The badge is real. The badge is not the test.
The Portugal Golden Visa's remaining serious door is a subscription in a Portuguese fund. Promoters will show you a glossy PPM and a CMVM-regulated badge. That badge is necessary and nowhere near sufficient. Lei 23/2007, as rewritten by Lei 56/2023, asks four things the CMVM register was not built to answer. Is the vehicle a non-real-estate collective investment undertaking under Portuguese law. Does it still have five years of maturity on the day you subscribe. Will 60 percent of the money sit in companies incorporated in Portugal. And is any of it, directly or indirectly, real estate.
The register tells you the fund is real. AIMA decides whether your particular subscription is an ARI. Two different institutions, two different questions, and a lot of marketing copy that quietly treats them as one. The €250,000 cultural donation route still exists on the site, and it stays a footnote here, because it is sunk capital rather than a fund and it is not what this page is about. The hero of the Portugal programme remains the €500,000 fund.
The four tests, in the statute's own words
The operative text is Lei n.o 56/2023, Article 44.o, rewriting Lei 23/2007 Article 3.o 1 d) vii):
Working English: a transfer of capital of at least 500,000 euro, to acquire units of a non-real-estate collective investment undertaking, constituted under Portuguese law, whose maturity, at the moment of investment, is at least five years, and at least 60 percent of the value of the investments is placed in commercial companies seated in national territory.
Article 3.o 5 of the same rewrite adds the ban that catches the workaround promoters like best: "as atividades de investimento previstas nas subalineas referidas no numero anterior nao se podem destinar, direta ou indiretamente, ao investimento imobiliario." In English, those investment activities cannot be destined, directly or indirectly, to real-estate investment. A Portuguese private-equity fund that holds shares in a company whose only asset is a building fails this sentence just as surely as a fund that buys flats outright. So does a fund that is, on inspection, actually a real-estate OIC (an OII) wearing a venture-capital label.
Lei 56/2023 Article 42.o also closed new ARI filings on the old real-estate and €1.5 million transfer routes from 7 October 2023. Renewals of real-estate ARIs granted before that date are a different file and a different sentence. This page is only about a new fund subscription made now.
| Test | Who stamps it | Where a buyer looks | What a "yes" does not mean |
|---|---|---|---|
| Manager is authorised | CMVM | Investor portal, sociedades gestoras | The fund is ARI-eligible |
| Fund/OIC is registered | CMVM | Same portal, OIC / capital de risco | The fund meets Art. 3.o 1 d) vii) |
| Portuguese-law vehicle | Constitutive documents + CMVM file | Regulamento de gestao / PPM | Five years remain today |
| Non-real-estate, no indirect RE | Constitutive documents + portfolio | Regulamento de gestao + latest carteira | AIMA will accept your subscription |
| At least 60% Portuguese companies | Manager confirmation + portfolio | Carteira / side letter | The 60% will still hold at renewal |
| At least 5 years maturity at your subscription | Constitutive documents + deed of adhesion | Duration clause | You can exit at year 5, many funds run 6 to 12 |
| €500,000 actually subscribed and paid | Bank + manager certificate | Proof AIMA wants on the ARI file | The investment is safe |
| ARI eligibility | AIMA, on your file | Portal ARI + lawyer's written opinion | The fund will return capital |
How the register actually works
CMVM's public surfaces are live but they run as OutSystems single-page applications. A plain fetch of cmvm.pt or investidor.cmvm.pt/PInvestidor returns the JavaScript shell, not a queryable table. That means we could not run an interactive search on this pass and could not pull a live codigo do fundo for either worked example below. That is a named gap, not a shortcut we papered over.
What a human does, with a browser rather than a server-side fetch:
- Open investidor.cmvm.pt/PInvestidor or cmvm.pt directly.
- Find Fundos de investimento (OIC), Capital de risco, or Sociedades gestoras. gov.pt's own instruction is to look for Gestao de ativos in the left-hand menu.
- Search by the exact legal name first, the denominacao printed on the regulamento de gestao, then by the CMVM codigo do fundo the manager printed on the PPM. Do not search the marketing nickname.
- Record the legal name, codigo, manager, depositary, status, constitution date and duration.
- Open the regulamento de gestao and the latest carteira. Check the duration remaining, the 60 percent sentence, and any real-estate limb.
- Ask the manager, in writing, for a sentence that tracks Article 3.o 1 d) vii) and Article 3.o 5, not a sentence that says only "Golden Visa eligible."
- Have a Portuguese lawyer, not the placement agent, put that sentence against your AIMA file.
If the search by legal name returns nothing, stop. A fund that cannot be found on the public CMVM surface is not a soft launch. It is a red flag.
| Door | URL | What we could open |
|---|---|---|
| CMVM institutional | cmvm.pt | Live, OutSystems single-page app |
| CMVM investor portal | investidor.cmvm.pt/PInvestidor | Live, JavaScript shell |
| gov.pt funds consultation service | gov.pt fund consultation | Listed in search, blocked to our fetch this pass |
| gov.pt quarterly asset-management stats | gov.pt quarterly stats | Opened, points readers back to cmvm.pt |
| ANI certified-funds list, 7 Jan 2025 | ANI certified funds PDF | Opened, a SIFIDE/R&D list, not an ARI list |
Expert tip
Ask for the CMVM codigo and the ISIN before you ask for the IRR. Then look the codigo up yourself on investidor.cmvm.pt. If the placement agent cannot produce a codigo that resolves to the same legal name and the same manager, you do not have a fund. You have a slide.
Common mistake
Treating "CMVM-regulated" as the ARI test. Every serious Portuguese FCR is CMVM-supervised. Most of them are not Golden Visa vehicles. The second frequent error is buying into a fund with four years of life left because a cousin subscribed in 2023: Article 3.o 1 d) vii) measures maturity at the moment of your investment, not the fund's original launch date. The third is assuming a real-estate-flavoured "Portuguese companies" book sneaks past Article 3.o 5. Indirectly is in the statute.
CMVM and ARI fund checklist
The missing stamp is: "I opened cmvm.pt or investidor.cmvm.pt myself." That does not mean the fund is ineligible. It means you have not evidenced the test yet. Get that one item in writing before you move on to the next.
You can search the CMVM register by legal name alone. A codigo do fundo you cannot resolve on the register is itself a reason to stop, not a formality to skip.
Two real funds, and what the identifiers do and do not prove
The two lookups below use public identifiers we could open on 21 August 2026: an ANI NIPC, a Euronext ISIN, and one GLEIF registration number used as a method demonstration. They are lookups, not a recommendation, and not an AIMA-approved list. We could not pull either fund's CMVM codigo do fundo off the live SDI form, because that form is a JavaScript app. A writer or investor with a browser should re-run the search the week they read this and confirm the codigo directly.
| Iberis Bluetech Fund II, FCR | Indico Venture Capital Fund II, FCR | |
|---|---|---|
| Manager | Iberis Semper, Sociedade de Capital de Risco, S.A. | Indico Capital Partners, Sociedade de Capital de Risco, S.A. |
| Public tax ID | NIPC 720016347 | NIPC 720019524, flagged with condicionantes on the ANI list |
| Public securities ID | ISIN PTIESGIM0014 | ISIN PTDICIIM0003, class D3; other classes exist |
| CMVM codigo (live SDI) | Gap, form not queried | Gap, form not queried |
| Opened as | Portuguese closed FCR | Portuguese closed FCR |
| Manager says "GV compatible"? | Not on the pages we opened | Yes, on indicocapital.com |
| May a writer call it ARI-eligible? | No | No |
| Next human step | CMVM capital-de-risco search by legal name; read duration, 60% and the RE ban | Same, plus match the class and ISIN to the subscription pack |
Indico's own site carries this sentence on its funds page: "Our funds are also compatible with Portuguese Golden Visa residency program applicants and with Portuguese corporates seeking SIFIDE2 tax incentives." That is a manager's marketing sentence, not a regulator's certificate and not an AIMA decision. Downgrade it accordingly: compatible is not the same word as eligible, and eligible is not the same thing as approved on your file.
As a method demonstration only, not a Golden Visa example, IBERIS RED FUND appears in GLEIF-derived records with LEI 254900HKFH25Y9BIGZ11, registration number 2268, validation authority RA000488, which is GLEIF's code for CMVM. That LEI lapsed on 11 July 2026. The point of including it here is narrow: GLEIF's RA000488 field is one way to recover a CMVM number when the SDI form will not load, nothing more. Square Asset Management, by contrast, is a real CMVM-supervised manager that is historically a real-estate house. It is not walked here as a qualifying route, because Article 3.o 5 is exactly why it would not be.
The fee line, kept short on purpose
This page prints no fee. The 1 to 2 percent management drag on fund vehicles is already published on the cost chapter, and repeating a fee schedule here would only create a second version to keep in sync. The order of operations, subscription before the AIMA file is opened, is covered in the application chapter. If the nationality clock is also part of the decision, our citizenship clock extra and the citizenship chapter cover the ten-year and seven-year tracks.
Frequently asked
Does a CMVM registration number make a fund Golden Visa eligible?
No. CMVM registration means the manager and the OIC sit under Portuguese securities supervision. ARI eligibility is a separate test, set out in Lei 23/2007 Article 3.o 1 d) vii) and Article 3.o 5, and it is applied by AIMA to your subscription, not to the fund in the abstract. Confirm both, in writing, before you wire anything.
Where do I actually look the fund up?
Start at cmvm.pt or investidor.cmvm.pt/PInvestidor/. Search by the exact legal name printed on the regulamento de gestao, then by the CMVM codigo the manager gave you. The gov.pt service page for consulting funds and asset management, updated 1 July 2026, points at the same CMVM area under Gestao de ativos. There is no official Golden Visa funds tab, on CMVM or on gov.pt.
What are the four statutory tests?
A Portuguese-law, non-real-estate collective investment undertaking. At least 500,000 euro transferred to acquire units in it. At least five years of maturity remaining on the day you invest, not on the day the fund launched. At least 60 percent of the invested value held in commercial companies seated in Portugal. Plus a fifth line that sits outside the numbered test but controls all of them: the activity cannot be destined, directly or indirectly, to real estate, under Article 3.o 5 of the same rewrite.
Can I split 500,000 euro across two funds?
Marketing sites say yes, provided each fund independently meets every test on its own subscription. We did not find an AIMA circular that confirms this in writing. That is a named gap here, not a green light. Do not tell a client that AIMA has confirmed splitting is acceptable, because on the record we could open, it has not.
The fund says it is CMVM-regulated and Golden Visa ready. What do I ask for?
The CMVM codigo, the ISIN, the regulamento de gestao, the name of the depositary, the remaining duration measured from your actual subscription date, a written sentence from the manager that tracks the 60 percent test and the real-estate ban rather than paraphrasing them, and an independent legal memo from a lawyer who is not paid by the placement agent. Then look the codigo up yourself, on the CMVM site, before you sign.
Is a real-estate-flavoured manager, or a fund that once did property, a qualifying route?
Not on the text in force since October 2023. Article 3.o 1 d) vii) requires a non-real-estate OIC, and Article 3.o 5 bans indirect real estate as well as direct. A closed pre-reform real-estate ARI can still renew, under Lei 56/2023 Article 42.o, but that is a renewal file, not a new subscription, and it is not what this page is about.
Named gaps
- CMVM's investor search and SDI form are JavaScript applications. A server-side fetch returns HTTP 200 shells, not a queryable table. No live codigo do fundo was read off cmvm.pt for either worked example on this page.
- The gov.pt funds-consultation service page, updated 1 July 2026, is real and search-visible, but our fetch of it was blocked this pass. We could not quote its body text.
- No official AIMA or CMVM "Golden Visa funds" register was found. There is not one to link to.
- Splitting €500,000 across two funds: secondary sites claim each fund must independently qualify. No AIMA circular confirming that was opened, so it is stated here as an unconfirmed claim, not a rule.
- The ANI certified-funds list is a SIFIDE and R&D certification, and a separate stamp from ARI eligibility. Do not read one as proof of the other.
- IBERIS RED FUND's LEI lapsed on 11 July 2026. It is used here only to demonstrate a lookup method, not as a Golden Visa example, and it has no ANI line or ISIN in the Euronext slice we opened.
- The AIMA ARI portal HTML timed out for us on this pass, so its interface is not restated here.
- No Reddit or first-person register thread was opened. No investor story is sourced to one.
Sources
- Lei n.o 56/2023, Article 44.o, rewriting Lei 23/2007 Article 3.o 1 d) vii) and Article 3.o 5. diariodarepublica.pt
- Lei 23/2007, consolidated text. pgdlisboa.pt
- Regulamento da CMVM n.o 7/2023. diariodarepublica.pt
- CMVM institutional site. cmvm.pt
- CMVM investor portal. investidor.cmvm.pt/PInvestidor
- gov.pt quarterly asset-management information. gov.pt
- ANI, list of certified funds, updated 7 January 2025. ani.pt
- Euronext Securities Porto, securities under custody. euronext.com
- Indico Capital Partners, funds page. indicocapital.com
- Iberis Capital. iberiscapital.com
- LEIScan, GLEIF-derived record for Iberis Red Fund. leiscan.com
- Square Asset Management, company page. squaream.pt
- AIMA, Autorizacao de Residencia para Investimento, Article 90.o-A. aima.gov.pt
- Methodology: every page above opened, or attempted and recorded as blocked, on 21 August 2026.
Not legal or investment advice. Readings here reflect Lei 23/2007 and Lei 56/2023 as available on 21 August 2026. CMVM's public search tools were not queryable by an automated fetch on that date. Confirm any fund's current codigo, duration and portfolio directly with CMVM and with a Portuguese lawyer before subscribing.