You’re researching the Portugal Golden Visa because you’ve heard it’s one of Europe’s most accessible residency programs.
And you’re right—but a lot has changed since October 2023.
If you’re still reading articles that mention buying property in Lisbon or Porto for €500,000 to qualify, you’re looking at outdated information. The real estate route is gone. Permanently.
But the Portugal Golden Visa isn’t dead. Far from it. It’s just evolved into something different—more focused on productive investments, less tied to the housing market that priced out locals.
Here’s what actually works in December 2025, based on the latest regulatory framework and what investors are doing right now.
What Changed in October 2023
The Portuguese government passed the “Mais Habitação” housing package in 2023. This wasn’t a minor tweak. It was a complete overhaul driven by political pressure to address housing affordability.
The changes removed three major routes that used to dominate Golden Visa applications:
Real estate purchases at all price points—whether €500,000 in coastal areas, €350,000 for rehabilitation projects, or the reduced thresholds in low-density regions.
Capital transfer routes where you could simply deposit €1.5 million in a Portuguese bank.
Investment funds with any direct or indirect real estate exposure.
The data tells the story. Before October 2023, real estate purchases accounted for 9,398 residence permits. Rehabilitation projects added another 1,783. Investment funds? Just 617.
Now those numbers have flipped. Funds and corporate investments are the dominant pathways.
The Four Active Routes in 2025
If you want a Portugal Golden Visa today, you’re choosing from four options. Each has different minimum investments, holding periods, and risk profiles.
CMVM-Regulated Investment Funds
This is where most sophisticated investors are going. You invest €500,000 minimum into a fund regulated by Portugal’s securities market commission (CMVM).
The fund must invest at least 60% of its capital in Portugal. It needs a minimum maturity around five years. And critically—it cannot have any real estate exposure, direct or indirect.
You’ll find funds focused on private equity, venture capital, infrastructure, renewable energy, tech, and hospitality. Some exceed €1 billion in assets under management with institutional backers.
The typical fund lifecycle runs 7-10 years. That’s longer than your five-year residency requirement, so you need to plan for liquidity.
Professional fees typically run €15,000-€30,000 for high-net-worth clients when you factor in legal work, due diligence, and subscription costs. Government processing fees add several thousand euros per family member.
Corporate Investment and Job Creation
You have two variants here.
First option: Create 10 new full-time jobs in Portugal (8 in low-density areas) and maintain them for at least three years. The capital requirement isn’t fixed by law, but you’ll need substantial investment to legitimately create and sustain those positions.
Second option: Invest €500,000 in the share capital of a Portuguese company and create five permanent jobs or maintain 10 jobs for at least three years.
This second variant has become popular as a turnkey corporate investment where you take an equity position in an operating Portuguese company that contractually handles the job-creation obligations.
The company must have its head office in Portugal. You’re expected to maintain the investment for at least five years, aligned with your residency timeline.
Scientific Research Contributions
Transfer €500,000 or more to public or private scientific research institutions that are integrated into Portugal’s national scientific or technological system.
These are typically structured as non-returnable donations rather than investments with expected returns. They work best for philanthropically inclined investors or those with strategic ties to specific research areas—health, environmental sciences, technology.
Cultural and Artistic Heritage
Capital transfers starting at €250,000 (potentially rising to €500,000 depending on project and region) to support artistic production or the recovery and maintenance of Portugal’s cultural heritage.
These flow through approved public foundations, museums, or recognized cultural entities. Like research contributions, they’re donation-style with limited financial return but potential impact value for legacy-focused investors.
How the Application Actually Works
The institutional landscape changed significantly. SEF (Serviço de Estrangeiros e Fronteiras) was dismantled. Immigration functions transferred to AIMA (Agência para a Integração, Migrações e Asilo) from late 2023.
This transition created backlogs. Current processing times run 6-12+ months from investment completion to card issuance. Sometimes longer.
The application structure follows this pattern:
You’ll need a Portuguese tax number (NIF) and a bank account. Most fund subscriptions still require this even though the funds are CMVM-regulated.
After selecting your investment route, you execute the subscription agreement and transfer funds. For CMVM funds, you’ll review the prospectus, subscription documents, and Golden Visa eligibility representations.
Next comes document preparation. Criminal records from all countries of residence (apostilled). Health insurance valid in Portugal. Proof of lawful origin of funds. Family documents for dependents.
Submit everything through AIMA’s online portal. Once preliminary approval comes through, you schedule a biometrics appointment in Portugal. Then you wait for your initial residence card—typically issued for one year.
The renewal cycle follows the classic 1+2+2 structure. After the first year, you renew for two years, then another two years. That’s five years total if you maintain your investment and meet the minimal physical presence requirements.
And those presence requirements remain incredibly light—around 7 days per year, or 14 days in each two-year renewal period. This is still one of the Golden Visa’s biggest selling points.
What Happens After Five Years
After five years of legal residence, you can apply for either permanent residency or Portuguese citizenship.
Citizenship requires A2 Portuguese language proficiency. That’s basic conversational ability—enough to handle everyday situations but not fluency. You’ll also need a clean criminal record and evidence of your residence pattern.
Portuguese citizenship means EU citizenship. You get broad mobility across the Union, rights to live and work anywhere in the EU, and access to Portuguese public healthcare and education systems.
For investors tracking the latest Portugal golden visa updates reported by Global Residence Index, the pathway to citizenship remains intact despite the 2023 reforms.
The Tax Planning Reality
Here’s where things got complicated.
Portugal’s Non-Habitual Resident (NHR) regime was heavily restricted or closed to new applicants in 2024. A narrower successor scheme exists, but the generous tax benefits that used to pair so well with Golden Visa residency are largely gone.
The Golden Visa itself doesn’t grant tax benefits. It grants residency. Tax residency is a separate question based on how many days you actually spend in Portugal.
Portugal still offers extensive double-tax treaties and favorable structuring opportunities for non-domiciled high-net-worth individuals. But you need bespoke tax advice based on your specific nationality, existing tax residency, and global income sources.
Different nationalities face different CFC rules, exit taxes, and reporting obligations that must be reconciled with Portuguese law.
How Portugal Compares to Other EU Programs
Spain historically offered golden visas through €500,000 real estate purchases. That route still technically exists as of late 2024, but it’s under significant political pressure and reforms are being debated.
Spain also requires 183 days per year for active tax residency, compared to Portugal’s 7 days for maintaining your Golden Visa status.
Greece centers its golden visa around real estate—€250,000 to €500,000 depending on location. No minimum stay requirement. But citizenship takes seven years.
Malta offers complex residency and citizenship by investment structures with substantial presence requirements and significant scrutiny from EU authorities.
Portugal’s combination of low physical presence, clear path to EU citizenship after five years, and quality of life metrics (safety, climate, healthcare, education) keeps it attractive even without the real estate angle.
What You Need to Know About Risk
Investment risk is real. CMVM-regulated funds aren’t guaranteed. Performance depends on sector dynamics, manager quality, leverage, and macroeconomic conditions.
The long fund lock-ups (7-10 years) versus your five-year residency requirement create timing tensions. You might complete your citizenship application while your capital is still tied up.
Currency risk hits non-euro investors. If you’re coming from USD, GBP, or other currencies, entry and exit points can materially affect your effective returns.
Political risk remains. Portugal survived the 2023 housing reform but significantly narrowed the program. Future tightening or reorientation isn’t impossible. Legislative change is a reality in investment migration.
Processing delays at AIMA create uncertainty. Six months is optimistic. Twelve months is common. Sometimes longer.
Getting Professional Guidance
The Portugal Golden Visa in 2025 requires navigating CMVM regulations, AIMA procedures, fund due diligence, tax implications across multiple jurisdictions, and complex document requirements.
Working with specialized advisors who understand the current regulatory framework makes the difference between a smooth application and a rejected one. Firms like Global Residence Index and their parent company Vancis Capital have direct relationships with government bodies and track record with successful applications.
Other reputable advisors in this space include Portugal Pathways and Global Citizen Solutions, though the depth of government relationships and processing experience varies.
Pre-screening before application submission identifies potential issues early. Criminal record complications, source of funds questions, or documentation gaps that could delay or derail your application.
The bottom line: Portugal’s Golden Visa survived the 2023 reforms. It just shifted from property speculation to productive investment. For investors who understand the new landscape and plan accordingly, it still offers one of Europe’s most practical paths to residency and eventual EU citizenship.
