Is the party over for the Portugal Golden Visa program? Absolutely not.
Although new requirements are now in effect, the program remains open for investment residency and eventual EU citizenship.
In the process of researching this article, we spoke in depth with several expert lawyers in our network, including Rui Passos of ERG Family Law.
Dr Passos was closely involved in drafting the new Mais Habitacão bill. He currently represents over 130 foreign clients and holds a PhD in taxation and international finance.
Read on for details of how the program has changed, and how you can apply.
Key takeaways: Golden Visa changes 2023
The following changes apply to anyone investing for a Golden Visa from October 7, 2023 onwards.
Two routes removed
- All real estate routes
- Capital transfer
Five routes still available
- Creation of at least 10 new permanent jobs (no minimum)
- Investment in artistic production and national heritage preservation (min. €250,000)
- Investment in scientific research activities (min. €500,000)
- Investment in Portuguese funds (min. €500,000)
- Investment to incorporate a commercial company, plus create 5 permanent jobs (min. €500,000)
The required investment for routes 1,2 and 3 can be reduced by 20% for investment activities taking place in a low-density zone of Portugal.
“Low density” is defined as having less than 100 inhabitants per square kilometer, or a GDP per capita of less than 75% of the national average. Note: Madeira and the Azores aren’t classed as low-density zones.
Brief background: Why did Portugal make these changes?
Portugal’s government changed the Golden Visa program as part of a wider package of measures.
These were designed to tackle the country’s growing housing crisis in the wake of the pandemic.
They came in the form of a new bill, Mais Habitacão (More Housing).
The bill pledged to create more housing in the market and increase access to housing in the medium-term.
The Golden Visa changes are one of several direct government interventions in the market, all under the remit of Mais Habitacão.
Other changes include:
- Limiting the increase of rent
- Higher taxes on short-term accommodation, such as Airbnb properties
- State repossession of empty houses
The biggest change to the Portugal Golden Visa is that real estate investment is no longer part of the program, in any shape or form.
Real estate had been the most popular Golden Visa route since the program began back in October 2012.
But now, all forms of real estate investment are out of the program. That includes direct real estate investment (both residential and commercial) and investment in funds that focus on real estate rehabilitation.
Unlike most other golden visa programs, Portugal allows investors a lot of freedom. It only requires you to spend around 7 days per year actually in-country.
Chinese citizens have been the main adopters of the program so far, followed by citizens of Brazil, South Africa, Turkey and Russia.
In 2022, Portugal Golden Visa applicants included increasing numbers of US and British nationals, due to the growing need to escape from the legacy of Trumpism and post-Brexit fallout.
The new Golden Visa changes are bad news if you planned to buy property in Portugal, either to live in or to rent out.
But the good news? Investment residency in Portugal is still alive and kicking. Several exciting routes have emerged to finally take their places in the spotlight.
Benefits of the Portugal Golden Visa
Portugal’s Golden Visa offers several huge benefits for potential investors.
Here’s a quick rundown:
- Access visa-free travel in Europe
- Start your five-year timeline to Portuguese (and EU) citizenship
- Include your spouse and children on your application
- Invest in various routes starting from €250,000
- Low physical stay requirements (just 7 days per year)
Plus, Portugal remains extremely attractive as a pathway to EU citizenship.
Although the Golden Visa program doesn’t offer immediate citizenship, getting residency via the program allows you to apply after five years.
Basic requirements to qualify for the program:
- Be a non-EU/EEA and non-Swiss citizen
- Make an investment in Portugal of the minimum threshold for your chosen route
- Have a clean criminal record
- Spend at least seven days in Portugal per year
Qualifying investment routes in 2023
#1. Job creation (no minimum)
Investment threshold: No minimum
Investment that creates a minimum of at least 10 new permanent jobs (not many further details are available at present, but we will update once we have them).
#2. Art and culture
Investment threshold: €250,000
In the past, most Golden Visa applicants have overlooked the cultural heritage route (also known as the cultural Golden Visa), because they believed it was a donation-only option.
But investing in film production is one way you can meet the Golden Visa’s requirements for this route – while also getting a return on your investment.
The film production route is the only one where all applications must be submitted by an eligible public entity.
This speeds up the process, as film production is the only Golden Visa route featuring a 15-day government pre-approval step.
What’s more, you don’t have to commit any capital before the pre-approval step is complete.
#3. Scientific research activities
Investment threshold: €500,000
The law describes this route as follows: “Transfer of capital equal to or greater than €500,000 applied to research activities by public or private scientific research institutions, integrated into the national scientific and technological system.”
So far, the scientific research route hasn’t been widely used. This is likely because the funds route offers a much more appealing prospect for the same minimum investment threshold.
For the same investment level, the funds route offers a far clearer and proven pathway to residency, with an efficient handling process.
#4. Investment funds
Investment threshold: €500,000
Fund investment is a fast and simple route to the Golden Visa, with years of proven success.
Investors can buy shares in certain Portuguese funds, which must have a maturity of at least five years at the time of investment.
To qualify for the Golden Visa program, at least 60% of the value of a fund’s investments must be in commercial companies based in Portugal.
Funds are also a tax-efficient way to get your Golden Visa. If you don’t become a tax resident in Portugal, then you won’t pay any tax on either dividends or capital gains.
#5. Company incorporation with job creation
Investment threshold: €500,000
The law describes this route as follows: “Transfer of capital equal to or greater than €500,000 for the incorporation of a commercial company with a registered office in the national territory, combined with the creation of five permanent jobs. Or for the reinforcement of the share capital of a commercial company with registered office in the national territory, already incorporated, and the creation of at least five permanent jobs or the maintenance of at least 10 jobs, with a minimum of five permanent jobs, and for a minimum period of three years.”
Once again, for the same investment level, the funds route offers a far clearer and proven pathway to residency, with an efficient handling process.
Bringing your family to Portugal
You can include family members on your Golden Visa application. This gives them the same residency rights as you.
Here’s a list of eligible family members:
- Spouse or legal partner (with proof of living together for over two years)
- Children under the age of 18, or dependent children under 26 who are also unmarried and in full-time education
- Parents over 66 or financially dependent on you
Fees and other costs
- Processing: €533 for main applicant + €83.30 per dependent (Paid at start and at each renewal)
- Application fee (paid at start): €5,325 per applicant
- Renewal fee (per renewal): €2,663 per applicant
Total fees over the full five years typically start from around €10,000 for a family of four. This includes all renewals. Fees vary according to which law firm you use to handle your application.
How to get the Golden Visa in 2023
- Select your preferred investment route
- Collect all required documents
- Get a NIF (Portugal’s tax number)
- Open a Portuguese bank account
- Make your investment and collect the proof
- Submit your Golden Visa application online
- Receive your application pre-approval
- Attend your biometrics appointment in person
- Receive your residency permit from SEF
- Golden Visa application form
- Receipt for the application fee
- Passport copy for each person on your application
- Proof of investment
- Declaration from your Portuguese bank confirming transfer of funds originating outside of Portugal (find out the best ways to transfer large amounts of money abroad)
- Health insurance policy covering Portugal and the rest of Schengen
- Criminal record certificate from country of origin (must be a certified copy and less than 90 days old)
- Authorization for SEF to check your Portuguese criminal record
- Proof of no outstanding debts from the Portuguese Tax and Customs Authority and Social Security system
- A signed declaration that you intend to follow the investment requirements (i.e. to maintain the investment for the required period of time)
Renewing your Golden Visa residency permit
Years 1 and 2
Your initial permit is valid for two years. During those two years, you’ll need to spend a minimum of 14 days physically in Portugal.
Before the end of year two, you’ll need to renew your residency permit.
As SEF can be prone to delays, it’s best to arrange renewal at least two months before the actual deadline.
You’ll need to submit updated versions of the same documents as before, conduct a new set of biometrics, and pay renewal fees for yourself and any family members included on your Golden Visa.
Years 3, 4 and 5
Your renewed residency permit will be valid for another three years. During that time, you’ll need to spend at least 21 days physically in Portugal (that’s just seven days per year – perfect for a nice beach vacation!)
After 5 years
After holding temporary residency for five years, you can convert it to permanent residency. This permit is valid for 10 years.
Five years is also the point at which you can apply for Portuguese citizenship.
If preferred, you also have the option to just keep renewing your temporary residency status. But we don’t advise this, as dual citizenship brings many benefits.
Once you become a permanent resident or a citizen, you no longer need to keep your original Golden Visa investment.
Getting EU citizenship with the Golden Visa
Getting EU citizenship with the Portugal Golden Visa is possible after holding your temporary residency permit for a minimum of five years.
The timeline to citizenship begins from the date SEF issues your temporary residency permit from SEF (not from the date you make your investment).
After that, all you need to do is maintain your investment, spend the required number of days in Portugal every year, and renew your residency permit on time.
Once you’ve held your residency permit for 5 years, you can submit an application for Portuguese citizenship by naturalization.
Final thoughts & recommendations
The Portugal Golden Visa changes of 2023 have given the program the biggest shakeup in its 11 year history.
But, at least the Golden Visa hasn’t ended.
The biggest change is the removal of all real estate investment options – spelling bad news for those who dreamed of establishing a part-time home in Portugal.
But despite the changes, several appealing Golden Visa investment options still exist.
The best two choices for new investors are:
The first option could be reduced to €200,000 for investment in a film being made in a low density area of Portugal.
We expect to see more projects unfolding in the coming months, as lawyers, fund managers, and film production companies navigate the changes and create new vehicles for investment.
Is Portugal ending the Golden Visa program?
No, Portugal is not ending the Golden Visa program. But the government has made significant changes to it. It’s no longer possible to get the golden visa by investing in real estate or making a capital transfer.
What are the disadvantages of the Portugal Golden Visa?
The main disadvantage of the Portugal golden visa is the high level of investment needed to obtain it. If that’s not an option for you, it’s worth checking out Portugal’s D7 passive income visa or digital nomad visa instead.
Can US citizens invest in Portuguese funds for the Golden Visa?
Yes, US citizens can invest in many of the Portuguese funds eligible for the Golden Visa.
Can UK citizens apply for the Portugal Golden Visa?
Yes, UK citizens can apply for the Portugal Golden Visa. Since Brexit, UK citizens have become third country nationals, making them eligible for the Golden Visa.
As a Golden Visa holder, can I work or study in Portugal?
Yes, Golden Visa holders get a residency permit which allows them to work or study in Portugal.
Which countries can I visit with my Golden Visa?
You can use your Golden Visa to travel freely in the Schengen area for up to 90 days in every 180. This is a significant benefit for applicants from countries that need a visa to access Schengen. But Brits, Americans and others with existing visa-free access won’t notice much difference.
Do I need to live full time in Portugal with the Golden Visa?
No, you don’t need to live full time in Portugal with your Golden Visa. Having Golden Visa residency gives you the option to move to Portugal whenever you want, but you don’t need to live there full time.
The Portugal Golden Visa may have changed, but it’s still very much alive and kicking.
It’s no longer possible to invest in anything real estate related, but you still have several promising options to get into the program.
Investing in funds focusing on Portuguese companies is the best remaining way to access the Golden Visa (with potential for excellent returns).
To find out more about eligible investment funds, we invite you to check our constantly updated list.