Portugal · Residency by investment
Golden Residence Permit Programme (Autorização de Residência para Investimento)
Open and investment minimums unchanged for 2026. Real-estate and capital-transfer routes were abolished in October 2023. The programme itself survived 2026 untouched — but Organic Law 1/2026 rewrote the citizenship endgame, which is what most investors were actually buying.
The value proposition inverted in May 2026. Anyone who applied for nationality before 19 May 2026 is grandfathered at five years; everyone else now faces ten years from card issuance — and because AIMA takes two to three years to issue that first card, a 2026 Golden Visa investor is realistically twelve to thirteen years from a Portuguese passport. The permanent residency at five years is still genuinely valuable and is now the honest reason to do this deal.
Qualifying routes
Fund must have at least 60% of capital invested in commercial companies headquartered in Portugal, minimum 5-year duration at subscription, and no direct or indirect residential real-estate exposure. This is the route the overwhelming majority of applicants use.
Reduced to EUR 200,000 in low-density territories. Requires prior GEPAC (Ministry of Culture) project approval. Non-recoverable — it is a donation, not an investment.
Reduced to EUR 400,000 in low-density territories. Paid to public or private research institutions in the national scientific and technological system.
Create 10 full-time permanent jobs (8 in low-density territories). No statutory capital minimum, but AIMA expects a substantively funded operating business.
Incorporate or reinforce a Portuguese company with EUR 500,000 of share capital and create at least 5 permanent jobs for 3 years.
The facts
- Minimum investment
- €250k
- Total landed cost
- EUR 500k into a fund plus roughly EUR 30–45k for a family of four in AIMA processing and card fees, legal fees, and fund subscription/management charges over the holding period; fund management fees of 1–2% a year are the cost most investors underestimate
- Timeline
- 18–40 months — Statutory decision period is 90 days. Reality in 2026 is 18–40 months to a first card; averages of roughly 34 months have been reported. The government pledged in October 2025 to clear the backlog during 2026 and AIMA added ~300 staff, but the pledge is unproven.
- Physical presence
- 7 days in year one; 14 days in each subsequent two-year period — among the lightest in the EU
- Family
- spouse or de facto partnerchildren under 18dependent unmarried children under 26 in full-time educationdependent parents over 65minor siblings under legal guardianship
- Permanent residency
- 5 years of legal residence — unchanged by the 2026 reform and now the programme's strongest remaining claim
- Citizenship
- 10 years for non-EU/non-CPLP nationals (7 years for EU and Portuguese-speaking-country nationals), counted from the issuance of the first residence permit — not from application submission
- Language test
- Portuguese language and culture test covering language, culture, history and national symbols; the A2 CIPLE standard applied historically, but the exact level is being reset by regulation due by roughly mid-August 2026
- Dual citizenship
- Permitted
- Requirements
- non-EU/EEA/Swiss nationalclean criminal record in country of origin and in PortugalPortuguese tax number (NIF) and a Portuguese bank accountinvestment funds must be demonstrably sourced from outside Portugalmaintain the qualifying investment for the full 5-year residence periodvalid health insurancemeet minimum stay of 7/14 days per period
- The citizenship clock doubled. Organic Law 1/2026 (in force 19 May 2026) took naturalisation from 5 years to 10 for most nationalities. Any adviser still marketing 'EU passport in five years' on this programme is selling a repealed law.
- Article 15(4) of the Nationality Law — the 2024 provision that let residence count from the date the residence-permit application was filed — has been revoked. That provision was the workaround for AIMA's backlog. It is gone, so the backlog now directly consumes years of the client's citizenship clock.
- Grandfathering is narrow. Article 7(2) protects 'pending administrative procedures' — i.e. nationality applications already filed by 19 May 2026. Holding a residence permit on that date does NOT protect you. This distinction is worth millions to families who assumed otherwise, and is being litigated.
- AIMA's backlog is the binding constraint on everything: roughly 400,000 immigration files of all types, including around 55,000 Golden Visa files. Investors are increasingly suing AIMA to compel appointments, and courts are granting those orders — budget for litigation as a normal cost of this programme.
- Fund quality dispersion is extreme. 'CMVM-regulated' is a licensing statement, not a quality statement. Several Golden Visa funds are thinly diversified, expensive, and effectively unexitable at NAV. Diligence the manager, not the visa.
- Reported exits: Bloomberg reported roughly 40 investors withdrawing about EUR 20m in early 2026, with lawyers preparing claims for around 500 holders. Treat the fund's redemption queue as a real risk, not a theoretical one.
- Tax trap: the Golden Visa does not make you a Portuguese tax resident, but spending over 183 days — or maintaining a habitual home — will, and Portugal taxes residents on worldwide income at up to 53%. IFICI will not rescue a passive investor: it requires qualifying employment or self-employment.
- The regulation implementing the new Nationality Law was due within 90 days of 18 May 2026 and remains outstanding as of mid-July 2026. Language level, culture-test format and procedure are genuinely unsettled right now.