Portugal’s Golden Visa: What Remains After the 2023 Reform
Joana Loureiro Veríssimo | Lawyer
Since its creation in 2012, Portugal’s Golden Visa programme has provided a gateway for non-EU citizens to obtain residency through qualifying investments. Over time, the programme has undergone significant reforms, reflecting shifts in national policy priorities, particularly concerning housing and urban development.
The most recent and impactful change came with the enactment of Law No. 56/2023, which entered into force in October 2023. This legislation redefined the scope of eligible investments, moving away from real estate and passive capital transfers and instead promoting investments in innovation, cultural contributions, and job creation. Several popular routes were eliminated, including:
- The acquisition of real estate valued at €500,000 or more.
- The purchase and rehabilitation of properties over 30 years old or located in designated urban rehabilitation areas with a minimum combined investment of €350,000.
- Capital transfers of €1.5 million or more.
The termination of these options significantly reshaped the programme.
Following these reforms, immediate concerns arose regarding the status of pending applications. Law No. 56/2023 clarified that it does not apply retroactively. Residence permits already issued, and family reunification applications approved under the previous regime, remain valid. Applications already submitted or at preliminary stages, such as those awaiting municipal pre-approvals, will continue to be processed under the former legal framework. However, upon renewal, these residence permits will be converted into residence permits for immigrant entrepreneurs. Renewals must be carried out in person before the Portuguese authorities, and the new permits will be subject to updated minimum stay requirements. This transitional mechanism protects the rights of investors who acted in good faith under the previous law, while gradually aligning their status with the current immigration policy.
Law No. 56/2023 marks a decisive shift in the Golden Visa programme. The government now aims to direct foreign investment towards sectors that generate long-term value for the Portuguese economy and society. Under the new regime, applicants may qualify by investing at least €500,000 in scientific research conducted by institutions within the national scientific or technological system, contributing a minimum of €250,000 to support artistic production or the preservation and restoration of cultural heritage through recognised public or private entities, transferring at least €500,000 into collective investment or venture capital funds established under Portuguese law, provided that at least 60% of the fund’s investments are made in companies headquartered in Portugal and that the fund has a minimum maturity of five years, incorporating or expanding a company that creates and maintains at least 10 full-time jobs, or transferring €500,000 to establish or reinforce a company’s share capital, combined with the creation or maintenance of the required number of jobs for at least three years.
Under the current framework, investments involving real estate, either directly or indirectly, are no longer eligible under the Golden Visa programme. However, investments made in designated low-density areas benefit from reduced thresholds or employment requirements. These areas are defined as regions with fewer than 100 inhabitants per square kilometre or a GDP per capita below 75% of the national average. In practice, this includes much of inland Portugal, excluding the coastal regions south of the River Lima and north of the River Sado, as well as the islands of Madeira and the Azores.
To qualify, applicants must not only complete a qualifying investment but also meet general eligibility criteria and minimum stay requirements. The two-year Golden Visa residence permit requires at least 14 nights spent in Portugal during each two-year period, which is typically interpreted as seven nights per year. For residence permits that are converted into immigrant entrepreneur permits, now issued with a three-year validity, the law does not specify a minimum stay. However, based on current practice, it is assumed that the same rule applies: seven nights per year, or 21 nights over three years.
Applicants must also consider the administrative fees, updated as of March 2025 and payable to the Agency for Integration, Migration, and Asylum (AIMA). For the initial residence permit, the processing fee is €618.60, and the issuance fee is €6,179.40. Renewals under the Golden Visa investment routes that are still valid are subject to a processing fee of €618.60 and an issuance fee of €3,089.70. In these cases, the residence permit remains valid for two years. However, if the investment is no longer eligible, for example, real estate or capital transfers, the residence permit will be converted into an immigrant entrepreneur permit, valid for three years, with significantly lower fees: a processing fee of €618.80 and an issuance fee of €181.50. Additional reductions apply to minors and Portuguese-speaking countries (CPLP) nationals, who benefit from an issuance fee of €58.10. These fees apply to each applicant, including in family reunification cases, and are revised annually in March.
The timeline for accessing Permanent Residence and Portuguese citizenship differs. For Permanent Residence, the five years is counted from the date of issuance of the initial residence permit. For Portuguese citizenship, however, the five years is calculated from the day after the payment of the Golden visa application analysis fee, provided that the residence permit is subsequently issued. In both cases, applicants must meet all general eligibility conditions and demonstrate sufficient knowledge of the Portuguese language. More information on the path to citizenship is available in the insight prepared by my colleague, Danielle Avidago, which you can access [here].
Despite the substantial changes introduced by Law No. 56/2023, Portugal’s Golden Visa programme remains active. It continues to offer a viable pathway to residency and citizenship for investors committed to supporting the country’s scientific development, cultural heritage, and economic growth.
