At a glance
- Spain fully terminated its golden visa effective 3 April 2025, though applications filed before that date may still be processed under transitional provisions.
- Greece now requires €800,000 in high-demand areas (Athens, Thessaloniki, Mykonos, Santorini) and €400,000 elsewhere — plus a new ban on short-term rentals for golden visa properties.
- Portugal’s remaining golden visa routes are fund and business-based (from €250,000), but processing averages nearly 40 months with over 20,000 applicants awaiting biometrics.
- Luxembourg’s investor residence repeal is before parliament as of March 2026 after only nine approvals since 2017.
- Six EU/Schengen countries still operate active golden visa programs: Italy, Malta, Hungary, Bulgaria, Cyprus, and Latvia.
- Armenia is emerging as a low-cost alternative with a new investor permanent residence pathway taking effect November 2026.
Europe’s golden visa landscape shifted decisively between 2024 and 2026. Spain shut its doors entirely. Greece doubled its thresholds. Portugal’s remaining routes face years-long backlogs. For mid-tier investors with budgets between €200,000 and €500,000, the options within the EU have narrowed sharply — but they have not disappeared. This guide maps every program still open in 2026, covers the non-EU alternatives gaining traction, and outlines a practical repositioning strategy.
What happened to Europe’s golden visas in 2024–2026
Housing affordability, political backlash, and EU-level pressure converged to reshape investor migration across Europe. Spain’s decision to end its golden visa was framed within a national push to prioritize housing access. Greece explicitly linked its threshold increase to combating housing shortages in Athens, Thessaloniki, and the islands. Portugal’s shift away from residential property followed similar concerns, while Luxembourg cited low program value and disproportionate administrative costs.
The numbers tell the story of scale. Spain issued nearly 250,000 residence permits to executives and investors over 2014–2023 before closing the channel entirely. Portugal’s golden visa waiting list exceeded 50,000 applicants by early 2025, with over 20,000 still awaiting biometrics in 2026. Luxembourg’s program, by contrast, approved only nine applications in eight years — but its repeal signals broader EU policy convergence away from passive-capital routes.
The Netherlands has also quietly discontinued its investor residence pathway. Romania proposed a €400,000 golden visa in November 2025 but cancelled it after security concerns were raised. The trend is clear: traditional property-based golden visas in Western Europe are being phased out or priced beyond mid-tier reach.
Spain: full termination and transitional rules
Spain terminated its investor residence permits effective 3 April 2025 under Organic Law 1/2025, published in the BOE on 3 January 2025. All property-based and capital investment routes for new applicants are now closed.
Transitional provisions apply in two situations. Applications filed before 3 April 2025 may still be examined and granted under the original rules. Existing permit holders can renew under the conditions that applied when their permits were first issued. However, no replacement investor route has been introduced, and there are no active proposals to reinstate one. Spain’s new visa options require 183 days of annual presence, making them unsuitable as a low-presence residency vehicle.
For investors who previously considered Spain, the closure means looking elsewhere — either to the remaining EU programs or to non-EU alternatives that offer comparable benefits at lower thresholds.
Greece: dual-tier thresholds and rental restrictions
Greece’s golden visa now operates on a dual-tier system introduced in January 2025. In high-demand areas — Athens, Thessaloniki, Mykonos, and Santorini — the minimum real-estate investment is €800,000. In the rest of Greece, the threshold is €400,000. A reduced €250,000 threshold is preserved only for commercial-to-residential conversions or historic building restoration projects. Non-property routes include €500,000 in government bonds or bank deposits, and €800,000 in equities.
A significant new restriction applies to rental use: golden visa properties in Greece cannot be listed for short-term rental on platforms like Airbnb, with violations carrying a €50,000 fine and potential permit revocation. This eliminates a common yield strategy for investor-buyers and changes the financial calculus substantially.
Greece’s backlog stood at approximately 42,390 pending applications as of November 2025. For mid-tier investors who previously targeted the €250,000–€500,000 bands in Athens or the islands, the new €800,000 threshold prices them out of prime locations entirely.
Portugal: fund routes survive, but backlogs persist
Portugal removed all residential real-estate routes from its golden visa program. Five qualifying categories remain: €500,000 in investment funds or venture capital, €500,000 in scientific research, €250,000 in cultural or artistic heritage projects, business incorporation creating 10 or more jobs (eight in low-density areas), and a company capital increase with job-creation requirements.
Processing times have become a serious concern. The average now stretches to approximately 39.6 months, with over 20,000 applicants still awaiting biometrics. AIMA launched a digital renewal portal in February 2026, but clearing the existing backlog will take time. In October 2025, the Portuguese parliament voted to extend the naturalization timeline to 10 years, though the measure was vetoed and revised discussions were ongoing as of April 2026.
Portugal remains attractive for its Schengen access, NHR tax regime benefits, and path to EU citizenship, but investors must factor in multi-year processing delays and the possibility of further legislative changes.
Luxembourg: repeal in progress
Luxembourg’s investor residence scheme is heading for formal repeal. Draft legislation was submitted in September 2025 and was before parliament as of March 2026. The program approved only nine applications since its 2017 launch, making it one of the least-utilized golden visa programs in Europe. While the repeal is small in absolute terms, it reinforces the broader EU trend away from passive-capital residence schemes and toward options perceived as delivering greater economic and social value.
EU golden visa programs still open in 2026
Despite the closures and restrictions, several EU and Schengen countries continue to operate investor residence programs. The table below summarizes the key parameters for each.
| Country | Minimum investment | Permit type | Key notes |
|---|---|---|---|
| Portugal | €250,000–€500,000 (funds, culture, business) | Temporary → PR → citizenship | No property route. ~40-month processing. Schengen access. |
| Greece | €400,000–€800,000 (location-dependent) | 5-year renewable | No Airbnb rentals. 42,000+ backlog. Schengen access. |
| Italy | €250,000 (startup) to €2,000,000 (bonds) | 2-year investor visa, renewable | Flat tax for new residents increased to €300,000/yr (Jan 2026). €50,000/dependent. |
| Malta (MPRP) | €98,000+ fees + property (buy €375,000+ or rent €14,000+/yr) | Permanent residence | CBI closed April 2025 per CJEU ruling. MPRP still active. Schengen access. |
| Hungary | €250,000 (fund investment) | 10-year permit | Zero physical presence requirement. Schengen access. |
| Bulgaria | ~€512,000 (AIFs/ETFs) | Immediate permanent residence | Joined Schengen Jan 2025, adopted euro Jan 2026. Growing appeal. |
| Cyprus | €300,000 (real estate or funds) | Permanent residence | €50,000 annual foreign income required. Targeting Schengen late 2026. |
| Latvia | €50,000 (company investment, <50 employees) | 5-year renewable | Zero stay requirement. Schengen access. Lowest EU entry point. |
Hungary and Latvia stand out for mid-tier investors. Hungary’s €250,000 fund route requires zero physical presence and offers a 10-year permit with Schengen travel. Latvia offers the lowest entry point in the EU at €50,000 for a small company investment, though the route requires genuine business activity. Bulgaria’s recent Schengen and eurozone accession has increased its attractiveness, though its threshold sits above €500,000.
Italy remains an option for startup investors at €250,000, though its new €300,000 annual flat tax for new residents (up from €100,000, effective January 2026) changes the tax planning equation for high-income individuals. Malta’s MPRP offers permanent residence but requires both government fees and a property commitment totaling well over €400,000 in practice.
EU Commission regulatory position
The European Commission’s March 2022 Recommendation remains the operative benchmark, urging member states to repeal citizenship-by-investment schemes and strengthen due diligence for residence-by-investment programs. The European Parliament’s March 2022 resolution went further, calling for a CBI ban and phase-out by 2025 along with an EU-level RBI framework with minimum standards.
Enforcement has been selective but consequential. The CJEU ruled against Malta’s investor citizenship program in April 2025, finding it violated EU law — which led to Malta closing its CBI scheme. However, no EU-wide directive or regulation specifically targeting residence-by-investment programs has been enacted as of April 2026. Individual member states retain discretion over their RBI schemes.
The regulatory trajectory is clear even without binding legislation. Programs that survive are likely to face increasing due diligence requirements and political scrutiny. Investors should build robust source-of-funds documentation and anticipate longer processing timelines across all EU jurisdictions.
One upcoming change that affects all golden visa holders: the European Travel Information and Authorisation System (ETIAS) is expected to launch in late 2026 with mandatory use from October 2027. ETIAS may create complications for holders of Caribbean CBI passports who currently enjoy visa-free Schengen access, as the system introduces an additional screening layer.
Non-EU alternatives for mid-tier investors
As European options narrow, non-EU programs are absorbing redirected demand. The following table covers the most relevant alternatives for investors with budgets between €200,000 and €500,000 (approximately $200,000–$500,000 USD).
| Country | Minimum investment | Processing | Outcome |
|---|---|---|---|
| Turkey | $400,000 real estate (3-year hold) | 4–6 months | Direct citizenship and passport |
| UAE Golden Visa | AED 2,000,000 (~€500,000) property | 1–3 months | 10-year renewable residence. No citizenship track. Low-tax environment. |
| St. Kitts & Nevis | ~$250,000 donation | 3–6 months | Direct citizenship. Visa-free to 150+ countries. ETIAS may affect Schengen access. |
| Dominica | $200,000 donation | 3–4 months | Lowest Caribbean CBI. Direct citizenship. |
| Grenada | ~$235,000 donation | 4–6 months | Direct citizenship. US E-2 treaty access — unique among Caribbean CBI. |
| Antigua & Barbuda | ~$230,000 donation | 4–6 months | Direct citizenship. 5-day presence in 5 years. |
| Armenia | Low thresholds (business-based) | 2–4 weeks | Immediate PR from Nov 2026. No minimum stay. Citizenship after 3 years. |
Turkey’s CBI stands out for speed and direct citizenship, though the $400,000 real-estate requirement and three-year hold period must be factored into liquidity planning. The Caribbean programs offer the fastest route to a second passport, with Dominica at the lowest price point ($200,000), though all Caribbean CBI holders should monitor the ETIAS rollout and its potential impact on Schengen visa-free travel.
Grenada’s program has a unique advantage: its US E-2 treaty allows Grenadian citizens to apply for a US investor visa, creating an indirect US market entry pathway that no other Caribbean CBI program offers.
Armenia: an emerging low-cost alternative
Armenia is increasingly relevant for investors who have been priced out of European golden visas. The country already offers a business-based temporary residence permit at very low thresholds compared to European programs — often accessible for a few thousand dollars through company formation and business activity. Processing is fast, typically two to four weeks, and the country imposes no minimum physical presence requirement for residence permit holders.
A new investor permanent residence pathway is scheduled to take effect on 1 November 2026 as part of a broader immigration law overhaul. Under the new framework, qualifying investors will receive immediate five-year permanent residence — skipping the temporary permit stage entirely. No minimum stay is required, and the path to Armenian citizenship opens after three years of permanent residence (with no absence exceeding six months per year).
The specific investment thresholds for the new November 2026 program have not yet been published by the Armenian government. Qualifying categories are expected to include real estate, business capital, and securities, though implementing regulations are still being finalized. The existing business-based route remains available in the meantime.
The November 2026 overhaul also abolishes the 10-year special residency category, introduces a digital-first quota model, and creates a formal work visa category. These changes signal Armenia’s shift toward a more structured and investor-friendly immigration framework.
Armenia does not offer EU or Schengen mobility, which limits its appeal for investors whose primary goal is European travel access. However, its combination of low cost, fast processing, zero presence requirements, and a clear path to citizenship makes it structurally one of the most generous residency programs available globally. For investors who prioritize a second passport, favorable tax environment, and a base for business operations, Armenia warrants serious consideration. Our firm handles the full process from residence by investment through to citizenship applications.
How to reposition your investment migration strategy
The days of straightforward property-to-passport routes in Western Europe are effectively over for most mid-tier investors. Repositioning requires a shift in thinking — from single-country applications to portfolio-based strategies that manage regulatory risk across multiple jurisdictions.
Diversify across jurisdictions and asset types
Concentration risk is the primary danger in today’s environment. An investor with all capital committed to a single EU program faces total pipeline loss if rules change mid-process. Consider splitting investment across a Schengen-access jurisdiction (Portugal funds, Hungary, or Latvia) and a fast-track non-EU option (Armenia, Caribbean CBI, or Turkey) to create redundancy.
Shift from property to productive investment
The surviving EU programs increasingly favor fund investments, business formation, and job creation over passive real-estate ownership. Portugal’s fund route, Hungary’s fund requirement, and Latvia’s company investment route all reflect this shift. Investors should work with qualified counsel to evaluate fund structures and business plans that satisfy both immigration and financial objectives.
Stress-test budgets and timelines
Model three scenarios — best case, base case, and worst case — for every application. Factor in processing delays (Portugal’s 40-month average), potential threshold increases (Greece’s trajectory), and holding period requirements (Turkey’s 3-year property hold). Ensure liquidity reserves cover at least 18 months of additional delay beyond advertised timelines.
Harden due diligence early
EU-level pressure on golden visa programs means stronger KYC, AML, and source-of-funds requirements across the board. Pre-clearing documentation before filing reduces rejection risk and speeds processing. Maintain audit-ready files covering at least five years of income history, tax filings, and asset provenance.
Build a contingency pathway
Every primary application should have a backup jurisdiction identified in advance. If Portugal’s backlog extends further, or if Hungary’s program faces political pressure, having Armenia or a Caribbean option pre-vetted saves months of restart time. Our firm assists with multi-jurisdiction strategy through our residence permit, citizenship, and real estate practice areas.
| Priority | Why it matters | Risk mitigated |
|---|---|---|
| Portfolio diversification | EU routes are shrinking. Spread capital across 2–3 jurisdictions. | Concentration risk |
| Budget stress-testing | Higher thresholds and multi-year delays amplify cost exposure. | Affordability risk |
| Enhanced due diligence | EU pressure means stricter KYC and source-of-funds requirements. | Rejection or delay risk |
| Contingency pathways | Pre-vet a backup jurisdiction to avoid restart delays. | Pipeline interruption risk |
| Tax integration | New flat-tax changes (Italy €300k) affect post-residence planning. | Unexpected tax liability |
EU golden visa program tightening has made predictability scarce. Mid-tier investors need substance-oriented pathways, multi-jurisdiction contingency planning, and robust documentation. Those who diversify early, stress-test their budgets, and maintain contingency options will be best positioned for whatever regulatory changes 2026 and 2027 bring. To discuss a tailored strategy, contact our team.
