Argentina CBI Tender Cancelled: What Resolution 522/2026 Means for Investors
Update (October 2026): Six months on from Resolution 522/2026, no new tender has been announced. 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 a master agent or application channel. The Agency's executive director is Aixa Granara, appointed ad honorem. DNU 366/2025 was declared invalid by two federal courts in June 2026 and is before the Supreme Court; Decree 524/2025 remains formally in force. On 2 October 2026 the Ministry of Economy officially announced pricing and a government target of Q4 2026 to open applications.
On April 14, 2026, Argentina's Minister of Economy Luis Caputo signed Resolution 522/2026 (RESOL-2026-522-APN-MEC), formally cancelling the international tender that was set to appoint a master consulting firm to design, launch, and operate the country's Citizenship by Investment program. You can read the full resolution here (PDF). The resolution was published without a press conference or public statement, but its implications for the program's timeline are significant and warrant a clear, factual account for investors following this space.
This guide explains exactly what happened, why it happened, and what the current status of the Argentina citizenship by investment program is as a result.
What the Tender Was and Why It Mattered
To understand the cancellation, it helps to understand what the tender was trying to accomplish.
The legal architecture for Argentina's CBI program was established through Decree 524/2025 in July 2025. That decree created the Agencia de Programas de Ciudadania por Inversion (APCI), the dedicated government agency that will administer the program under the Ministry of Economy. It set the framework: up to 5,000 citizenship approvals, processed through a formal inter-agency procedure, with no automatic tax residency triggered by citizenship alone - a clarification that was later reinforced through a separate regulatory update in February 2026.
What the decree did not create was the operational infrastructure to actually run the program - the marketing apparatus, the agent network, the due diligence systems, the global promotion strategy. That operational layer was what Tender 34-0001-CPU25 was designed to procure. The government issued the tender in December 2025, calling for a single consulting firm or consortium to build and run the entire operation over a four-year contract.
What Happened During the Tender Process
Six firms submitted offers by the January 20, 2026 closing date. Four were eliminated at the evaluation stage for procedural and financial disqualifications. Two reached the final evaluation: Henley and Partners Immigration Services FZCO, one of the world's most established CBI operators, and a four-firm consortium of investment migration companies operating under the Chilean legal vehicle Asesorias Legal Advisor Limitada.
Both finalists scored identically on the technical evaluation. The decisive factor was price. The consortium bid USD 10,000 per tranche across five tranches of 1,000 applications - a total of USD 50,000 for the entire four-year contract. Henley bid USD 2 million for the first tranche, escalating to USD 8 million for the fifth, for a total of USD 25 million.
The Evaluation Commission's scoring formula, weighted 40% on economics, produced a final score of 88.00 for the consortium against 48.09 for Henley. On March 5, 2026, the Commission recommended awarding the contract to the consortium.
Henley and Partners subsequently filed a formal legal challenge (impugnacion) to that recommendation. Latitude Consultancy Malta Limited, which had been disqualified at the threshold stage, also filed a challenge.
Why the Government Cancelled Rather Than Awarded
Following the challenges, the Ministry's Legal and Administrative Secretariat produced a new technical report reviewing both the challenges and the underlying bids. That report concluded that while two offers were formally admissible, relevant divergences persisted regarding the proposed approaches and their integral adequacy to the public policy objectives to be developed.
The report found that continuing the tender process as structured could not ensure the degree of coherence, integrality, and strategic articulation required for the adequate implementation of the program.
In practical terms: a USD 50,000 contract to design and run a program intended to attract 5,000 high-net-worth investors to Argentina was not a credible operational basis for a program of this scale and ambition. The Ministry had a choice - award to the consortium and risk a program that lacked the infrastructure to function at any serious level, or cancel and find a better path. They chose to cancel.
Resolution 522/2026 voids Tender 34-0001-CPU25 in its entirety. No contract was awarded. No compensation is owed to any bidder. Bid maintenance guarantees will be returned.
What This Does Not Change
The cancellation of the tender is not a cancellation of the program.
The legal foundations established over the past year have partly held and partly been challenged. Decree 524/2025, which created the APCI and the citizenship-by-investment pathway, remains formally in force. DNU 366/2025, which amended Argentine citizenship law to permit naturalization through qualifying investment regardless of prior residency, was subsequently declared invalid by two federal courts in June 2026 and is now before the Supreme Court on the government's appeal. The February 2026 clarification confirming that CBI citizenship does not trigger automatic Argentine tax residency remains in force and is unaffected by the court challenge.
What does not yet exist is the operational program: an implementing regulation codifying the investment amounts announced on 2 October 2026, the application portal, the agent approval framework and the global distribution infrastructure. With no master agent contracted, that layer is being built from a different starting point, with AMIGO Ltd advising the Agency.
What Comes Next
When this article was first published, the Ministry had not indicated its next steps, and three paths seemed plausible:
A new tender, issued with a revised procurement structure that addresses the gaps the first process exposed - in particular, minimum operational budget requirements and a more rigorous assessment of how bidders propose to build global marketing and due diligence capacity.
A restructured procurement that breaks the contract into separate components rather than seeking a single master agent, with procurement, marketing, and due diligence handled by different specialist firms.
In-house development through APCI directly, without a master agent, relying on the agency to build operational capacity using government resources and contracted specialists.
Since then, no new tender has been issued. The government has instead taken technical advice from AMIGO Ltd under a collaboration agreement signed on 15 May 2026, and on 2 October 2026 announced pricing and a Q4 2026 target. Rules for agents and application channels have not been announced.
Government target: Q4 2026. Not yet open. Slippage remains possible, because launch still depends on an implementing regulation and the pending Supreme Court appeal on DNU 366/2025. For the latest confirmed milestones, see the Argentina CBI Program Status tracker.
A Note on What This Decision Actually Signals
There is a broader point worth making here that goes beyond the procedural details of a cancelled tender.
The decision to cancel rather than proceed says something meaningful about how the current administration is approaching this program. Rather than advance a procurement outcome that raised serious questions about operational viability, the Ministry paused, reviewed, and chose the harder path of starting again. That is not the default mode of government decision-making anywhere - and it is not the historical baseline in Argentina.
The signal here is that the government would rather get this right than get it done quickly. A CBI program's credibility with the international investor community is built or destroyed in its first years of operation. Launching with infrastructure that could not support the program's ambitions would have been far more damaging - to the program, to Argentina's reputation in the investment migration space, and to the investors who rely on the passport's international standing - than the delay this reset requires.
No new tender has followed. Instead, the government has opted for technical advice under a collaboration agreement and a direct announcement of pricing. Whether that approach delivers the operational quality the cancellation demanded will become clear when the implementing regulation and application channels are published. ArgentinaCitizenships.com will analyse both the moment they appear.
For now, the program is moving forward on the administrative side while its legal foundation is tested in the Supreme Court. What investors are waiting for is an implementation framework that matches the quality of the legal architecture that underpins it.
What This Means if You Are an Interested Investor
The program's delay is disappointing for investors who had been monitoring developments closely. However, the direction of travel has not changed. The Milei government's commitment to the program as a foreign investment and passport policy has not been publicly questioned. Decree 524/2025, the administrative framework that makes the program possible, remains formally in force, though the no-residency provision it depends on is under Supreme Court review.
For investors at the due diligence stage, the right response to this news is patience, not exit. Programs of this kind routinely encounter implementation delays, particularly in the early phases. What matters for the long-term value proposition - passport strength, dual citizenship rights, tax treatment, Mercosur mobility, and the 30-business-day decision deadline built into the legal framework - remains unchanged. For a full picture of what the Argentine passport offers, including access to 169 destinations without a prior visa and comparison against other CBI programs, see the relevant guides on this site.
ArgentinaCitizenships.com will continue to track every official development and publish accurate updates as they emerge.
For the full current status of the program across all tracked milestones, visit the Argentina CBI Program Status tracker.
