If you want EU residency without moving your life to Portugal, this program still works: a statutory stay of 14 days per two-year renewal cycle (sometimes described as about 7 days a year) keeps your status live. Officially it's the Autorização de Residência para Atividade de Investimento (ARI), and it remains the most flexible residency-by-investment program in Europe. The October 2023 reform (Law 56/2023) closed the real estate route and rebuilt the program around CMVM-regulated funds and donations. A separate April 2026 nationality reform then changed the second half of the journey: the residency-to-citizenship clock is now ten years for most non-EU nationals, running from your first residence card.
Who this is for: This program suits founders, CPLP nationals and wealthy families who want an EU foothold without relocating. The trade-off: for most non-EU applicants, the passport is now a ten-year horizon, not five.
The full Portugal series runs across 10 separate articles - each one its own page:
- Portugal Golden Visa Cost in 2026: The All-In Number for the €500,000 Fund Route
- Portugal Golden Visa Tax in 2026: Why the Visa Isn't a Tax Plan
- Portugal Golden Visa Application in 2026: The Real Step-by-Step
- Portugal Golden Visa for Families: Who You Can Include
- Portugal Golden Visa Citizenship After the 2026 Reform: The Real Timeline
- The 10-year clock
- A CMVM listing is not a Golden Visa fund
- Is the Portugal Golden Visa worth it?
- Portugal Golden Visa requirements
- My Portugal file is stuck
- Also read: Portugal Golden Visa requirements
- Also read: My Portugal file is stuck (AIMA, card, clock)
- Also read: Is the Portugal Golden Visa worth it?
Investment routes
Dominant route since 2023. CMVM-regulated, 5-year minimum maturity, ≥60% Portugal exposure, no real estate.
Non-refundable. −20% in low-density territory.
Public or private R&D institutions.
8 jobs in low-density areas.
Investment in a Portuguese company maintaining 5 jobs for 3+ years.
Deep dive
What October 2023 changed
Real estate is gone as a Golden Visa route - that's the single biggest change here. Law 56/2023 (Mais Habitação) removed direct property purchase, REITs and property-exposed funds, and also scrapped the old capital-transfer-to-a-bank-account route. In their place, CMVM-regulated investment funds became the dominant path: a five-year minimum maturity, at least 60% of the fund's capital in Portuguese-incorporated companies, and no real estate exposure allowed.
What April 2026 changed (and what it didn't)
That covers the investment side. Next is the citizenship clock, which moved for the first time in years. On 1 April 2026 Parliament voted 152-64 (one abstention) to stretch the residency-to-citizenship requirement from 5 to 10 years for most third-country nationals - 7 years for CPLP citizens, and EU citizens fall under the same 7-year rule though they were never ARI-eligible. The clock now starts from the date your first residence title is issued, reversing a 2024 amendment. It was promulgated on 3 May 2026 as Decreto 48/XVII (amending Lei 37/81), published 18 May 2026 as Lei Orgânica n.º 1/2026, and took effect 19 May 2026. The Golden Visa itself didn't change: routes, fees, family rules, physical presence and permanent residency at year 5 are all untouched. One transitional detail matters: nationality applications filed on or before 18 May 2026 keep the old 5-year rule, while pending Golden Visa files that hadn't yet filed for nationality are on the new 10-year (or 7-year CPLP) clock. Worth flagging: a separate decree that would have made loss of nationality a criminal penalty (Decreto 49/XVII) was not signed and remains under review at the Constitutional Court.
How the application actually works
That's the law. Here's what actually happens on the ground when you apply. Get a NIF (tax ID) through a fiscal representative, open a Portuguese bank account, make the qualifying investment, and file with AIMA. Since a February 2026 digital portal launch, renewals and follow-up appointments are booked online, though AIMA still schedules your first biometric appointment once your dossier is accepted. Realistic timing for a clean new file in 2026 is 12–18 months to the first residence card; legacy pre-reform files in the backlog have run 2–3 years. The first card lasts 2 years, then renews in 3-year blocks. At year 5 you can apply for permanent residency, which drops the requirement to keep the investment in place. Between the backlog and the new clock, the real time to a citizenship application is now roughly 9–13 years for many investors, not a clean 10.
The real cost, end to end
That's the timeline. Now the actual bill. Budget the €500,000 fund subscription, plus AIMA fees charged per person, not per household: roughly €620 at submission and about €6,180 for the residence permit, paid by card at the biometrics appointment - for every applicant, including dependents, though children's fees are reduced. On top of that, expect €8,000–€25,000 in legal fees across the programme, and one renewal fee of about €3,090 per person around year two. AIMA adjusts these fees annually without notice. The biggest recurring cost is usually the fund itself, where management fees of 1–2% a year on €500,000 run €5,000–€10,000 annually.
Tax: IFICI replaced NHR
That's the cost side. Tax works differently now too. The old Non-Habitual Resident regime closed to new applicants on 1 January 2024, with the transitional window ending 31 March 2025. Its replacement, IFICI, was introduced by Ordinance (Portaria) 352/2024/1: a 20% flat rate on qualifying Portuguese employment and self-employment income for 10 years, plus an exemption on most foreign-source income, in force from 24 December 2024 and retroactive to 1 January 2024. It's narrower than the old regime - eligibility is limited to scientific research, higher-education teaching, technology and innovation roles, qualified industrial professions, and senior staff at certified startups or major exporters. Foreign pensions no longer get special treatment; they're taxed at standard progressive IRS rates, roughly 13% to 48% across nine brackets in 2026, plus a 2.5%–5% solidarity surcharge above €80,000.
Permanent residency at year 5 - what the 2026 reform left intact
Tax aside, one part of this program is easy to overlook. The April 2026 reform extended the citizenship clock, but it left permanent residency alone. PR is still available at year 5 of the Golden Visa, and it's arguably the most under-rated part of the programme. Once you have it, you can exit the fund and still keep EU residency - the €500,000 no longer needs to stay invested. For investors who never planned to naturalise, year-5 PR, not the now ten-year passport, is the real destination: durable EU residence at roughly 7 days a year on the ground, with your capital freed up. The language bar for PR is the same A2 Portuguese required for citizenship.
Choosing a CMVM-regulated Portugal Golden Visa fund: what to actually check
PR and citizenship both assume you pick a fund that actually qualifies - and that's its own decision. Since the fund route is now the dominant path, choosing the fund is the most consequential decision in the whole application - and it's an investment decision, not an immigration one. First confirm it's CMVM-regulated and structured for Golden Visa rules: five-year minimum maturity, at least 60% of capital in Portuguese-incorporated companies, no real-estate exposure. Then scrutinise it like any private fund: strategy (venture, private equity, private credit), the manager's track record, the full fee schedule including performance and redemption fees, the lock-up and expected return-of-capital window - often 6–12 years, beyond the five-year minimum - and the realistic downside, because the €500,000 is at risk and only comes back if the fund performs. If a commission-paid promoter is steering you toward a specific fund, ask whether they earn a placement fee on it, and get independent advice on the fund itself.
The honest tradeoffs
- + Statutory minimum stay of 14 days per two-year renewal cycle (about 7 days a year)
- + Permanent residency at year 5 - unaffected by the 2026 nationality reform
- + Family file covers spouse, kids to 26 (if dependent), parents 65+
- + IFICI tax overlay for qualifying tech, research and industrial roles
- − April 2026 nationality reform extends the citizenship clock from 5 to 10 years (7 for CPLP nationals; EU citizens share the 7-year rule but are not ARI-eligible); Lei Orgânica n.º 1/2026 in force 19 May 2026
- − Real estate route closed in October 2023 - fund and donation only
- − AIMA backlog means new files take ~12–18 months to a first card; legacy cases 2–3 years
- − IFICI eligibility narrower than the old NHR; pensions no longer favoured
Frequently asked
Is the Portugal Golden Visa still worth it in 2026?+
Yes - but the case has changed.
- •Permanent residency at year 5 is unaffected by the April 2026 nationality reform.
- •Citizenship is now a 10-year horizon for most non-EU applicants (7 for CPLP nationals; EU citizens share the 7-year rule but are not ARI-eligible).
- •~7 days/year on the ground is enough to maintain residency.
- •The fund route is the only major path now (real estate closed in Oct 2023).
- •If a 5-year EU passport was the goal, Greece's 7-year track is now competitive on timeline.
Did the April 2026 law change the Golden Visa itself?+
No - only the path to citizenship.
- •Golden Visa fee, routes, family rules and physical presence are unchanged.
- •Permanent residency at year 5 is preserved.
- •The change is the residency-to-citizenship clock: 10 years for most non-EU, 7 for CPLP nationals, starting from first residence title.
- •Transitional rule (Artigo 7.º.2): nationality applications filed on or before 18 May 2026 keep the old 5-year rules; pending Golden Visa files without a nationality application are on the new 10-year (or 7-year CPLP) clock.
Do I need to learn Portuguese?+
Only for citizenship - not for residency.
- •No language test to get or renew the Golden Visa.
- •For naturalisation you must pass the CIPLE A2 exam.
- •A2 is roughly 80–120 hours of study; most applicants prep in 3–6 months.
Who can I include in my application?+
One file covers the nuclear family.
- •Spouse or registered de facto / same-sex partner.
- •Children under 18, plus children 18–26 if single, dependent and studying.
- •Parents over 65 with no dependency proof; under 65 with documented dependency.
- •Each dependent adds ~€3,000 in government fees.
What does IFICI actually cover?+
Narrower than the old NHR - and pensions are out.
- •20% flat rate on qualifying Portuguese employment/self-employment income for 10 years.
- •Most foreign-source income exempt (dividends, interest, royalties, capital gains, rental).
- •Foreign pensions taxed at the standard progressive IRS rates (about 13%–48% in 2026, plus a solidarity surcharge above €80,000).
- •Eligibility: scientific research, higher-ed teaching, tech & innovation roles, qualified industrial professions, certified startup/major-exporter senior employees.