On April 14, 2026, Argentina’s Ministry of Economy signed Resolution 522/2026 (RESOL-2026-522-APN-MEC), formally cancelling the international public tender (Concurso Público N° 34-0001-CPU25) that was meant to appoint a master consultant for the country’s Citizenship by Investment (CBI) program. The cancellation was carried out under Article 20 of Decree 1023/2001, which allows the Argentine state to annul a procurement process without compensation to bidders.
This article provides a full technical breakdown of the tender process, the participating firms, the evaluation outcomes, and the implications for Argentina’s CBI program going forward.
Background: Argentina’s CBI Framework
Argentina’s CBI program was established under Decree 524/2025, creating a new agency — the Agencia para la Promoción de la Ciudadanía por Inversión (APCI) — housed within the Ministry of Economy. The program was designed to grant Argentine citizenship to up to 5,000 qualified investors over a four-year period. The international tender was issued to select a consulting firm responsible for designing, launching, marketing, and operating the program on behalf of the APCI.
The tender closed on January 20, 2026, with six firms submitting bids. By March 2026, the Evaluation Commission had issued a recommendation. By April 14, 2026, the Ministry terminated the entire process.
The Six Bidders
The following firms participated in the tender:
- Hong Kong Qian Cheng Business Co., Ltd. (China)
- Latitude Consultancy Malta Limited (Malta)
- Salzburg International for Law LLC / Reach Immigration (International)
- Ancova Associates FZCO (UAE)
- Henley & Partners Immigration Services FZCO (UAE/Global)
- Asesorías Legal Advisor Limitada (Chile) — operating as UT Consorcio AAPA
Disqualifications: Four Firms Eliminated
Four of the six bidders were disqualified during the administrative and financial compliance review, before the technical evaluation stage:
- Hong Kong Qian Cheng: The firm deposited its USD 1.25 million bid guarantee into its own account at China Construction Bank instead of the designated Banco de la Nación Argentina account specified in the tender documents. The funds also arrived ten days past the deadline.
- Salzburg International (Reach Immigration): Uploaded a SWIFT bank guarantee to the COMPR.AR procurement platform but failed to deliver the original physical document with the required certified translation and apostille.
- Latitude Consultancy Malta: Failed the mandatory financial solvency tests. The firm’s indebtedness ratio was 1.36 (maximum permitted: 0.50) and its solvency ratio was 1.73 (minimum required: 2.00).
- Ancova Associates: When asked for clarifications, Ancova submitted a document titled “Rectification of the Technical and Financial Proposal.” The Evaluation Commission deemed this a modification of the original bid, in violation of the principle of inmodificabilidad de las ofertas (bid immutability) under Argentine procurement law.
The Two Finalists
Only two bidders advanced to the full technical and economic evaluation:
Henley & Partners Immigration Services FZCO
Henley & Partners is the largest and most established firm in the global investment migration industry, with operational experience across programs in Malta, St. Kitts and Nevis, Grenada, Dominica, Antigua and Barbuda, and several other jurisdictions. The firm submitted a standalone bid.
Asesorías Legal Advisor Limitada — UT Consorcio AAPA
The Chilean-registered entity served as the legal vehicle for an international consortium of four investment migration firms structured as a Unión Transitoria (temporary joint venture). According to IMI Daily reporting on the March 5 evaluation, the consortium comprised:
- Apex Capital Partners
- AIM Global
- Passport Legacy
- Arton Capital
Both finalists scored comparably on the technical evaluation. The decisive divergence emerged in the economic evaluation, which carried a 40% weighting in the total score.
The Pricing Gap
The economic proposals revealed a significant disparity:
| Bidder | Total Contract Price (USD) |
|---|---|
| Consorcio AAPA | $50,000 |
| Henley & Partners | $25,000,000 |
The consortium bid USD 10,000 per tranche across all five tranches of 1,000 applications, totaling USD 50,000 for the full four-year contract. Henley & Partners bid USD 2 million for the first tranche, escalating to USD 8 million for the fifth tranche, totaling USD 25 million. The difference between the two bids was a factor of 500x.
Given the economic evaluation’s 40% weighting, the consortium’s price advantage was mathematically decisive. The Evaluation Commission recommended awarding the contract to Consorcio AAPA on March 5, 2026.
Legal Challenges and Cancellation
Following the recommendation, both Henley & Partners and Latitude Consultancy filed formal legal challenges (impugnaciones) against the award decision during March–April 2026.
The Ministry’s Legal and Administrative Secretariat subsequently reviewed the proposals in light of the challenges. The official resolution states that the review found persistent divergences between the proposed approaches and the public policy objectives of the program. Specifically, the Ministry concluded that continuing the process under existing conditions could not guarantee the strategic coherence and operational capacity required for adequate program implementation.
On April 14, 2026, Economy Minister Luis Caputo signed Resolution 522/2026, cancelling the tender in its entirety. All bid guarantees are to be returned to participants. No compensation is owed to any bidder under the applicable legal framework.
What This Means for Argentina’s CBI Program
Several important points should be noted:
- The CBI program itself is not cancelled. Decree 524/2025 remains in force, as does the legal framework establishing the APCI. What has been cancelled is the specific procurement process to select a master consultant.
- The government has multiple paths forward. It may issue a new tender with revised evaluation criteria and minimum operational requirements, or it may choose to build the program’s operational capacity in-house through the APCI directly.
- Bidders retain appeal rights. Under Argentine administrative law, participating firms have 20 business days to file a recurso de reconsideración or 30 days for a recurso jerárquico. Whether any firm will pursue this avenue, given the cost and timeline of Argentine administrative litigation, remains to be seen.
- The timeline has shifted significantly. The CBI program is unlikely to open for applications before Q4 2026 at the earliest, assuming the government moves quickly on a replacement procurement process or an in-house buildout. Realistic estimates may push into 2027.
Broader Context: Argentine Citizenship Pathways
The CBI tender cancellation is not the only disruption affecting access to Argentine citizenship. Decree 366/2025 (May 2025) transferred naturalization processing from the federal courts to the Dirección Nacional de Migraciones (DNM). Nearly a year later, DNM has not yet established the operational infrastructure to process new naturalization applications. The only cases currently advancing are those that were already pending before federal judges prior to the transfer.
As of April 2026, both the CBI pathway and the standard naturalization route face significant operational delays, with no confirmed timeline for resolution of either.
Stay informed on Argentina’s CBI program and global RCBI developments. Join SovSpot for real-time updates on program launches, regulatory changes, and investment migration opportunities worldwide.
Source: This article is based on Resolution RESOL-2026-522-APN-MEC published in the Argentine official registry, publicly available procurement records from the COMPR.AR platform, and original reporting by BowTiedMara.
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