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Argentina's 2025 CBI Master Operator Tender: What Was Announced, and Why It Was Cancelled
Update, October 2026. The tender described below was cancelled. On 14 April 2026, Resolution 522/2026 voided Tender 34-0001-CPU25 in its entirety and no operator was appointed. Since 15 May 2026, AMIGO Ltd, a group of investment migration firms, has advised the Agency for Citizenship by Investment Programs under a non-onerous technical collaboration agreement. It is a technical adviser, not an operator or application channel. On 2 October 2026, the Ministry of Economy officially announced pricing and a Q4 2026 launch target. Separately, DNU 366/2025, the decree behind the program's no-residency principle, was declared invalid by two federal courts in June 2026 and is now before the Supreme Court. Decree 524/2025 remains formally in force. Applications are not open. This article is kept as a record of the original tender. For the current position, see our tender cancellation analysis and the live status tracker.
Argentina has officially taken the decisive step that the investment migration world has been anticipating: the Ministry of Economy has published a global tender to select a “Master Operator” that will design, implement, and run the country’s upcoming Citizenship by Investment (CBI) program.
This is not a rumor, a leak, or speculation. This is the first fully official, publicly released government tender to create the operational and regulatory foundation of Argentina’s CBI framework. The publication marks a historic moment, not just for Argentina, but for the global citizenship-by-investment industry.
As the country moves from conceptual discussions to formal institutional implementation, the details released in this tender provide the clearest picture to date of how the Argentine CBI program will be structured, how it will function, and what the path to international launch looks like.
A Landmark Government Announcement
On December 5, 2025, the Ministry of Economy published Tender No. 34-0001-CPU25, the procurement process through which Argentina will select a global consultancy to architect and operate the country’s new CBI program for a four-year term.
The program will be supervised by the Agencia de Programas de Ciudadanía por Inversión (APCI), a decentralized government agency established under Decree 524/2025. Decree 524/2025 built this administrative structure on top of DNU 366/2025, the separate decree that amended the underlying citizenship law to allow investment to replace the traditional residency requirement. DNU 366/2025 was declared invalid by two federal courts in June 2026 and is now before the Supreme Court on the government's appeal. Decree 524/2025 itself remains formally in force. Government documents for the tender estimated the system could process up to 5,000 favorable approval recommendations over the four-year contract period originally proposed.
This initiative moves Argentina firmly into the world of structured, high-compliance, economically driven investment migration programs. The tender outlines not only the operational design but also the enforcement mechanisms, timelines, compliance obligations, and performance benchmarks that the selected operator must meet.
Further background on the program’s legal foundations can be found in our Argentina Citizenship by Investment overview. For 40+ investor questions answered on costs, eligibility, and the application process, see our Complete Argentina CBI FAQ (2026).
The Master Operator’s Role: Architecture, Operation, and Global Rollout
The Master Operator will serve as the technical architect and operational engine of Argentina’s forthcoming CBI program. Unlike other jurisdictions where a single firm may control both program management and distribution, Argentina has deliberately structured the contract to prevent monopolization. The government will compensate the operator only for applications submitted through certified independent agents or third-party firms, ensuring that a broad international ecosystem must be developed rather than a single consolidated channel.
Under this model, all applications whether sourced domestically, internationally or by the operator itself, will pass through a unified evaluation system supervised by APCI. The operator is responsible for designing the full program architecture, establishing investment routes and due diligence procedures, preparing operational manuals, developing Argentina’s international positioning strategy, and managing global promotion over the four-year contract. It must also deliver a digital multi-stage evaluation platform and provide APCI with institutional training.
This structure represents one of the most comprehensive operator roles introduced in the investment migration sector and illustrates the government’s intention to build a robust, globally competitive program from the ground up.
Four Milestones Define the 48-Month Implementation Timeline
The tender outlines four major stages that shape the timeline for program launch and international rollout:
Milestone 1 | Program Design (Within 2 Months)
The consultancy must deliver:
- Full program rules
- Process architecture
- Staffing and operational structure
- Cost frameworks
- Implementation roadmap
Nothing moves forward until the APCI Director approves these deliverables.
Milestone 2 | Implementation & Launch Preparation (Within 6 Months)
This phase involves:
- Building operational capacity
- Developing the international go-to-market strategy
- Training APCI teams
- Preparing the agency to begin receiving applications
By the end of this stage, APCI must be fully certified as operationally ready.
Milestone 3 | Global Launch (Within 12 Months)
This is where the program goes public. The operator must:
- Execute the approved international marketing plan
- Penetrate target investor markets
- Begin active global promotion
This milestone would have defined the earliest realistic timeline for program rollout under the original tender structure. That structure was superseded when Resolution 522/2026 cancelled the tender in April 2026. The government now targets a Q4 2026 launch, though slippage remains possible while the implementing regulation and the Supreme Court appeal on DNU 366/2025 are pending. Follow our Argentina CBI Program Status Tracker for confirmed developments.
Milestone 4 | Ongoing Promotion & Technical Support (Through Month 48)
For years 2-4, the consultancy must deliver:
- Annual international promotion plans
- Updated strategies for global positioning
- Technical support
- Operational updates
Control checkpoints at months 24, 36, and 48 (and potentially month 60 if extended) ensure continuous accountability.
High Entry Barriers: Only Top-Tier Global Firms Qualify
The tender imposes unusually strict qualification standards. Bidders must demonstrate:
1. Proven CBI/RBI Program Design Experience
At least one government mandate in the past 10 years is mandatory.
2. Legislative Drafting Capability
Firms must have drafted citizenship or residence legislation elsewhere.
3. Senior Leadership
A minimum of five directors or executives must each possess at least five years of sector-specific experience.
4. Global Network Strength
This includes:
- CBI agents
- Banks and financial institutions
- Due diligence firms
- Legal advisors
- Wealth management networks
5. Financial Solvency Requirements
The firm must meet strict ratios:
- Debt-to-equity ≤ 0.50
- Current ratio ≥ 1.00
- Solvency ≥ 2.00
- Profit margin ≥ 10%
These criteria ensure that only highly capable, well-established global operators enter the competition.
How Bids Are Evaluated: 60% Technical / 40% Economic
The evaluation matrix strongly favors expertise, quality, and capacity rather than price alone.
Technical (60%)
Five categories at 20 points each:
- Program uniqueness & innovation
- Expertise & operational capability
- Track record in government mandates
- Business plan strength & long-term sustainability
- International promotional network
Economic (40%)
The operator is paid in five tranches of 1,000 approved applications each, with declining coefficients. Payments are issued only after APCI recommends approval.
Rejected applications generate no compensation, reinforcing the program’s emphasis on quality over volume.
Strict Compliance & Performance Enforcement
Argentina embeds advanced accountability mechanisms:
- Missing major milestones: 1% penalty
- Missing annual control points: 0.5% penalty
- Five violations allow contract termination
- Early termination compensation equals only 100 approvals
- Termination possible if approval targets (200 by month 24, 300 by month 36, etc.) are not met
This is one of the most tightly regulated and performance-driven tender frameworks in the CBI world.
Investment Thresholds: From Open Question to Officially Announced Figures
The tender left one essential element undefined: the minimum investment amount. It intentionally left investment categories and minimums open for the Master Operator to propose. That question has since moved on. On 2 October 2026, the Ministry of Economy officially announced two routes for the main applicant: a non-refundable contribution of USD 350,000 to the National Treasury, or a USD 800,000 investment in government bonds. Family members add USD 100,000 for a spouse, USD 100,000 for each unmarried, childless child aged 18 to 25, and USD 25,000 for each child under 18. These figures are officially announced, not yet codified, and may change in the implementing regulation. For the full family cost, see our Argentina CBI cost breakdown.
Under the original tender structure, the selected operator would have proposed specific routes and financial levels, for final approval by APCI and the Ministry of Economy. That process did not conclude. The tender was cancelled before an operator was appointed, and no master operator contract exists. The government has since set the headline routes itself through the 2 October 2026 announcement, with AMIGO Ltd acting as a technical adviser to the Agency.
The tender consistently signalled that eligible investments should support Argentina's "real economy", suggesting a focus on areas such as agribusiness, renewable energy, technology, tourism infrastructure and other productive sectors. The officially announced routes are narrower: a Treasury contribution or a government bond investment. No real estate route has been announced. Fees, processing times and the application portal remain unpublished. What is already confirmed is that Argentina's tax framework for CBI investors provides specific protections under Law No. 27802, see our Argentina CBI tax exemption guide for the full breakdown.
What This Means for the Investment Migration Industry
The tender confirms Argentina’s intent to introduce a high-standard, internationally credible CBI program built on strong compliance and clear institutional oversight. Its structure points to a competitive framework balancing economic impact with operational integrity, supported by a coordinated certification ecosystem. This approach is already drawing interest from investors and industry professionals, particularly given Argentina’s geopolitical relevance and passport strength.
A key implication under the original model was the early-mover advantage for agents preparing before launch. The tender's hybrid distribution model placed agents, not the operator, as the primary referral channel. Agent rules for the program itself have not yet been announced.
Interest from global investors is expected to be significant. Argentina's passport strength, reputation and strategic geography make it one of the most notable Western CBI introductions in recent years, and a credible option for families and entrepreneurs seeking long-term mobility and stability. For a full breakdown of passport mobility and visa-free access, see our Argentina Passport by Investment guide. For dual citizenship rules and tax implications, see our Argentina Dual Citizenship investor guide.
When Can Investors Apply?
The key dates:
- Tender publication: Dec 5, 2025 - Confirmed
- Consultation period: Dec 5, 2025 - Jan 9, 2026 - Completed
- Submission deadline: Jan 20, 2026 - Completed
- Tender cancelled: April 14, 2026 - Resolution 522/2026 voided the tender in its entirety
- New procurement path: None. AMIGO Ltd has advised the Agency as a technical adviser since 15 May 2026, and pricing was officially announced on 2 October 2026
- Public program launch: Government target Q4 2026. Not yet open. Slippage remains possible pending the implementing regulation and the Supreme Court appeal on DNU 366/2025
For live updates as milestones are confirmed, visit our Argentina CBI Program Status Tracker.
Investors should begin preparing early, especially those who wish to be first in line when the program opens.
The Future of the Argentina CBI Program
Argentina is building the foundation for what could become one of the most advanced and economically meaningful CBI programs in the market. The tender reveals a strong emphasis on transparent rules, productive investment, and long-term competitiveness. Its structure, separating technical operation from distribution and establishing clear accountability, indicates a program designed for durability and international trust.
Further perspective on why Argentina is positioned to become a major player in the global investment migration landscape can be found in our analysis on why Argentina is emerging as the next citizenship hub.
Conclusion
This tender was the first step toward building Argentina's Citizenship by Investment program's operational layer, and it has since been superseded. Resolution 522/2026 cancelled the tender in April 2026. Since then, AMIGO Ltd has advised the Agency for Citizenship by Investment Programs as a technical adviser, and on 2 October 2026 the Ministry of Economy officially announced pricing and a Q4 2026 launch target. Separately, DNU 366/2025, the decree that underpins the program's no-residency principle, was declared invalid by two federal courts in June 2026 and is now before the Supreme Court. Decree 524/2025 itself remains formally in force.
At ArgentinaCitizenships.com, we continue providing timely updates and regulatory analysis as the program evolves, including when the implementing regulation is published and when applications open.
Argentina's CBI program remains a genuine government initiative. The government targets a Q4 2026 launch, but the program is not yet open and slippage remains possible.
The global investment migration community continues to watch closely.
