Portugal · Residency by investment
Golden Residence Permit Programme (Autorização de Residência para Investimento)
The programme is open, and the investment minimums are unchanged for 2026. The 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, and that endgame is what most investors were actually buying.
The value proposition flipped 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. 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 it 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.
This drops to EUR 200,000 in low-density territories. It requires prior approval from GEPAC, the Ministry of Culture's project office. The amount is non-recoverable. It is a donation, not an investment.
This drops to EUR 400,000 in low-density territories. The funds are paid to public or private research institutions within the national scientific and technological system.
Applicants must create 10 full-time permanent jobs, 8 of them in low-density territories. There is no statutory minimum capital requirement, but AIMA expects to see a substantively funded operating business.
Investors must incorporate or reinforce a Portuguese company with EUR 500,000 of share capital and create at least 5 permanent jobs, maintained for 3 years.
The facts
- Minimum investment
- €250k
- Total landed cost
- EUR 500k goes into a fund. On top of that, a family of four should budget roughly EUR 30–45k for AIMA processing and card fees, legal fees, and fund subscription and management charges over the holding period. Fund management fees of 1–2% a year are the cost most investors underestimate.
- Route type
- Residency by investment
- Timeline
- 1.5–3.3 years (The statutory decision period is 90 days. The reality in 2026 is 18–40 months to a first card, with averages of roughly 34 months reported. The government pledged in October 2025 to clear the backlog during 2026, and AIMA added ~300 staff, but the pledge remains unproven.)
- Physical presence
- 7 days in year one, then 14 days in each subsequent two-year period. This is among the lightest physical presence requirements 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. This is unchanged by the 2026 reform and is now the programme's strongest remaining claim.
- Citizenship
- 10 years for non-EU and non-CPLP nationals, or 7 years for nationals of EU and Portuguese-speaking countries. The clock starts from the issuance of the first residence permit, not from the date the application is submitted.
- Language test
- Applicants must pass a 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
- a non-EU/EEA/Swiss nationala clean criminal record in both your country of origin and Portugala Portuguese tax number (NIF) and a Portuguese bank accountproof that your investment funds come from outside Portugalkeeping the qualifying investment in place for the full 5-year residence periodvalid health insurancemeeting the minimum stay requirement of 7/14 days per period
- The citizenship clock doubled. Organic Law 1/2026, in force from 19 May 2026, took naturalisation from 5 years to 10 for most nationalities. Any adviser still marketing an 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 now, so the backlog directly eats into years of the client's citizenship clock.
- Grandfathering is narrow. Article 7(2) protects pending administrative procedures, meaning 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 it is being litigated.
- AIMA's backlog is the real constraint on everything here. There are roughly 400,000 immigration files of all types, including around 55,000 Golden Visa files. Investors are increasingly suing AIMA to force appointments, and courts are granting those orders. Budget for litigation as a normal cost of this programme.
- Fund quality varies enormously. Being CMVM-regulated is a licensing fact, not a quality signal. Several Golden Visa funds are thinly diversified, expensive, and effectively impossible to exit 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.
- There is a tax trap here. The Golden Visa does not make you a Portuguese tax resident on its own, but spending over 183 days in the country, or keeping a habitual home there, will. Portugal taxes residents on worldwide income at up to 53%. IFICI will not rescue a passive investor either. It requires qualifying employment or self-employment.
- The regulation implementing the new Nationality Law was due within 90 days of 18 May 2026. It remains outstanding as of mid-July 2026. Language level, the format of the culture test, and the procedure itself are all genuinely unsettled right now.