Portugal Golden Visa Changes in 2026: What Investors Need to Know
Última actualización: May 13, 2026
Portugal's Golden Visa still exists in 2026, but the path from investment to a Portuguese passport is significantly longer than it used to be. Following the April 2026 Nationality Law amendments, third-country nationals now face a 10-year residency requirement before they can apply for citizenship, double the previous threshold.
Last updated: May 13, 2026
What actually changed in 2026
The headline change is to the Nationality Law, not to the Golden Visa investment routes themselves. Portugal's Parliament voted to amend the Nationality Law on April 1, 2026, with 151 votes in favour and 64 against. President António José Seguro promulgated the revised law on May 3, 2026.
The practical effects for Golden Visa investors:
- The residency period required for naturalisation rose from 5 years to 10 years for third-country nationals (which includes the vast majority of Golden Visa holders from the US, UK, China, Brazil with non-CPLP status, South Africa, and elsewhere).
- For EU nationals and citizens of CPLP (Comunidade dos Países de Língua Portuguesa) countries, the requirement rose from 3 years to 7 years.
- The clock now starts running from the issuance date of the first residence permit card, not from the date you submitted the application. Given that AIMA backlogs currently push the wait for that first card to 12 to 18 months, this is a meaningful change.
- Citizenship applications already pending when the new law enters into force will continue under the previous Nationality Law. If you filed before the cutoff, you are protected.
A separate decree that would have introduced loss of nationality as a criminal penalty was not signed by the President and remains under Constitutional Court review.
What did not change:
- Permanent residency is still available after 5 years of Golden Visa residency.
- The qualifying investment routes (funds, donations, R&D, job creation) remain in place at their existing thresholds.
- Real estate purchases still do not qualify. That route was removed by Law 56/2023 in October 2023 and has not been reinstated.
- Minimum physical presence requirements are unchanged: roughly 35 days across the 5-year period.
Who can still apply
Eligibility is essentially unchanged from the post-2023 framework. To qualify in 2026, you must:
- Be a non-EU, non-EEA, and non-Swiss national.
- Be at least 18 years old.
- Hold a clean criminal record in your country of origin and any country where you have lived for more than one year.
- Demonstrate a lawful source of funds for the qualifying investment.
- Make and maintain a qualifying investment for the minimum required period (typically 5 years).
- Meet the minimum physical stay requirements in Portugal.
Family members who can be included on the same application:
- Spouse or legally recognised partner.
- Financially dependent children under 26 (if still in education and unmarried).
- Dependent parents of either spouse, generally those over 65 or younger if proven dependent.
- Unmarried minor siblings under 18 who are in the main applicant's legal care.
The qualifying investment routes in 2026
With real estate off the table since 2023, most applicants now choose the regulated investment fund route. Here is how the current options compare:
Route | Minimum amount | Key conditions |
|---|---|---|
Investment fund (CMVM-regulated) | €500,000 | Portugal-domiciled fund, minimum 5-year maturity, at least 60% invested in Portuguese-based companies or assets |
Cultural and artistic heritage donation | €250,000 | Donation to qualifying Portuguese cultural projects |
Research activities | €500,000 | Investment in accredited Portuguese R&D institutions |
Job creation | No fixed capital threshold | Creation of at least 10 permanent jobs in Portugal |
Capital transfer for scientific research | €500,000 | Public or private institutions in the national scientific and technological system |
Incorporation or capital increase of a Portuguese company | €500,000 | Combined with creation of at least 5 permanent jobs |
The fund route dominates for a reason: it is passive, the threshold is fixed, and CMVM oversight provides a baseline level of regulatory comfort. That said, fund quality varies dramatically. Before subscribing, request the fund's regulamento de gestão, audited financials, and the manager's track record on prior vehicles. Confirm directly that the fund is registered with CMVM and that its prospectus expressly includes ARI (Autorização de Residência para Investimento) eligibility.
Note that despite the changes, demand has not collapsed. Portugal issued a record 4,987 Golden Visas in 2024, the year after real estate was removed, suggesting investor appetite has shifted to funds rather than disappeared.
Document checklist
Document requirements vary slightly depending on your nationality and chosen route, but every applicant should prepare:
- Valid passport with at least 6 months of remaining validity and blank pages.
- Two recent passport-size photographs.
- Proof of legal entry into Portugal (Schengen entry stamp or visa).
- Portuguese tax identification number (NIF).
- Portuguese bank account in the applicant's name.
- Proof of the qualifying investment (fund subscription agreement and bank wire confirmation, donation receipt, employment contracts, etc.).
- Criminal record certificate from your country of origin and from any country where you have lived for more than one year, apostilled or legalised.
- Authorisation for AIMA to consult Portuguese criminal records.
- Proof of valid health insurance covering Portugal.
- Sworn declaration committing to maintain the investment for the minimum required period.
- Proof of regularised tax and social security situation in Portugal.
- Receipt of payment of the AIMA application analysis fee.
For family members add:
- Marriage certificate or proof of registered partnership.
- Birth certificates for children.
- Proof of dependency (academic enrolment for children over 18, financial dependency declarations for parents).
- Individual criminal record certificates for each applicant over 16.
All foreign documents must be apostilled (Hague Convention countries) or legalised by the Portuguese consulate, and translated into Portuguese by a certified translator.
Application steps and timeline
The procedural sequence in 2026:
- Get a Portuguese tax number (NIF). This can be done remotely through a fiscal representative.
- Open a Portuguese bank account. Most banks now accept remote onboarding for Golden Visa candidates, though some require an in-person visit.
- Make the qualifying investment. For the fund route, this means subscribing to units and wiring the €500,000 from your Portuguese account.
- Gather and legalise all supporting documents.
- Submit the online pre-application via the AIMA portal. AIMA (Agência para a Integração, Migrações e Asilo) replaced SEF as the competent authority in 2023.
- Attend the biometrics appointment. This requires physical presence in Portugal and is typically the longest queue. Slots are scarce and have been a major bottleneck.
- Receive the first residence card valid for 2 years.
- Renew every 2 years, evidencing that the investment is maintained and that minimum stay requirements were met.
- After 5 years, apply for permanent residency.
- After 10 years from issuance of the first card (under the new Nationality Law), apply for citizenship if desired, including A2-level Portuguese proficiency.
Minimum stay across the 5-year residency period:
- Year 1: 7 days.
- Each subsequent 2-year renewal cycle: 14 days.
- Approximate total: 35 days over 5 years.
Fees and processing times
Official fees are set by AIMA and updated periodically. Verify current figures at aima.gov.pt before budgeting, as the amounts below are the most recently reported.
Item | Approximate fee (per person) |
|---|---|
Initial application analysis | €533 |
Residence card issuance (first card) | €5,325 |
Renewal (each 2-year cycle) | €2,663 |
These fees apply per applicant, including each family member. For a family of four, the cumulative AIMA fees over a 5-year residency cycle can comfortably exceed €30,000, on top of the qualifying investment, legal fees (typically €5,000 to €15,000), fund subscription fees, and translation and legalisation costs.
Processing times are the single biggest pain point. Initial AIMA processing for the first residence card currently runs 12 to 18 months, sometimes longer. Biometrics appointment availability is the most common cause of delay. Several court rulings have ordered AIMA to schedule overdue appointments, and judicial pressure has improved throughput modestly, but applicants should plan for a long wait between filing and the start of the residency clock.
Common pitfalls in 2026
- Assuming the citizenship clock starts at filing. It does not. Under the new Nationality Law, the 10-year period runs from the issuance of your first residence card. With AIMA backlogs, that can mean an effective wait of 11 to 12 years from initial application to citizenship eligibility.
- Choosing a fund without independent due diligence. CMVM regulation sets a minimum bar; it does not vouch for performance. Several ARI-eligible funds have underperformed or had liquidity issues. Have an independent advisor, ideally one not paid by the fund, review the documentation.
- Underestimating the physical presence requirement. 35 days sounds trivial, but missed renewals due to insufficient stays are a common reason applications fail. Keep boarding passes, hotel bookings, and stamps.
- Skipping the language requirement until the end. A2 Portuguese is not difficult, but acquiring it on a deadline while balancing the citizenship paperwork is stressful. Start early.
- Confusing Golden Visa with the D7 or D8 visa. The D7 (passive income) and D8 (digital nomad) visas are unrelated routes with different eligibility, lower costs, and stricter physical presence requirements. They were not affected by the Golden Visa reforms but are also not affected by the citizenship law in the same way some commentators suggest, since the 10-year rule applies to all third-country nationals across most residency categories.
- Over-relying on advisor estimates of fees. AIMA fees have been adjusted multiple times since 2020. Always confirm at the official source.
Frequently asked questions
Is the Portugal Golden Visa still worth it in 2026?
For investors who want EU residency rights, Schengen mobility, and a long-term path to Portuguese citizenship, yes. For investors whose primary goal was a fast passport, the math has changed. A 10-year wait makes Portugal less competitive against Spain (which closed its Golden Visa in 2025), Greece, or Malta on speed-to-citizenship, but Portugal remains attractive on quality of life, tax flexibility, and the low physical presence threshold.
Can I still buy property to qualify?
No. Real estate purchases stopped qualifying for the Golden Visa under Law 56/2023, which came into force in October 2023. You can still buy property in Portugal, but it will not earn you a Golden Visa.
Does the new Nationality Law affect my pending application?
If your citizenship application was already pending when the new law entered into force, it continues under the previous rules. If you currently hold a Golden Visa but have not yet filed for citizenship, the new 10-year rule applies to you.
Do I need to speak Portuguese?
Not for the Golden Visa itself. You do need A2-level Portuguese to naturalise as a citizen later. A2 is a basic conversational level, achievable with consistent study.
What happens if I sell my fund units before the 5-year mark?
Your residence permit can be cancelled and any pending renewal denied. The investment must be maintained throughout the qualifying period.
Can my children apply for citizenship after 5 years if they were minors when we got the visa?
This is a complex area touched by the 2026 amendments. Children born in Portugal to legal residents have separate pathways. Children who arrived as minors are typically still subject to the new residency timelines, though some special provisions may apply. Take individual legal advice.
Are other European residency-by-investment programmes a better fit?
It depends on your priorities. If you want a comparable lifestyle path elsewhere in Southern Europe, Italy and France have non-investment residency routes worth considering. See our guides on the Italy Elective Residence Visa 2026, the Spain Non-Lucrative Visa for 2026, and France Long Stay Visitor Visa options.
If you do commit to Portugal, picking up Portuguese well before the A2 exam will pay off socially and bureaucratically. Try Migaku to learn from the kind of native Portuguese content you'll actually encounter once you land.