- The need for a holistic hierarchy guiding mobility planning decisions.
- Integration of mobility rights into the asset registry of the family office.
- Citizenship and residency rights are legally distinct assets with materially different durability, enforceability and inheritability.
- Regional citizenship (notably EU citizenship acquired through a Member State like Malta) constitutes a multi-jurisdictional legal status rather than a single-country benefit.
- Residence and citizenship acquisition regimes must be assessed against evolving international law principles, including substance requirements evolving in international law into the principle of Contributive Belonging, coined by the author to describe the latest iteration of the Genuine Links doctrine, moving away from purely transactional acquisition or merely formal requirements.
- Mobility rights derive from primary law (treaties, constitutions) or secondary administrative regimes, affecting long-term asset stability.
Who this is for: Business families, family offices, private wealth advisors, trustees, and legal professionals involved in long-term cross-border planning, governance, succession, and contingency structuring.
What This Means for You: The Mobility Assets Spectrum provides a structured way to evaluate mobility solutions beyond headline visa-free travel counts of earlier Passport Indexes. It enables families and advisors to assess which mobility assets genuinely protect optionality, continuity, and legacy across generations, and which remain tactical or temporary tools.
Relationship to Existing Passport & Mobility Indexes
Global wealth advisors have long relied on passport or residence indices measuring visa-free travel. These lists ignore what matters most to a family office: permanence, intergenerational transfer, and legal resilience.
The Mobility Assets Spectrum reframes mobility rights as enduring holdings that can be ranked by durability and legacy value. It mirrors how families classify property, trusts, or equity - each with its own tenure, liquidity, and governance weight.
Why a Spectrum, Not an Index? Existing passport indexes primarily measure visa-free travel counts. While useful for short-term mobility, they do not assess establishment rights, residence security, or long-term enforceability. The Mobility Assets Spectrum complements these tools by addressing structural legal value, making it more relevant for families concerned with governance, succession, and long-term planning rather than travel convenience alone.
Residency & Citizenship ranking based on sustainable Legal Foundations
This model builds on three long-standing doctrines:
- Genuine Links (ICJ, Nottebohm 1955): citizenship carries international validity only when a genuine connection exists.
- Substance Principle in Tax Law: rights and benefits must rest on real activity or presence.
- Contributive Belonging Doctrine (Chetcuti 2025): modern mobility rights should reflect reciprocal contribution between applicant and host state.
Together, these principles justify ranking mobility statuses by authenticity and permanence rather than by investment volume alone.
The CCLEX Mobility Assets Spectrum Explained
The CCLEX Mobility Assets Spectrum places mobility rights on a continuum from low optionality and reversibility to high durability and legacy value. At the lower end sit temporary residence permissions that are time-bound and policy-sensitive. Moving up the spectrum are permanent residence rights, followed by national citizenship. At the highest end sits regional citizenship, where rights extend automatically across multiple states by operation of supranational law.
The Spectrum is intentionally qualitative rather than transactional. It focuses on what the status enables over time, not on visa-free access, minimum investment thresholds or processing speed.
Mobility Assets as a Distinct Asset Class
Mobility assets are legal statuses that grant an individual the right to reside, work, establish, or move across one or more jurisdictions. Unlike financial assets, their value lies not in yield but in optionality – the ability to respond to geopolitical, regulatory, personal, or business change. Citizenship and residency therefore operate as risk-mitigation and continuity instruments, particularly relevant for internationally exposed families.
Methodology Behind the CCLEX Mobility Assets Spectrum
The Mobility Assets Spectrum is built on five core assessment criteria:
- legal durability,
- geographic scope of rights,
- enforceability,
- intergenerational continuity,
- independence from discretionary renewal.
Each mobility status is assessed against these criteria to determine its relative position on the Spectrum. The framework deliberately excludes lifestyle considerations and focuses instead on legal effect and structural resilience.
From Spectrum to Valuation Matrix
The Mobility Assets Spectrum™ provides the qualitative ranking. The forthcoming Mobility Assets Valuation Matrix™ adds quantitative assessment — assigning weights for permanence, inheritability, rights, and compliance cost.
Together they create the first family-office-oriented alternative to public passport indices: a professional valuation tool grounded in law, not marketing.
Comparative Insights
- Permanent Residence vs Citizenship: Permanent residence grants indefinite stay subject to continued good conduct. Citizenship provides political membership, enhanced protection, and automatic inheritance - qualities that lift it to the top of the Spectrum.
- EU Citizenship vs Non-EU Citizenship: EU citizenship (e.g. Malta, Austria) multiplies value through union-wide establishment rights and integration into the single market. Non-EU citizenship (e.g. St Kitts, Grenada) still carries diplomatic and travel value but narrower economic utility.
- Permanent Residence vs Golden Visa: Golden Visas (e.g Portugal Golden Visa, Greek Golden Visa, Italy Golden Visa) are often probationary, annual or biennial permits. True permanent residence (e.g. Malta PR) is open-ended, less exposed to policy reversal, and therefore ranks higher in stability and legacy transfer.
- Schengen vs Non-Schengen Residence: Schengen residence (Malta, Italy) enables intra-zone short-stay access and regulatory consistency. Non-Schengen residence (e.g Cyprus, Switzerland) may deliver lifestyle or tax advantages but with less travel and institutional robustness.
Regional Citizenship as the Apex Mobility Asset
Regional citizenship represents the highest tier of the Spectrum. EU citizenship, acquired through citizenship of an EU Member State, confers directly effective rights across twenty-seven jurisdictions, enforced through supranational institutions and courts. From an asset perspective, this creates a multi-state legal platform rather than exposure to a single sovereign system. Comparable regional regimes elsewhere remain either incomplete or not legally accessible through investment or merit pathways.
Core Mobility Asset Categories on the Spectrum
Each category differs materially in revocability, enforceability, intergenerational transfer, and resilience to political change. These differences are often obscured in mainstream “passport rankings” but are critical for family office planning.
Placing Residencies & Citizenships on the CCLEX Mobility Assets Spectrum
At the lower end lie short-term or easily revocable statuses, useful tactically but offering limited permanence.
Mid-range assets include long-term or permanent residence - especially within the Schengen area - offering family continuity and education access.
At the upper end lie citizenships with full political, establishment, and inheritance rights, particularly of EU Member States.
| Tier 1 – Short-Term Visas and Entry Permits |
| Temporary rights of entry, often renewable but non-establishing. Limited duration, no legacy value. |
| Tier 2 – Temporary Residence by Investment (“Golden Visa”) |
| One- to two-year residence subject to renewals and compliance. Provides optionality but remains dependent on continued investment or physical presence. |
| Tier 3 – Permanent Residence in Non-Schengen States |
| Open-ended residence rights confined to a single jurisdiction (e.g. Cyprus, UAE). Offers family stability but limited regional mobility. |
| Tier 4 – Conditional Permanent Residence in Schengen States |
| Grants indefinite residence plus Schengen-wide short-stay mobility (e.g. Greece) but lost on disposing of property or children reaching age of 18. |
| Tier 5 – Full Permanent Residence in Schengen States |
| Grants indefinite residence plus Schengen-wide short-stay mobility without taking away residency from children reaching the age of majority (e.g. Malta) and allowing newly born children in the family to be added on. Represents continuity assets with stronger legacy potential. |
| Tier 6 – Citizenship of Non-EU States |
| Full nationality and inheritance, with mobility depending on treaty networks (e.g. St Kitts & Nevis, Grenada, Turkey). Valuable, but narrower establishment rights. |
| Tier 7 – Citizenship of EU Member States |
| Highest tier. Full rights of residence, work, and establishment across the EU/EEA (e.g. Malta, Austria). Combines permanence, inheritance, and multi-jurisdictional access — the hallmark of legacy mobility. |
From Spectrum to Valuation Matrix
How Family Offices Use the Spectrum
- Asset Mapping: record every family member’s statuses and place them on the spectrum.
- Gap Analysis: identify over-reliance on temporary or low-durability statuses.
- Strategic Upgrading: plan progression to higher-tier assets through contribution-based frameworks.
- Governance Integration: incorporate mobility assets into the Family Charter or Investment Policy Statement.
Strategic Implications
The Spectrum introduces a language for comparing mobility options on strategic rather than emotional grounds. It reinforces that mobility rights, like other assets, should be acquired, maintained, and reported with rigour.Families that apply this framework elevate mobility planning from transactional decision-making to long-term governance — building reputation, resilience, and legacy value.
How Our Citizenship & Residency Lawyers Can Help You
Our Citizenship & Residency Lawyers assist family offices in building balanced mobility portfolios across the Spectrum - combining temporary, permanent, and citizenship rights that align with governance, tax, and succession planning. CCLEX provides expert planning, acquisition, structuring, and governance integration of mobility assets across jurisdictions. Our approach is jurisdiction-agnostic, legally grounded, and aligned with long-term family objectives rather than short-term incentives. Our advisory work applies the CCLEX Mobility Assets Spectrum™ to assess, rank, and sequence residencies and citizenships in line with individual and family objectives.
Copyright © 2025 Chetcuti Cauchi. This document is for informational purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking any action based on the contents of this document. Chetcuti Cauchi disclaims any liability for actions taken based on the information provided. Reproduction of reasonable portions of the content is permitted for non-commercial purposes, provided proper attribution is given and the content is not altered or presented in a false light.
