This guide is general information, not advice for your case. Rules and fees change; check the official source before you file.
What changed since 2023
Three things matter:
- Real-estate was removed in October 2023. Direct purchases of residential or commercial property no longer qualify. So-called "real-estate funds" that hold property indirectly are also out, AIMA looks at the underlying assets, not the wrapper.
- The €500k venture-capital fund route was kept and is now the dominant pathway. Approved Portuguese-regulated funds that invest in Portuguese companies (not real estate) remain qualifying investments.
- The 2026 Nationality Law (in force since 18 May 2026) doubled the wait for citizenship: 10 years for most foreigners, 7 years for CPLP nationals. The clock starts from the date your residency card is issued, not the application date. This affects new applicants, see below.
The qualifying investments in 2026
| Pathway | Threshold | Notes |
|---|---|---|
| Venture-capital fund (PME / innovation) | €500,000 | Dominant route. Must be a Portuguese-regulated FCR/SCR, with at least 60% invested in Portuguese-domiciled companies, minimum 5-year maturity, no real-estate exposure. |
| Scientific research | €500,000 | Donation or investment in approved R&D institutions. Rare in practice. |
| Cultural & artistic heritage | €250,000 | Donation to approved heritage projects. Lower threshold, but tightly scoped. |
| Job creation | 10 jobs | Create 10 permanent jobs in Portugal, usually combined with a D2 founder structure. |
| Portuguese company capitalisation + 5 jobs | €500,000 | Capital injection into an existing or new Portuguese company that creates 5 jobs. |
In 2026 the vast majority of new Golden Visas are filed via the €500,000 fund pathway. The other routes still technically exist but have either thin supply (R&D, heritage) or operational friction (10-job creation requires running a real Portuguese employer).
What "qualifying fund" actually means
Not every fund qualifies. AIMA checks the fund's regulatory wrapper and its investment policy at the time of your application. The four hard rules:
- Portuguese regulator (CMVM): the fund must be regulated by the Comissão do Mercado de Valores Mobiliários. It will be a Fundo de Capital de Risco (FCR) or a Sociedade de Capital de Risco (SCR) vehicle.
- Maturity ≥ 5 years at the time of subscription.
- ≥ 60% of NAV invested in Portuguese-headquartered companies.
- No direct or indirect real-estate exposure. If the fund's underlying portfolio includes operating companies whose core business is real-estate development, it fails the test.
Past performance is irrelevant: what matters is regulatory wrapper, lock-up, redemption mechanics, who the GP is, and how exits work. Ask the fund manager for: (1) the prospectus and regulamento de gestão, (2) the CMVM registration confirmation, (3) the last two audited NAV reports, and (4) a written confirmation that the fund's investment policy complies with the ARI Article 3 paragraph 1(d) requirements. Then cross-check that with AIMA's most recent informal guidance.
Costs to budget for, beyond the €500k
The €500,000 is the headline. Realistic all-in cost for a single applicant in 2026:
| Item | Cost (2026) |
|---|---|
| Fund subscription | €500,000 (qualifying) |
| Fund subscription fee (one-off) | 0.5%–2.0% of NAV |
| Annual management fee | ~1.0%–2.0%/year of NAV |
| Performance fee on exit | typically 15–20% above hurdle |
| AIMA government fees: initial | ~€8,000 (main applicant) + ~€3,000 per dependent |
| AIMA renewal fees (years 2, 5) | ~€3,000 per applicant per renewal |
| Legal & immigration fees | €8,000–€20,000 depending on scope |
| NIF, fiscal representation, bank, NIB, KYC | €500–€1,500 |
| Apostilles, translations, criminal record | €400–€1,200 |
The 7-day-per-year rule
The Golden Visa's signature feature is the minimum physical presence requirement: 7 days in the first year, then 14 days per subsequent 2-year period. This is far below any other Portuguese residency permit. You can keep tax residency outside Portugal, treat Lisbon as a base for European travel, and still satisfy AIMA.
What it does not mean is "7 days in 5 years." The 7 days are per year, then 14 days per 2-year renewal. Miss the threshold and your renewal can be rejected.
Citizenship under the new law
The big strategic question in 2026 is what the new Nationality Law does to Golden Visa holders' citizenship timeline.
Applications submitted before 18 May 2026 are assessed under the previous 5-year rule. If you got your Golden Visa residency card in 2021 and filed citizenship before 18 May 2026, the 5-year clock applies and you should be naturalising soon.
Applications submitted on or after 18 May 2026 follow the new rule:
- 10 years of legal residency for most foreigners.
- 7 years for nationals of CPLP countries (Brazil, Angola, Cabo Verde, Guinea-Bissau, Mozambique, São Tomé and Príncipe, East Timor, Equatorial Guinea).
- The clock starts on the date the residence card is issued: not the date you applied for it. That is a meaningful difference because AIMA backlogs can mean the card lands 12–18 months after the application.
- Permanent residency remains available after 5 years. The Golden Visa residency rights are unchanged: only the citizenship timeline shifted.
The AIMA backlog: the elephant in the room
AIMA backlogs are real and they affect outcomes. Some files that should issue in 3 months take 12–18. Renewals that should be routine require chasing. Delays can be challenged in court: the Tribunal Administrativo will order AIMA to decide a file when the statutory limit is breached.
What this means in practice: file early, use the formal exhaustion-of-administrative-remedies route quickly when a file stalls, and keep a written log of every contact. For Golden Visa specifically, the most common pain point is the first residency card after the entry; renewals tend to be smoother.
Who the Golden Visa is right for
- UAE / Gulf nationals who want EU optionality without giving up tax residency in Dubai or Riyadh. The 7-day rule is the killer feature here.
- US founders who exited and have $500k+ in liquid capital they want to park into a regulated EU venture vehicle.
- UK citizens who lost EU rights after Brexit and want a permanent fallback for retirement, education or business in Europe.
- Indian, Saudi and South African investors looking at long-term family planning, Portuguese citizenship gives the children EU passports.
It is not the right move for someone who wants to live in Portugal full-time. For that, the D7 or D8 is cheaper and faster.
Timeline: realistic in 2026
- Month 1: NIF, fiscal representation, KYC documents, criminal record with apostille. Initial fund due-diligence call.
- Months 1–3: Open a Portuguese bank account, subscribe to the qualifying fund, wire the €500,000.
- Month 3: AIMA pre-screening through the ARI online portal (SAPA).
- Months 3–6: Biometrics appointment, fingerprinting, additional documents if AIMA requests them.
- Months 9–18: Residency card issued (the realistic range under current AIMA load).
- Year 5: Apply for permanent residency. Citizenship clock continues under the new 10/7-year rule.
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