Portugal Golden Visa after real estate: the routes that are still open

Amir Ismail & Associates · Updated Oct 31, 2026 · 9 min read
Portugal Golden Visa after real estate: the routes that are still open
In this article

The Portugal Golden Visa did not close. What closed was the property route. Law 56/2023, the Mais Habitação law, took effect on 7 October 2023 and ended real estate and capital transfer applications. The residence by investment permit, called the ARI, is still open.

Five routes remain. The one most families now use is EUR 500,000 into a qualifying investment fund that holds no real estate. This guide lists what is open, what each route costs in official fees, and how the steps run.

Key takeaways

  • Real estate and the EUR 1,500,000 capital transfer route closed on 7 October 2023. Applications filed before that date, and renewals of permits already granted, continue under the old rules.
  • Five routes remain: investment funds, company capital with jobs, job creation, scientific research, and arts and heritage.
  • The physical presence rule is light: seven days in the first year, then 14 days in each two-year period.
  • The citizenship clock changed in 2026. Most non-EU applicants now need ten years of legal residence, counted from the first permit.
  • Government fees are charged per person, including each family member.

What closed in the Portugal Golden Visa after real estate, and when

Law 56/2023 rewrote Article 3 of Law 23/2007, the Portuguese immigration law. Three routes were struck out of the ARI list.

Closed routeOld minimumStatus
Capital transfer to a Portuguese bank accountEUR 1,500,000Closed to new applications since 7 October 2023
Purchase of real estateEUR 500,000Closed to new applications since 7 October 2023
Purchase of older real estate for renovationEUR 350,000Closed to new applications since 7 October 2023

Two protections matter if you are already in the system. Applications filed before the law changed are decided under the rules in force when they were filed. And investors who already hold an ARI, including property-based permits, keep the right to renew on the same terms. Nobody has to sell a property or move money because of the 2023 law.

One more change is easy to miss. Funds are still open, but a qualifying fund may not invest in real estate, directly or indirectly. A fund with property exposure, however it is dressed up, does not qualify.

The routes that remain

These are the five ARI routes in Article 3 of Law 23/2007 today. The investment must be held for at least five years in each case.

RouteMinimumCore condition
Investment fund unitsEUR 500,000The fund must be set up under Portuguese law, have a maturity of at least five years at the time you invest, put at least 60 percent into companies based in Portugal, and hold no real estate
Company capital with jobsEUR 500,000Set up a Portuguese company, or add capital to an existing one, and create five permanent jobs, or keep ten jobs with at least five permanent, for at least three years
Job creationNo fixed capital sumCreate at least ten jobs. Eight jobs are enough in a low-density area
Scientific researchEUR 500,000Money goes to public or private research bodies in the national science system. EUR 400,000 in a low-density area
Arts and cultural heritageEUR 250,000Money goes through eligible public bodies or foundations to artistic work or the upkeep of national heritage. EUR 200,000 in a low-density area

The low-density discounts cut some routes by 20 percent. They apply to the jobs, research and arts routes. They do not cut the fund route, which stays at EUR 500,000 wherever the fund’s companies sit.

What fund due diligence looks like

Most new applicants use the fund route, so the checks that matter sit there. Before any money moves, confirm four things in writing.

  • The fund is registered with the CMVM, the Portuguese securities market regulator, and the fund rules are in order.
  • The fund’s mandate bars real estate, directly and indirectly, in line with the 2023 law.
  • At least 60 percent of the fund goes into companies headquartered in Portugal, and the maturity runs at least five years from your subscription.
  • You get the subscription documents AIMA will ask for: proof of the units, the fund statement and the bank records that trace your money in.

A fund is an investment, not a deposit. Its value can fall, and Golden Visa approval does not protect the capital. Read the fund’s own risk documents, not only its brochure.

The official fees

AIMA, the agency that runs the ARI, publishes one fee table for all residence procedures. For the ARI it sets an analysis fee of EUR 842.80 per person and a grant fee of EUR 8,418.90 per person.

Lower rates of EUR 632.10 and EUR 6,314.20 apply where the reduction in the same table applies, including filings handled through AIMA’s online services. Each renewal costs EUR 4,210.30 per person, or EUR 3,157.80 at the reduced online rate. A renewal analysis fee of EUR 842.80 per person, or EUR 632.10 online, is also charged. Family members pay the same grant and renewal fees as the main applicant.

Budget on the full rates. For a family of four, analysis plus first grant at the full rates comes to EUR 37,046.80 in AIMA fees alone, before legal fees. Two renewals normally fall within the first five years, so plan the fee line beyond the first card.

Step by step

  1. Get a Portuguese tax number (NIF) and open a Portuguese bank account in your own name.
  2. Choose the route, complete the fund subscription or other investment, and gather the proof AIMA requires.
  3. Your legal representative files the application on AIMA’s ARI portal and pays the analysis fee.
  4. AIMA reviews the file, then calls you and each family member for biometrics at an AIMA office in Portugal.
  5. Pay the grant fee for each person and the residence cards are issued. The first card runs for two years.
  6. Renew every two years, showing the investment is still held and the presence rule has been met. Renewals are now filed through AIMA’s online renewals portal.

On timing, be blunt with yourself. AIMA publishes no guaranteed decision time for ARI files, and the queue built up over years. Plan in months for each stage, not weeks, and do not book life decisions around a card arriving by a set date.

Presence, renewal and permanent residence

The presence rule is the lightest in Europe. You must spend at least seven days in Portugal in the first year, and at least 14 days in each two-year period after that. Keep boarding passes and entry records, because you will be asked to show the days at renewal.

After five years of holding the ARI, you can apply for permanent residence, which ends the link to the investment. AIMA charges EUR 11,786.70 per person to grant permanent residence to ARI holders and their families, or EUR 8,840 when filed online. Many families apply for permanent residence and citizenship around the same stage, but they are two separate applications with two separate tests.

The 2026 Portugal Golden Visa nationality change

This is the change most summaries still get wrong. Organic Law 1/2026 was published in the Diário da República on 18 May 2026 and took effect on 19 May 2026. It lengthened the residence period for naturalisation.

EU citizens and citizens of Portuguese-speaking countries now need seven years of legal residence. Other nationals, which means most Golden Visa holders, need ten years.

The clock runs from the issue of your first residence permit, not from the day you applied. The years can include gaps, but they must all fall within a 12-year window for the ten-year group, or nine years for the seven-year group. Nationality applications already filed when the law changed stay under the old law, which asked for five years. You must also pass tests in Portuguese language and culture, history, national symbols, and civic rights and duties.

The practical effect is simple. A family that files for the Golden Visa in 2026 should plan citizenship as a ten-year project, not a five-year one, unless a parent holds an EU or Portuguese-speaking-country passport.

Golden Visa or D7?

The D7 is Portugal’s passive income residence route. It usually costs far less to enter, but it asks you to live in Portugal. The Golden Visa asks for capital instead of your calendar. This table sets the two side by side.

QuestionGolden Visa (ARI)D7 passive income
What qualifies youAn investment from the five open routes, most often EUR 500,000 in a fundSteady passive income, such as a pension, rent or dividends, at least at the level of the Portuguese minimum wage: EUR 920 a month in 2026, plus 50 percent for a spouse and 30 percent for each child
Time in PortugalSeven days in year one, then 14 days in each two-year periodYou live in Portugal. Long absences can break the residence
Family feesGrant and renewal fees are charged per personStandard residence fees per person, far lower than ARI fees
Best fitFamilies who want a European base without moving yetFamilies ready to move to Portugal now

Our Portugal passive income visa page sets out the D7 in full. If you will live in Portugal from day one, price the D7 first. If you will not, the Golden Visa is the route built for you.

Official sources

  • AIMA, residence permit for investment activity (ARI): aima.gov.pt
  • AIMA, table of fees for administrative procedures: aima.gov.pt fee table (PDF)
  • Law 23/2007, Article 3 and Article 90-A, as amended by Law 56/2023, and Organic Law 1/2026 on nationality, both published in the Diário da República

Frequently asked questions about the Portugal Golden Visa after real estate

Can I still buy a property for the Portugal Golden Visa?

No. Law 56/2023 closed the real estate routes to new applications on 7 October 2023, but the Portugal Golden Visa after real estate remains open through five other routes. You can still buy a home in Portugal, but the purchase no longer counts toward a Golden Visa. The open entry routes are funds, company capital with jobs, job creation, research, and arts and heritage.

I already hold a property-based Golden Visa. Am I safe?

Yes. The 2023 law protects applications filed before it took effect and the renewal rights of existing ARI holders. You keep your permit and renew on the same terms. You do not have to sell the property or move the money into a fund.

Can a Golden Visa fund invest in real estate?

No. Since October 2023 a qualifying fund may not invest in real estate directly or indirectly. Check the fund rules before you subscribe. A fund with property exposure does not qualify, whatever its marketing says.

How much time must I spend in Portugal each year?

Very little. The rule is at least seven days in the first year, then at least 14 days in each following two-year period. Keep proof of your days in Portugal, such as boarding passes, for each renewal.

When can a Golden Visa holder apply for Portuguese citizenship?

Under Organic Law 1/2026, in force since 19 May 2026, most non-EU nationals need ten years of legal residence for Portuguese citizenship, counted from the issue of the first residence permit. EU and Portuguese-speaking-country citizens need seven years. Applications filed before the change stay under the old five-year law. You must also pass tests in Portuguese language and culture, history, national symbols, and civic rights and duties.

To see the cost for your own spouse, children and budget, use our calculator: Work out the cost for your family.

Want a second opinion on your shortlist? Book a Strategy Consultation

Written by Amir Ismail & Associates, which helps families compare residence by investment programmes and brings in a local partner in each country once a case is qualified. This article is general information, not legal or tax advice. A residence permit is not a passport.

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