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.

Decree 524/2025: The Procedure for Argentina Citizenship by Investment Applications.

Direct Answer:

Decree 524/2025 establishes the administrative procedure applicable to applications for Argentine citizenship based on investment. Under the decree, a foreign national who has made an investment considered relevant under the criteria established by the Ministry of Economy may submit a citizenship application to the Citizenship by Investment Programs Agency.

The Agency evaluates the investment, requests information and reports from relevant public authorities and, based on that review, submits a reasoned recommendation for approval or rejection to the National Directorate of Migration (Dirección Nacional de Migraciones — DNM).

The DNM is then responsible for making the final decision through a reasoned administrative act within 30 business days from receipt of the Agency’s report.

Decree 524/2025 therefore provides the procedural framework for an individual Citizenship by Investment application. It does not itself establish the amount or specific financial instrument that constitutes a relevant investment.

Key Facts:

• Decree 524/2025 establishes the administrative procedure for Argentina Citizenship by Investment applications.

• Applications are submitted to the Citizenship by Investment Programs Agency.

• The Agency initially evaluates whether the applicant’s investment qualifies as «relevant» under the criteria established by the Ministry of Economy.

• The procedure allows for information and reports to be obtained from authorities dealing with security, financial information, criminal records, identity and intelligence.

• The National Directorate of Migration must issue a reasoned decision within 30 business days from receipt of the Agency’s report.

Introduction: What Does Decree 524/2025 Regulate?

Decree 524/2025, published in the Official Gazette on July 31, 2025, occupies a specific place within Argentina’s Citizenship by Investment framework.

While the amendments to Argentina’s Citizenship Law No. 346 established investment as a basis for naturalization and created the institutional structure responsible for developing and administering Citizenship by Investment programs, Decree 524/2025 addresses a different question:

How should an individual Citizenship by Investment application be processed?

This distinction is essential when analyzing the scope of the decree.

Decree 524/2025 does more than acknowledge the existence of an investment-based naturalization route. It establishes a defined administrative sequence, identifies the authorities involved, provides for different forms of review of the applicant, establishes the role of the National Directorate of Migration and also addresses the administrative steps necessary for obtaining a CUIT after citizenship has been granted.

The result is a procedure designed to subject an application to several stages of review before the competent authority makes its final decision.

Article 1: Who May Apply and Where Is the Application Filed?

Article 1 of Decree 524/2025 provides that a foreign national who has made a relevant investment, as determined by the Ministry of Economy under Article 2 bis of Law No. 346, may apply for Argentine citizenship under the investment-based naturalization route.

The provision also identifies the administrative body before which the application must be initiated: the application is submitted to the Citizenship by Investment Programs Agency, a decentralized agency operating within the Ministry of Economy.

This establishes the formal entry point into the procedure.

The application is not initially filed directly with the National Directorate of Migration. Instead, the Agency is responsible for the first stage of the administrative review.

Article 1 also maintains an express connection with the concept of a relevant investment. The decree does not independently define which investments qualify. Rather, it refers to the criteria established by the Ministry of Economy under Article 2 bis of Law No. 346.

The first substantive question in the procedure is therefore whether the investment made by the applicant can be brought within the applicable legal category.

Article 2: The Initial Assessment of the Investment

Article 2 establishes the Agency’s first substantive task once an application has been submitted.

The Agency must determine whether the investment made by the applicant qualifies as «relevant» under the criteria established by the Ministry of Economy.

This stage is significant because it operates as an initial qualification of the application.

The decree therefore distinguishes between an applicant’s assertion that an investment has been made and the administrative determination that the investment satisfies the requirements necessary to qualify as relevant within the Citizenship by Investment framework.

The practical consequence is straightforward: before the application proceeds through the other verification mechanisms contemplated by the decree, the Agency must assess the legal and regulatory status of the investment.

Article 3: Interinstitutional Review of the Applicant

Once the Agency determines that the investment qualifies as relevant, the procedure moves into a broader stage of review.

Article 3 provides for the Agency to request information from various public authorities and other entities so that, within their respective areas of competence, they may assess whether granting citizenship to the applicant could pose a risk to national security or national interests.

The decree expressly identifies the Ministry of National Security, the Financial Information Unit (UIF), the National Criminal Records Registry, the National Registry of Persons (RENAPER) and the State Intelligence Secretariat (SIDE).

The Agency may also request information from other public or private bodies when it considers such information necessary.

The breadth of this provision demonstrates that the procedure is not limited to verifying the existence of an investment.

An application may involve information obtained from different areas of government and from other sources considered relevant to the assessment. The purpose expressly identified by the decree is to determine whether granting citizenship could affect national security or national interests.

The Agency’s Report and Recommendation

After obtaining the relevant reports and information, the Agency must prepare and submit to the National Directorate of Migration a detailed report recommending approval or rejection of the application based on its assessment of the applicant.

The decree expressly contemplates two circumstances in which the Agency must recommend rejection: where the investment does not qualify as relevant, or where the areas consulted recommend against the granting of citizenship.

This is significant because the Agency’s report is not merely an administrative formality.

Decree 524/2025 gives the report a defined role within the decision-making process and requires it to reflect the relevant circumstances identified during the review.

Article 4: The Decision of the National Directorate of Migration

Once the Agency has completed its assessment, the procedure moves to the decision-making stage.

Article 4 provides that the National Directorate of Migration has 30 business days from receipt of the Agency’s report to analyze the application and issue its decision.

The decision must take the form of a reasoned administrative act, through which the DNM either grants or rejects the application.

This provision is particularly important because it clarifies the distribution of functions established by Decree 524/2025.

The Agency is responsible for receiving and evaluating the application and preparing its recommendation. The National Directorate of Migration is the authority that makes the decision on whether citizenship should ultimately be granted or rejected.

When Does the 30-Business-Day Period Begin?

The wording of Article 4 is precise: the 30-business-day period begins when the National Directorate of Migration receives the report prepared by the Agency.

It is therefore not a period that necessarily runs from the date on which the applicant initially submits the citizenship application to the Agency.

The application must first pass through the Agency’s evaluation and reporting stage. Only once the DNM receives that report does the specific decision-making period established by Article 4 begin.

This distinction is important when assessing the overall timeline of an application.

Article 5: CUIT for Newly Naturalized Citizens

Article 5 assigns the Agency for the Collection and Customs Control (ARCA) responsibility for making the regulatory and system adjustments necessary to enable individuals who obtain citizenship under the decree to process their Unique Tax Identification Code (CUIT).

This provision does not establish a substantive requirement for obtaining citizenship.

Its function is administrative and subsequent to the granting of citizenship. It is intended to facilitate the tax identification process applicable to a person who has become an Argentine citizen under the investment-based naturalization framework.

Its inclusion also demonstrates that the decree addresses consequences arising after the citizenship decision, rather than ending exclusively with the approval or rejection of the application.

Article 6: Complementary and Clarifying Regulations

Article 6 provides that the Citizenship by Investment Programs Agency may issue the complementary and/or clarifying regulations necessary to govern the citizenship application procedure and the evaluation of those applications.

This provision is particularly relevant when considering the practical implementation of Decree 524/2025.

The decree establishes the general procedural structure, while expressly anticipating that the Agency may develop additional rules needed to implement that framework.

Accordingly, Decree 524/2025 should not be treated as a complete statement of every operational rule applicable to an individual application.

For an applicant, foreign lawyer, family office or wealth adviser, the relevant legal analysis should therefore consider the broader body of rules in force rather than relying exclusively on the text of the decree itself.

Article 7: Entry Into Force

Article 7 provides that Decree 524/2025 enters into force on the date of its publication in the Official Gazette.

The decree was published on July 31, 2025, and therefore became effective in accordance with that provision.

The Administrative Structure Created by Decree 524/2025.

Read as a whole, the decree establishes a sequence that can be summarized as follows:

1. Relevant investment

The foreign national makes an investment that must fall within the applicable criteria.

2. Submission of the application

The Citizenship by Investment application is submitted to the Citizenship by Investment Programs Agency.

3. Assessment of the investment

The Agency determines whether the investment qualifies as relevant under the criteria established by the Ministry of Economy.

4. Interinstitutional review

If the investment passes this stage, the Agency requests information from the relevant authorities to assess whether the granting of citizenship could raise concerns relating to national security or national interests.

5. Agency report

Based on the information obtained, the Agency prepares a detailed report and recommends approval or rejection.

6. Decision by the National Directorate of Migration

The DNM reviews the Agency’s report and must issue a reasoned decision within 30 business days from its receipt.

7. CUIT

If citizenship is granted, ARCA must have the necessary regulatory and system adjustments in place to enable the new citizen to process a CUIT.

This sequence is arguably the most practical contribution of Decree 524/2025. It translates the broader Citizenship by Investment framework into an identifiable administrative procedure, with separate stages, authorities and review mechanisms.

What Does Decree 524/2025 Mean for an International Investor?

From the applicant’s perspective, the decree makes clear that Argentine Citizenship by Investment should be understood as a legal and administrative process, rather than simply as a financial transaction.

The assessment begins with the investment, but it continues with an analysis of whether that investment qualifies as relevant and, subsequently, with reviews that may involve multiple government authorities.

This can be particularly significant for international investors whose wealth structures, financial history, transactions or supporting documentation involve several jurisdictions.

The decree does not provide that demonstrating an investment is, by itself, sufficient to obtain citizenship. Instead, it expressly provides for an assessment of the applicant and interinstitutional consultations before the National Directorate of Migration makes its decision.

For this reason, proper legal preparation should address not only the structure of the investment but also the documentation necessary to present the relevant aspects of the application clearly and consistently.

A Critical Distinction: Decree 524/2025 Does Not Define the Relevant Investment.

One distinction is particularly important when interpreting the decree.

Decree 524/2025 establishes what happens once there is an application based on a relevant investment, but it expressly refers to the Ministry of Economy for the determination of which investments qualify as relevant.

The decree should therefore not be interpreted as independently establishing a particular investment amount, financial instrument or investment structure.

Its primary function is different:

It establishes the procedure through which a person who has made an investment falling within the applicable definition may apply for citizenship and undergo the corresponding administrative review.

This distinction is essential to avoid attributing to Decree 524/2025 provisions that are not contained in its text.

Decree 524/2025 as a Procedural Regulation

From a legal perspective, Decree 524/2025 can principally be characterized as a procedural and institutional regulation within Argentina’s Citizenship by Investment framework.

Its significance lies in establishing:

• who receives the application;

• who initially assesses the investment;

• which authorities may be consulted;

• what role the Agency performs;

• which authority makes the final decision;

• how long the DNM has to decide;

• the requirement that the decision be reasoned; and

• what administrative action is contemplated after citizenship is granted.

The decree therefore supplies an essential part of the administrative architecture of the program without replacing the rules that determine which investments qualify as relevant.

For professional legal analysis, the distinction between substantive citizenship law, investment criteria and administrative procedure is therefore essential.

Conclusion: The Legal Significance of Decree 524/2025.

Decree 524/2025 is a central instrument for understanding how an Argentine Citizenship by Investment application is processed.

Its principal contribution is to establish a structured administrative procedure beginning before the Citizenship by Investment Programs Agency, continuing through the assessment of the investment and interinstitutional review, and culminating in a reasoned decision by the National Directorate of Migration.

The decree also establishes a specific timeframe for the decision-making stage: 30 business days from the date on which the DNM receives the Agency’s report.

At the same time, the text of the decree requires an important distinction to be maintained:

Decree 524/2025 establishes the procedure, but it does not itself determine which investments qualify as relevant for purposes of Argentine Citizenship by Investment.

That determination is connected to the authority of the Ministry of Economy under the framework established by Law No. 346.

For international investors and the professionals advising them, this distinction is fundamental. Before structuring an investment or submitting an application, it is necessary to examine not only the procedure established by Decree 524/2025, but also the rules currently in force concerning qualifying investments and any complementary regulations issued by the competent authorities.

Argentina’s Citizenship by Investment framework may be amended, supplemented or further clarified through subsequent official measures. Any investment decision or naturalization application should therefore be assessed against the legal framework in force at the relevant time.

Frequently Asked Questions About Decree 524/2025 and Argentina Citizenship by Investment.

What does Decree 524/2025 regulate?

Decree 524/2025 establishes the administrative procedure for Argentina Citizenship by Investment applications and identifies the principal stages and authorities involved in the process.

Where is an Argentina Citizenship by Investment application submitted?

Under Article 1 of the decree, the application is submitted to the Citizenship by Investment Programs Agency.

Who determines whether an investment is relevant?

The Agency evaluates whether the applicant’s investment qualifies as relevant under the criteria established by the Ministry of Economy.

Which authorities may be involved in the review?

Article 3 provides for the involvement, among others, of the Ministry of National Security, the Financial Information Unit (UIF), the National Criminal Records Registry, RENAPER and the State Intelligence Secretariat (SIDE). The Agency may also request information from other public or private bodies it considers necessary within their respective areas of competence.

Who decides whether Argentine citizenship will be granted?

The National Directorate of Migration reviews the Agency’s report and decides whether to grant or reject the application through a reasoned administrative act.

How long does the National Directorate of Migration have to decide?

Article 4 establishes a period of 30 business days from receipt of the Agency’s report.

Does Decree 524/2025 establish the amount that must be invested?

No. The decree refers to the Ministry of Economy for the determination of which investments qualify as relevant. Its principal purpose is to regulate the administrative procedure for applications.

What happens if the investment is not considered relevant?

Article 3 provides that where the investment does not qualify as relevant, the Agency must reflect that circumstance in its report to the DNM and recommend rejection of the application.

What happens after citizenship is granted?

Article 5 assigns ARCA responsibility for making the necessary regulatory and system adjustments to enable a person who has obtained citizenship under the decree to process a CUIT.

Legal Advice on Argentina Citizenship by Investment.

Argentina Citizenship by Investment requires an integrated assessment of the investment, its legal classification, the applicant’s documentation and the applicable administrative procedure.

Rojas Pascual Abogados advises international investors and professional advisers seeking Argentine legal counsel to assess investment-based naturalization applications and prepare the relevant documentation and legal strategy in accordance with the applicable framework.

The information contained in this article is provided for general informational purposes and does not constitute legal advice for any particular case. Applicable rules, procedures, requirements and conditions may be amended, supplemented or further clarified through subsequent official measures.

Updated Text of Decree 524/2025

The current official text of Decree 524/2025 can be consulted through the Government of Argentina’s official legal information portal.

Consult the official text of Decree 524/2025 — Argentina.gob.ar

About the Author

Juan Pablo Rojas Pascual is an Argentine attorney and founder of Rojas Pascual Abogados. His practice includes Argentine Citizenship by Investment, legal assistance to international investors and foreign nationals, corporate and technology law, and emerging legal structures for autonomous and AI-enabled companies.

He advises international clients and professional advisers seeking Argentine legal counsel in connection with investment, citizenship and other cross-border legal matters.

Dr. Juan Pablo Rojas Pascual
Attorney at Law — Mendoza, Argentina
ROJAS PASCUAL – Abogados

Argentine Legal Counsel for International Investors and Families