The New Portuguese Golden Visa

This Briefing reflects the state of the regime as at the date of publication. Residence-by-investment legislation changes with some regularity — before any decision, values and requirements should be confirmed with AIMA or a specialist lawyer. Nothing in this document constitutes legal, tax or investment advice.

The Golden Visa has not ended — but it is no longer what it was two years ago. The purchase of real estate has been ineligible for new applications since October 2023. The programme remains active through other investment routes, primarily funds. It confers residency, not automatic citizenship, and the path to Portuguese nationality has recently become longer. Its suitability depends entirely on the objectives of the individual investor — there is no single right answer for everyone.

The Golden Visa — formally designated the Autorização de Residência para Atividade de Investimento (ARI) — is a Portuguese residency scheme established in 2012 for third-country nationals undertaking an eligible investment activity in Portugal.

The programme came into force on 8 October 2012 and allows investors 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 established by law, through a company incorporated in Portugal or another EU Member State with a permanent establishment in Portuguese territory.

Despite the name by which it became known, the Golden Visa is neither an entry visa nor a purely real estate programme. It is a residence permit tied to the undertaking and maintenance of an investment activity provided for by law.

For many years, property acquisition was the best-known route under the programme. That option ceased to exist for new applications in October 2023. The scheme itself, however, was not abolished. It now favours other forms of investment, including eligible funds, scientific research, cultural support, company formation and job creation.

The programme is distinguished from other residence permits by its reduced physical presence requirement. AIMA stipulates 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.

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

In summary: the Golden Visa remains active. Property acquisition is no longer eligible for new applications, but the scheme retains several investment routes. It is a residence permit — it does not constitute automatic permanent residency or Portuguese nationality, nor does it require an immediate move to Portugal, retaining a reduced physical presence requirement. Above all, the Golden Visa is a legal instrument; it is not, in itself, a wealth management, tax or family strategy — the decision must integrate all of these elements before any investment is made.

The Golden Visa did not change overnight. It has evolved over more than a decade, in step with Portugal's economic and political priorities. Understanding that evolution is essential to grasping why the programme today is so different from what existed in 2012.

Much of the information still in circulation about the Golden Visa refers to a regime that no longer exists. Before examining the investment routes currently available, it is therefore important to understand how we arrived here.

With the entry into force of Law no. 56/2023 (Mais Habitação), property acquisition ceased to be eligible for new applications, as did simple capital transfers. Routes including investment funds, scientific research, culture, company formation and job creation were retained.

This was the change that generated the most confusion. Many people interpreted the end of the real estate route as the end of the Golden Visa. That was not what happened — the scheme remained in force, but shifted its focus to other forms of investment.

In 2026, amendments to the Nationality Act also came into force, leading many people to conflate the rules on residency with the rules on access to nationality. These are distinct matters and must be considered separately.

If you consulted information about the Golden Visa some years ago, it is likely that part of it is no longer current. Today, the programme is no longer associated with property acquisition and now favours investments considered strategic to the Portuguese economy. The essence of the scheme, however, remains: it is still a residence permit granted upon the undertaking and maintenance of an eligible investment, in accordance with the terms set out in law.

In summary: the Golden Visa created in 2012 remains in force. The most significant change occurred in 2023, with the end of real estate investment eligibility for new applications. The programme continues to be available through different investment routes provided for in Portuguese legislation. Amendments to the Nationality Act do not mean the Golden Visa has ended.

Following the changes introduced by Law no. 56/2023, the Golden Visa continues to be available through different investment routes provided for in Portuguese legislation. The end of property acquisition eligibility for new applications did not mean the end of the programme — it signalled a change in the way Portugal seeks to attract foreign investment.

Where real estate investment was the dominant route for more than a decade, the current framework favours investments considered strategic to the Portuguese economy, directing capital towards companies, scientific research, culture and innovation. Each route serves different objectives and requires the fulfilment of its own conditions. Understanding those differences is the first step towards identifying which might suit a given investor.

Currently eligible routes

* Amounts and requirements are subject to legislative change. Before any decision, the legislation in force should be confirmed. None of the eligible routes may be directed, directly or indirectly, towards real estate investment.

What has changed in practice? Until 2023, most investors associated the Golden Visa with property acquisition. That reality has changed. The programme now favours investment routes that channel capital into areas considered strategic for Portugal's economic, scientific, business and cultural development. This represents a paradigm shift.

"Which property should I buy?"

has given way to

"Which investment route best serves my objectives?"

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

A decision before the decision. It is natural for many investors to compare the different routes on the basis of minimum investment alone. That, however, is only one element of the decision. Each route implies different levels of involvement, different time horizons, different risk profiles and different wealth management objectives.

For this reason, the choice should not begin with the investment. It should begin with an understanding of what the investor seeks to achieve. That analysis is what will allow, in due course, the identification of which route may be most appropriate to each individual's circumstances.

In summary: the Golden Visa continues to be available through different investment routes. Property acquisition is no longer 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 circumstances and goals.

Since the changes introduced by Law no. 56/2023, investment funds have become the primary route used by investors seeking to apply for the Portuguese Golden Visa. In practice, the investment no longer rests on the acquisition of a property but is instead made through a fund that meets the legal requirements set out for this scheme. The objective becomes the financing of the Portuguese economy through regulated and supervised investment vehicles.

This shift represents a profound change in the philosophy of the programme. Where investment was previously often associated with the acquisition of real estate assets, the focus is now on participation in financial instruments that support companies, innovation, internationalisation and economic development.

It is important to understand, however, that not all funds are alike. Each fund has its own investment strategy, distinct time horizon, specific risk profile and 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 management objectives and the role that investment plays in their overall strategy.

Answering these questions does not, in itself, guarantee a sound 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 that a sound decision begins long before the choice of investment. Our role is not to recommend funds or provide financial advice. Our role is to help each client understand the context of their decision, identify the right questions and ensure that the various recommendations — legal, tax, financial and wealth-related — remain coherent with one another.

Whenever the strategy includes a financial investment, we work in coordination with financial advisers, lawyers, tax specialists and other experts, so that each dimension of the decision is analysed by those with the appropriate technical expertise. Because a wealth-related decision rarely depends on a single variable — it depends on how all of them fit 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 examining any investment, it is important to understand whether the priority is international mobility, residency in Portugal, potential access to nationality, wealth diversification or family planning.

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

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

A sound 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 primary route to 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 is as important as the choice of investment itself.

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

Beyond making an eligible investment, applicants must satisfy a set of legal requirements that persist throughout the entire validity period of the residence permit. More than an investment, the Golden Visa represents an ongoing legal relationship with the Portuguese State, grounded in continuous compliance with the conditions set out in law.

Among other legally prescribed requirements. Compliance is verified both at the time of application and at each successive renewal of the residence permit.

Family reunification

One of the most significant features of the Golden Visa is the possibility of applying for family reunification. Under certain conditions provided for in Portuguese legislation, certain family members may equally 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 confer?

The granting of the Autorização de Residência para Atividade de Investimento confers a set of important rights.

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

In summary: the Golden Visa is available to third-country nationals. It requires the making of an eligible investment and compliance with the prescribed legal conditions. It allows for family reunification applications, in accordance with the law. It confers a residence permit, but not an automatic right to permanent residency or Portuguese nationality. Continuation of the permit depends on ongoing compliance with the conditions required by law.

Throughout this Briefing we have examined the Golden Visa framework, the evolution of the scheme, the investment routes currently available and the principal eligibility conditions. It is natural that, having read this far, the question becomes: what is the next step?

The answer depends less on the investment 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 where both have the financial capacity to invest. Before beginning any process, it is worth answering, honestly, five questions.

1. Why do I want a Golden Visa? The answer may seem obvious, but it rarely is. Are you seeking 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 future residency alternative? Different objectives often lead to different strategies.

2. Is the Golden Visa genuinely the most appropriate solution? Not every situation calls for a Golden Visa. Depending on personal, family, professional or tax circumstances, other residency options may be better aligned with the investor's objectives. The first decision is therefore not always to choose an investment — sometimes it is to confirm whether this is the right scheme.

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

4. Do I have the right specialists alongside me? A process of this nature may involve several different areas of expertise. Lawyers, financial advisers, tax specialists, immigration consultants and other professionals play complementary roles. More important than assembling a team of specialists is ensuring that they all work towards the same objective and that their recommendations are coherent with one another.

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

A final reflection

Over recent years, the Golden Visa has generated thousands of investment decisions. Some proved to be very well considered. Others were taken too quickly, based on incomplete information or with excessive focus on the financial product itself.

At Vieira da Fonseca, we believe that the role of an advisory firm is not to indicate the path. It is to help each client understand their own path before they begin to walk it. Because a sound 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 examined what this scheme is, how it has evolved since 2012, what investment routes are currently available, who can apply and what the key considerations are before starting an application.

But there is one question that 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 assets, how you intend to organise your future and the role that Portugal plays in that life project.

This is precisely why two people, faced with the same legislation, may arrive at completely different decisions. Both may be right, because the best decision never stems solely from the existence of an opportunity — it stems from the alignment 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 management strategy. It is not a tax plan. It is not a life project. It may form part of any of those, but it does not replace them.

This is why the most robust decisions are rarely made by looking only at a single investment or legal benefit. They are made when all the elements of context are understood and brought together coherently.

The role of Vieira da Fonseca

At Vieira da Fonseca, we do not believe that the best decisions are born of haste. Nor do we believe that an investment should be analysed in isolation. Our work consists in helping each client to understand the context of their decision and to coordinate the different perspectives — legal, tax, financial and wealth-related — so that all contribute towards a single objective.

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

A final thought

Having reached the end of this Briefing, we hope you have a better understanding of how the Golden Visa works. Above all, we hope you will ask better questions. Because the decisions that transform lives rarely begin with an answer — they begin with the right question.

A wealth decision does not begin with an investment. It begins with an understanding of context.