Portugal's Golden Visa in 2026: What's Left, What's Changed, and What Expats Should Know
When Portugal's government announced the end of the Golden Visa programme in 2023, it triggered a wave of uncertainty among wealthy investors and property buyers. Three years on, the picture is clearer — and more nuanced than the initial headlines suggested.
What Actually Happened to the Golden Visa
The Portuguese Golden Visa — formally the Autorização de Residência para Atividade de Investimento (ARI) — was suspended for new real estate investments in October 2023 under the Mais Habitação (More Housing) package. However, the programme was not entirely abolished. Several investment routes remain open:
- Fund investments: Minimum €500,000 in qualifying Portuguese investment funds (the most popular current route)
- Capital transfer: €1.5 million transferred to Portugal
- Job creation: Creating 10+ permanent jobs for Portuguese nationals
- Cultural investment: €250,000 in arts/cultural heritage
- Scientific research: €500,000 in qualifying research activities
What was closed: direct real estate purchases as a qualifying investment, which had been the dominant route, accounting for roughly 90% of ARI applications.
The Investment Fund Route: How It Works in 2026
For most new applicants, the investment fund route is now the primary path. The €500,000 minimum must be invested in a qualifying closed-end fund registered and regulated by the Portuguese Securities Market Commission (CMVM). The fund must have at least 60% of its portfolio invested in Portuguese companies or assets, with a minimum 5-year lock-up period.
Several asset management firms have established CMVM-registered funds specifically designed for ARI qualification — ranging from private equity focused on Portuguese SMEs to real estate funds (which still qualify when structured as regulated funds rather than direct property ownership). Due diligence matters: not all marketed funds have performed as projected, and the lock-up means capital is illiquid for the duration.
Immigration lawyers in Lisbon note that AIMA (the immigration authority that replaced SEF in 2023) processing times for ARI applications have improved but remain lengthy — averaging 12–18 months from submission to approval in 2026.
What Golden Visa Holders Get
The benefits haven't changed. Successfully granted ARI holders receive:
- A renewable Portuguese residence permit (initially 2 years, then 2+2+2)
- The right to live and work in Portugal (though minimum stay requirements are low: 7 days in year 1, 14 days per subsequent 2-year period)
- Access to the Schengen Area without a visa
- Eligibility to apply for permanent residence after 5 years
- Eligibility to apply for Portuguese citizenship after 5 years (with a basic Portuguese language test)
The low minimum stay requirement is a deliberate feature — the programme was always designed for investors who maintain primary residence elsewhere but want a European foothold and eventual citizenship pathway.
The NHR Question
Many Golden Visa applicants historically combined residency with Portugal's Non-Habitual Resident (NHR) tax regime, which offered a flat 20% rate on Portuguese-sourced income and exemptions on most foreign income for 10 years. The original NHR was closed to new applicants from January 2024. Its replacement — IFICI (the Incentivo Fiscal à Investigação Científica e Inovação) — is more narrowly targeted at researchers, qualified professionals in high-tech sectors, and startup founders.
For investment-focused Golden Visa applicants who don't qualify for IFICI, standard Portuguese personal income tax rates now apply if they establish tax residency. Many choose to maintain tax residency elsewhere and use Portugal purely for the residency permit and citizenship pathway.
Alternatives Worth Considering
For those who wanted the Golden Visa primarily as a residency-through-property route, two alternatives have become more popular:
- D7 Passive Income Visa: For those with sufficient passive income (pensions, rental income, investments), the D7 offers a simpler path to Portuguese residency without a minimum investment requirement. The threshold is approximately €760/month in verifiable passive income for a single applicant.
- D8 Digital Nomad Visa: For remote workers earning at least €3,040/month (4x Portugal's minimum wage), the D8 provides a 1-year temporary stay permit renewable for 2-year periods.
Neither grants the same quick citizenship pathway as ARI — the citizenship clock for D7 and D8 holders requires 5 years of actual legal residence, not just 35 days as with Golden Visa holders.
The Numbers in 2025
Despite the real estate closure, ARI applications didn't collapse. AIMA data from 2025 shows approximately 1,200 new ARI applications filed, down from a peak of around 2,400 in 2022 but stabilising as fund-route awareness grew. Nationalities leading in 2025: US, Chinese, Brazilian, and British citizens, in that order. Total ARI permits in force: approximately 13,500.
For Expats: Practical Advice
If you're considering an ARI in 2026:
- Use an AIMA-registered immigration lawyer — the complexity of fund due diligence plus immigration bureaucracy makes DIY applications high-risk
- Verify fund qualification with CMVM before committing capital
- Budget 12–24 months for processing; plan your biometrics appointment early (AIMA backlogs remain a bottleneck)
- Consider tax advice specific to your home country — the ARI grants Portuguese residence but tax treatment in your home country (especially the US) varies significantly
