Decision and Appeal
From due diligence to approval in principle: what happens to a file after lodging, and what an applicant can do if refused.
Reviewed by Dr. Anatoliy Yarovyi, Senior Partner
An application under Vanuatu's Development Support Program (DSP) ends in one of two ways: the Citizenship Commission approves it in principle, or it refuses it. This page explains who makes that decision, what the decision is based on, what happens between approval and the passport, and what options an applicant realistically has after a refusal. Timelines are indicative and no outcome can be promised in advance.
Citizenship Commission - The Vanuatu body that considers applications for citizenship, including applications under the DSP, and decides whether citizenship should be granted under the Citizenship Act [CAP 112].
Approval in principle - The Commission's preliminary decision that an applicant has passed due diligence and may proceed to pay the government contribution. It is not yet citizenship: the certificate is issued only after payment and the oath.
Who decides a DSP application, and on what basis?
The decision belongs to the Citizenship Commission, acting under the Citizenship Act [CAP 112] and the rules made for the DSP. Applicants do not deal with the Commission directly. Every application must be lodged through a designated agent appointed for the program, and the agent remains the point of contact for requests for further information and for the decision itself.
Before the Commission decides, the file goes through due diligence. This includes checks involving Vanuatu's Financial Intelligence Unit (FIU) and looks at identity, criminal and civil history, sanctions exposure, and the origin of the money used for the contribution. The Commission weighs the due diligence results together with the documents in the application. A clean due diligence report does not oblige the Commission to approve; it is one input into a discretionary decision.
The DSP is the program currently open to new applicants. The Capital Investment Immigration Plan (CIIP) has not accepted new applications since March 2025, so this page refers to DSP applications only.
What are the stages between submission and a passport?
The published process follows a fixed order, and the order matters because it determines how much money is at risk at each point.
- Submission and due diligence. The designated agent lodges the complete application and the non-refundable due diligence fee of US$5,000. Due diligence runs on the main applicant and on every included family member.
- Approval in principle. If the Commission is satisfied, it issues approval in principle. If it is not, the application is refused at this stage.
- Payment of the contribution. Only after approval in principle does the applicant pay the DSP contribution, in US dollars. The published amounts are US$130,000 for a single applicant, US$150,000 for a couple, US$165,000 for a family of three and US$180,000 for a family of four.
- Oath of allegiance. The applicant takes the oath in the manner the Commission requires (see the next section).
- Citizenship certificate. The Commission issues the certificate of citizenship.
- Passport. With the certificate, the new citizen can apply for a Vanuatu passport through the usual channel.
The whole sequence commonly takes about 2–4 months from a complete submission. That is a typical range, not a commitment. Requests for further documents or complex source-of-funds questions can extend it, and no agent or adviser can promise a date.
How is the oath of allegiance taken?
The oath is a formal step, not a courtesy. A published notice of the Citizenship Commission states that the oath is to be taken in the physical presence of a Commissioner for Oaths. While COVID-19 restrictions were in force, the oath was also accepted by video link.
Because arrangements of this kind can change, applicants should not rely on older descriptions found online. Ask your designated agent which method the Commission accepts at the time of your approval, where the oath can be taken, and what identification the Commissioner for Oaths will need to see.
Why are DSP applications refused?
Based on how the procedure is designed, the typical grounds for a negative decision are these:
- Incomplete documents. Missing police certificates, civil documents, translations or certifications can stop a file or lead to refusal if the gaps are not filled.
- False or misleading information. Undisclosed name changes, earlier citizenships, prior refusals elsewhere or inaccurate statements in the forms undermine the whole application once discovered.
- Unclear origin of funds. If the applicant cannot show a credible, documented trail for the money used for the contribution and fees, the file is unlikely to clear due diligence.
- Sanctions exposure. A match with a sanctions list, for the applicant or a dependant, is a serious obstacle.
- Adverse due diligence findings. Criminal history, ongoing proceedings or reputational concerns identified in the checks may lead the Commission to refuse even where the paperwork is complete.
What does a refusal cost the applicant?
A refusal is issued instead of approval in principle, so its financial consequences follow from the payment order described above:
- The US$5,000 due diligence fee is not refundable, whatever the outcome.
- At least part of the government fee is already paid: under the DSP Regulations, 25% falls due before the Commission considers the file and is not refunded on refusal, while the remaining 75% is due before the certificate is issued.
- Professional fees already paid to the designated agent or other advisers depend on the terms of your engagement letter. Read those terms before you sign.
A refusal may also be relevant later. Other countries' visa, residence and citizenship forms often ask whether an application has ever been refused, and the answer must be truthful.
Can a refusal be challenged or the application filed again?
Whether a DSP refusal can be formally appealed is not something general guidance can settle, so treat any confident statement that an appeal "always" or "never" exists with caution. In practice, the options worth discussing are these:
- Ask for the reasons. Through your designated agent, request whatever explanation the Commission is able to give. Without knowing why the file failed, no next step can be assessed properly.
- Correct the problem and reapply, if permitted. Where the refusal rests on a fixable issue, such as a missing document or an insufficiently evidenced source of funds, it may be possible to file a new application once the defect is cured. Whether a new application is accepted, and on what terms, is for the Commission; ask your agent which fees would apply again.
- Consider judicial review. A decision of a public body in Vanuatu may, in principle, be challenged before the Supreme Court by way of judicial review. Whether that route is available and sensible in a particular case is a question for a lawyer with a right to practise in Vanuatu, who can advise on procedure, timing and prospects.
Whatever route is chosen, keep copies of everything submitted and all correspondence.
How can an applicant reduce the risk of a negative decision?
Most refusals trace back to issues that could have been identified before filing. Disclose your full history to the designated agent at the pre-screening stage, including matters you consider minor. Assemble source-of-funds evidence that explains where the money came from, not just where it sits now. Check every family member included in the application, since an issue with a dependant affects the whole file. Finally, make sure the forms, the supporting documents and any earlier applications in other countries tell the same story.
Sources
Questions
Frequently Asked Questions
No. Approval in principle is the Citizenship Commission's preliminary decision that you have passed due diligence and may pay the DSP contribution. Citizenship follows only after the contribution is paid in US dollars, the oath of allegiance is taken and the Commission issues the citizenship certificate. With that certificate you can then apply for a Vanuatu passport.
The US$5,000 due diligence fee is not refundable, whatever the outcome. The DSP contribution is normally not yet paid at that point, because it is due only after approval in principle. Whether any professional fees paid to your designated agent or other advisers come back depends on the terms of your engagement letter.
The published program rules do not set out a dedicated appeal procedure for DSP applicants. Through your designated agent, ask for the reasons. If the problem can be fixed, a new application may be possible where the Commission permits it. Whether judicial review before the Supreme Court is available in your case is a question for a lawyer with a right to practise in Vanuatu.
A published Citizenship Commission notice says the oath is taken in the physical presence of a Commissioner for Oaths, and that it was accepted by video link while COVID-19 restrictions were in force. Arrangements can change, so ask your designated agent which method the Commission currently accepts, where the oath can be taken and what identification you will need.
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