Is Portugal Golden Visa still available?
Yes. The Portugal Golden Visa — officially the Residence Permit for Investment Activity (ARI) — is still accepting applications in 2026. The program was not cancelled; it was restructured. Real estate investment as a qualifying route was removed in October 2023 under the Mais Habitação (More Housing) Law. The investment fund route, cultural donation option, and job creation path all remain.
With Spain's Golden Visa program ending in April 2025, Portugal is now the only major EU member state running an active, scaled residency-by-investment program for fund investors. That has made it more competitive, not less relevant.
Three things to know upfront
- Real estate is no longer an eligible investment route — any guide still describing property purchases is outdated
- The fund investment path requires a minimum €500,000 tied up for at least five years
- The five-year citizenship timeline most guides cite is facing a legislative challenge that was not resolved as of early 2026
What investment options remain in 2026
The Portugal Golden Visa now has four qualifying routes. In practice, one of them dominates.
| Route | Minimum | Capital returned? | Practical difficulty |
|---|---|---|---|
| Investment fund | €500,000 | Usually yes, at maturity | Moderate |
| Cultural donation | €250,000 | No — it's a donation | Low |
| Job creation | No fixed minimum | N/A | High |
| Company formation | No fixed minimum | N/A | High |
Fund investment — €500,000
The primary path for the overwhelming majority of applicants in 2026. You invest €500,000 into a qualifying Portuguese investment fund and hold it for a minimum of five years. The fund must be regulated by the CMVM, at least 60% of its capital must be invested in Portugal-headquartered companies, it cannot have real estate exposure, and minimum fund maturity is five years.
The investment is not a donation. The principal is typically returned at maturity, minus management fees. If that €500,000 is not genuinely surplus capital, the fund route creates real liquidity risk.
Cultural and artistic donation — €250,000
A donation of €250,000 toward Portuguese cultural heritage, arts, or scientific research qualifies. This money is not returned. The lower entry point is the appeal — in practice it's a small fraction of applications.
Job creation and company formation
Creating 10 full-time positions for Portuguese nationals qualifies. The practical cost of establishing a viable business that employs 10 people is substantially higher than it sounds. These routes suit founders genuinely building businesses in Portugal, not mobility-focused applicants.
What it actually costs: beyond the €500,000
| Item | Estimate |
|---|---|
| Fund investment (principal, returned at maturity) | €500,000 |
| Legal and advisory fees | €8,000–€15,000 |
| AIMA application fees | ~€5,500 |
| Health insurance (annual, per adult) | €1,000–€2,000 |
| Portuguese tax advisor | €2,000–€5,000 |
| Fund management fees (year 1, 1–2% p.a.) | €5,000–€10,000 |
| Non-investment costs, first year | €21,500–€37,500 |
Legal fees
Engaging a Portuguese immigration lawyer is not optional. Realistic fees range from €8,000 to €15,000. Errors in the application are costly. Don't structure this without legal support.
Fund management fees
Annual fund management fees usually run 1–2% of invested capital — €5,000–€10,000 per year. Over five years that's €25,000–€50,000 in management costs before any returns. The €500,000 is the floor, not the total.
The citizenship question: 5 years or 10?
This is the most important open question for anyone considering the program — and the one most guides handle poorly.
What current law says
Under the law as it stands in March 2026, holding an ARI residence permit for five years makes you eligible to apply for Portuguese citizenship. The five-year clock starts from the date your first residence card is issued — not from the date of application.
What happened in late 2025
On October 28, 2025, Portugal's parliament approved amendments extending the minimum residency period for naturalisation from five years to ten years (seven years for EU citizens and CPLP nationals including Brazil, Angola, and Mozambique). The law was passed, then sent for Constitutional Court review.
On December 15, 2025, the Court rejected several provisions — retroactive application and certain exclusion mechanisms — but did not reject the ten-year extension itself.
What this means for applicants
The program as a residency vehicle is on solid legal footing. The citizenship path involves unresolved legislative risk. If Portuguese citizenship on a confirmed short timeline is your primary goal, be direct with yourself about this uncertainty before committing.
Who Portugal Golden Visa is right for
- Investors with €500,000 in genuinely surplus capital — not earmarked for other purposes within five years
- Remote professionals and founders who want EU residency without full relocation — the seven-day annual minimum stay is the program's defining advantage
- Non-EU nationals for whom Schengen access is a structural priority — Turkish citizens, for example, gain significant travel flexibility
- Families with a long-term EU integration horizon — low presence requirements mean no forced family disruption before you're ready
Who should look elsewhere
- Your budget is under €500,000 — Portugal's D7 Passive Income Visa is worth evaluating instead (no capital requirement, same citizenship path, higher presence requirement)
- You need your €500,000 accessible within three to four years — the fund route doesn't accommodate clean early exits
- Portuguese citizenship on a confirmed five-year timeline is your primary objective — treat the citizenship path as uncertain given the pending Nationality Law reform
- You're a US citizen expecting to reduce US tax obligations — US citizens are taxed on worldwide income regardless of residence; Portuguese residency does not change your US obligations
- You were planning around the original NHR tax benefits — the IFICI framework that replaced NHR targets specific professional categories; verify your income qualifies before proceeding
Fund selection without sales pressure
Most of what you'll find about qualifying Golden Visa funds comes from service providers with a financial interest in directing you to specific funds. What you're looking for is a fund that meets the legal requirements and fits your risk tolerance — not the one your advisor earns the highest commission from.
Questions worth asking any fund or advisor
- What is the fund's historical return, and what fees apply annually?
- What percentage of capital is deployed in Portugal, and in what sectors?
- What is the exit mechanism at maturity, and what is the track record on principal return?
- Is the fund CMVM-regulated and does it have a clean audit history?
- What happens if you need to exit early?
Processing time
Historically 12–24 months from application to first ARI card. Portugal's fully digital processing platform has accelerated some cases to four to six months. Budget 12–18 months as a realistic baseline. The five-year citizenship clock starts from when your first residence card is issued, not from the application date.
Two separate professionals
The path forward involves a licensed Portuguese immigration lawyer who doesn't also sell fund products, and a Portuguese tax advisor who can assess your income under the current IFICI regime. Firms that offer both in a single engagement may have conflicting incentives.