Portugal Golden Visa after Law 56/2023: compliance reset

Portugal Golden Visa changes under Law 56/2023 removed real estate and capital transfer routes permanently. Five non-property investment pathways remain open, but processing backlogs, Spain’s parallel closure, and shifting EU policy mean investors and advisors must reset compliance strategies for 2026.

What Law 56/2023 changed

Law 56/2023, part of Portugal’s “Mais Habitação” (More Housing) legislative package, entered into force on 7 October 2023. The law was designed to redirect foreign capital away from residential property and toward social housing objectives. For immigration practitioners and investors, the impact is structural: the rules governing Portugal’s ARI (Autorização de Residência para Atividade de Investimento) program changed permanently.

The reform eliminated every real-estate-based investment route — residential, commercial, and touristic property purchases, as well as real-estate-related investment funds. It also removed passive capital transfers, including bank deposits at the former €1 million and €1.5 million thresholds. These were historically the most popular pathways: the majority of Portugal’s Golden Visa approvals from 2012 onward were tied to property transactions.

The law is not retroactive. Applications submitted before 7 October 2023 continue to be processed under the prior rules, and existing permit holders retain their rights through normal renewal cycles.

Five qualifying investment routes that remain

Despite the headline closures, Portugal’s Golden Visa program remains legally active. AIMA (the successor to SEF) lists five qualifying categories for new applications:

Current qualifying Golden Visa investment routes

Route	Minimum investment	Key requirements
Non-real-estate collective investment undertakings	€500,000	CMVM-regulated fund, 60%+ invested in Portuguese companies, no real estate exposure, 5-year maturity minimum
Scientific research contribution	€500,000	Directed to approved public or private research institutions
Cultural and artistic heritage	€250,000 (€200,000 in low-density areas)	Supporting national heritage preservation or arts production; 20% reduction available across multiple low-density categories
Company creation or capital injection	€500,000 + creation of 5 jobs	Establishing or reinforcing a Portuguese company with job creation
Standalone job creation	No capital minimum	Creation of at least 10 permanent jobs in Portugal

The official legal description for the fund-based route uses the term “non-real-estate collective investment undertakings” rather than “venture capital” or “private equity” — an important distinction for compliance documentation and marketing materials.

Program scale: historical data and 2024 figures

Between 2012 and 2022, Portugal issued approximately 11,628 main-applicant Golden Visas, with the vast majority tied to real estate purchases. The program attracted cumulative investment of approximately €7.3 billion through late 2023, according to the last published official figures from the former SEF (Serviço de Estrangeiros e Fronteiras). No official update to that cumulative figure has been published since.

In 2024, the first full year under the reformed rules, Portugal issued 2,081 main-applicant Golden Visas — a 28% decline from the 2,901 issued in 2023. Including family reunification permits, total beneficiaries in 2024 reached approximately 5,000. Cumulative main applicants since the program’s inception now stand in the range of 13,000 to 16,000, with total beneficiaries (including dependents) estimated at 33,000 to 37,000.

What happened to the Solidarity Visa

When Law 56/2023 was announced, Portuguese authorities signaled an intention to create a housing-focused investment channel — commonly referred to as the “Solidarity Visa” — that would direct foreign capital toward affordable housing and migrant accommodations. The concept appeared in Portugal’s Plano de Ação para as Migrações (Migration Action Plan) published in July 2024.

As of April 2026, the Solidarity Visa remains a policy proposal. No formal legislation has been enacted, AIMA’s qualifying criteria do not include it, and there is no application procedure available. Advisors should not market this channel as an active option. If and when legislation materializes, it will require fresh compliance review before any client engagement.

Processing backlog and timeline reality

Processing times remain the most significant operational challenge for Portugal’s Golden Visa program. As of January 2025, approximately 50,000 ARI requests were pending with AIMA. Decision timelines vary widely and often extend well beyond initial expectations, with biometric appointment backlogs adding further delays.

In February 2026, AIMA launched a digital ARI Renewal Portal intended to accelerate processing for existing permit holders seeking renewals. While this signals institutional commitment to reducing the backlog, new applicants should prepare for variable timelines and plan documentation shelf-life, liquidity, and family logistics accordingly.

Existing holders: transitional rules and renewals

Law 56/2023 is explicitly non-retroactive. Existing Golden Visa holders whose permits predate the reform retain their rights and can continue to renew under normal conditions. Applications submitted before 7 October 2023 are processed under the rules that were in force at the time of filing.

Upon renewal, legacy permits are being re-labelled as “Immigrant Entrepreneur Residence Permits” — a change in administrative classification rather than a substantive change in rights. Holders should ensure their renewal documentation reflects the updated terminology and complies with current AIMA procedures.

Path to citizenship: current rules

Portuguese nationality law allows Golden Visa holders to apply for citizenship after five years of legal residence, subject to meeting language and connection requirements. In October 2025, Portugal’s Parliament approved an amendment extending this period from five to ten years. However, in December 2025, the Constitutional Court struck down certain provisions of that amendment.

As of early 2026, the five-year rule technically remains in force, but the legal landscape is unsettled. Investors planning a citizenship timeline should build in flexibility and monitor legislative developments closely. This is an area where professional legal advice — specific to the applicant’s permit type and timeline — is essential.

EU landscape: Spain’s closure and shifting alternatives

Portugal’s reform does not exist in isolation. Spain formally abolished its real-estate Golden Visa under Organic Law 1/2025, effective 3 April 2025, eliminating another major EU property-based residency route. The EU Parliament has also voted to constrain golden visa programs more broadly, signaling a restrictive policy direction across the bloc.

For a detailed analysis of how Spain’s closure reshapes EU investment migration strategy, see our companion briefing: After Spain’s Closure: Repositioning EU RBI Portfolios for 2026.

Alternative jurisdictions at a glance

Jurisdiction	Route	Minimum	Status (2026)
Greece	Real estate (tiered)	€800k high-demand areas; €400k other regions; €250k heritage/preservable buildings	Active
Hungary	Real-estate fund shares (guest-investor permit)	~€250,000	Active
Armenia	Residence permits, investment-based residency	Varies by route	Active

For investors considering diversified residency strategies, Armenia offers several pathways including temporary and permanent residence permits, residence by investment, and a streamlined path to citizenship. Cross-border tax implications should be reviewed early — see our guide on taxes in Armenia.

Compliance actions for law firms and intermediaries

The combined effect of Portugal’s reform and Spain’s closure creates an urgent compliance moment for any firm advising on EU investment migration. The following steps should be implemented immediately:

Stop marketing discontinued routes. Remove all web pages, brochures, pitch decks, and advertising that reference Portuguese real-estate or capital-transfer Golden Visa options. Do the same for Spain’s property-based route. Continued promotion of eliminated pathways creates regulatory and reputational risk.

Update engagement letters and scopes. Revise client-facing documents to reflect the post-Law 56/2023 framework. Include clear disclosures that new ARI applications under discontinued routes are barred, and specify which of the five remaining categories each engagement covers.

Reassess client pipelines. For clients who were pursuing property or deposit routes, conduct suitability reviews and present compliant alternatives. Document the reassessment process to demonstrate compliance with advisory obligations.

Coordinate with fund managers and introducers. Ensure that due diligence packs, term sheets, and marketing materials from third parties align with the current legal framework. Verify that any fund marketed for Golden Visa purposes meets CMVM regulation requirements and the no-real-estate-exposure criterion.

Refresh KYC/AML procedures. Update source-of-funds narratives and counterparty assessments to match the investment modalities now in play — primarily fund subscriptions and business investments rather than property transactions.

Train client-facing teams. Ensure marketing, sales, and advisory staff use accurate language about what routes remain available, and can redirect inquiries about discontinued options appropriately.

Implications for investors: what to expect

Market cooling. With the majority of historical Golden Visa approvals tied to property, removing real estate eligibility suppresses investor-driven demand in the Portuguese housing market. This aligns with the policy goal of easing housing pressures in major cities like Lisbon and Porto.

Redirected capital. The remaining routes channel investment toward regulated funds, business creation, scientific research, and cultural heritage — fundamentally different asset classes from residential property. Investors need to evaluate fund governance, management track records, and exit terms rather than property location and rental yield.

Timeline uncertainty. With a backlog of approximately 50,000 applications and an evolving digital infrastructure, processing times remain unpredictable. Investors should plan for extended timelines, maintain document currency, and build liquidity buffers for the commitment period.

Minimum stay requirements. Golden Visa holders must spend a minimum of seven days in Portugal during the first year and fourteen days in each subsequent two-year renewal period. This remains one of the lowest physical-presence requirements among EU residency programs.

Family inclusion. Dependents — including spouses, minor children, and dependent parents — can be included in a Golden Visa application. Family reunification permits accounted for a significant portion of total beneficiaries in 2024.

To discuss how these changes affect your specific situation, or to explore alternative residency strategies including visa planning and digital nomad options, contact our team for a confidential assessment.

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