Do You Need a Vanuatu Citizenship Lawyer?
The law requires a designated agent, not a lawyer. What each party does on your file, what we handle and how to verify any agent before you pay.
Written by Tatiana Del Moral, Associate Partner · Updated 5 November 2026
Vanuatu law does not require you to hire a lawyer to obtain citizenship by investment, but it does require a designated agent: under the Development Support Program (DSP) Regulations, an investment application can only be lodged through an agent designated by the Citizenship Commission. A Vanuatu citizenship lawyer or adviser works on what decides the outcome, which is eligibility, the family plan, the documents and the evidence for your funds. Vanuatu CBI does that work with you. We are not a designated agent, and your application is lodged through one whose name you can check on the official list before any government fee is paid.
Below we set out who does what on a Vanuatu citizenship file, what the law expects of a designated agent, what we handle for you, and how to verify any agent you are offered.
Three Roles That Are Often Confused
Much of the confusion around Vanuatu citizenship agents comes from mixing up three separate parties. Each has its own job, and only one of them makes the decision.
| Who | What they do | What they cannot do |
|---|---|---|
| Citizenship Commission | A constitutional body that decides every application and grants or refuses citizenship; it may also revoke a grant made unlawfully | Hand the decision to an agent or adviser |
| Designated agent | Appointed by the Commission; applies to the Financial Intelligence Unit (FIU) for due diligence, lodges the application and receives the Commission's decision | Decide the application or guarantee its result |
| Adviser or citizenship lawyer | Assesses eligibility and cost, plans the family application, prepares and checks documents and source-of-funds evidence, and works with the client through each stage | Lodge an investment application directly or replace the designated agent |
The passport is a separate matter again. It is issued by the Immigration and Passport Services, not by the Citizenship Office or the Commission, once citizenship has been granted.
What the Law Expects of a Designated Agent
The DSP Regulations, Order No. 33 of 2019 as amended by Order No. 39 of 2020, set out who can be a designated agent and what the agent must do. In summary:
- the agent is designated by the Citizenship Commission and must be a Vanuatu citizen with a main registered office in Port Vila;
- the agent applies to the FIU for due diligence and supplies the documents the Regulations name, including the applicant's passport and a police or judicial record certificate;
- after the checks, the agent lodges the application with the Citizenship Office, which passes a complete file to the Internal Screening Committee and then to the Commission;
- the Office notifies the agent of an approval in principle within 48 hours of the Commission's decision;
- once due diligence is complete, the applicant stays with the same agent unless that agent has not progressed the file within a reasonable period, which may not exceed six months.
The last rule is easy to overlook. It means the choice of agent is, in practice, a choice for the whole application, so it is worth checking properly before you begin. The stages themselves are covered in our walkthrough of how a file moves from lodging to the Commission's decision.
Our Share of the Work on a Citizenship File
Our part covers everything except lodging and deciding, from your first question until the passport is issued:
- a free assessment of eligibility and of the full cost for your family, returned in writing;
- choosing the route and planning who goes on the application, including whether older children and parents qualify as dependants;
- collecting and preparing the documents: civil records, police certificates, apostilles, certified translations and a notarized CV;
- building the source-of-funds evidence, which is often where a file succeeds or stalls;
- having the file lodged through a government-designated agent, as Vanuatu law requires, and naming that agent at the start;
- answering the questions raised during FIU due diligence and by the Commission;
- guiding the payments in US dollars through official channels, in the stages the Regulations set;
- preparing you for the oath before a Commissioner for Oaths, the certificate and the passport application.
Everything you tell us is treated as confidential and is used only for your application.
What We Do Not Do
Being clear about limits is part of the service. We do not lodge investment applications ourselves, we are not part of the Vanuatu government and we have no affiliation with the Citizenship Office or the Commission. We do not promise approval or a decision date, because the Commission decides each file and no official processing time is published. We do not offer any route around due diligence or disclosure. And we do not handle residence permits, relocation or company formation; our work is citizenship.
How to Verify a Vanuatu Citizenship Agent
Whether you work with us or not, run these checks before paying anyone:
- Use the official website. The Citizenship Office's site is vancitizenship.gov.vu. Its home page warns about fake websites pretending to be official, and official Vanuatu government sites end in .gov.vu.
- Find the exact name on the list. Look up the individual or company on the Designated Agents page. A brand name or a website is not enough; the legal name must match.
- Check the "Cancelled Agents" page. Under that title the Office lists the individuals and companies not recognized as designated agents. A name there cannot lodge your file.
- Ask the Office if in doubt. The Citizenship Office invites inquiries by telephone on (+678) 33365.
- Follow the money. The Regulations treat a DSP payment as made when it has been deposited in the DSP account held with the National Bank of Vanuatu, and only US dollars are accepted. Ask in writing where each payment goes before you send it.
- Get the plan in writing. A genuine adviser can tell you which agent will lodge the file, what each payment is for and when it falls due.
Red Flags in an Agent's or Adviser's Pitch
- Guaranteed approval, or citizenship "in 30 days". Neither the Act nor the DSP Regulations set a deadline for the Commission's decision, and nobody outside the Commission controls it.
- "You pay nothing until approval." A quarter of the prescribed government fee has to be paid before the Commission takes up the file, and the Regulations keep it if the file is refused.
- A passport without citizenship, or a diplomatic passport for sale. In February 2025 the Citizenship Office and Commission stated that they issue no passports of any kind; diplomatic passports are a matter for the Ministry of Foreign Affairs.
- CIIP terms with no official source. The CIIP was suspended in March 2025; industry sources report it reopened in May 2025 under amended rules, but no official notice confirming the current terms has been published, so any CIIP figure you are quoted should come with its written source.
- Payment to the government in cryptocurrency. The Office has said it does not accept Bitcoin or any other cryptocurrency.
- A file that "does not need" police certificates or source-of-funds evidence. The due diligence requires both, and the Regulations bar approval for anyone with a criminal conviction.
Why the Preparation Matters More Than the Paperwork Route
A designated agent is the legal channel, but the agent cannot fix what is missing from a file. The outcome turns on whether the documents are consistent, whether every fact is disclosed and whether the funds can be traced. A refused visa left out of a form, a company history that does not match the bank records, or a gap in how wealth was built will be found by the checks; explained in advance, the same point can often be addressed. Our guide to how the background checks are run covers what the reviewers look at.
A refusal also has a price. The 25% advance is not refunded under the Regulation, and the published sources do not say whether the US$5,000 due diligence fee can be recovered once the checks have run, as our breakdown of each payment and its due date explains. That is why our first step is an honest assessment: if a file is not ready, we say so before any government money moves.
Questions to Ask Any Adviser Before You Pay
- Which designated agent will lodge my application, and where is the name on the official list?
- Which government amounts apply to my family, and on what date does each one fall due?
- What is your own fee, what does it cover, and is it written down?
- Which documents do you need from each person, and who prepares translations and apostilles?
- What happens to each payment if the application is deferred or refused?
Clear answers to these five questions tell you more about an adviser than any marketing claim. You are welcome to put them to us in the free assessment.
FAQ
Vanuatu Citizenship Lawyers and Agents: FAQs
Vanuatu law does not require a lawyer, but it does require a designated agent: investment applications are lodged only through an agent designated by the Citizenship Commission. A lawyer or adviser adds value on eligibility, the family plan, documents and source-of-funds evidence, which is often where a file succeeds or fails. We do that work with you, and a designated agent lodges the file.
They are the individuals and companies designated by the Citizenship Commission under the DSP Regulations. The Citizenship Office publishes them on its Designated Agents page at vancitizenship.gov.vu, alongside a separate list of those it does not recognize as designated agents. A designated agent must be a Vanuatu citizen with a main registered office in Port Vila. Check the exact legal name, not a brand or website.
Use only the official site, vancitizenship.gov.vu, since the Office warns about fake sites and genuine government sites end in .gov.vu. Find the agent's exact name on the Designated Agents list and make sure it is not on the list of those not recognized. If in doubt, call the Citizenship Office on (+678) 33365, and ask in writing where each payment goes before sending it.
A Vanuatu citizenship lawyer or adviser prepares the application rather than lodging or deciding it. The work covers eligibility and the full cost, the choice of family members, documents such as police certificates, apostilles and translations, and the evidence for your funds, followed by answers to questions raised in due diligence and by the Commission. The investment application itself is lodged by an agent the Citizenship Commission has designated.
No. Nobody outside the Citizenship Commission can. The Commission alone approves, defers or rejects each file, and no law fixes how long it may take to decide a DSP application. Anyone who guarantees approval, or citizenship within a fixed number of days, is promising something outside their control. What a good adviser can do is make sure the file is complete and consistent when it is lodged.
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