Portugal Golden Visa

Yes. It was restructured in October 2023, not cancelled. Real estate was removed as a qualifying route; the fund, cultural donation, job creation and company formation routes remain and are accepting applications in 2026.

With Spain's Golden Visa closed since April 2025, Portugal stands out as the only EU program built around a real-estate-free venture and private-equity fund route. It is not the only residency-by-investment program in the EU, Hungary, Greece, Italy and Malta all run active schemes, but none is structured around funds the way Portugal's is.

Legal and advisory fees run €8,000–€15,000. Government (AIMA) fees are higher than most guides admit: the issuance fee alone is around €6,300–€8,400 per person, and with application, analysis and later renewals the government total reaches €15,000–€18,000 per person across the five-year programme, charged per family member and indexed annually. Health insurance is €1,000–€2,000 a year per adult, a tax advisor €2,000–€5,000, and fund management fees 1–2% a year, €5,000–€10,000. First-year non-investment costs land around €23,000–€41,000 per applicant.

Over five years, management fees alone run €25,000–€50,000 before any return. The €500,000 is the floor, not the total.

The five-year path is gone. Since May 19, 2026, naturalisation requires ten years of residence for most applicants, seven for nationals of EU and Portuguese-speaking (CPLP) countries. The clock starts when your first residence card is issued, and only lawful residence counts.

The change came through Lei Orgânica 1/2026: voted on April 1, 2026, promulgated in May, and in force since May 19. The transitional protection is narrow, it covers only citizenship applications filed with the IRN on or before May 18, 2026. It does not protect a Golden Visa residence application: if you held residency but had not yet filed for citizenship before the cutoff, you are not grandfathered into the old five-year rule. For a Golden Visa investor who is not an EU or CPLP national, plan on ten years to citizenship, and confirm your own position with a current Portuguese immigration lawyer.

The Non-Habitual Resident (NHR) regime closed to new applicants on January 1, 2024. A transitional regime kept it open for people whose ties predate the change, and the tax authority’s own FAQ says a qualifying 2024 resident who registers after March 31, 2025 can still be admitted, for the remaining years only. For anyone moving now, it is closed. Its replacement, the IFICI framework (sometimes called “NHR 2.0”), applies to residents from January 1, 2024 but is far narrower, targeting highly qualified workers in designated sectors and scientific research. If your income doesn’t fit those categories, the old NHR benefits are no longer available to new applicants.

US citizens are taxed on worldwide income regardless of residence, Portuguese residency does not change that. Verify your position with a Portuguese tax advisor before deciding anything on tax grounds.

The fund must be CMVM-regulated, hold at least 60% of its capital in Portugal-headquartered companies, carry no real estate exposure, and have a minimum five-year maturity.

Most fund information online comes from providers with an interest in steering you. Ask any fund or advisor: the historical return and annual fees; how much capital is deployed in Portugal and in what sectors; the exit mechanism at maturity and the record on returning principal; whether it is CMVM-regulated with a clean audit; and what happens if you need to exit early. Get the prospectus and read it before committing.

Historically 12–24 months from application to first card, and AIMA's current backlog can push cases beyond that. Budget 12–18 months as a realistic baseline, and don't count on anything faster.

Keep the lawyer and the fund as two separate professionals, a licensed immigration lawyer who does not also sell fund products, and a tax advisor who can read your income under IFICI. A single firm offering both may have conflicting incentives.