAS PASCUAL – Abogados – Argentine attorney focused on the legal structuring and design of Autonomous Companies, AI-Automated Companies, Argentina Citizenship by Investment, and related international legal matters.

Key Facts:

• Legal basis: Decree 366/2025 amended Law 346 to recognize a relevant investment as a separate basis for naturalization.

• Procedure: Decree 524/2025 established the administrative process for investment-based citizenship applications.

• First reviewing authority: Agency of Programs for Citizenship by Investment.

• Final decision-maker: National Directorate of Migration (DNM).

• Due diligence: May involve security, financial, criminal-record, identity and intelligence authorities.

• Financial review: The Government has announced scrutiny of source, legality and traceability of funds.

• Investment routes announced: USD 350,000 non-refundable contribution or USD 800,000 public-security subscription.

• Residence: The investment route does not require the ordinary two-year continuous-residence period.

• 30-business-day period: Applies to the DNM’s decision after it receives the Agency’s report.

• Overall timeline: No fixed total processing period should be promised solely on the basis of the 30-business-day DNM period.

• Current implementation: The Argentine Government announced that the program would be operational to receive applications during Q4 2026.

How Does the Argentina Citizenship by Investment Process Work? Stages, Authorities and Timeline.

Argentina’s Citizenship by Investment Program creates a distinct legal pathway for foreign nationals who make a qualifying investment in Argentina and seek Argentine citizenship through naturalization.

For international investors, however, the process should not be understood simply as “make the investment and receive a passport.” The Argentine legal framework establishes a structured administrative process involving the Agency of Programs for Citizenship by Investment and the National Directorate of Migration (Dirección Nacional de Migraciones, or DNM), together with background, financial, security and other governmental reviews.

The legal framework was established in 2025, when Decree 366/2025 amended Argentina’s Citizenship Law to recognize a relevant investment as an independent basis for naturalization, regardless of the applicant’s period of residence in Argentina. Decree 524/2025 subsequently established the administrative procedure through which investment-based citizenship applications are evaluated.

In October 2026, the Argentine Government announced the launch of the program and stated that it would be operational to receive applications during the fourth quarter of 2026. The Government also announced two investment mechanisms: a USD 350,000 non-refundable contribution to the National Treasury and a USD 800,000 subscription to a public security created specifically for the program.

For a foreign investor, understanding who evaluates the application, what happens at each stage, and what the 30-business-day period actually means is essential before committing capital.

Direct Answer:

The Argentina Citizenship by Investment process is structured around several stages: investment qualification, application before the Agency of Programs for Citizenship by Investment, governmental due diligence, the Agency’s reasoned recommendation, and a final decision by the National Directorate of Migration.

Under Decree 524/2025, once the Agency determines that the applicant’s investment qualifies as a “relevant investment,” it requests information from various government bodies, including the Ministry of National Security, the Financial Intelligence Unit (UIF), the National Criminal Records Registry, RENAPER and the State Intelligence Secretariat (SIDE), as well as other public or private entities when necessary. The Agency then submits a reasoned report recommending approval or rejection to the DNM.

The DNM has 30 business days from receipt of the Agency’s report to issue a reasoned decision granting or rejecting the citizenship application. This should not be confused with a 30-business-day guarantee for the entire citizenship process.

The overall timeline will therefore depend on several factors, including document preparation, the complexity of the applicant’s financial and personal profile, governmental due diligence, the Agency’s evaluation and the operational rules applicable when applications are formally received.

1. The Legal Foundation of Argentina’s Citizenship by Investment Program

The first point to understand is that Argentina’s investment-based citizenship route is legally distinct from the traditional naturalization pathway.

Under Article 2 of Law 346, as amended by Decree 366/2025, foreign nationals may qualify for naturalization through a relevant investment regardless of the length of their residence in Argentina. The same amendment created the Agency of Programs for Citizenship by Investment and assigned it responsibility for receiving and evaluating investment-based citizenship applications.

This distinction is important for international investors.

The investment route should not be analyzed as merely a faster version of the ordinary two-year residence pathway. It is a separate legal basis for naturalization with its own investment, evaluation and administrative framework.

For investors who have no intention of relocating to Argentina before applying, this distinction can be particularly significant.

2. Who Handles the Application?

One of the most important aspects of the program is the division of responsibilities between the different Argentine authorities.

The Agency of Programs for Citizenship by Investment

The Agency of Programs for Citizenship by Investment, operating within the Ministry of Economy, is responsible for receiving and evaluating investment-based citizenship applications.

Its statutory responsibilities include implementing citizenship-by-investment programs, receiving applications, requesting information from relevant governmental and private entities, evaluating applications and submitting a reasoned recommendation to the DNM.

The Agency therefore plays a central role in the substantive evaluation of the investor.

The National Directorate of Migration

The National Directorate of Migration, or DNM, is responsible for issuing the final administrative decision.

Once it receives the Agency’s reasoned report, the DNM must analyze that report and issue a reasoned decision granting or rejecting the citizenship application within 30 business days.

This distinction matters because the Agency and the DNM are not interchangeable.

The Agency evaluates and recommends.

The DNM decides.

3. Stage One: Pre-Application Legal and Eligibility Review

For a sophisticated international investor, the process should ideally begin before the formal application.

A pre-application legal review can identify potential issues before capital is committed or documents are submitted.

This review may include:

• nationality and identity;

• immigration history;

• criminal-record history;

• international residence history;

• family circumstances;

• source of wealth;

• source of funds;

• corporate ownership;

• trusts and other wealth structures;

• banking relationships;

• tax documentation;

• sanctions or regulatory exposure;

• and reputational issues that could require clarification.

This is particularly important for high-net-worth individuals whose wealth is spread across several countries or legal entities.

The objective is not simply to determine whether the applicant has sufficient funds.

The objective is to determine whether the applicant’s investment, financial history and personal profile can be documented consistently and withstand governmental due diligence.

4. Stage Two: Determining Whether the Investment Qualifies

The investment itself must qualify under the applicable Argentine rules.

Decree 366/2025 established that the Ministry of Economy determines which investments qualify as “relevant investments” for purposes of investment-based citizenship.

The Argentine Government subsequently announced two mechanisms for the current program:

USD 350,000 route

A direct, non-refundable contribution of USD 350,000 to the National Treasury.

USD 800,000 route

A subscription of USD 800,000 to a public security created specifically for the Citizenship by Investment Program.

These two alternatives should not be treated as economically interchangeable.

The USD 350,000 route involves a non-refundable contribution.

The USD 800,000 route involves a public-security structure whose legal and economic characteristics should be reviewed carefully before an investor commits capital.

A sophisticated investor should therefore evaluate not only the nominal amount, but also the legal nature of the transaction, the rights associated with the investment, the treatment of the capital and the consequences of an unsuccessful citizenship application.

5. Stage Three: Filing the Citizenship Application

Under Decree 524/2025, a foreign national who has made a relevant investment may apply for citizenship before the Agency of Programs for Citizenship by Investment.

This is an important point in understanding the architecture of the program.

The application does not simply begin with the DNM.

The Agency is the initial specialized authority responsible for evaluating whether the investment qualifies and whether the applicant should receive a favorable recommendation.

The precise operational requirements for filing, including forms, documentary specifications, submission mechanics and other administrative details, must be considered together with the implementing rules applicable when the program receives applications.

For that reason, investors should rely on official Argentine regulations and administrative instructions rather than unofficial intermediaries or promotional summaries.

6. Stage Four: Government Due Diligence

Once the Agency determines that the investment meets the applicable requirements, the process moves into a broader governmental review.

Decree 524/2025 expressly provides for the involvement of multiple authorities.

The Agency may request information from:

• the Ministry of National Security;

• the Financial Intelligence Unit (UIF);

• the National Criminal Records Registry;

• RENAPER;

• the State Intelligence Secretariat (SIDE);

• and other public or private entities considered necessary.

The purpose is to determine whether granting citizenship could represent a risk to national security or national interests.

The Argentine Government has also stated that the program will incorporate due-diligence, financial-transparency and risk-management standards aligned with OECD and FATF recommendations. The Government specifically identified identity verification, source and traceability of funds, financial and asset analysis, jurisdictional risk, criminal and reputational background, and immigration history as elements of the review.

For an international investor, this means that the citizenship application is also a compliance exercise.

7. Source of Wealth and Source of Funds

For high-net-worth applicants, the financial component of the application deserves particular attention.

There is an important distinction between Source of Wealth and Source of Funds.

Source of Wealth

Source of Wealth explains how the applicant accumulated his or her overall wealth.

For example, an applicant may have accumulated a USD 20 million fortune through:

• entrepreneurship;

• sale of a company;

• investments;

• real estate;

• professional activities;

• inheritance;

• or a combination of these.

Source of Funds

Source of Funds addresses the specific capital being used for the citizenship investment.

An applicant may have a substantial overall net worth but use USD 800,000 generated from the recent sale of a business interest.

That transaction should be capable of being documented independently.

For complex investors, the relevant documentation may extend across several entities, banks and jurisdictions.

The objective is to establish a coherent documentary chain from the creation of wealth to the specific funds used for the investment.

8. Stage Five: The Agency’s Reasoned Recommendation

After conducting its review and receiving the relevant reports, the Agency prepares a reasoned report.

The report recommends either approval or rejection of the citizenship application.

Decree 524/2025 expressly provides that where the investment does not qualify as relevant, or where the areas consulted recommend against granting citizenship, that circumstance must be reflected in the report submitted to the DNM.

This is a critical stage because it represents the transition between the Agency’s substantive evaluation and the DNM’s final administrative decision.

The investor should therefore understand that satisfying the investment threshold does not automatically result in a favorable citizenship decision.

The applicant must also pass the broader legal and governmental evaluation.

9. Stage Six: The National Directorate of Migration Makes the Final Decision

The final decision is issued by the National Directorate of Migration.

Once the DNM receives the Agency’s report, it has 30 business days to analyze the report and issue a reasoned decision granting or rejecting the application.

This is one of the most frequently misunderstood aspects of the program.

The 30-business-day period is not necessarily the total processing time.

The 30-day period begins when the DNM receives the Agency’s report.

It does not mean that an applicant necessarily receives a final decision 30 business days after submitting the initial application.

Before the DNM receives that report, the file may have to go through:

application → investment qualification → governmental information requests → due diligence → Agency evaluation → reasoned Agency report → DNM review.

Accordingly, the overall processing period cannot simply be equated with the statutory 30-business-day period applicable to the DNM’s decision.

10. What Happens After a Favorable Decision?

Once citizenship is granted, the legal process moves into the documentation stage.

The amended Citizenship Law provides that the DNM grants the naturalization certificate and coordinates with RENAPER so that the relevant information can be used for issuance of the Argentine national identity document (DNI).

For international applicants, the practical implementation of post-approval formalities should be reviewed under the rules and administrative procedures applicable at the time the citizenship is granted.

The acquisition of citizenship and the subsequent issuance of identity and travel documents are related but legally distinct steps.

This distinction is important when advising clients who are planning international travel immediately after naturalization.

11. How Long Does Argentina Citizenship by Investment Take?

At present, it would be inappropriate to promise a fixed overall processing time.

The legal framework establishes a specific 30-business-day period for the DNM to decide after receiving the Agency’s report.

But that is not a statutory guarantee for the entire process.

The total timeline can depend on factors such as:

• how quickly the applicant can assemble the required documents;

• whether foreign documents require apostille or legalization;

• translation requirements;

• the complexity of the applicant’s financial structure;

• the number of jurisdictions involved;

• governmental due diligence;

• requests for additional information;

• the Agency’s evaluation;

• and the administrative implementation of the program once application intake begins.

The Argentine Government announced that the program would be operational to receive applications during the fourth quarter of 2026.

Accordingly, applicants should distinguish between a legally established decision period for the DNM and the total time required to complete the entire citizenship process.

12. Does the Applicant Need to Live in Argentina?

The investment route is specifically designed to operate independently of the ordinary two-year continuous-residence requirement.

Article 2 of Law 346, as amended by Decree 366/2025, provides that foreign nationals may qualify through a relevant investment regardless of the length of their residence in Argentina.

That does not mean that the applicant is exempt from all procedural or documentation requirements.

Rather, it means that the investment-based naturalization route has a different legal basis from the ordinary residence-based route.

For internationally mobile investors, this distinction can be highly significant.

13. What Should an International Investor Do Before Applying?

A sophisticated applicant should not begin with a form.

The better approach is to begin with a legal assessment.

A comprehensive pre-application review should ideally answer five questions:

1. Is the applicant eligible?

The applicant’s personal, immigration, criminal, reputational and financial background should be reviewed.

2. Is the investment legally appropriate?

The proposed investment should be compared against the applicable program rules and official implementation requirements.

3. Can the wealth be documented?

The applicant should be able to explain how the overall fortune was accumulated.

4. Can the investment funds be traced?

The specific capital being used for the investment should have a clear and documentary source.

5. Is the application procedurally ready?

Foreign civil records, criminal certificates, corporate records, financial documents and other evidence should be reviewed before filing.

This preparation can be particularly valuable for HNWIs, entrepreneurs, family offices and internationally structured families.

14. Why Legal Counsel Matters in an Investment-Based Citizenship Application

An investment migration application is not simply a financial transaction.

It is a legal process involving immigration law, citizenship law, administrative procedure, financial compliance, documentary evidence and, in many cases, international private-client considerations.

For an international investor, legal counsel can help bridge the gap between the investor’s existing wealth structure and the documentary requirements of an Argentine citizenship application.

The objective is not to guarantee an outcome.

No responsible lawyer should promise that.

The objective is to identify legal and documentary risks before they become problems in the governmental review.

For a high-net-worth applicant, that can include reviewing the structure of the applicant’s wealth, the origin of the investment funds, foreign corporate entities, family relationships, immigration history and the documentation supporting the application.

Frequently Asked Questions.

Is Argentina Citizenship by Investment already legally established?

Yes. Decree 366/2025 amended Argentina’s Citizenship Law to establish relevant investment as a basis for naturalization, and Decree 524/2025 established the administrative procedure and institutional roles. The Government announced the launch of the program in October 2026 and stated that it would be operational to receive applications during Q4 2026.

Who receives the citizenship application?

The application is submitted to the Agency of Programs for Citizenship by Investment, which evaluates the investment and the applicant before sending a reasoned recommendation to the National Directorate of Migration.

Who makes the final decision?

The National Directorate of Migration makes the final decision through a reasoned administrative act.

Does the 30-business-day period cover the entire process?

No. The 30-business-day period applies to the DNM’s decision after it receives the Agency’s report. It is not a statutory deadline for the entire application process.

Does the applicant need two years of residence in Argentina?

No. The investment-based naturalization route is legally distinct from the ordinary two-year continuous-residence pathway.

Will the applicant’s financial history be reviewed?

Yes. The Government has stated that the program will include review of the legality and traceability of funds, financial and asset information, jurisdictional risk and other due-diligence factors.

Does making the required investment guarantee citizenship?

No. The investment is one component of the legal framework. The application is subject to governmental evaluation and a final decision by the DNM.

Conclusion:

Argentina’s Citizenship by Investment Program should be understood as a structured legal and administrative process, not as a simple transaction in which an investor exchanges capital for a passport.

The current framework establishes a clear institutional architecture.

The Agency of Programs for Citizenship by Investment evaluates the investment and the applicant, coordinates the relevant governmental reviews and submits a reasoned recommendation.

The National Directorate of Migration then makes the final decision.

For the investor, the most important practical distinction is that the 30-business-day period applies to the DNM’s decision after receipt of the Agency’s report, rather than necessarily representing the total duration of the application process.

For high-net-worth individuals and internationally structured families, the most effective strategy is therefore to prepare before filing: review eligibility, document the source of wealth, establish the source and traceability of the investment funds, assess the investment structure and identify potential regulatory or documentary issues in advance.

The stronger the legal preparation before submission, the clearer the applicant’s position will be when the file enters governmental due diligence.

Legal Assistance for Argentina Citizenship by Investment

If you are considering Argentine Citizenship by Investment, professional Argentine legal counsel can help you evaluate the legal structure of the application before capital is committed.

At Rojas Pascual Abogados, we assist international investors and families with Argentine citizenship matters, including investment-based naturalization, eligibility analysis, documentation, source-of-funds preparation and the legal aspects of the application process.

For international investors, the objective is not merely to submit an application. It is to approach the Argentine citizenship process with a legally structured, documented and defensible file.

Author: Dr. Juan Pablo Rojas Pascual.

Attorney at Law — Mendoza, Argentina

ROJAS PASCUAL – Abogados.  Argentine Legal Counsel for International Investors and Families