Record Keeping

Record keeping in a Vanuatu citizenship application means the files that several different parties build and retain about you: the designated agent's client records, the due diligence provider's report, the Citizenship Office's application file and decision, and the passport records held by the Department of Immigration and Passport Services. Each holder keeps different information, for a different purpose, under different rules on how long it may be retained.

This page is for applicants who want to know where their personal data ends up once they start the process, and what they should keep themselves. It does not repeat how the procedure runs; it follows the paper trail. For the duties an agent carries more generally, see the page on agent obligations.

Who Holds Records About a Vanuatu Applicant?

A single application typically generates records in at least five places. Some sit in Vanuatu, some in the applicant's home country, and some with intermediaries elsewhere.

Holder	What is typically kept	Why it is kept
Marketing intermediary or sub-agent (if any)	Enquiry details, copies of documents you sent them, correspondence	Commercial relationship; passing your file to the licensed agent
Licensed designated agent in Vanuatu	Identity documents, source-of-funds evidence, signed forms, payment records	Lodging the application; anti-money laundering obligations
Due diligence provider	Background-check findings, database results, the final report	The check paid for through the US$5,000 due diligence fee
Citizenship Office and Citizenship Commission	The application file, the due diligence report, the decision and grant records	Deciding and recording citizenship status
Department of Immigration and Passport Services	Passport application, photograph and the personal data shown in the passport	Issuing and later renewing the travel document

Banks that handle the contribution transfer — US$130,000 for a single applicant up to US$180,000 for a family of four under the Development Support Program, paid in US dollars — keep their own transaction and customer records under the law of the country where they operate.

What Ends Up in the Citizenship File?

The Citizenship Office's file is the record that matters most over the long term, because it is the basis of your status as a citizen of Vanuatu. In broad terms it holds:

• the application as lodged by the designated agent, with the personal details of the main applicant and every dependant;
• certified copies of civil-status documents such as birth and marriage certificates, and their translations;
• police certificates and the source-of-funds evidence;
• the due diligence report;
• the Commission's decision, confirmation of payment and the record of the grant.

Because citizenship obtained on the basis of false or concealed information can be revisited under the Citizenship Act [CAP 112], this file is not something that is processed and then discarded. Applicants should assume that it is kept for as long as the citizenship it supports, and that what was submitted years ago can be read again later.

How Long Is Data Retained?

There is no single retention period that applies to everything. Each holder works under its own rules, and we do not quote specific numbers of years because they differ between laws and change over time.

Agents and financial-crime records

Businesses covered by anti-money laundering law are generally required to keep customer identification and transaction records for a minimum period after the business relationship ends. That period is set by the applicable law; Vanuatu's regime, in which the Financial Intelligence Unit plays the central role, is one source of such rules. Your agent should be able to tell you the period it applies.

Intermediaries in Europe or the UK

If any intermediary handling your file is established in the European Union or the United Kingdom, its handling of your personal data is governed by the GDPR or UK GDPR. That means it must have a lawful basis for keeping your documents, keep them no longer than necessary, and respond to requests for access to the data it holds about you.

Government records

Citizenship and passport records held by the Vanuatu authorities are kept under Vanuatu law and administrative practice. Applicants have no practical way to ask for them to be deleted, and should not expect to.

Record Keeping Is Not Publication

Record keeping and publication are different things. Most of what is held about an applicant is confidential to the holders listed above. What is published officially — laws, regulations, notices about the programmes — and what stays closed is the subject of the separate page on published registers and the Gazette.

Applicants sometimes worry that their name will appear on a public list visible to their home country. The more realistic exposure is through the ordinary information flows that already exist: banks reporting under international tax-information rules, and governments sharing data in the course of visa applications. A Vanuatu passport holder applying for a Schengen visa, which has been required permanently since 3 February 2025 under Regulation (EU) 2025/11, provides their data to that Schengen state directly.

What Should You Keep Yourself?

The record most often missing years later is the applicant's own. Agents close, staff change and email accounts are lost. A sensible personal archive includes:

1. The approval letter and the payment instructions you received.
2. Bank confirmations of the contribution transfer and receipts for the due diligence fee and any small fees set by regulation.
3. The certificate of citizenship and the record of the oath, if one was taken.
4. A copy of the passport data page for each family member, and later each renewed passport.
5. The engagement letter with your agent, including who the licensed designated agent was.
6. Copies of the civil-status documents and translations exactly as submitted.

These papers answer the questions that tend to come up later — from a bank asking how a second citizenship was acquired, from a consulate processing a visa, or from your own authorities checking whether you hold another nationality. Keep both paper and secure digital copies, stored somewhere that does not depend on the agent who handled the file.