Introduction: Portugal’s Golden Visa Is Still Alive—But the Rules Have Changed

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Portugal’s Golden Visa has long been a top-tier pathway to EU residency for investors worldwide, especially those who prefer a low-maintenance, fund-based route over traditional real estate. But in 2025, while the program remains active, it no longer offers the same set-it-and-forget-it appeal.

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Following a series of legislative reforms in 2023, Portugal officially removed real estate and capital transfer options from the program. By 2025, regulators have taken things a step further: authorities are now enforcing stricter interpretations of “effective residency”, even for fund investors who previously met the minimum stay requirement of just 7 days per year.

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If you’re currently holding—or planning to apply for—a Portuguese Golden Visa through a qualifying investment fund, here’s what you need to know about the new compliance environment, what risks to avoid, and how to ensure your pathway to EU citizenship stays intact.

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What Qualifies for Portugal’s Golden Visa in 2025?

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As of 2025, the only eligible investment categories for Portugal’s Golden Visa include:

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• €500,000 in a qualifying private equity or venture capital fund
  
• €250,000 contribution to cultural heritage preservation
  
• €500,000 toward scientific research or R&D
  
• Business incorporation creating at least 10 jobs

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The most common route now is the regulated fund investment, which gives investors access to a growing portfolio of CMVM-approved funds in sectors like tech, healthcare, sustainability, and tourism.

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Most funds are structured with 6–8 year holding periods, dividend strategies, and defined exits—making this the closest thing to a recoverable and potentially profitable investment within the framework.

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See more in our detailed Portugal Golden Visa Guide

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The 7-Day Rule Is No Longer a Free Pass

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For years, one of Portugal’s biggest Golden Visa selling points was its low physical presence requirement: investors needed to spend just 7 days per year in the country to maintain residency.

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That rule is still technically on the books—but in 2025, it’s no longer enough on its own.

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Portuguese immigration authorities (now under AIMA, which replaced SEF in 2023) have quietly begun applying stricter scrutiny when evaluating renewal applications and, more importantly, citizenship petitions. Their focus: whether the applicant has demonstrated a “genuine link” or effective residency in Portugal.

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While not explicitly defined in law, this concept is increasingly being used to filter applicants who appear to be “passive residents”—especially those who only meet the 7-day minimum through brief annual visits.

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What This Means for Investors:

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• Short stays alone may no longer be sufficient to support a citizenship application after 5 years.
  
• Authorities may look for signs of integration, such as:
  
  • Local bank or utility accounts
    
  • Residential leases or property ownership
    
  • Portuguese tax filings
    
  • Evidence of language acquisition or cultural participation
    
• Delays in renewals or naturalization could arise if documentation doesn’t reflect meaningful ties.
  
  

This is not speculation—it’s part of an evolving enforcement shift that’s already impacting applicants in 2024 and 2025.

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Fund Investors Must Take a More Active Posture

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If you’re investing through a fund, your financial structure is sound—but it’s time to think about your lifestyle posture as well.

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While you don’t need to relocate full-time, we now recommend that clients take at least some of the following steps to future-proof their Golden Visa strategy:

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1. Spend more than the minimum required days—ideally 14–21 days per year.
   
2. Establish a residential lease or utility contract (even if you don’t live full-time in Portugal).
   
3. Set up a Portuguese bank account and use it for routine payments.
   
4. If possible, enroll in Portuguese language courses to support eventual citizenship.
   
5. Keep detailed travel and presence records—these may be requested during renewals.

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Portugal still offers one of the clearest and fastest routes to EU citizenship (5 years), but it increasingly favors those who demonstrate a genuine relationship with the country, not just a paper trail.

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What About Fund Exit and ROI?

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On the investment side, CMVM-regulated funds remain a credible and recoverable vehicle for the Golden Visa. Most are structured with:

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• A fixed term of 6–8 years
  
• Target IRRs ranging from 3% to 8%, depending on the sector
  
• Built-in capital repayment schedules post-holding period
  
• Exit strategies aligned with your citizenship timeline
  
  

However, not all funds are created equal. You’ll want to review:

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• Fund strategy and sector exposure
  
• Fee structures (management and performance)
  
• Exit mechanisms (secondary market options, liquidity buffers)
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Working with a vetted advisor or migration firm ensures you're aligned with a fund that fits both your immigration and wealth management objectives.

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