Portugal's Golden Visa in 2026: Which Investments Qualify and Why Real Estate Is Not Among Them

What is Portugal's Golden Visa and what remains of it

Portugal's Golden Visa is a residence permit by investment, officially called ARI, requiring only seven days of presence in the country in the first year. The program has been operating since 2012 and remains open in 2026, but its content has changed beyond recognition from what Russian-speaking buyers once sought it for.

The key change occurred in October 2023: the housing measures package Mais Habitação (Lei n.º 56/2023) removed both direct real estate purchases and investments in real estate funds from the list of qualifying grounds. From that point on, an apartment in Lisbon, a villa in Algarve, or an apartment on Madeira ceased to be a gateway to the program—in any amount and in any region of the country.

The second change comes on 19 May 2026. The citizenship law reform increased the naturalization requirement to 10 years for third-country nationals, including Russia. The Golden Visa itself did not suffer from this, but the horizon of "invest—get an EU passport in five years," under which the program was marketed for a decade, has closed.

Five grounds for residence by investment and their amounts

There are five active grounds for Portugal's Golden Visa, and the minimum returnable investment starts from €500,000. The €250,000 threshold exists, but applies to a non-refundable contribution, not to an investment that can be returned.

None of the five grounds involve real estate purchases. Funds that qualify for the program must be registered with Portugal's securities regulator CMVM and cannot invest in real estate—this prohibition is precisely what was added by the 2023 reform.

Why €250,000 in advertising is not the cheapest Golden Visa

The €250,000 threshold applies to a non-refundable contribution to cultural heritage, not to an investment that the investor gets back. When searching for "Portugal residence by investment," this figure appears in headlines on most consultant websites, and from the snippet it is not clear that the money does not return.

The difference between the two thresholds is not in 250 thousand euros, but in the nature of the payment:

• €250,000—a donation. Funds are directed to support artistic production, reconstruction, or preservation of national cultural heritage. Refund is not provided for by the structure of this ground.
• €500,000—an investment. Fund shares remain an asset of the investor; when exiting the fund, they receive the value of the shares—which may be higher or lower than invested.

Neither option guarantees returns. A fund is a market instrument with the risk of losing part of the invested amount, not a deposit. Formulations about "guaranteed return" or "guaranteed fund returns for the Golden Visa" contradict the nature of the instrument.

Government fees for application review and card issuance and renewal are added to the investment sum—they are charged separately for each family member. Current tariffs are published by the migration agency AIMA, and they should be checked on the date of submission before budgeting: they have been revised multiple times in recent years.

Funds: how the most popular option works

Investment in fund shares under CMVM oversight is the most sought-after ground for Portugal's Golden Visa after the exclusion of real estate. The mechanics differ from property purchase in three fundamental ways.

1. Object of ownership. The investor purchases not a property but shares of a closed or open fund. Asset management is conducted by a management company; the investor is not involved in operational decisions.
2. Sectors. Funds are formed around renewable energy, tourism, healthcare, agriculture, and other sectors. Residential and commercial real estate cannot be included in the portfolio of a qualifying fund.
3. Horizon. The term of a closed fund typically exceeds the period in which an investor expects to obtain permanent status, so exit from the investment and residence renewal must be planned together, not separately.

The full cycle—from document preparation to a decision on the application—takes from 12 months, according to practicing consultants: roughly two weeks for package preparation, obtaining a tax ID (NIF) and opening an account, about a month and a half to purchase shares, and five to six months for review. The actual time depends on AIMA's workload, which has been processing an accumulated backlog for several years.

Real estate and the Golden Visa: the Azores, Madeira, and other myths

Real estate does not provide Portugal's Golden Visa in any region of the country, including the Azores and Madeira. This is the most persistent myth on the topic: in search results it often appears at the top position, where the program is described as "fund investments, real estate on the Azores."

Let us examine three versions of this myth separately.

What a real estate purchase in Portugal actually provides an applicant for residency is proof of residence address in files for D7 and D8 visas. Own property with an extract from the land registry and caderneta predial is accepted equally with a registered long-term rental agreement, and unlike rent, does not need to be renewed each year. The ground for residence remains passive income (D7) or remote work (D8).

Portuguese law establishes no restrictions based on the buyer's citizenship: a Russian citizen can buy property in Portugal on ordinary terms; a tax ID (NIF) is required for the transaction. If you view the country as a place to live or a source of rental income rather than a path to a passport, the choice is made by usual criteria—[real estate in Portugal](/portugal/) in the catalog is sorted by Lisbon, Porto, Algarve, and Madeira with different price and demand profiles, and the rental model can be conveniently checked with a [yield calculator](/calculators/yield/).

Timeline, presence in the country, and renewal

A Portugal Golden Visa holder needs to spend only seven days in the country in the first year and 14 days in each subsequent two-year period. This is the mildest requirement for presence among European investment programs and was the main reason investors who did not plan to relocate chose ARI.

The first residence card is issued for two years, renewal is also for two years, provided the investment is maintained. The obligation to hold the investment applies throughout the duration of the status: early exit from the fund terminates the ground.

An important detail for calculating timelines: the period of legal residence for future naturalization is counted from the date the first residence title is issued, not from the date of application. Months or years waiting in the AIMA queue do not count toward this period.

What the Golden Visa provides and does not provide after the 2026 reform

Portugal's Golden Visa provides the right to reside and travel throughout the Schengen area, but does not provide an EU passport in five years—from 19 May 2026, for Russians this period is ten years. A significant portion of materials in search results still describes the five-year path: it was accurate until the reform and remains accurate only for those who applied for citizenship by 18 May 2026 inclusive.

A detailed breakdown of the new requirement, transitional rules, and how the period of residence is counted can be found in a separate article about Portugal's new citizenship law.

Is the program available to Russian citizens

Portuguese legislation contains no formal ban on Russian citizens' participation in the ARI program. In 2022, the minister of internal affairs announced a suspension of applications from Russians and Belarusians, but this decision was not formalized by a normative act; applications simply did not move forward. After a series of court proceedings, cases that had been stalled for years began to be reviewed—without an official announcement of the suspension being lifted (IMI Daily, July 2024).

The practical barrier lies not in migration law but in banking compliance. Under Article 5b of Regulation (EU) No. 833/2014, credit institutions of the European Union do not accept deposits exceeding €100,000 from Russian citizens and persons residing in Russia. An exception is spelled out in the regulation itself: the restriction does not apply to citizens of EU, EEA, and Swiss states, nor to those with temporary or permanent residence in these countries.

From this comes a practical consequence: managing an investment of €500,000 through a European bank for an applicant with a Russian passport and no active residence permit in the EU is a separate task that must be solved before, not after, choosing a fund. We analyze the mechanics of transferring funds from Russia in the section on money transfers.

Where real estate still provides residence

Twelve countries in our summary provide residence for real estate purchases—Portugal is not among them. If the goal is formulated as "buy property and get status on that basis," Portugal drops out not because of price but because of program structure, and comparing it with ARI alternatives makes no sense.

Thresholds are verified against primary sources as of 27.07.2026—the normative act and verification date are listed for each row in the summary of [residence by investment in real estate](/residence/). It also shows the opposite: Hungary, Italy, and the USA have investment residence programs, but real estate is not a qualifying ground—exactly as in Portugal.

Pros and cons of Portugal's Golden Visa in 2026

The program retained a mild presence requirement and family coverage, but lost both real estate as a qualifying ground and the five-year path to a passport.

Pros:

• presence requirement—7 days in the first year and 14 days in each subsequent two-year period;
• spouse, children, and parents can be included in the application;
• residence provides the right to live, work, and study in Portugal and travel throughout the Schengen area;
• the returnable option (fund) keeps the asset in the investor's ownership.

Cons:

• real estate is excluded from qualifying grounds—since October 2023 and without regional exceptions;
• minimum returnable investment—€500,000; only a non-refundable contribution costs less;
• the path to citizenship for Russians—10 years instead of the previous 5;
• processing time depends on AIMA's queue and is measured in months;
• a fund does not guarantee returns and allows loss of part of the invested amount;
• banking servicing of the investment for an applicant with a Russian passport is limited by Article 5b of EU Regulation No. 833/2014.

How we verify data

The amounts and conditions in this article are verified against normative acts and subject-matter sources, not retold from consultant marketing pages. Where primary sources could not be confirmed—for example, current government fee rates—figures are not included in the text, and the entity that publishes those fees is indicated.

Thresholds for other countries are taken from our program summary, where each row lists the normative act and verification date with the primary source.

Homzer is a marketplace for overseas real estate with transaction support. We do not process residence by investment or provide consultation on migration and investment law. This material is for reference: ARI program conditions have changed three times in recent years, so before making a decision, verify publications from AIMA and consult with a Portuguese attorney. Nothing in this text is an investment recommendation.

Sources:

• Lei n.º 56/2023 (Mais Habitação)—exclusion of real estate and real estate funds from ARI grounds
• Lei Orgânica n.º 1/2026—Diário da República, 18.05.2026—new naturalization requirement
• CMVM—regulator overseeing qualifying funds
• AIMA—Portugal's migration agency: fee rates and processing timelines
• IMI Daily, 20.07.2024—resumption of review of applications from Russian and Belarusian citizens
• Regulation (EU) No. 833/2014, Article 5b—deposit restrictions
• Summary of residence by investment programs homzer.com—thresholds for 12 countries, verified 27.07.2026

Frequently asked questions

Can I get Portugal residence through real estate purchase in 2026?

No. Real estate has been excluded from Golden Visa grounds since October 2023, and the exclusion applies throughout the country, including the Azores and Madeira. Property is used as proof of residence address in files for D7 and D8 visas, but is not itself a qualifying ground.

How much does Portugal's Golden Visa cost?

The minimum threshold is €250,000, but this is a non-refundable contribution to cultural heritage. The minimum returnable investment is €500,000 in fund shares under CMVM oversight. Beyond the investment amount, government fees are paid for each family member.

How many days per year must I spend in Portugal?

Seven days in the first year and 14 days in each subsequent two-year period—provided the investment is maintained.

How many years after the Golden Visa can I apply for citizenship?

For Russian citizens—after 10 years of legal residence: the requirement changed on 19 May 2026. The previous five-year term is preserved only for applications submitted by 18 May 2026 inclusive.

Can a Russian citizen apply for Portugal's Golden Visa?

There is no formal ban in Portuguese legislation; the 2022 suspension was not formalized by a normative act, and applications have been processed since 2024. The practical limitation relates to banking compliance and Article 5b of EU Regulation No. 833/2014.

Can I invest in a fund that invests in real estate?

No. A fund qualifying for the program is not permitted to direct funds to real estate directly or indirectly.

Does a fund guarantee returns?

No. Fund shares are a market instrument: the value on exit may be higher or lower than the amount invested.

In which countries does real estate still provide residence?

According to our summary as of 27.07.2026—in twelve, including Egypt, Georgia, Turkey, Greece, Cyprus, Bulgaria, and the UAE. Thresholds and restrictions vary; each row lists the normative act and verification date.