Portugal Golden Visa 2026: What's Left After Real Estate Removal

Portugal's golden visa programme was once the most popular residency-by-investment scheme in Europe, attracting over EUR 7 billion in foreign investment since its launch in 2012. The elimination of the real estate investment route in October 2023 fundamentally changed the programme — but it remains active, and for the right investor, still offers one of the clearest paths to EU permanent residency and citizenship.

What Changed in October 2023

The Portuguese government, through Decree-Law No. 56/2023, removed the following investment routes:

• Real estate acquisition (previously the most popular route at EUR 500,000 or EUR 350,000 for rehabilitation)
• Capital transfer (EUR 1.5M minimum)
• Bank deposits

The removal was driven by concerns about housing affordability, particularly in Lisbon and Porto, where golden visa investment was seen as contributing to price inflation.

Remaining Investment Options

Qualifying Investment Funds — EUR 500,000

The primary remaining route. Applicants must invest EUR 500,000 in qualifying Portuguese investment funds registered with the CMVM (Comissão do Mercado de Valores Mobiliários). Requirements:

• Fund must be registered in Portugal and regulated by the CMVM
• Minimum 60% of the fund's portfolio must be invested in Portugal-based companies
• Investment must be maintained for the minimum period (typically 5 years for golden visa purposes, though fund lock-up periods vary)
• Fund can be venture capital, private equity, or mixed

Typical fund structures: Portuguese VC funds investing in technology startups, real estate rehabilitation funds (indirect real estate exposure is still permitted through fund structures), and SME growth funds.

Expected returns: Highly variable. VC funds carry significant risk with potential for high returns. Conservative funds targeting Portuguese SMEs may deliver 3-6% annually.

Scientific Research — EUR 500,000

A contribution of EUR 500,000 to scientific research activities conducted by Portuguese institutions. This is rarely used due to the non-investment nature of the contribution.

Cultural Heritage — EUR 250,000

Investment of EUR 250,000 in the preservation of Portuguese national cultural heritage. This includes:

• Restoration of classified buildings
• Cultural production and artistic events
• Museum and heritage site support

The lower threshold makes this the most affordable golden visa option, but qualifying projects are limited and the investment is effectively a donation.

Company Formation — EUR 500,000 and 5 Jobs

Creation of a commercial company in Portugal with EUR 500,000 in capital and at least 5 permanent jobs. This route is suitable for entrepreneurs genuinely establishing a Portuguese business.

The Fund Route in Detail

Since the fund route is now the primary pathway, understanding its mechanics is essential.

Fund Selection Criteria

Not all Portuguese funds qualify. Key factors to evaluate:

• CMVM registration: Mandatory — unregistered funds do not qualify
• Portugal allocation: At least 60% must be invested in Portuguese-domiciled entities
• Track record: Prefer funds with established managers who have prior vintage performance
• Fee structure: Management fees (typically 1.5-2.5%) and carry (typically 15-20%) affect net returns
• Liquidity: Most qualifying funds are closed-end with 7-10 year terms and limited redemption rights
• Minimum subscription: Some funds accept exactly EUR 500,000; others have higher minimums

Open-Ended vs Closed-End Funds

Closed-end funds (most common):

• Fixed term (typically 7-10 years)
• Capital is locked up for the fund's life
• Returns are distributed as investments are realised
• Limited secondary market for early exit

Open-ended funds (less common for golden visa):

• Continuous subscription and redemption
• Greater liquidity but potentially less favourable for golden visa compliance
• NAV-based pricing

For golden visa purposes, most applicants use closed-end VC or PE funds. The key risk is that the fund's term may exceed the golden visa's 5-year residency-to-citizenship timeline, meaning the investment remains locked beyond the point at which citizenship is obtained.

Path to Permanent Residency and Citizenship

The golden visa is a temporary residence permit that leads to permanent residency and, ultimately, Portuguese (EU) citizenship:

Timeline

• Year 0: Golden visa issued (valid 2 years)
• Year 2: First renewal (valid 2 years)
• Year 4: Second renewal (valid 2 years) — eligible for permanent residency
• Year 5: Eligible for Portuguese citizenship by naturalisation

Physical Presence Requirements

The golden visa has the lowest physical presence requirements of any European residency programme:

• 7 days in year 1
• 14 days in each subsequent 2-year renewal period

This means a total of approximately 35 days over 5 years — making it compatible with living and working outside Portugal.

Citizenship Requirements

To naturalise as a Portuguese citizen, applicants must:

• Hold a valid residence permit for at least 5 years
• Demonstrate basic Portuguese language proficiency (A2 level on the CEFR scale)
• Have no serious criminal record
• Show ties to the Portuguese community (the minimal physical presence of the golden visa is generally accepted)

Portuguese citizenship grants an EU passport with visa-free access to 190+ countries.

Tax Implications

During the Golden Visa Period

Golden visa holders who do not become Portuguese tax residents (i.e., who spend fewer than 183 days per year in Portugal and do not have their habitual abode or centre of vital interests in Portugal) are not subject to Portuguese income tax on worldwide income.

However, Portuguese-source income (such as returns from Portuguese investment funds) may be subject to Portuguese withholding tax.

NHR Replacement: IFICI Regime

Portugal's Non-Habitual Resident (NHR) tax regime was replaced by the IFICI (Incentivo Fiscal à Investigação Científica e Inovação) regime effective January 2024. IFICI offers:

• 20% flat rate on qualifying Portuguese-source employment and self-employment income
• Potential exemption on certain foreign-source income

However, IFICI is significantly narrower than NHR. It applies primarily to:

• Scientific researchers
• Highly qualified professionals in specific sectors
• Individuals who have not been Portuguese tax residents in the previous 5 years

Most golden visa investors will not qualify for IFICI. Tax planning should account for full Portuguese taxation if residency is established.

Costs Summary

Component	Amount
Fund investment	EUR 500,000
Golden visa application fee	EUR 5,340 (per applicant)
Residence card fee	EUR 5,340 (per renewal)
Legal/advisory fees	EUR 10,000-25,000
Fund management fees (annual)	1.5-2.5% of invested amount
Portuguese language course	EUR 500-2,000
Total (5-year period, single applicant)	EUR 540,000-575,000

Family Inclusion

The golden visa allows inclusion of:

• Spouse or registered partner
• Children under 18 (or over 18 if dependent and in education)
• Dependent parents (over 65 or over 55 if dependent)

Each dependant pays separate application and card fees but does not need to make an additional investment.

Key Takeaways

• Portugal's golden visa remains active despite the removal of real estate investment — the fund route (EUR 500,000) is now the primary pathway
• The programme still offers one of the clearest paths to EU citizenship, with only 35 days of physical presence required over 5 years
• Fund investment carries risk — closed-end VC funds have long lock-up periods and variable returns
• The NHR regime has been replaced by the narrower IFICI, meaning most golden visa investors will not benefit from preferential tax treatment
• Total costs including fees and fund management over 5 years range from EUR 540,000-575,000 for a single applicant
• Portuguese citizenship (obtainable after 5 years) grants an EU passport with 190+ visa-free destinations — the strongest passport available through investment migration
• Applicants should select funds carefully, prioritising CMVM-registered funds with experienced managers and transparent fee structures