- Spain has abolished its Golden Visa for new applicants; the halt takes effect three months after Organic Law 1/2025 was published on January 3, 2025 (effective April 3, 2025)
- Greece raised real estate investment thresholds to €800,000 in key regions and €400,000 elsewhere from September 1, 2024
- Portugal's October 7, 2023 reform ended the real estate and capital-transfer routes for new Golden Visa filings; pending cases remain valid but will convert to the new entrepreneur permit regime
- Immediate compliance priority: stop marketing closed/altered routes, correct thresholds and eligibility, and document every update to reduce legal exposure.
- Advisers should clarify transitional windows (Spain's April 3, 2025 effective date; Greece's legacy deadlines; Portugal's October 7, 2023 cutoff) with precise client messaging
Golden Visa programs across Europe are moving fast—and compliance risk is rising just as quickly. With Spain's halt to new Golden Visa applications, Greece's higher thresholds, and Portugal's removal of real estate and capital transfer routes, any outdated guidance can mislead clients and trigger reputational or legal issues. This briefing explains the program changes, key deadlines, and what legal advisory teams must do now to stay compliant.
Table of Contents
- Snapshot of recent Golden Visa reforms: Spain abolished; Greece raised thresholds; Portugal reformed
- Immediate compliance duties for law firms and advisers — stop, correct, and document marketing changes
- Transitional windows and critical deadlines clients must know (Spain effective date; Greece and Portugal cutoffs)
- Audit checklist: update websites
Snapshot of Recent Golden Visa Reforms: Spain Abolished
Spain has formally ended its Golden Visa route for new applicants. Organic Law 1/2025 was published on January 3, 2025, with the halt to new investment-residency filings taking effect three months later—April 3, 2025 Over its 12-year lifespan, Spain issued 14,576 Golden Visas, underlining the scale of client interest and the magnitude of the change
What this means for EU residency and legal advisory work:
- After April 3, 2025, marketing Spain's investment-residency to new applicants is inaccurate and risks misleading clients
- Prospective investors should be redirected to compliant alternatives and routes fitting their objectives. For example, consider standard visa and residency pathways in appropriate jurisdictions, or structured investment options elsewhere.
Greece Raised Thresholds
Greece's Golden Visa now requires higher real estate investments: as of September 1, 2024, the minimum is €800,000 in key regions and €400,000 elsewhere (replacing widely cited €250,000 routes) Any client-facing material still listing €250,000 is outdated and risks both client confusion and compliance exposure.
Portugal Reformed
Portugal's "Mais Habitação" reform of October 7, 2023, eliminated the classic routes for new Golden Visa applications via direct real estate purchases (≥€500,000) and capital transfers (≥€1.5 million) Applications submitted by October 7, 2023, remain valid, but successful cases convert to the updated entrepreneur permit regime rather than the legacy Golden Visa category
Practical implications for EU residency advice:
- Promotions of Portugal's property or capital-transfer Golden Visa routes for new applicants are now inaccurate
- Client expectations should be reset toward eligible categories (e.g., entrepreneurial/innovation-driven routes).
Quick Status Comparison
| Country | Status for New Golden Visa Filings | Key Threshold or Rule | Effective Date | Source |
|---|---|---|---|---|
| Spain | Closed to new applicants | Program abolished for new filings | April 3, 2025 | KPMG |
| Greece | Open, increased thresholds | €800,000 key regions; €400,000 elsewhere | September 1, 2024 | Varnavas |
| Portugal | Open, but legacy routes ended | No real estate or capital transfer route for new filings | October 7, 2023 | Valadas & Coriel |
Immediate Compliance Duties for Law Firms and Advisers — Stop
Stop all marketing or advice that implies availability of the following:
- Spain's Golden Visa route for new applicants after April 3, 2025
- Portugal's Golden Visa via direct real estate purchases or capital transfers for new filings post–October 7, 2023
- Greece's €250,000 property route or any outdated threshold representations after September 1, 2024
Correct
Correct all channels with precise, source-backed statements:
- Spain: Clearly note the program's halt for new applications from April 3, 2025 and remove calls-to-action that invite new filings
- Greece: Update minimum investment thresholds to €800,000/€400,000 as applicable, and specify the applicable regions where relevant
- Portugal: Remove references to real estate and capital transfer routes for new filings; if applicable, explain how pre–October 7, 2023 applications transition to the new entrepreneur permit category
At the same time, steer clients to compliant alternatives that still meet their goals (for example, standard visas, residency permits, or cross-border investment options). Where clients are exploring non-EU pathways, ensure downstream considerations like tax and real estate implications are addressed.
And Document Marketing Changes
Document your updates to reduce regulatory and reputational risk:
- Maintain a change log noting the date, channel (website, brochure, ad), and the exact wording added/removed.
- Archive pre-change screenshots and files to evidence good-faith remediation.
- Add versioning and "last reviewed" dates to high-traffic pages.
- Roll out internal approvals for client alerts and sales decks, with named sign-offs.
Transitional Windows and Critical Deadlines Clients Must Know (Spain Effective Date; Greece and Portugal Cutoffs)
Transitional rules are a flashpoint for client confusion. Counsel must state what still qualifies—and what no longer does—with dates and sources.
| Jurisdiction | Cutoff / Effective Date | Who is Still Eligible Under Transitional Terms? |
|---|---|---|
| Spain | April 3, 2025 | New Golden Visa applications are halted from this date. Ensure any in-flight filings are assessed for admissibility before the halt takes effect. |
| Greece | Legacy window detailed for earlier applicants | Investors who signed contracts and paid ≥10% by July 31, 2023 on €250k properties could complete investments by April 30, 2024 under prior terms. Beyond that, new higher thresholds apply |
| Portugal | October 7, 2023 | Applications filed by the cutoff remain valid; approvals convert to the reformed entrepreneur-permit regime rather than the legacy GV category. |
Action for client-service teams:
- Proactively email or call all clients with pending/expected filings touching these cutoffs.
- Update retainer letters or scopes where program changes materially affect advice.
- Publish a dated client alert summarizing each country's current status with links to primary sources.
Audit Checklist: Update Websites
Use this quick checklist to align your public-facing content with current Golden Visa rules and minimize compliance risks.
- Homepage and high-traffic pages: remove or rewrite any references to Spain's Golden Visa for new applicants post–April 3, 2025
- Country landing pages:
- Greece: update thresholds to €800,000/€400,000 and specify regional applicability
- Portugal: remove real estate/capital transfer routes; explain new eligible categories and transitional handling for pre–Oct 7, 2023 filings
- Forms and CTAs: eliminate "Apply now" prompts for discontinued routes; add screening questions about filing dates and contract status.
- Sales decks and brochures: refresh numbers, maps, and timelines; append a "last reviewed" date and source list.
- Training: brief intake and marketing teams; include a short Q&A on Spain, Greece, and Portugal changes.
How to Implement a Real-time Update Protocol
- Assign owners: designate a compliance lead and a content owner for each jurisdiction.
- Source monitoring: subscribe to official gazettes and reputable analyses (e.g.,,).
- Update sprints: when a change lands, push a 24–72 hour content sprint to correct web, print, and sales materials.
- Legal review: require sign-off from a partner before republishing updated materials.
- Client comms: issue a branded alert with dated citations and an internal FAQ for your front-line team.
When EU residency routes tighten, clients often explore other structures—second residency, alternative visas, or regional investments. If Armenia aligns with their objectives, we can advise on business registration, residency permits, and long-term citizenship planning.
Conclusion: Golden Visa program changes in Spain, Greece, and Portugal significantly raise compliance risks for legal advisory teams. To protect clients and your firm, stop outdated promotions, correct all thresholds and eligibility rules, document updates, and communicate transitional windows clearly. For tailored guidance on compliant EU residency strategies—or alternative investment-led mobility options—contact our team today.