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Argentina Launches Tender to Appoint Master Agent for Its New Citizenship-by-Investment Program

 

Argentina’s government has officially launched a public tender to select a global consultancy that will design, implement, and manage the nation’s first Citizenship by Investment (CBI) program. The Ministry of Economy issued Tender No. 34-0001-CPU25, which will remain open for submissions until January 20, 2026.

The program will be overseen by the newly established Agencia de Programas de Ciudadanía por Inversión (APCI) — a decentralized body created by Decree 366/2025 and governed under Decree 524/2025 — marking a major step toward operationalizing Argentina’s CBI framework.

 

A Unique Master Operator Role with Built-In Market Development

Argentina’s CBI tender outlines a four-year consulting contract in which the winning firm will act as the program’s architect and operator, responsible for establishing the entire program structure, from regulatory design and investment routes to application processing systems and global rollout plans.

Unlike many other jurisdictions, Argentina’s model is structured to prevent market monopolization. The government will compensate the master operator only for applications submitted by independent certified agents or unrelated third parties. Consultancy-sourced cases will not be paid by the government, encouraging the contractor to develop a broad, certified agent network rather than command the market itself.

Payments to the consultant will be made in U.S. dollars based on approved applications, with fees distributed over five groups of 1,000 approvals each. Application processing fees will be released only after APCI issues a formal recommendation for approval, and rejected cases do not generate compensation.


 

Program Development and Implementation Milestones

The tender divides the contract into four key milestones:

  1. Design (2 months) – Establish program rules, procedures, staffing needs, cost estimates, and a full implementation timeline.
  2. Implementation & Launch Planning (6 months) – Build operational capacity and international positioning, and ready APCI to start accepting applications.
  3. Launch Execution (12 months) – Implement marketing strategies and begin program outreach.
  4. Ongoing Promotion & Technical Support (up to 48 months) – Maintain international promotion and technical assistance through the contract’s later years.

High Qualification and Scoring Standards

Bidders must show significant experience in citizenship or residence-by-investment programs, including legislative drafting and at least one government-level mandate within the past decade. Firms must also demonstrate strong international networks with agents, financial institutions, due diligence providers, and legal advisors.

Technical merit accounts for 60% of the evaluation, with criteria such as program innovation, operational capacity, track record, strategic business planning, and global network strength. The remaining 40% is based on economic competitiveness.

Investment Thresholds Still to Be Set

The current tender does not fix investment minimums. Instead, the selected consultancy will develop recommended investment categories and criteria, subject to APCI and Ministry approval. While industry commentary has suggested figures around US$500,000, no official thresholds are yet established in legal texts or government directives.

The government’s focus on real economy investments hints that preferred sectors may include agribusiness, renewable energy, technology, tourism infrastructure, and industry projects that create jobs and sustainable growth. Real estate might only qualify as part of broader productive investments.

What This Means for the CBI Industry

By separating operational functions from distribution, Argentina’s CBI model aims to foster a wider agent ecosystem rather than a centralized sales channel. The master agent will heavily influence program design and rollout while building the foundation for certified global partnerships.

Because APCI currently lacks formal structure and leadership, the winning consultancy will play a key role in establishing early processes and institutional capabilities. A successful bid could translate into shaping Argentina’s CBI offering from the ground up.

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