The New Portuguese Golden Visa

This Briefing reflects the state of the scheme at the date of its publication. Residence-by-investment legislation changes with some frequency — before making any decision, figures and requirements should be confirmed with AIMA or with a specialist lawyer. Nothing in this text constitutes legal, tax or investment advice.

The Golden Visa has not ended — but it is no longer what it was two years ago. Property purchase ceased to be eligible for new applications from October 2023. The programme remains active through other investment routes, chiefly funds. It grants residence, not automatic nationality, and the path to nationality has recently become longer. Whether it suits a given investor depends entirely on their objectives — there is no single right answer for everyone.

The Golden Visa, officially known as the Autorização de Residência para Atividade de Investimento (ARI) — Residence Permit for Investment Activity — is a Portuguese residence scheme created in 2012 for third-country nationals who carry out an eligible investment activity in Portugal.

The programme came into force on 8 October 2012 and allows the investor to obtain a temporary residence permit without first requiring a residence visa. The investment may be made in the investor's own name or, under certain conditions provided for by law, through a company incorporated in Portugal or in another European Union Member State with a permanent establishment in Portuguese territory.

Despite the name by which it became known, the Golden Visa is not an entry visa, nor is it an exclusively property-based programme. It is a residence permit linked to the making and maintaining of an investment activity provided for by law.

For several years, property acquisition was the best-known route under the programme. That option ceased to be available for new applications in October 2023. The scheme, however, was not abolished. It came instead to favour other forms of investment, including eligible funds, scientific research, support for culture, business creation and job creation.

The programme is distinguished from other residence permits by requiring a reduced physical presence in Portugal. AIMA — the Agency for Integration, Migration and Asylum — provides for a minimum stay of seven days in the first year and fourteen days in each subsequent two-year period. This flexibility makes it particularly relevant for those who wish to maintain their professional, family or business life in another country.

Residence, tax residency, investment and nationality are related concepts, but they are legally distinct. Understanding this distinction is essential to avoid decisions based on incorrect assumptions.

In summary: the Golden Visa remains active. Property acquisition ceased to be eligible for new applications, but the scheme retains several investment routes. It is a residence permit — it does not constitute an automatic grant of permanent residence or Portuguese nationality, nor does it require an immediate move to Portugal, given its reduced physical presence requirement. Above all, the Golden Visa is a legal instrument; it is not, in itself, a wealth, tax or family strategy — the decision should bring all these elements together before any investment is made.

The Golden Visa has not undergone a single change. It has evolved over more than a decade, tracking Portugal's shifting economic and political priorities. Understanding that evolution is essential to seeing why the programme today is very different from the one that existed in 2012.

Much of the information still circulating about the Golden Visa refers to a scheme that no longer exists. Before examining the investment routes currently available, it is therefore worth understanding how we arrived here.

With Law No. 56/2023 (the "More Housing" law) coming into force, property acquisition ceased to be eligible for new applications, simple capital transfer likewise ceased to be eligible, and routes such as investment funds, scientific research, culture, business creation and job creation remain available.

This was the change that generated most of the confusion. Many people interpreted the end of the property route as the end of the Golden Visa itself. That is not what happened — the scheme remained in force, but came to favour other forms of investment.

In 2026, amendments to the Portuguese Nationality Law also came into effect, leading many people to conflate residence rules with the rules governing access to nationality. These are distinct matters and should be considered separately.

If you looked into the Golden Visa some years ago, some of what you found is likely out of date. Today, the programme is no longer associated with property acquisition and now favours investments considered strategic for the Portuguese economy. The essence of the scheme, however, remains the same: it continues to be a residence permit granted on the making and maintaining of an eligible investment, as provided for by law.

In summary: the Golden Visa created in 2012 remains in force. The biggest change occurred in 2023, with the end of eligibility for property investment in new applications. The programme remains available through different investment routes provided for under Portuguese law. Changes to the Nationality Law do not mean that the Golden Visa has come to an end.

Following the changes introduced by Law No. 56/2023, the Golden Visa remains available through different investment routes provided for under Portuguese law. The end of eligibility for property acquisition in new applications did not mean the end of the programme. It meant, rather, a change in how Portugal seeks to attract foreign investment.

Where property investment was the dominant route for more than a decade, the current framework favours investments considered strategic for the Portuguese economy, supporting the financing of businesses, scientific research, culture and innovation. Each route serves different objectives and requires compliance with its own requirements. Understanding these differences is the first step in identifying which route may make sense for each investor.

The routes currently eligible

* Amounts and requirements may be changed by legislation. Before making any decision, the legislation in force should be confirmed. None of the eligible investment routes may be used, directly or indirectly, for property investment.

What changed in practice? Until 2023, most investors associated the Golden Visa with buying a property. That is no longer the case today. The programme has come to favour investment routes that channel capital into areas considered strategic for Portugal's economic, scientific, business and cultural development. This change represents a paradigm shift.

"Which property should I buy?"

has given way to

"Which investment route best matches my objectives?"

That difference is more than a legislative change. It is a shift in how the Golden Visa itself should be understood.

A decision before the decision. It is natural for many investors to compare the different routes solely by the minimum amount required. However, that is only one element of the decision. Each route involves different levels of involvement, different time horizons, different risk profiles and different wealth objectives.

For this reason, the choice should not begin with the investment. It should begin with understanding what the investor wants to achieve. That analysis is what will later make it possible to identify which route may best suit their context.

In summary: the Golden Visa remains available through different investment routes. Property acquisition ceased to be eligible for new applications. Each route serves distinct objectives and has its own requirements. The choice should result from an integrated analysis of the investor's situation and objectives.

Since the changes introduced by Law No. 56/2023, investment funds have become the main route used by investors applying for the Portuguese Golden Visa. In practice, the investment no longer rests on buying a property, and is instead made through a fund that meets the legal requirements set for this scheme. The focus shifts towards financing the Portuguese economy through regulated and supervised investment vehicles.

This change represents a profound shift in the philosophy of the programme. Where the investment was previously often associated with acquiring property, today it favours participation in financial instruments that support businesses, innovation, internationalisation and economic development.

It is important to understand, however, that not all funds are alike. Each fund has its own investment strategy, a distinct time horizon, a specific risk profile and a different cost structure. For this reason, the choice of a fund should not rest solely on its eligibility for Golden Visa purposes — it should result from a careful analysis of the investor's profile, their wealth objectives, and the role that investment plays within their overall strategy.

Answering these questions does not, on its own, guarantee a good decision. But it significantly reduces the risk of investing without fully understanding the financial product being acquired.

The Vieira da Fonseca perspective

At Vieira da Fonseca, we believe a good decision begins long before an investment is chosen. Our role is not to recommend funds, nor to provide financial advice. Our role is to help each client understand the context of their decision, identify the right questions, and ensure the different recommendations — legal, tax, financial and wealth planning recommendations — remain consistent with one another.

Whenever the strategy includes a financial investment, we work alongside financial advisers, lawyers, tax advisers and other specialists, so that each dimension of the decision is examined by those with the right technical expertise. Because a wealth decision rarely depends on a single variable — it depends on how all of them come together.

If this were our client...

Before any investment, we would seek to understand three fundamental aspects.

1. What is the real objective? The Golden Visa is a means, not an end. Before looking at any investment, it matters to understand whether the priority is international mobility, residence in Portugal, eventual access to nationality, wealth diversification, or family planning.

2. Is the Golden Visa really the most suitable solution? Not every investor needs a Golden Visa. Depending on personal and family circumstances, other residence schemes or wealth strategies may be better suited to the investor's objectives.

3. Who should be involved in this decision? A decision of this nature rarely rests on a single professional. Lawyers, tax advisers, financial advisers and wealth specialists play complementary roles. The real challenge lies in ensuring that all these recommendations point in the same direction.

A good decision rarely depends on a single answer. It depends on asking the right questions of the right people.

In summary: investment funds are currently the main route into the Golden Visa. Not all eligible funds share the same characteristics. The choice should result from an informed analysis suited to the investor's profile. Coordination between specialists matters as much as the choice of the investment itself.

The Golden Visa is aimed at third-country nationals — that is, people who do not hold the nationality of a European Union Member State, of the European Economic Area, or of Switzerland. Nationality is therefore the first requirement to check. It is not, however, the only one.

In addition to making an eligible investment, the applicant must satisfy a number of legal requirements that continue to apply throughout the validity of the residence permit. More than an investment, the Golden Visa represents an ongoing legal relationship with the Portuguese State, based on continued compliance with the conditions set out in law.

Among other legally required conditions. Compliance is checked both at the time of application and at each subsequent renewal of the residence permit.

Family reunification

One of the most significant features of the Golden Visa is the ability to apply for family reunification. Under certain conditions set out in Portuguese law, certain members of the household may also benefit from a residence permit.

Each situation must be assessed individually, as the legal framework depends on the specific circumstances of each family.

What rights does the Golden Visa grant?

The granting of the Residence Permit for Investment Activity confers a set of significant rights.

It is important, however, to clearly distinguish these concepts. The Golden Visa constitutes a residence permit. Permanent residence and Portuguese nationality depend on their own requirements and separate procedures. One does not automatically follow from the other.

In summary: the Golden Visa is aimed at third-country nationals. It requires making an eligible investment and meeting the legal requirements set out for the scheme. It allows applications for family reunification, under the terms of the law. It confers a residence permit, but not an automatic right to permanent residence or Portuguese nationality. Maintaining the permit depends on continued compliance with the legally required conditions.

Throughout this Briefing, we have examined the Golden Visa framework, how the scheme has evolved, the investment routes currently available, and the main eligibility requirements. After this reading, it is natural to ask: "what is the next step?"

The answer depends less on the investment itself and more on how clearly you understand your own objectives. A Golden Visa may be an excellent solution for one person and a poorly suited decision for another, even if both have the financial capacity to invest. Before starting any process, it is worth answering five questions honestly.

1. Why do I want to obtain a Golden Visa? The answer seems obvious, but rarely is. Are you looking for greater international mobility? Do you intend to move to Portugal? Are you planning a wealth reorganisation? Are you thinking about your children's education? Do you want to create a residence option for the future? Different objectives often lead to different strategies.

2. Is the Golden Visa really the most suitable solution? Not every situation calls for a Golden Visa. Depending on personal, family, professional or tax circumstances, other forms of residence may be better suited to the investor's objectives. So the first decision is not always choosing an investment — sometimes, it is confirming whether this is the right scheme.

3. Do I truly understand the investment I am making? No investment should be chosen simply because it enables an application. It is important to understand where the capital will be applied, what risks are involved, the expected time horizon, the associated costs, and the exit conditions. The better you understand the investment, the more informed the decision will be.

4. Do I have the right specialists by my side? A process of this nature can involve different areas of expertise. Lawyers, financial advisers, tax advisers, immigration specialists and other professionals play complementary roles. More important than assembling the right specialists is ensuring they work towards the same objective and that their recommendations remain consistent with one another.

5. Will this decision still make sense in a few years? This is perhaps the most important question of all. The Golden Visa may open doors, but the real question is whether the investment, the wealth strategy and the life plan will still be aligned once those doors open. The best decisions are the ones that stand the test of time.

A final reflection

Over the past few years, the Golden Visa has given rise to thousands of investment decisions. Some have proven very sound. Others were made too quickly, based on incomplete information or an excessive focus on the financial product.

At Vieira da Fonseca, we believe the role of an advisory firm is not to point the way. It is to help each client understand their own path before setting out on it. Because a good decision does not begin with the investment — it begins with clarity.

Throughout this Briefing, we have sought to answer the most important questions about the Portuguese Golden Visa. We have looked at what the scheme is, how it has evolved since 2012, which investment routes are currently available, who can apply, and the main considerations before starting an application.

But there is one question no piece of legislation can answer.

Is this the right decision for you?

That answer does not depend on the law alone. It depends on your personal circumstances, your objectives, your family, your wealth, how you intend to organise your future, and the role Portugal plays in that life plan.

That is precisely why two people, faced with the same legislation, can arrive at completely different decisions. Both can be right, because the best decision is never simply the result of an opportunity existing — it is the result of the coherence between that opportunity and what each person is seeking to build.

Beyond the Golden Visa

The Golden Visa is a legal instrument. It is not a wealth strategy. It is not a tax plan. It is not a life plan. It may form part of any of these, but it does not replace them.

That is why the soundest decisions are rarely made by looking only at an investment or a legal benefit. They are made when every element of the context is understood and considered together.

The role of Vieira da Fonseca

At Vieira da Fonseca, we do not believe the best decisions are born of haste. Nor do we believe an investment should be examined in isolation. Our role is to help each client understand the context of their decision and coordinate the different perspectives — legal, tax, financial and wealth planning — so that all contribute towards the same objective.

We do not replace specialists. We work with them, because we believe a good decision depends less on finding a quick answer and more on ensuring that all the answers make sense when considered together.

One final thought

As you reach the end of this Briefing, we hope you now understand the Golden Visa more clearly. But above all, we hope you ask better questions. Because the decisions that transform lives rarely begin with an answer — they begin with the right question.