Decree Law 07/2025 Sets Annex I Amounts And A Formal Path For Any Future Updates
When market chatter suggests São Tomé & Príncipe may be adjusting its citizenship by investment minimum investment, the only defensible response is document first. For client facing professionals, quoting a new figure without a published legal instrument creates avoidable engagement risk and marketing compliance exposure.
Decree Law No. 07/2025 (Regulamentação da Nacionalidade por Investimento ou Doação), published in the Diário da República on 01 August 2025, is the operative regulation that anchors qualifying eligibility to a non refundable contribution to the Fundo Nacional de Transformação, with minimum amounts set out in Annex I. The same decree law also builds in a mechanism for future updates under Article 22, which is where any genuine “threshold change” must appear.
This note summarises the current Annex I figures, the decree law pathway for revisions, and the practical file handling implications for your firm while advising clients under the São Tomé & Príncipe Citizenship by Investment Program.
Operative Legal Basis And The Qualifying Contribution
Decree Law No. 07/2025 (Regulamentação da Nacionalidade por Investimento ou Doação), published in the Diário da República on 01 August 2025, frames São Tomé & Príncipe nationality by investment or donation around a non refundable financial contribution to the Fundo Nacional de Transformação (National Transformation Fund). The decree law states that the qualifying contribution must meet the minimum amounts set out in Annex I.
For advisory teams building a defensible record, that structure matters: the minimum contribution is not an informal pricing schedule. Annex I is part of the operative regulation, and the decree law itself points practitioners to Annex I as the controlling reference for the minimums.
Where your practice uses co branded program summaries and client fee tables, align your published parameters to Annex I, and keep the decree law PDF in the client file as the primary reference point for the amounts you are quoting.
For an overview of how Abroad Mobility supports application co management and back office processing for immigration professionals on this file type, see the São Tomé & Príncipe Citizenship by Investment Program page.
Current Annex I Minimums And Published Fees (Decree Law 07/2025)
Annex I to Decree Law No. 07/2025 sets the current official minimum contribution amounts in USD and also lists specific due diligence and post approval additions. The following table follows Annex I wording and figures.
| Annex I Item (Decree Law No. 07/2025) | Amount (USD) |
|---|---|
| Individual applicant minimum contribution | 90,000 |
| Family application minimum contribution (2 to 4 members) | 95,000 |
| Each additional qualifying dependent (minimum contribution add on) | 5,000 |
| Due diligence and processing fee (per application) | 5,000 |
| Post approval addition: spouse | 10,000 |
| Post approval addition: other dependents | 5,000 |
| Post approval addition: newborn up to 1 year | 500 |
The listing follows the source wording, and eligibility and intake outcomes remain file specific under the competent authorities’ review.
How A Real “Threshold Change” Must Happen Under Article 22
The rumour to watch is a minimum increase or restructuring of Annex I. Decree Law No. 07/2025 already anticipates this possibility. Article 22 (Actualização dos Montantes Mínimos de Investimento) authorizes the responsible ministers, under UCID oversight, to alter fees and minimum investment amounts in Annex I by joint ministerial order (despacho conjunto).
Article 22 also frames what should inform any update, including economic conditions and international inflation. Practically, this is the hinge point for advisor risk control: an Annex I change is a legal act with an identifiable form (a despacho conjunto) rather than an agent circulated schedule.
Article 22 further states that updates do not affect already admitted files. That detail is a second order planning point for counsel: once an application is admitted, future Annex I updates described under Article 22 do not apply to that admitted file, which can materially affect how you stage client decisions and how you document your submission milestones inside your case management record.
Practice Handling: What To Do With Market Chatter While Keeping Files Defensible
As of 28 September 2026, no published joint ministerial order or amendment changing the Annex I minimums was identified in the sources reviewed. For day to day client work, the cleanest control is operational: quote Annex I, cite Decree Law No. 07/2025 by name and date, and treat any alternate schedule as outside your engagement scope until it is tied to a specific despacho conjunto issued under Article 22.
Internally, many firms tighten two points when rumours circulate. First, keep a single controlled fee table in your templates aligned to Annex I amounts and additions (including the due diligence and processing fee of USD 5,000 per application). Second, run intake through a structured pre screen so the household composition is mapped consistently to the Annex I brackets (individual, family application 2 to 4 members, and each additional qualifying dependent) before any numbers are communicated.
Where you want a standardised way to record which route and household sizing the client is being quoted under, Abroad Mobility’s Eligibility Engine can support a uniform intake narrative across partner firms, while keeping the controlling figures anchored to Annex I.
What Has Not Changed In The Decree Law Framework
Decree Law No. 07/2025 continues to anchor the program to a non refundable contribution to the Fundo Nacional de Transformação, with minimums set out in Annex I. Article 22 continues to describe a formal update path via a despacho conjunto under UCID oversight and states that updates do not affect already admitted files.
For professional teams fielding client questions on São Tomé citizenship by investment minimum investment, the compliance answer is straightforward: work from Decree Law No. 07/2025 and Annex I, and treat Article 22 as the only pathway for a lawful update to minimums and fees.
If your firm wants case co management, controlled documentation, and partner ready fee tables aligned to Annex I, start with Abroad Mobility’s Strategic Partnership Program. This content is informational and does not constitute legal advice.
Contact Abroad Mobility to arrange case co management, controlled fee tables, or to discuss Annex I alignment: Contact Abroad Mobility.
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