Investing in Portugal After Golden Visa Changes

After the 2023 reform, the Portuguese Golden Visa effectively became a different program. Previously, many investors associated it primarily with buying real estate in Lisbon, Porto or the Algarve. After the adoption of Law No. 56/2023, however, real estate was removed from the list of qualifying investment routes.

The current eligible routes include investments starting from €500,000 in qualifying funds, from €500,000 in scientific research, from €250,000 in support of arts and cultural heritage, the creation of at least 10 jobs, as well as investments in commercial companies that create or maintain employment.

In this article, we examine which investments in Portugal remain available after the Golden Visa changes, why real estate is no longer a qualifying basis for the program, and which routes investors now use to obtain residency.

Why Portugal Removed Real Estate from the Golden Visa

Law No. 56/2023 directly defines the purpose of the legislative package as increasing access to housing and includes, among its measures, the termination of residence permits for investment activity in real estate.

The reform was linked to efforts to reduce speculative pressure on the housing market. According to SEF, between October 2012 and September 2023, the program attracted €7.318 billion in investment, of which €6.451 billion went into real estate purchases. This represented about 88% of the total investment volume under the program.

This structure meant that the Golden Visa was effectively operating primarily as a channel for purchasing real estate, rather than as a tool for financing productive business activity, innovation or job creation.

By that point, a persistent gap had already formed in the housing market between property prices and the purchasing power of local households. From 2013 to the end of 2023, real housing prices in Portugal rose by 83%, compared with 28% in Spain.

Price pressure was especially visible in regions where international capital was concentrated. In 2023, the median housing price in Portugal reached €1,611 per m², up 8.6% year on year. In the metropolitan area of Grande Lisboa, the figure was €2,740 per m²; in the Algarve, €2,613 per m²; and in the Área Metropolitana do Porto, €1,800 per m².

The problem affected not only property purchases, but also rentals. In Q4 2023, the median rent under new contracts in Portugal reached €7.71 per m², 11.6% higher year on year. In Grande Lisboa, the rate was €12.54 per m²; in the Algarve, €9.09 per m²; in the Área Metropolitana do Porto, €8.64 per m²; and in the municipality of Lisbon, €15.51 per m².

An additional factor was the concentration of housing in investment and tourism-related use. The OECD notes that the growth of tourism increased demand for housing: tourist overnight stays in Portugal rose by 15% between 2019 and 2024, while revenue from tourist accommodation increased by 55%.

In Lisbon, the number of Airbnb properties rose from 18,277 in September 2019 to 21,181 in December 2024, equivalent to approximately 7.6% of the city’s total housing stock. Together, these factors reduced access to local real estate, primarily for Portuguese residents themselves.

Which Investments Still Qualify for the Golden Visa

After the reform, Portugal’s Golden Visa remained in place as an investment activity regime. New applicants can qualify for residency only through the routes expressly provided under the current ARI framework.

The main Golden Visa routes in Portugal are:

After real estate was removed from the Golden Visa, investment funds became the most practical route. This option does not require the investor to create a business, hire employees or manage an operating project in Portugal. The investor acquires units in a fund, while the capital is managed by a licensed management structure.

The fund route has become popular for several reasons:

• It preserves the investment logic. Unlike a cultural contribution, a fund involves participation in an investment instrument with potential capital return and possible yield.
• There is no need to manage a business directly. The investor is not required to hire staff, rent an office, conduct operating activity or oversee the day-to-day management of a company.
• The entry threshold is clear in advance. The minimum investment amount is €500,000. For high-net-worth applicants, this makes the route more predictable than entrepreneurial scenarios, where actual costs may exceed the stated minimum.
• The instrument is regulated by financial law. Funds are established under Portuguese law and operate in a regulated environment. Regulation does not eliminate investment risk, but it does create a basic level of supervision, reporting and formal requirements for management companies.
• The format is compatible with long-term migration planning. Since the Golden Visa requires the investment to be maintained throughout the period of the status, the fund model is better suited to investors who are prepared from the outset for a multi-year horizon.

At the same time, the fund must be a non-real-estate fund, established under Portuguese law and with a maturity of at least five years at the time of investment. At least 60% of the fund’s investments must be allocated to commercial companies registered in Portugal.

The Portuguese Golden Visa After the Reform

One of the key advantages of the Golden Visa remains in place after the reform: the program does not require a full relocation to Portugal. The holder has the right to live and work in Portugal, while being required to stay in the country for at least 7 days during the first year and at least 14 days during subsequent periods.

The status also provides the right to visa-free travel within the Schengen Area, family reunification, the possibility of later applying for permanent residence and, subject to additional requirements, citizenship.

The minimum physical presence requirement under the Golden Visa can be structured as follows:

Family members included in the process through reunification must also comply with the conditions for maintaining their status. For this reason, travel planning should take into account not only the main investor, but also the spouse, children or other dependent family members included in the migration file.

Permanent Residence After the Golden Visa

Permanent residence remains an intermediate option for investors who want to maintain a legal connection with Portugal, but are not ready or not yet able to move directly toward citizenship.

When preparing for permanent residence, several requirements should be taken into account:

• Temporary residence permit for at least 5 years. To apply for permanent residence, the applicant must confirm a period of legal residence in Portugal.
• Proof of basic Portuguese language knowledge. AIMA lists several acceptable forms of proof, including an education certificate, a Portuguese language course, the CAPLE test or other recognized documents.
• Fiscal and social compliance. The applicant must confirm compliance with tax obligations and social security obligations, where applicable.
• Maintenance of the legal basis for residence. For a Golden Visa investor, it is critical to maintain the investment and comply with the ARI regime throughout the period before applying.

Citizenship is the next possible stage after permanent residence, but it has its own nuances. Organic Law No. 1/2026 introduced longer periods of legal residence for naturalization: at least 7 years for citizens of countries where Portuguese is an official language, as well as for citizens of EU member states; and at least 10 years for citizens of other countries. The new provisions apply only to applications submitted after the law entered into force.

Golden Visa Application Procedure

The first stage is assessing eligibility for the program. The Golden Visa is intended for third-country nationals and does not apply to citizens of Portugal, the EU, the EEA, Andorra or Switzerland.

At this stage, the following points are checked:

• the applicant’s citizenship and migration status;
• absence of restrictions on entry and stay in Portugal;
• absence of criminal grounds that could prevent the issuance of a residence permit;
• ability to confirm the lawful origin of funds;
• applicability of family reunification for a spouse, children and other dependent family members;
• compliance of the selected investment route with the current ARI requirements.

Next, for most investment routes, the applicant needs a Portuguese tax identification number, NIF, and a bank account. The NIF is used to identify the applicant in financial, tax and administrative procedures, including the payment of fees and the formalization of the investment.

Portuguese banks carry out client checks under KYC and AML rules. They assess the source of funds, professional profile, tax residence, business structure, movement of capital and possible sanctions risks.

The investment must be completed before the full migration file is submitted, because the applicant must confirm not an intention to invest, but the actual fulfillment of the investment requirement. The set of supporting documents will differ depending on the selected route.

In practice, three documents are the most critical: proof of transfer of funds, a document from the fund or receiving organization confirming the completed investment, and a legal opinion on the compliance of the route with ARI requirements. The legal opinion does not replace AIMA’s decision, but it reduces the risk of an error in the application structure.

Preparing the Migration File

After the investment is completed, the full document package is prepared. Its composition depends on the investment route and the family structure, but it usually includes the applicant’s personal documents, proof of investment, documents confirming the source of funds, criminal record certificates, confirmation of tax and social compliance, health insurance, documents confirming family relationships, and translations with an apostille or consular legalization, where required by the country of issue.

The application is submitted online: the applicant or representative logs into Portal ARI, completes the application, uploads documents according to the investment type, confirms the submission, proceeds to the payment page, enters the NIF, generates the Documento Único de Cobrança and pays the fee within the required period. After that, AIMA sends a notification: the application is either accepted for the next appointment stage, or it contains errors that must be corrected.

For family applications, a family group is created in Portal ARI. For each family member, identification details, degree of relationship, passport information and required documents are entered. A family reunification request is then submitted and the relevant fees are paid.

After the preliminary document check, the applicant can schedule an appointment. AIMA states that, after document validation, the appointment is made through the calendar in Portal ARI: the applicant selects the AIMA office, year, month, day and time. After the appointment is booked, the applicant receives an email with the visit details for submitting documents and providing biometric data.

During the biometrics appointment, original documents are usually checked, the applicant’s identity is confirmed, biometric data is collected and the details of the file are clarified. For family members, the procedure takes place separately or in parallel, depending on available slots and the organization of the process.

Issuance of the Residence Card and Ongoing Compliance

After approval, the applicant receives a temporary residence permit for investment activity. AIMA states that the temporary Autorização de Residência para Investimento is valid for two years from the date the card is issued.

Receiving the first card does not complete the strategy. The investor must:

• maintain the qualifying investment;
• comply with the minimum stay requirement in Portugal;
• monitor the validity periods of the applicant’s and family members’ cards;
• prepare for renewal in advance;
• keep documents confirming the investment and presence in the country;
• monitor changes in ARI regulation, the tax regime and naturalization rules.

The main feature of the procedure is that the Golden Visa is assessed not only at the time of application. The investment, documents and applicant’s status must remain valid and compliant throughout the entire period of holding the residence permit and during subsequent renewals.