Ask a Vanuatu file holder what their citizenship is actually built on, and most will say something like the DSP, or the citizenship-by-investment program, a marketing name for a folder of paperwork and a wire transfer. That answer is not wrong, exactly. It is just incomplete in the way that matters most: a marketing name is not what a court, a bank's compliance officer, or a due-diligence analyst at a private bank ever looks up. What they look up is legislation, and the legislation behind a Vanuatu file is not a single statute wearing a program's branding. It is four separate instruments, passed across nearly half a century, each doing a distinct legal job, the newest of them amended as recently as May 2025. Read those four instead of the brochure name, and the file in front of you looks less like a product a government could quietly discontinue and more like something a legislature keeps coming back to build on. None of what follows is a legal opinion. It is closer to a citation index, the four places a skeptical reader can go verify, independently, that a Vanuatu file rests on public law rather than a minister's current goodwill.
One file, four statutes
Four different instruments sit behind a single Vanuatu file, each answering a different question, and each administered by a different arm of the government. The Citizenship Act, Cap. 112, is the oldest and most foundational: it says who can become a Vanuatu citizen and by what routes, with citizenship by investment written in as one option among several, and the Vanuatu Citizenship Commission is the body that actually administers grants under it. Order No. 215 of 2016 is the instrument that built the donation route inside that statute into a standing program, the Development Support Programme, in force from 1 January 2017; due diligence on applicants under it runs through the Vanuatu Financial Intelligence Unit, a separate question from the statutes themselves and not this piece's subject. Order No. 33 of 2019 is newer still, and it is the one that sets today's price and decides who is licensed to bring an applicant's file forward as an agent. And the Vanuatu Passport (Amendment) Act 2025 is the newest layer of all, touching none of the three questions above. It governs something narrower and, for anyone thinking about mobility rather than paperwork, more consequential: the physical, biometric document a successful applicant is eventually issued.
Who can become a citizen: the Citizenship Act, Cap. 112
Cap. 112 is Vanuatu's foundational citizenship statute, in force since independence in 1980 and amended repeatedly in the decades since, including changes through the 1990s and as recently as 2023, well before the 2025 passport amendment arrived to touch a different part of the file entirely. It sets out the routes into Vanuatu citizenship, including by descent and, most relevant here, the donation-based route citizenship-by-investment applicants use. Section 20 is where that donation-based route sits within the statute's structure, the specific provision under which the Order that follows was made; as with the newer Passport Act discussed later, this piece treats that section number with the same caution it applies to any statutory detail it cannot independently verify beyond secondary sourcing, rather than dressing it up with more precision than the public record actually supports. This is the layer that answers the most basic legal question a diligence officer will ask: under what law does Vanuatu grant citizenship to someone with no birthright or ancestral claim to it. The answer is not a program brochure. It is a statute that predates the marketing name by decades, and that a citizenship-by-investment applicant is, legally, simply using in exactly the way Parliament wrote it to be used.
The donation route: Order No. 215 of 2016
Cap. 112 makes the donation route possible. Order No. 215 of 2016 is what actually built it. Made under the authority Section 20 provides, the Order established the Development Support Programme, the donation-route citizenship-by-investment scheme cbi.vu still administers files under today, and brought it into force on 1 January 2017. It replaced an earlier, looser arrangement, the Vanuatu Economic Rehabilitation Program, an honorary-citizenship route the government had run in the aftermath of Cyclone Pam in 2015 to raise emergency reconstruction funds. The DSP was, in that sense, already a formalization exercise the first time around: Vanuatu took an ad hoc emergency scheme and rebuilt it as a standing, statutory program with defined rules rather than case-by-case ministerial discretion. That is worth sitting with, because it previews exactly the pattern the rest of this piece is describing. When Vanuatu's citizenship legislation has needed updating, the legislature has consistently chosen to formalize it into a new instrument rather than leave the old one to erode or run the file on discretion alone.
Today's price and the agents: Order No. 33 of 2019
Order No. 33 of 2019 is the instrument in force today. It is what actually sets the current fee schedule under the DSP, including the government contribution that starts at $130,000 for a single applicant, and it is what defines the categories of licensed agent permitted to bring a file to the Vanuatu Citizenship Commission on an applicant's behalf. cbi.vu's own published figures are cited from this Order specifically, not from Order 215/2016, which created the program's architecture but does not govern its current price. That distinction matters more than it sounds: a program's founding order and its current fee order are not always the same instrument, and conflating them is a common, sloppy mistake made by writers who have not actually read either one. Order 33/2019 is also, not incidentally, evidence of the same pattern as Order 215/2016 before it: Vanuatu revisits and re-legislates its own program rather than letting a several-year-old fee schedule quietly go stale.
The newest layer: the Vanuatu Passport (Amendment) Act 2025
The Vanuatu Passport (Amendment) Act 2025 is the newest of the four instruments, and it is also the one most likely to be misdescribed. It does not touch citizenship eligibility, and it does not touch the DSP's fees or its screening architecture; those questions stay with Cap. 112, Order 215/2016, and Order 33/2019 respectively. What the 2025 Act governs is narrower and, for a mobility-focused buyer, arguably more consequential: the physical, biometric passport document itself. From May 2025, the amendment aligned Vanuatu's passport issuance with existing ICAO biometric standards, specifically ICAO Doc 9303, the Machine Readable Travel Documents specification that governs how a passport's biometric chip, facial image, and security features have to be built for the document to be trusted at another country's border. That last point is worth being precise about, because it is easy to get backwards: ICAO did not introduce anything in 2025. ICAO Doc 9303 already existed. What changed in 2025 is that Vanuatu's own law caught up to it, bringing local passport issuance into line with a standard the rest of the ICAO-compliant travel-document world had already adopted.
Practically, that alignment is why the file now requires exactly one mandatory in-person biometric enrolment, fingerprint and facial-image capture, available at the Vanuatu Immigration Service in Port Vila or at the Vanuatu missions in Hong Kong, Dubai, or New Caledonia. Manual, non-biometric passport applications stopped being accepted from that same point, a genuine operational shift for anyone who assumed the whole process could be handled by mail. It is also worth being honest about where the public record runs out. A bill for this amendment was tabled in Parliament's 2025 session under a title that names it plainly, the Passport (Amendment) Act, and the substance described here, biometric enrolment, ICAO Doc 9303 alignment, the May 2025 effective date, is well corroborated across independent sources including Vanuatu's own consular offices. What this piece will not pretend to know is the Act's internal section numbering or its precise Gazette commencement date beyond May 2025. cbi.vu has a standing policy against printing statutory detail it cannot independently verify from primary text, the same reason an earlier Journal piece on Vanuatu's own government declines to name a sitting Prime Minister whose office turns over faster than a page can stay current. Where the record is solid, this piece states it as fact. Where it is not, it says so rather than inventing a citation that looks precise and is not.
Why the layering matters
Put the four instruments next to each other and a pattern appears that a single, flashy law never shows: a legislature that keeps coming back. 1980, the founding citizenship statute. 2016, the order that built a formal donation route out of an emergency-relief precedent. 2019, the order that reset the price and the agent rules to reflect a program that had matured. 2025, the amendment that modernized the physical document to meet a document-security standard the rest of the travel-document world already runs on. That is not one law frozen in time, and it is not a program running on ministerial discretion that could be withdrawn as easily as it was granted. It is a decade of a legislature returning to its own citizenship framework and updating specific, identifiable pieces of it, on a record any applicant's counsel can pull and read directly rather than take on faith from a sales page.
A favor a minister granted can be withdrawn by the next one; a decade of statutes a legislature keeps returning to amend is a legal fact, not a favor.
This is the same honest trade-off logic we apply to mobility itself. The Schengen question, answered does not pretend Vanuatu's visa-free list, 87 destinations, ranked roughly 57th globally, still includes the Schengen area; it was revoked in December 2024, and the honest answer is to say so plainly rather than bury it in an asterisk. The statutory question deserves the same treatment. A reader evaluating jurisdictional statute quality more broadly, not just Vanuatu's, has a natural next stop in offshoreguy.com, the company-formation side of the same advisory group, for a sense of how thin or thick the legislative record looks across other jurisdictions entirely. And for the conversation that connects any of this to an actual file, the advisory team at 21cbi.io is where the statutes above turn into a specific set of steps for a specific applicant.
What this does not resolve
Reading four statutes does not make anyone their own immigration lawyer, and nothing in this piece should be read as legal advice on an individual file. Legislation this layered is also not self-executing: knowing that Order 33/2019 sets the current fee schedule does not tell you what the Vanuatu Financial Intelligence Unit or the Vanuatu Citizenship Commission will actually make of a specific source-of-funds file, and that approval workflow, who signs off, on what timeline, under what screening, is deliberately not this piece's subject; it is its own piece, coming separately. Nor does statutory durability guarantee that a future Parliament will never touch the DSP again, whether by tightening it, loosening it, or eventually retiring it outright; a legislature that revisits its own law is, by definition, also a legislature that can revise it again. What four amended, layered, publicly citable statutes do buy a buyer is something narrower and more honest than a guarantee: a paper trail a due-diligence officer can actually verify, instead of a program that exists only because a minister currently favors it. That is a meaningfully different kind of durability than a marketing name, and it is the kind worth actually reading before anyone wires anything.
Sources & Authorities- Citizenship Act, Cap. 112
- The statutory basis for Vanuatu citizenship and the framework under which citizenship by investment is granted.
- Order No. 215 of 2016
- Established the Development Support Programme (DSP), the donation route, in force from 1 January 2017.
- Order No. 33 of 2019
- Governs the current DSP fee schedule and the agent categories. The figures on this site are cited from this instrument.
- Vanuatu Passport (Amendment) Act 2025
- The legal basis for the biometric passport. From May 2025 it aligns Vanuatu passport issuance with ICAO standards; the change is the Act's, not ICAO's.
- Vanuatu Consulate General, Hong Kong (official government office)
- Names ICAO Doc 9303, the Machine Readable Travel Documents standard, as the specific compliance benchmark for the 2025 biometric passport.
Adam Juchniewicz, CEO, 21 CBI
Port Vila · July 2026