Patricia Casaburi
Portugal’s Golden Visa has been one of Europe’s most attractive residency-by-investment programs since its launch in 2012. It has offered international investors a straightforward pathway to European residency, access to the Schengen Zone, and eventual Portuguese citizenship. However, in recent years, the program has undergone major reforms.
Most notably, the Portuguese government removed the real estate investment option in October 2023, a decision that significantly reshaped the landscape for investors. Since then, new regulations, the transition from SEF to AIMA, and wider immigration law reforms have continued to shape how the Golden Visa works in practice.
This article explores the most recent Golden Visa changes, explains the available investment options, and outlines what applicants can expect moving forward.
You’ll also learn more about:
Latest Portugal Golden Visa Updates
In mid-2025, Portugal undertook a significant overhaul of its immigration system. In July 2025, Parliament approved amendments to the Foreigners Law, which restructured the management of various residency and work permits.
One of the most notable changes was the termination of the “manifestação de interesse” (expression of interest) route, which had allowed undocumented migrants already in Portugal to regularize their status through employment contracts.
The reforms also introduced stricter conditions for certain work and family reunification visas, reflecting the government’s aim to tighten entry requirements and streamline processes.
Immigration reform in 2025
For Portugal Golden Visa applicants, however, the investment categories were left untouched. The program continues under the 2023 rules — real estate remains excluded, while the current fund, research, culture, and job-creation routes remain valid.
That said, the reform is not entirely irrelevant to Golden Visa holders, and three points are worth noting:
Administrative centralisation under AIMA: The law confirmed AIMA’s role as the primary authority for migration and integration issues, streamlining the functions that were previously scattered under SEF. As a result, the processing of Golden Visas, renewals, and family reunification requests is now more integrated within AIMA’s comprehensive immigration system.
Legal uncertainty during Constitutional review: On 24 July 2025, President Marcelo Rebelo de Sousa referred the new immigration law to the Constitutional Court for preventive review. While this review does not specifically target Golden Visa provisions, any delay or rejection of parts of the law may affect AIMA’s regulatory framework and implementation capacity, potentially influencing processing timelines for all visa categories, including ARI.
Stability for the Golden Visa: Despite heated debates around migration, the fact that the Golden Visa was not curtailed further in this reform signals political intent to retain the program in its revised, post-2023 form. Investors can therefore take some comfort in the stability of the program, even as other immigration pathways tighten.
For Golden Visa investors, the message is clear: while other visa types are becoming more restrictive, the Golden Visa remains available, but applicants should continue to expect bureaucratic delays as AIMA integrates these sweeping changes into its operations.
Demand and processing times
Since 28 April 2025, AIMA has enforced a strict “complete-file” rule. Any application submitted without full documentation is rejected outright. This is to reduce delays, as in 2024, Golden Visa applications moved to AIMA’s digital portal, streamlining submission and status tracking.
Despite the reforms, demand for the Golden Visa remains strong. In 2024, approvals rose by around 72% compared to 2023, even as delays at AIMA continue. Many applications still take over a year to be fully processed.
Check out our Ultimate Guide to Portugal's Golden Visa
Portugal's Golden Visa Changes in 2024
There were no substantive changes to the Golden Visa investment categories or eligibility in 2024. However, Parliament approved a change in how the five-year residency period for citizenship eligibility is calculated: the countdown began when the application was submitted, not when the permit was issued. This adjustment was aimed at compensating for processing delays under AIMA and acknowledging administrative lag.
New Social Investor Visa Portugal
Portuguese Prime Minister Luis Montenegro announced an Action Plan for Migration on June 3, 2024, which will transform Portugal’s immigration framework.
A notable change involves the Portugal Golden Visa introducing the New Residence Permit for Solidarity Investment, also known as the Social Golden Visa. This initiative aims to channel private capital into social investment for immigrant integration projects.
This includes investments in reception infrastructure, integration projects, and support for vulnerable immigrants.
The Government views this residence-by-investment program as a tool for the Migration Plan and the “Build Portugal” Plan, suggesting a new Golden Visa option through investment in affordable housing projects.
Portugal Digitalizes Golden Visa Applications
The Portuguese government has also announced that Golden Visa applications will now be digitalized. All documents are to be submitted digitally, including the issuance of the Portuguese individual tax number (NIF). The change will help reduce bureaucracy and create a faster Golden Visa application process.
Previous Changes to Portugal's Golden Visa
Golden Visa changes in 2023
The most significant reform to Portugal’s Golden Visa came in 2023, when the government passed the “Mais Habitação” housing bill. In October 2023, all real estate investment routes — which had long been the program’s cornerstone — were abolished.
This included residential and commercial property purchases, as well as rehabilitation projects. At the same time, the popular €1.5 million capital transfer option was also eliminated.
From that date, only alternative investment pathways remained: €500,000 in investment funds, €500,000 in scientific research, €250,000 in cultural or artistic projects, €500,000 in company incorporation or expansion with job creation, or the direct creation of ten jobs.
Importantly, applicants who had already filed under the old rules were protected by grandfathering provisions, allowing them to complete their applications and renewals under the previous framework.
Golden Visa changes in 2022
The 2022 reforms were an earlier step in tightening the program. On 1 January 2022, Portugal restricted where real estate investments could qualify.
Investors could no longer buy property in Lisbon, Porto, or most coastal areas; instead, eligible real estate investments were pushed toward interior regions and the Azores or Madeira.
At the same time, the minimum thresholds for certain options increased. The venture capital transfer route rose from €1 million to €1.5 million, and the minimum for investment funds increased from €350,000 to €500,000.
These measures were introduced to redirect foreign capital away from overheated urban property markets and toward more diversified and sustainable sectors of the economy. The following changes came into place on 1 January 2022:
- Investors cannot invest in residential property in popular urban areas such as Lisbon, Porto, and much of the Algarve, as well as coastal towns like Setúbal and the Silver Coast.
- Applicants can no longer get residential property in major cities such as Lisbon or Porto, or in coastal towns of the mainland. Now, you can only buy residential property in designated interior areas of Portugal worth at least €500,000 or €350,000 if investing in a rehabilitation project. If the residential property is located in a designated ‘low-density’ area, then a 20 percent discount applies.
- Investors can purchase commercial property anywhere in the country worth at least €500,000 or €350,000 if investing in a commercial rehabilitation project. If the commercial property is located in a designated ‘low-density’ area, then a 20 percent discount applies.
- Investors can buy residential and commercial property anywhere in Portugal’s autonomous islands of Madeira and Azores, worth at least €500,000 or €350,000 if investing in a rehabilitation project.
Capital transfers changes in 2022 included:
- The capital transfer amount requirement increased from €1 million to €1.5 million.
- The Investment fund’s minimum subscription requirement increased from €350,000 to €500,000.
- Investment in scientific research increased from €350,000 to €500,000
- Investment into an existing Portugal-registered business increased from €350,000 to €500,000
- An investment in the arts and cultural heritage worth €250,000 stayed the same.
Check out our Ultimate Guide on Portugal's Golden Visa Investment Fund
Implications of 2022's Changes to the Portugal Golden Visa
While some stakeholders vocalized opposition to the changes, they’re not necessarily seen as ‘good’ or ‘bad.’ Rather, Portugal’s Golden Visa changes were designed to drive investment in Portugal’s interior areas, relieving pressure from metropolitan locations and encouraging foreign investment into other areas of the country.
From 1 January 2022, investors could not buy residential properties in popular urban areas of the country like Lisbon, Porto, and much of the Algarve, as well as in coastal towns like Setúbal and the Silver Coast.
Only residential property investments in interior parts of the country qualify (there are no location restrictions on commercial real estate).
In the wake of the changes, alternative investment routes to Portuguese residency have become more popular, namely the investment fund option.
Impact of 2022’s Golden Visa changes on existing investments
If you were in the process of purchasing a property in a thriving urban area, you would not have been impacted by the Portugal Golden Visa updates. However, from 1 January 2022, if you had been interested in purchasing a property in Lisbon, Porto, or parts of the Algarve, you could not buy property and apply for the Golden Visa program.
Following the end of the real estate route, the Portugal investment fund Golden Visa is a very attractive investment route.
Portugal Golden Visa: A Brief History
Launched in 2012, the Portugal Golden Visa scheme is one of the most popular residency-by-investment schemes in Europe. The scheme allows investors and their families to obtain residency permits in exchange for a qualifying investment.
Since its launch, the Portugal Golden Visa has been a true success, with 11,384 investors and 18,617 family members benefiting from the Golden Visa program.
Portugal Golden Visa statistics show that, in terms of top residency-by-investment programs, Portugal is recognized as offering the best program in the world. There are multiple reasons for the program’s success. Portugal is one of the best European countries for expats due to its outstanding quality of life, excellent weather, and freedom.
While purchasing real estate properties is no longer eligible for the scheme, the Golden Visa program still offers several attractive investment routes suiting various investment goals. Some of the attractive Golden Visa investment routes that remain include investing in venture capital, research, or an existing business.
Golden Visa Delays Causing Applicants to Take AIMA to Court
As part of the Golden Visa process, applicants must attend an AIMA appointment to provide the required legal documents and for AIMA to collect their biometric data.
Once AIMA analyzes the Golden Visa application and receives the go-ahead, the agency indicates the dates available to schedule the appointment.
This process should take about three months, but because of the agency’s slow pace of processing residency and immigration paperwork, thousands of complaints have been filed against AIMA. As many as 50 complaints per day have made their way through the legal system, and recent estimates peg the total number of complaints to around 8,000.
A large percentage of the legal actions are aimed at compelling AIMA to provide definitive decisions on individual Golden Visa applications.
These legal measures have been successful in many cases, benefiting not only applicants awaiting final decisions but also those still seeking pre-approval.
It’s important to note that while courts cannot directly decide on Portugal Golden Visa applications, they can require AIMA to issue decisions within specified deadlines. If AIMA fails to comply, its directors could be held accountable, as higher courts have already ruled.
These lawsuits are proving to be an effective tool for addressing the ongoing delays as legal action has often accelerated timelines by pressuring AIMA to prioritize responses.
However, even with legal intervention, further bottlenecks could arise during subsequent stages, such as biometric data collection. The hope is that at that point, a more streamlined system will be in place, although the potential need for additional legal measures cannot be entirely ruled out.
Portugal’s Golden Visa: What to Expect in the Future
The Portugal Golden Visa program continues to evolve. While real estate investments were removed in 2023, the program remains a vital way for Portugal to attract foreign investment and channel international capital into areas such as venture capital fund investment, private equity funds, and research activities.
Going forward, foreign investors can expect stricter oversight by Portuguese authorities, particularly when working with a Portuguese financial institution or when choosing qualifying funds.
For existing Golden Visa holders, the government has confirmed that their Golden Visa residency status and renewals remain protected. This means that current Golden Visa holders and their dependent children can continue family reunification and maintain their Golden Visa residence cards.
Successful renewals will, however, depend on compliance with Portuguese regulations, including proof of a Portuguese bank account, settlement of any outstanding tax payments, and, in some cases, proof of private health insurance.
For new applicants, the focus has shifted to more sustainable investment routes. Options include contributing €500,000 to an existing Portuguese business that creates at least five permanent jobs, or investing in a commercial company under Portuguese law.
Another popular route is fund investment through qualifying funds managed by a Portuguese bank or licensed management company, often structured as private equity funds. These routes are designed to support the Portuguese economy, from job creation to the protection of national cultural heritage.
Despite ongoing debates in the Portuguese Parliament about migration policy and the role of foreign residents in the housing crisis, the Golden Visa program continues to be a core mechanism to attract international capital, support cultural heritage, and strengthen the Portuguese economy.
Portugal still offers a stable, rules-based framework for foreign investors to achieve legal residency, benefit from social security, health insurance, and Portuguese tax regimes such as IFICI, and, in time, obtain citizenship after permanent residency.
Why choose Global Citizen Solutions for your Immigration Visa?
GLOBAL APPROACH BY LOCAL EXPERTS
- GCS has offices located across Portugal.
- Members of the US-Portugal and UK-Portugal Chambers of Commerce in Portugal, and the Investment Migration Council (IMC).
- Our expert team can help you throughout your journey to secure your Visa.
100% APPROVAL RATE
- Our successful track record in applications provides reassurance to applicants.
- We have helped clients from more than 35 countries secure residency in Portugal.
ALL-ENCOMPASSING SOLUTION
- With a single channel of communication, our approach ensures that you have complete clarity on your application.
- Our BeGlobal® Onboarding System allows for a total flow of information.
TRANSPARENCY AND PRIVACY
- Our pricing is clear and detailed, you will not face any hidden costs.
- All data is stored within a GDPR-compliant database on a secure SSL-encrypted server.
Frequently Asked Questions About Portugal Golden Visa
What are the recent changes to the Portugal Golden Visa program?
The most recent changes came in October 2023, when Portugal removed all real estate investment routes and the €1.5 million capital transfer option. From then on, only funds, research, cultural donations, and job-creation investments qualify. In 2024–2025, no further investment categories were added or removed, though stricter filing rules and digital procedures were introduced under AIMA.
How do the 2025 Portugal Golden Visa changes affect investors?
In 2025, the Golden Visa investment categories stayed the same. However, AIMA now strictly enforces a “complete-file” requirement, rejecting any application missing documents. Broader immigration reforms did not alter the Golden Visa, but they reinforced AIMA’s central role, meaning applicants should expect tighter compliance checks and continued processing delays.
Is real estate still eligible for the Portugal Golden Visa?
No. Since 7 October 2023, real estate is no longer eligible for the Portugal Golden Visa. This includes residential, commercial, and rehabilitation property investments.
Can existing property owners keep their Portugal Golden Visa under the new rules?
Yes. Grandfathering rules protect applicants who invested in real estate before 7 October 2023. They can keep and renew their Golden Visa, and their family members can also apply under the same framework.
What is the minimum investment required after the Portugal Golden Visa changes?
The lowest qualifying threshold is €250,000 for cultural or artistic contributions (or €200,000 if it is in a low-density area). Most other routes, such as funds and scientific research, require €500,000.
How do the Portugal Golden Visa changes impact real estate investors?
New investors can no longer qualify with real estate purchases. However, those who invested before the rule change can continue under transitional rules, including renewals. This means real estate is effectively closed to newcomers but protected for existing applicants.
Are there alternative investment routes to replace real estate in the Portugal Golden Visa program?
Yes. Investors can now opt for fund investments, scientific research, cultural contributions, or company/job-creation projects. These routes were designed to redirect foreign capital away from housing markets and toward innovation, culture, and employment.
Do the Portugal Golden Visa changes apply to both new and existing applications?
The new rules apply only to new applications filed after 7 October 2023. Existing applications submitted under the old framework are safeguarded and continue to be processed under the rules in effect at the time of submission.
How do the new Golden Visa rules affect renewals in Portugal?
Renewals are unaffected for existing investors. Those who applied under real estate or capital transfer routes before the 2023 reform can continue renewing their Golden Visa permits, and their family members remain eligible for reunification.
What are the benefits of the Portugal Golden Visa after the real estate option was removed?
Despite the changes, the Golden Visa still offers residency in Portugal, visa-free travel across the Schengen Zone, family inclusion, access to healthcare and education, and the right to apply for Portuguese citizenship after five years. The removal of real estate narrowed the investment options but did not diminish the program’s core benefits.
