Portugal Golden Visa: What Changed in 2024 and What Remains

The Portugal Golden Visa still exists in 2026. The real estate route that dominated it for a decade does not. Following the Mais Habitação reforms enacted in October 2023 and implemented through 2024, direct and indirect investment in Portuguese residential property no longer qualifies. The investment fund route, the cultural and research donation routes, and the job creation route all remain, and the headline benefit, a path to European Union citizenship after five years, is intact.

This article explains the current state of the programme as it operates in 2026, what each route actually costs, what processing now looks like under the post-reform backlog, and who the Golden Visa is still appropriate for.

What the 2023-2024 reforms changed

The Mais Habitação package, framed as a response to housing affordability in Lisbon and Porto, removed the following qualifying investments:

• Direct purchase of residential property (previously the EUR 500,000 route)
• Direct purchase of low-density or rehabilitation residential property (previously EUR 350,000 and EUR 280,000)
• Investment in real estate funds with material real estate exposure
• Capital transfer of EUR 1.5 million held in a Portuguese bank account

What was preserved:

• Investment of at least EUR 500,000 in a qualifying Portuguese venture capital or private equity fund with no real estate exposure
• Donation of at least EUR 250,000 to artistic production or cultural heritage
• Investment of at least EUR 500,000 in scientific research
• Creation of at least ten jobs in a Portuguese company, or investment of EUR 500,000 in an existing Portuguese company that creates at least five jobs

The naturalisation pathway was also preserved: five years of legal residence with a minimum physical presence requirement (seven days in year one and fourteen days every subsequent two-year period), plus an A2-level Portuguese language test, leads to Portuguese and therefore European Union citizenship.

The fund route in practice

In 2026 the fund route is the dominant choice for Golden Visa applicants. Approximately three quarters of new approvals run through qualifying funds.

The minimum investment is EUR 500,000 in a Portuguese-regulated venture capital or private equity fund that holds no real estate. Funds must be registered with the Portuguese Securities Market Commission (CMVM) and structured to comply with the Golden Visa rules: typically a six-to-eight-year horizon, an early-redemption mechanism aligned with citizenship eligibility at year six, and underlying exposure to Portuguese technology, agriculture, energy or industrial companies.

Realistic total cost for a single applicant pursuing the fund route in 2026:

• Fund investment: EUR 500,000 (recoverable subject to fund performance)
• Fund subscription and management fees: 1.0 to 2.0 per cent annually
• Legal fees: EUR 8,000 to EUR 15,000
• Government application fees per applicant: EUR 5,500 initial plus EUR 3,000 at each renewal
• Translation, notarisation and apostille: EUR 1,500 to EUR 3,000

The economic case rests on the underlying fund. A well-selected fund returning four to six per cent annually leaves the applicant approximately whole on the original capital after fees and citizenship. A poorly selected fund can lose meaningful capital. Fund selection is the single most important decision in the post-reform programme.

The donation routes

The cultural production donation (EUR 250,000) is the lowest absolute cost route in the programme. It is a non-recoverable contribution to qualifying Portuguese artistic, cultural heritage or museum projects.

For applicants whose primary objective is European Union citizenship and who are prepared to treat EUR 250,000 as a sunk cost in exchange for that outcome, the donation route is straightforward, predictable, and removes investment risk. It has historically been the lowest-volume route but its share has grown since the fund route became the default.

The scientific research donation (EUR 500,000) and the job creation route are operationally more complex and are now used primarily by applicants with an existing business connection to Portugal.

Processing times in 2026

The Portuguese Foreigners and Borders Service (SEF) was dissolved in October 2023 and replaced by AIMA (Agência para a Integração, Migrações e Asilo). The transition created a significant processing backlog that, by mid-2026, has narrowed but not closed.

Realistic timelines:

• Application submission to first biometrics appointment: nine to fifteen months
• Biometrics to initial residence permit: three to six months
• Renewal cycles: two-year permits, renewable
• Total to citizenship eligibility: five years from initial application date, not from permit issuance (a 2024 legislative change confirmed this)

The five-year clock starting from application date, rather than from permit issuance, is a material benefit for applicants caught in the AIMA backlog.

Tax residence is a separate question

The Golden Visa is a residence permit. Holding it does not, by itself, make the applicant tax resident in Portugal. Tax residence is triggered by spending more than 183 days in Portugal in a calendar year, or by having a home in Portugal that is treated as a habitual residence.

The previous Non-Habitual Resident (NHR) tax regime, which gave qualifying new residents ten years of favourable tax treatment on foreign income, was closed to new applicants from 1 January 2024 and replaced by the more restrictive Tax Incentive for Scientific Research and Innovation (IFICI) regime. The IFICI regime is genuinely useful but is narrower in scope, applying primarily to qualifying employment in research, innovation or specific listed activities.

For most Golden Visa applicants in 2026, the tax planning is to maintain non-resident status for tax purposes throughout the five-year residency-to-citizenship period, then take a deliberate decision about tax residence after citizenship is granted. See for the detail.

Who the programme is right for

The Golden Visa in its post-2024 form is appropriate for:

• Applicants whose primary objective is European Union citizenship and who can wait five to six years
• Applicants who can deploy EUR 500,000 into a fund without needing the capital for that period
• Families where the spouse and dependent children should all hold European Union citizenship within the same period

It is not appropriate for:

• Applicants seeking immediate physical residence in Portugal (a D7 or D8 visa is the correct route)
• Applicants seeking a property investment with a residency wrapper (no longer possible)
• Applicants who need citizenship in under three years (Caribbean CBI is the correct route)
• Applicants whose primary objective is short-term tax optimisation (the NHR window has closed)

Common mistakes

The most common mistake in 2026 is selecting a fund on the basis of marketing material rather than the fund manager's track record, fee structure and underlying portfolio. The Golden Visa label is now a sales channel for funds, and the quality dispersion is wide.

The second is underestimating the AIMA backlog and assuming the five-year clock starts at permit issuance rather than application date. It starts at application date, which works in the applicant's favour but requires correct documentation of the application date.

The third is conflating the Golden Visa (a residency permit) with tax residence (a separate legal status). They are independent and must be planned independently.

Frequently asked questions

Can I still buy property in Portugal under the Golden Visa? No. Direct and indirect real estate investment no longer qualifies. You can buy property in Portugal at any time as a private purchase, but it does not contribute to the Golden Visa.

How long must I physically spend in Portugal? Seven days in year one, fourteen days in each subsequent two-year period. Realistically, less than two weeks per year on average.

Will my children become Portuguese citizens? Dependants included in the original application follow the same five-year path. Children under eighteen at the time of citizenship application can be naturalised alongside the principal.

Can I lose the residence permit? Yes, by failing to meet the minimum physical presence requirement or by failing to maintain the qualifying investment for the required period.

Is the programme likely to close? The October 2023 reforms were the substantive change. The remaining routes have political support and are not currently subject to active legislative review. That said, all European residency-by-investment programmes face ongoing European Union pressure and applicants should not assume the programme will exist in its current form indefinitely.

Where to go next

For a wider comparison of European residency-by-investment options now that Portugal real estate has closed, see. For the tax residence questions that sit alongside the Golden Visa decision, see and.

This article is general information and is not legal, tax, or financial advice. The Golden Visa programme has been reformed several times in recent years and further change is possible. Consult a Portuguese immigration lawyer and a tax advisor in your country of current residence before committing funds.