Portugal has rescinded their real estate Golden Visa program in October 2023, now investment funds account for the vast majority of Portugal residency by investment applications. The minimum amount required in a qualifying fund regulated by the CMVM (Portuguese Securities Market Commission) is EUR 500K. It's not something they have to fall back on, it's the primary pathway and it is the pathway that most of the new applicants are using in 2026.
This guide will cover all the elements you need to take into account: what types of funds can you invest in; how CMVM regulation works; lock-up periods; expected returns; risk profiles; and exactly how funds are subscribed and how the residence card is applied. All the details below are representative of the current regulatory framework and verified fund structures.
Why funds became the dominant route
In October 2023, Portugal removed real estate from the Golden Visa and gave the reason to be to focus foreign funds on productive investments, such as technology, innovation and business growth – away from real estate, which was being used to fuel price inflation in some cities.
The fund route was already in place but not widely used, as it was thought that real estate was more straightforward and tangible, and easier to understand by the applicants, prior to 2023. The real estate sector has been eliminated and the fund ecosystem has grown up very quickly. For investors looking for Golden Visa funds, there are dozens of funds regulated by the CMVM that are tailored for the Golden Visa investor with professional investment management teams and with specific investment mandates.
The other two routes (scientific research (EUR 500K) and cultural heritage (EUR 250K)) are technically possible but not feasible for most applicants. For scientific research, there must be a collaboration with an accredited institution and for the cultural heritage projects they are limited and available. When it comes to Golden Visa applications in 2026, the only viable solution is funds.
Types of qualifying investment funds
The Portuguese Golden Visa is not available for all funds. The fund should be registered with the CMVM, localised in Portugal and at least 60% of the assets should be invested in Portuguese companies or projects. In those provisions, qualifying funds are divided into a number of categories.
Venture capital funds (FCR)
Portuguese venture capital funds (Fundos de Capital de Risco – FCR) invest in early and growth stage companies in Portugal with a focus on technology, health tech, fintech and clean energy. These funds are the riskiest of all and also have the greatest return potential.
- Typical strategy: Portfolio of 10-20 Portuguese startups and scale-ups
- Expected return profile: Highly variable. Target IRR of 8-15%, but actual outcomes depend entirely on portfolio company performance
- Lock-up period: Typically 7-10 years
- Liquidity: Very limited. No secondary market for most FCR positions
- Risk level: High. Early-stage companies have high failure rates
Venture capital is suitable for investors with a high risk tolerance who don't need to be able to retrieve EUR 500K at a certain time and are truly passionate about the Portuguese innovation ecosystem.
Private equity funds
Private equity funds buy majority and/or substantial minority shares in existing Portuguese companies. These are the more established businesses than VC targets: they are most often making money and in most cases generating revenue.
- Typical strategy: Buyouts, growth equity, or restructuring of mid-market Portuguese companies
- Expected return profile: Target IRR of 6-12%
- Lock-up period: Typically 5-8 years
- Liquidity: Limited. Exit depends on the fund selling its portfolio companies
- Risk level: Moderate to high. Less volatile than VC but still illiquid private markets
Real estate investment funds
This is an important distinction: while direct real estate purchase no longer qualifies for the Golden Visa, investing in a CMVM-regulated real estate fund does qualify. These funds pool capital to invest in Portuguese commercial real estate, development projects, or residential rehabilitation.
- Typical strategy: Commercial property portfolios, urban rehabilitation projects, hotel and tourism assets
- Expected return profile: Target IRR of 4-8%
- Lock-up period: Typically 5-7 years
- Liquidity: Limited, but underlying assets (property) are more tangible than VC/PE
- Risk level: Moderate. Real estate provides tangible collateral but is subject to market cycles
Mixed and balanced funds
Some qualifying funds mix strategies (real estate, PE and fixed-income Portuguese instruments). These combinations of funds seek to limit concentration risk by investing in multiple asset classes.
- Typical strategy: 40-60% real estate, 20-30% PE/VC, 10-20% bonds or fixed income
- Expected return profile: Target IRR of 3-7%
- Lock-up period: Typically 5-7 years
- Risk level: Moderate. Diversification reduces but does not eliminate risk
Fund comparison table
CMVM regulation: what it means for your investment
The CMVM (Comissao do Mercado de Valores Mobiliarios) is the SEC (US) or FCA (UK) equivalent of Portugal. All funds eligible to be a part of the Golden Visa process are required to be registered with and supervised by the CMVM. This offers the investors multiple safeguards.
What CMVM oversight guarantees
- Fund registration and licensing: The fund and its management company must be approved by the CMVM before accepting investors
- Audited financials: Annual audited financial statements are mandatory and filed with the CMVM
- Custodian requirement: Fund assets must be held by an independent custodian bank, separate from the management company
- Investment policy compliance: The CMVM monitors that the fund adheres to its stated investment policy and the 60% Portuguese allocation requirement
- Reporting obligations: Regular reporting to the CMVM on portfolio composition, NAV, and investor communications
There can be no guarantee of returns or protection from investment losses under the CMVM scheme. It assures transparency in fund operation, fly safe applications of your capital (not mixing it with the manager's capital), and that the fund remains invested in its teaching method stated in the prospectus. The risk of the investment still lies with you.
Lock-up periods and exit mechanics
One of the most important conditions for the Golden Visa fund investors is the lock-up period. EUR 500K investment will have to be maintained over the length of Golden Visa stay (min. 5 years, as part of the process to obtain Portuguese citizenship).
How lock-ups work in practice
The majority of Golden Visa funds organise their lock-up in line with the 5-year length of time required for citizenship. That said, the life of the investment in this fund itself might be longer. The meaning here is that:
- Minimum hold: 5 years (for permanent residency) Note: citizenship eligibility under the revised May 2026 Nationality Law is now 10 years for most applicants. Plan fund lock-up accordingly. Selling before this voids your Golden Visa.
- Fund lifecycle: Most funds have a 5-10 year lifecycle with optional extensions. Your capital is returned when the fund liquidates its portfolio, not when your 5-year Golden Visa period ends.
- Early exit: Generally not possible. These are closed-end funds with no redemption mechanism during the lock-up period. There is no secondary market for most Portuguese Golden Visa fund positions.
- Extension risk: Fund managers can typically extend the fund term by 1-2 years if portfolio exits are not complete. Your capital may be locked longer than initially planned.
Exit scenarios
Best case: The fund is successful, exits from all companies in its portfolio or properties within its specified holding period and returns your principal plus profits at the close of the fund. Your money and citizenship will be returned.
Base case: The fund takes 1-2 years longer to complete the exit. In year 7-8 you get your capital back, rather than 5-6. The IRR of returns is moderate (3-8%). Nevertheless, you are still granted citizenship.
Worst case: The portfolio companies go bankrupt or real estate market drops. This fund returns less than your EUR 500K. Even if you meet the requirement of investing (not of profiting from it), you can suffer a capital loss. CMVM regulation does not mitigate against losses in the market place.
Due diligence: how to evaluate a Golden Visa fund
The quality of the funds regulated by CMVM is variable as dozens of funds fight for the capital of Golden Visa. Below is the key set of aspects to consider prior to spending EUR 500k.
Management team track record
Track record with the fund manager is first as far as the topmost important criteria goes. Consider teams that can claim success at managing funds issued in Portuguese with reliable track record, rather than those that have just international experience repackaged for the Golden Visa market. Don't expect projected returns; instead, get audited results from past funds.
Fee structure
Typical fee structures for Golden Visa funds include:
- Management fee: 1.5-2.5% of committed capital per year
- Performance fee (carry): 15-20% of profits above a hurdle rate
- Subscription fee: 0-3% (one-time, at entry)
- Exit fee: Rare but occasionally 1-2%
A 2% annual management fee would eat into your EUR 500K investment by a total EUR 70,000 over 7 years, or 14% of the investments. This is prior to performance fee. If you can, discuss the deal and, if not, evaluate which funds charge the most fees. While the lowest fee may not be the best fund, an overdosed fee will severely compromise returns.
Portfolio diversification
Do not put all of your funds in one or two businesses or properties in a fund. Inquire about the number of companies the fund will hold in its portfolio and how much the maximum amount the fund puts into a single company will be. A fund where you would invest EUR 500K in just 1 company is a lot riskier than a fund where you invest in 10-15 positions.
Red flags to watch for
- Guaranteed returns: No legitimate investment fund can guarantee returns. This is a regulatory violation.
- No audited track record: First-time fund managers launching specifically for the Golden Visa market. Unproven teams handling EUR 500K of your capital.
- Opaque fee structures: If you cannot clearly understand all fees from the offering documents, walk away.
- Pressure to subscribe quickly: Legitimate funds do not create artificial urgency. Your due diligence period should be respected.
The subscription process: step by step
The process includes a number of steps in sequence, from deciding to invest to your Golden Visa residence card.
Total realistic timeline for decision to residence card: 14-22 months. The process of making a fund subscription only requires 4-8 weeks (steps 1-5). The immigration process takes 12 to 18 months – steps 6-9.
Portuguese golden visa investment options beyond funds
There are two alternative qualifying categories with investments for completeness along with funds.
Scientific research (EUR 500K)
Public or scientific research institution in Portugal that receives EUR 500K contribution. The investment is informal and made with the intention to donate, and does not provide a financial return, but instead funding research activities. It's philanthropy-friendly, however the EUR 500K is most definitely in irrecoverable territory.
Cultural heritage (EUR 250K)
A EUR 250K investment in preserving national heritage, arts and culture in Portugal. The lower level is a wonderful option, but the project is scarce and will not involve a return of investment. Few if any use these.
Tax considerations for fund investors
The Non-Habitual Resident tax scheme for foreigners who have moved to Portugal was abolished and was replaced by the IFICI (Incentivo Fiscal a la Investigacion Cientifica e Innovacion) regime. Unlike NHR, which attracted passive investors with wide tax privileges, IFICI has a narrower focus, and benefits mostly those working in the scientific research and innovation sector.
For Golden Visa fund investors, the key tax considerations are:
- Portugal's minimum stay is 7 days per year. If you are not tax-resident in Portugal (spending fewer than 183 days), Portuguese tax on your worldwide income generally does not apply.
- Capital gains on fund distributions: If you are a Portuguese tax resident, gains from fund investments are taxable. If you are non-resident, Portuguese withholding tax may apply to distributions from Portuguese-source income.
- Your home country's tax obligations: The Golden Visa does not exempt you from tax obligations in your country of tax residence. Consult a cross-border tax advisor.
Comparing Portugal to other programs
What are the pros and cons of the Portugal Golden Visa fund route compared to other options? The on-the-honest comparison for investors who are thinking about which options they should think about.
Portugal vs. Greece: Greece real estate (tangible, controllable) EUR250K, processing takes 3 months. Portugal provides funding – illiquid – managed through third parties of EUR 500K, with processing time 12-18 months. Simplicity, speed, and low price are the advantages of Greece. On the citizenship timeline, Portugal beats the United States (1 years vs. 7) and on the small residency necessary (7 days).
Portugal vs. UAE: In real estate the UAE takes 2-4 weeks with a price tag of AED 2M (appx USD 545K). No citizenship path. No income tax. A slower and less liquid option, but with EU citizenship - the holy grail of many investors - is Portugal.
Portugal vs. Caribbean CBI: In 3-9 months, you can obtain citizenship in the Caribbean after a donation of USD 200K-250K. However, Caribbean nationality does not provide EU citizenship, employment or Schengen visa, unlike Portuguese nationality does.
The key selling points of the Portugal Golden Visa are both its pathway to acquiring EU citizenship after 10 years, and its requirement for limited daily residency of 7 years a year. There's no other program that provides all three.
Frequently asked questions
What is the minimum investment for the Portuguese Golden Visa?
The minimum investment is EUR 500K in a qualifying Portuguese investment fund regulated by the CMVM. Real estate is no longer eligible since October 2023. Alternative routes include EUR 500K in scientific research or EUR 250K in cultural heritage, but investment funds are the primary pathway used by the vast majority of applicants.
Can I still buy property for the Portugal Golden Visa?
No. Direct real estate purchase was removed from the Portuguese Golden Visa in October 2023. However, investing in a CMVM-regulated real estate investment fund does qualify. The key difference is that in a fund, a professional manager selects and manages the properties – you are a passive investor with no control over specific assets.
How long is the lock-up period for Golden Visa funds?
Most qualifying funds have lock-up periods of 5-10 years. You must maintain your investment for at least 5 years to be eligible for Portuguese citizenship. The fund's own lifecycle may extend beyond this. Plan for your EUR 500K to be illiquid for 7-8 years in realistic scenarios, accounting for potential fund extensions.
What returns can I expect from Portuguese Golden Visa funds?
Target returns vary by fund type: venture capital funds target 8-15% IRR, private equity targets 6-12%, real estate funds target 4-8%, and mixed funds target 3-7%. These are targets, not guarantees. Actual returns depend on market conditions and fund management quality. CMVM regulation ensures transparency but does not protect against investment losses.
What is the minimum investment for golden visa in UAE?
The UAE Golden Visa requires a minimum investment of AED 2M (approximately USD 545K) in eligible real estate. The 10-year renewable visa processes in 2-4 weeks – dramatically faster than Portugal's 12-18 months. However, the UAE does not offer a path to citizenship, while Portugal offers EU citizenship eligibility after 10 years of residency.
How long does it take to get Portuguese citizenship through the Golden Visa?
Portuguese citizenship is available after 10 years of Golden Visa residency, with a minimum stay requirement of just 7 days per year. The Golden Visa application itself takes 12-18 months to process. Total timeline from first investment to citizenship eligibility: approximately 6.5-7 years. Proposed changes may extend the citizenship eligibility period to 10 years, but this has not been enacted.
This article is for informational purposes only and does not constitute legal, financial, or investment advice. Fund performance data reflects target returns and is not guaranteed. Past performance does not predict future results. Investment in funds carries risk including potential loss of capital. The Portuguese Golden Visa program may be modified or terminated by the Portuguese government at any time. CMVM regulation ensures fund transparency but does not guarantee investment returns. Always consult a qualified immigration attorney, financial advisor, and tax professional before making investment decisions. Golden Keys Global is not a law firm or investment advisor.
