ECCIRA regional regulator and 2025 reform arc (pending)

Example scenarios

• No residency or physical-presence requirement applies to the Dominica CBI route as of the build date; the reported 30-day rule is part of the incoming ECCIRA reform arc and is delayed.

  The operative CBI law is SRO 8 of 2024 (current as of 2024-06-28), which imposes no residency or physical-presence requirement, and SRO 46 of 2025 changed only the post-grant newborn window — it added no residency rule. The reported 30-day physical-presence requirement belongs to the ECCIRA track (DM-PND-01), which is a pending regulatory overlay (A228) not yet binding-operative across all five OECS states, with the residency dimension reported delayed (~mid-2026) and as to commencement. He can apply now under the no-physical-presence regime, but should monitor the DM Official Gazette for ECCIRA's entry into force.

• The agent should prepare for biometrics, designated escrow, accredited due-diligence firms and fines up to US$250,000, but none of these are yet binding until ECCIRA enters into force across all five states.

  Dominica gave ECCIRA force of law by an enabling Act passed 14 October 2025 (gov.dm pressroom), but the Agreement required ratification across all five participating OECS CBI states to be binding, now complete (all five have ratified), coordinated by an Interim Regulatory Commission under the ECCB; operationalisation is anticipated early 2026. The Agreement's substance — binding standards on processing and due diligence, biometrics, escrow, internationally accredited due-diligence firms, and administrative fines up to US$250,000 — will constrain how the agent submits and supports applications. Until in force, the agent operates under SRO 8/2024 (mandatory interview for all 16+, FIU-commissioned due diligence, JRCC information sharing).

• He may register the post-grant minor child with no time limit, because SRO 46 of 2025 deleted the former five-year window.

  Under SRO 8 of 2024 Schedule 1 paragraph 3(1), a main applicant who obtained citizenship through the Programme could register a child under eighteen born to or adopted by him after citizenship, but only 'not more than five years after the main applicant obtained citizenship.' SRO 46 of 2025 (gazetted 27 November 2025) amended paragraph 3(1) by deleting exactly those words — so post-amendment the post-grant newborn add-on has NO time limit. This is the single operative change made by SRO 46/2025; all monetary figures (the paragraph 3(2) processing, due-diligence and certificate fees) remain as set in SRO 8/2024. This resolves the earlier FAQ-versus-gazette conflict in favour of 'no time restriction.'

• Waiting will not lower cost (figures are unchanged) and may add a genuine-link/residency burden; applying now locks in the current no-physical-presence regime.

  The investment thresholds are set by SRO 8 of 2024 (US$200,000 single / US$250,000 family-of-4 for EDF; US$200,000 plus tiered government fees for real estate) and were not changed by SRO 46/2025 or by ECCIRA. ECCIRA is integrity-focused (biometrics, escrow, accredited due diligence, fines up to US$250,000) and may introduce a residency/genuine-link condition once in force, which would be a new burden rather than a saving. Because ECCIRA is now ratified by all five states (operationalising ~early 2026) (A228) and its residency element is delayed/, a client who values the current absence of residency and physical-presence requirements has a rational basis to apply under the present SRO 8/2024 regime rather than wait.