A Bitcoiner does not run a node on trust. Before pulling a new release, the careful ones read the changelog, diff the commits, and check what changed and why, because a project that revises itself in the open is easier to trust than one that ships with no history to show. Point that instinct at Vanuatu's citizenship program and the first thing it snags on is a worry that sounds fatal: this program keeps changing. Schengen access gone, biometrics added, an EU listing that outlived a FATF clearance, a fee order that superseded an earlier one. Read uncharitably, that reads like instability, like a thing being made up as it goes. Read honestly, it is a changelog, and a changelog is the opposite of instability; it is the record of a system that is documented, dated, and revised in public. So here is the changelog, node by node: every material change to the Development Support Programme (DSP), Vanuatu's donation route to citizenship by investment (CBI, a legal pathway by which a sovereign nation grants citizenship in exchange for a government-approved contribution), since it came into force. Dated. And, at the end, sorted into the two piles a skeptic actually needs: the changes that made the program more credible, and the ones that genuinely cost the passport something.
The foundation, 1980: older than the program it carries
Start before the beginning. The thing most skeptics assume is new, citizenship attached to money, rests on a statute that is not new at all. The Citizenship Act, Cap. 112, is Vanuatu's foundational citizenship statute, in force since the country's independence in 1980, decades before anyone attached an investment route to it. That matters for the same reason the commit history of a mature library matters: the base layer has been running, and being amended, far longer than the feature everyone is arguing about. Citizenship in Vanuatu did not begin with a brochure in 2016; it began with an act of Parliament in 1980, and the same act still governs who is Vanuatu and who is not, including the rule that citizenship passes to children by descent. The nation underneath the passport has its own longer story, told separately in this Journal's piece on the country that has been independent since 1980. The point for a timeline is narrow: the legal floor predates the program by thirty-six years, and it has not wobbled once.
2016 to 2017: the DSP is established
The donation route itself is the part with an actual birthday. Order No. 215 of 2016 established the Development Support Programme, the donation route, under the authority of Cap. 112, and brought it into force on 1 January 2017. This is node zero of the changelog, the initial commit. Everything a skeptic reads about the Vanuatu program, every fee, every screen, every later revision, hangs off this instrument and the statute above it. It is worth being precise about what was created: not a new kind of citizenship, but a regulated, priced, agent-mediated pathway into the citizenship Cap. 112 already defined. From the first day, the structure separated the people who prepare a file from the government body that grants it, which is the single most important design fact in the whole program and the subject of a separate piece on who actually signs off on a Vanuatu file. Node zero, dated 1 January 2017.
2018: the FATF clears Vanuatu
The first change after launch is the one skeptics should weigh most heavily, because it is an outside verdict rather than a self-description. Vanuatu had been grey-listed by the Financial Action Task Force (FATF), the intergovernmental anti-money-laundering standard-setter. In 2018 the FATF delisted it, removing Vanuatu from its increased-monitoring list after the country closed the deficiencies the review had found. That is not a claim the program makes about itself; it is a judgment a global body reached about the jurisdiction, and Vanuatu has stayed off that list since, including through the FATF's most recent plenary. For a Bitcoiner used to distrusting self-reported metrics, this is the kind of change that counts: an independent reviewer looked, found problems, and later confirmed they were fixed. It belongs squarely in the tightening pile, and it is the cleanest single answer to the flat assertion that the program was never legitimate.
2019: Order No. 33 sets today's fee schedule
The next node is administrative, and it is the reason cbi.vu's published figures look the way they do. Order No. 33 of 2019 is the instrument in force today for pricing. It sets the current DSP fee schedule, including the $130,000 government contribution for a single applicant, and it defines the categories of licensed designated agent permitted to bring a file to the Vanuatu Citizenship Commission. When this site quotes a figure, it is cited from this 2019 order specifically, not from the 2016 instrument that preceded it. Two honesty notes belong in the body rather than a footnote. First, the government contribution is one line, not the whole cost; the all-in for a single applicant is $145,000 once due diligence, agent, and enrolment fees are added, and this site publishes the itemized version rather than the headline. Second, that fees are fixed by a public order, and revised by a later public order, is itself the reassuring part: the price is set by statute and superseded in the open, not quoted off a whiteboard.
July 2023: the United Kingdom adds a visa
Now the losses, and they are real. The first is the United Kingdom. Since July 2023, Vanuatu nationals have needed a Standard Visitor visa to enter the UK, where before they could arrive visa-free. This change is its own event, earlier than and separate from the European one that followed it, and it deserves to be counted on its own line rather than folded into a single closed-Europe story. It narrowed the passport. There is no honest way to describe a new visa requirement as anything but a reduction in the document's reach. July 2023: the UK moved from visa-free to visa-required for Vanuatu.
December 2024: Schengen access is revoked
The larger loss is Schengen, and it is the single change a skeptic is most right to care about. In December 2024 the European Union ended Vanuatu's Schengen visa exemption permanently. Vanuatu nationals no longer enter the Schengen area visa-free, and the revocation is not framed here as a technicality or an asterisk, because it is neither. It removed one of the most valuable blocs any passport can carry, and it is the honest reason the Vanuatu document is worth less for European travel today than it was in 2023. This is the change that does not go in the tightening pile. It is a straightforward reduction in mobility, it is permanent as things stand, and any advisor who talks around it is selling rather than informing. Stated plainly: Schengen is gone, revoked in December 2024, and that is a genuine cost.
May 2025: the Passport (Amendment) Act and one visit
The 2025 change is process, not price or passport strength, and it is easy to misread as a downgrade when it is closer to the opposite. The Vanuatu Passport (Amendment) Act 2025 modernized the travel document itself. From May 2025 it aligned Vanuatu passport issuance with existing ICAO biometric standards, and because those standards already existed, the change was Vanuatu's own law catching up to them rather than any new standard appearing in 2025. Practically, the file now includes exactly one mandatory in-person biometric enrolment, fingerprint and facial-image capture, available at the immigration service in Port Vila or at Vanuatu missions in Dubai, Hong Kong, or New Caledonia. The honest phrasing is that the process is remote except for one in-person biometric visit. And the placement matters: enrolment happens after the citizenship grant, under a different statute, so it is not a decision point and cannot change the answer, only produce the document that follows a yes already given. The four instruments underneath a file, and how this Act fits among them, are laid out in the piece on the statutes underneath the file. For a skeptic, a passport moving to the same biometric baseline every serious travel document already meets is a maturation, not a red flag.
A program with a public changelog is not an unstable program; it is a documented one. The changes since 2017 sort into two piles, tightening that made the file more credible and mobility the passport genuinely lost, and the honest move is to name both, not just the flattering one.
December 2025: cleared by the FATF, still listed by the EU
The most recent node is the one an honest timeline has to hold in tension, because it contains a fact that cuts against the program and a fact that cuts for it, and both are true. The FATF cleared Vanuatu in 2018 and has kept it off the increased-monitoring list since. The European Union, separately, still keeps Vanuatu on its own high-risk third-country anti-money-laundering list, and reconfirmed that listing in its December 2025 update. So the accurate status is neither clean nor flagged; it is FATF-cleared and EU-listed at the same time, two different bodies reaching two different conclusions. A skeptic deserves both halves, not the convenient one. The regulatory history behind this split, and the decades of financial-sector supervision that sit under it, are covered in the piece on the VFSC and four decades of offshore finance. The takeaway for this changelog is that the AML picture improved on the measure most jurisdictions treat as authoritative, and has not yet on the EU's.
What did not change
A changelog is also defined by the lines that held across every release, and three of them carry more weight than any single change above. The tax structure held. Vanuatu still levies zero personal income tax, zero capital gains tax, zero inheritance tax, and zero corporate income tax; a 15% Value Added Tax on local consumption is the only material tax, and the tax-exempt International Business Company framework has run under Vanuatu Financial Services Commission supervision since 1993. That is a fact about Vanuatu, not a promise about your own position: a passport is not automatically tax residency, and US persons and most others still owe their home country its own answer, a distinction this site keeps in its page on Vanuatu citizenship, tax, and residency. The second constant is the one marketing most likes to blur, so state it plainly: Vanuatu participates in the Common Reporting Standard (CRS), the OECD framework for automatic exchange of financial-account information. It did before, it does now, and nothing on this timeline turned it into a secrecy jurisdiction. The third constant is the foundation itself, Cap. 112, unmoved since 1980. The floor did not shift; only the room built on top of it was renovated.
How to read what changed
Line the nodes up and the pattern a skeptic wanted is right there. In the tightening-and-maturation pile: an independent FATF clearance in 2018, a fee schedule fixed and revised in public by order in 2019, a passport brought to the same biometric baseline as every serious travel document in 2025, and a screening regime that coordinates with INTERPOL and reports in about a week. Every one of those raised the cost of getting a bad file through, which is exactly what you want from a program you are about to attach your name to. In the loss pile, honestly and without softening: the United Kingdom in 2023 and the Schengen area in December 2024, two real reductions in where the passport carries you, plus an EU high-risk listing the country has not yet shed. Today the document stands at eighty-seven visa-free destinations, ranked #57 on the Henley Passport Index, concentrated in the Asia-Pacific corridor: Singapore, Hong Kong, Malaysia, and the Pacific Islands Forum bloc. That is the number after the losses, stated as it is rather than as it was.
So the honest answer to the worry that the program keeps changing is: yes, and read the diff. The changes that alarmed you are mostly the program getting harder to game, and the two that genuinely cost something are named on their own lines instead of hidden under an asterisk. A thing that revises itself in public, under statutes you can cite and outside reviews you did not commission, is more trustworthy than a program with no history to show, not less. Where a timeline turns into a specific file, with your own facts and your own source-of-funds trail, is the conversation the advisory team at 21cbi.io exists to have. The changelog is public. What you build on top of it is not, and that is where the work actually starts.
Sources & Authorities- Citizenship Act, Cap. 112
- Vanuatu's foundational citizenship statute, in force since independence in 1980. It empowers the Vanuatu Citizenship Commission to consider, approve, and grant citizenship, including by the donation route, and predates the DSP by decades.
- Order No. 215 of 2016 (Development Support Programme Regulations)
- Established the DSP donation route under Cap. 112, in force from 1 January 2017. This is the instrument that created the program.
- Order No. 33 of 2019
- Governs the current DSP fee schedule and the categories of licensed designated agent. The figures on this site are cited from this instrument, not from the 2016 order that preceded it.
- Vanuatu Passport (Amendment) Act 2025
- Aligned Vanuatu passport issuance with existing ICAO biometric standards from May 2025, adding one mandatory in-person biometric enrolment after the grant. It governs the travel document, not the citizenship decision; the change is the Act's, not ICAO's.
- FATF delisting (2018) and the EU high-risk list
- The Financial Action Task Force delisted Vanuatu in 2018 and has kept it off its increased-monitoring list since. Separately, the European Union keeps Vanuatu on its high-risk third-country anti-money-laundering list, reconfirmed in its December 2025 update. Both are true and both belong on the record.
- CRS participation
- Vanuatu participates in the OECD Common Reporting Standard, the framework for automatic exchange of financial-account information. It is a CRS participating jurisdiction, not a non-reporting one; this site states that plainly.
Adam Juchniewicz, CEO, 21 CBI
Port Vila · July 2026