Most of what you will read online about Portugal’s Golden Visa describes a route that no longer exists. Direct property purchase stopped qualifying in October 2023. If you are planning around a guide that tells you to buy an apartment in Lisbon and collect residency in return, you are working from an old map. The programme still runs, and it is still one of the more practical residency-by-investment options in Europe. The way in has changed. Since the 2023 reform, the qualifying investment fund has become the main path, and for most international buyers it is now the only serious one to understand.
I have sat across the table from buyers who arrived in Lisbon with a property shortlist and a firm belief that the purchase would hand them a residence permit. It will not, and it has not for over two years. This is the current picture.
Key takeaways
- Direct property purchase has not qualified for the Golden Visa since October 2023.
- The main route today is a €500,000 subscription to a qualifying investment fund.
- Qualifying funds must be regulated by the CMVM and hold no direct or indirect real estate.
- From 19 May 2026, most non-EU nationals need 10 years of legal residence to apply for citizenship.
- The physical presence requirement is 14 days in every two-year permit period.
What changed in October 2023
The real estate route is closed. Portugal’s Mais Habitação housing reform, brought in through Law 56/2023, ended new Golden Visa applications tied to property. That included direct purchase, renovation projects, and real-estate-linked funds, along with the €1,500,000 capital transfer route.
This was not a small adjustment to the rules. For more than a decade, property had accounted for the large majority of Golden Visa applications, and Lisbon apartments were a favourite. The 2023 reform stopped all of that for new applicants. Since then, the subscription to a qualifying investment fund has become the route most buyers use, particularly those who want professional management and a clean separation between their residency plan and any property they may buy later.
The practical problem is that the internet has not caught up. A large share of the guides ranking today still describe the pre-2023 framework as if it were current. If a source tells you to buy to qualify, stop reading it.
How the investment fund route works
A qualifying fund must be regulated by the CMVM, the Comissão do Mercado de Valores Mobiliários, which is Portugal’s securities market regulator. The fund has to be constituted under Portuguese law, carry a maturity of at least five years, and invest most of its capital in Portuguese companies. Any fund with direct or indirect exposure to real estate is excluded under the post-2023 rules. The minimum subscription is €500,000.
The mechanics are simple. You subscribe to a qualifying fund, and its licensed management team makes the investment decisions. You have no day-to-day role. Most investors plan to exit somewhere between six and ten years in, by selling their units, through a fund repurchase mechanism, or by holding to maturity.
Fund strategies vary. Some target private equity in established Portuguese companies, some back venture capital in higher-growth sectors, some hold agribusiness or a blend of financial and alternative assets. Expected annual returns differ widely with the strategy and the risk taken, and you should treat any figure a promoter quotes as a projection rather than a promise. A fund with a five-year lock-up is an investment decision first and a residency decision second. Treat it that way.
For a buyer based in London, Dubai, Singapore or New York, the fund route has one clear practical benefit. Once the money is subscribed, it runs without asking you to be in Portugal or to manage anything yourself.
What the fund route actually costs
The €500,000 subscription is only part of what you will pay. Government fees, fund charges and legal costs all sit on top, and the total capital you should model is meaningfully higher than the headline number.
Government processing and issuance fees apply per applicant, with renewals falling due during the permit period. The figures below are approximate and move with annual inflation adjustments, so confirm the current schedule before you budget to the euro. Contact us for latest government information.
| Applicant | Approx. processing | Approx. issuance | Approx. total over 5 yrs |
| Single | ~€630 | ~€6,315 | ~€26,500 |
| Couple | ~€1,265 | ~€12,630 | ~€53,000 |
| Family of four | ~€2,530 | ~€25,255 | ~€106,000 |
Fund-level charges are where the real money moves over time. Expect a subscription or KYC fee, usually around 1 to 2 percent of the amount invested; an annual management fee, typically 1 to 2 percent a year; and a performance fee, often 10 to 25 percent of profits above a set hurdle rate. Exit and redemption terms vary by fund, and some are far more restrictive than they first appear. Read the full fund documentation before you commit, not after.
Legal fees for the whole Golden Visa period, covering the application, the renewals and the associated processes, generally run in the region of €15,000 to €20,000, paid in instalments across the programme. Add all of this together and a single applicant should plan for a grand total meaningfully above €500,000 before any performance fees. Model the full cost across the whole holding period. The minimum subscription is the start of the number, not the end of it.
Who qualifies for the Golden Visa
The programme is open to any non-EU, non-EEA and non-Swiss national over the age of 18, provided you hold a clean criminal record, carry no debts in Portugal, and can show that your investment funds come from a lawful source outside the country. Those conditions are not a formality. The source-of-funds check in particular is where weak applications tend to stall.
You can include close family in a single application. That covers a spouse or partner, children under 26 who are financially dependent and either living with you or studying at university, and parents aged 65 or over. Parents under 65 can be included where you can evidence their financial dependence on you. Same-sex couples qualify on the same terms, provided the relationship is registered or has lasted at least two years.
A few points by nationality. UK citizens became eligible after Brexit, from 1 January 2021, and the freedom to travel across the Schengen area once the card is issued is the main draw for many British applicants. Americans have been among the largest groups of Golden Visa investors through the fund route, with no treaty conflict and no extra barrier to qualifying. For buyers from the Gulf, South and Southeast Asia and East Asia, no nationality restriction applies beyond the non-EU, non-EEA, non-Swiss rule. The door is the same width for everyone outside the bloc.
Residency, citizenship and the 2026 timeline
The Golden Visa does not ask you to move to Portugal. The minimum physical presence is 14 days within each two-year permit period, which averages out to roughly a week a year. That structure is the whole appeal for investors who are settled elsewhere and want Portuguese residency as a long-term asset rather than an immediate home.
Your first residence card is valid for two years and is then renewable. After five years of legal residence you can apply for permanent residency, and once you hold it you are generally no longer required to keep the qualifying investment in place.
Citizenship is where 2026 brought the significant change. Portugal’s new nationality law applies to applications submitted on or after 19 May 2026. Under it, EU and CPLP (Portuguese-speaking country) nationals become eligible for citizenship after seven years of legal residence, and all other nationals, including US, UK, UAE, Indian and Singaporean applicants, after ten years. The previous rule was five years for everyone, so this is a material shift for most international buyers. Applications filed on or before 18 May 2026 are still assessed under the old five-year timeline. The new law also counts residence only from the date your permit is issued, not the date you applied, and adds integration requirements around Portuguese language, culture and civic knowledge.
For anyone starting the process now, plan on a 10-year horizon to citizenship. That is the honest planning assumption for US, UK, Middle Eastern and Asian applicants in 2026. Residency itself is a separate and much nearer milestone, and it is what most fund investors are actually buying. Where you are eligible for a given residency or citizenship route, a specialist lawyer should confirm the current thresholds before you rely on them, because this area has moved more than once.
The application process step by step
The process runs in a fixed order, and no step can be skipped.
It starts with the NIF, the Número de Identificação Fiscal, which is Portugal’s nine-digit tax number and roughly the equivalent of a US Social Security Number or a UK National Insurance number. You need it before any banking or investment step, and a Portuguese lawyer can obtain it for you under power of attorney without you being in the country.
Next is a Portuguese bank account in your own name, because the fund subscription has to be made from one. Opening an account usually takes four to six weeks and can be arranged remotely through your lawyer. Once the account is active and funded, you subscribe to a qualifying CMVM-regulated fund, and the fund manager issues documentation confirming the investment.
The application itself goes to AIMA, the Agency for Integration, Migrations and Asylum, which replaced the former SEF. Documents are filed electronically, and AIMA has been accepting fully digital signatures. After submission, you and every included family member attend an in-person biometrics appointment in Portugal to give fingerprints and hand over original documents.
Then you wait. Processing currently runs anywhere from about 12 to 36 months, driven by AIMA’s administrative backlog. Plan for the longer end of that range. Renewals, at least, have moved online through AIMA’s digital portal, which has taken some friction out of the later stages.
How to choose a qualifying fund
Fund selection is the single most consequential decision in the whole process. The application stands or falls on the fund being correctly structured. A disqualified fund means a disqualified application, and by then your capital is already committed.
Four criteria are non-negotiable. The fund must be CMVM-regulated. It must hold no direct or indirect real estate, which has been an absolute bar since October 2023. The subscription must meet the €500,000 minimum. And it must carry a minimum five-year holding period.
Beyond those, scrutinise the things that determine whether this is a sound investment as well as a valid one: the management team’s track record, the exit mechanism and how liquid your units really are, and the full fee structure across subscription, management and performance. Look hard at whether the fund’s stated strategy matches its actual portfolio. You are locking capital away for at least five years, so the quality of the fund matters as much as its eligibility. Independent due diligence here is worth far more than it costs.
Frequently asked questions
Can I still get a Golden Visa by buying property in Lisbon?
No. Direct property purchase has not qualified for the Golden Visa since October 2023. You can still buy an apartment in Lisbon, and many fund investors do exactly that, but the property is a separate decision from the qualifying fund investment. The two can sit side by side; they cannot be combined into a single qualifying route.
How many days a year do I have to spend in Portugal?
The minimum is 14 days of physical presence within each two-year permit period, which averages about seven days a year. Most investors plan one short trip a year and keep evidence of entry and exit, such as boarding passes and accommodation bookings, in case it is requested at renewal.
Did the citizenship timeline change in 2026?
Yes, significantly. Under the nationality law that applies from 19 May 2026, most non-EU nationals now need 10 years of legal residence before applying for Portuguese citizenship, up from five. EU and CPLP nationals need seven. Applications filed on or before 18 May 2026 are still judged under the previous five-year rule.
Can my family be included in one application?
Yes. A spouse or partner, financially dependent children under 26 who live with you or are studying, and parents aged 65 or over can all be included under a single application. Parents under 65 can be added where you can evidence their financial dependence on you.
How long does the application take in 2026?
Current processing runs from roughly 12 to 36 months, from submission to the residence card being issued, depending on AIMA’s scheduling and workload. Treat the longer end as your planning assumption rather than the shorter one, and build that timeline into any decision that depends on holding the card.
Buying in Lisbon alongside your fund investment
Many people who take the fund route also want a home in Lisbon, whether as a base for their annual visits, a rental asset, or a future primary residence. These are two separate decisions, and it helps to keep them separate in your head. The fund secures your residency. The property is a purchase on its own terms, and it should stand on its own merits.
That property side is where we work. Lisbon BA represents buyers only, so there is no seller or developer on the other side of our advice. If you decide to buy in the city while your fund investment runs, you get access to the wider market, including off-market listings, an independent view on value, and someone negotiating for you rather than for the sale. If you want to understand the city itself before you commit, our why Lisbon page is a good place to start.
For the Golden Visa itself, the fund route turns on current thresholds and eligibility that keep changing, so it belongs with a specialist. Book a private consultation and we will point you to the right legal and fund advice, then handle the Lisbon property side ourselves when you are ready.
