Spain’s Property Golden Visa Is Over: Real‑Estate Strategy Shifts for 2026

At a glance

The end of Spain’s property-based Golden Visa closes one of the EU’s most popular real-estate migration channels. With Greece restructuring thresholds, Portugal redirecting to fund-based routes, and Malta raising costs, property-anchored strategies face a structural reset. Investors and advisors must shift toward non-property instruments to secure EU residence — or consider cost-effective alternatives outside the bloc.

Spain Ends Its Property Golden Visa (Effective 3 April 2025)

Spain terminated all investor-residence routes under Law 14/2013 through Organic Law 1/2025, published in the Official State Gazette (BOE) on 3 January 2025 and effective from 3 April 2025. The EUR 500,000 property purchase pathway — along with shares, bonds, and bank deposit routes — is no longer available for new applicants.

Over the 2014–2023 period, Spain issued 22,430 Golden Visas according to the Ministry of Inclusion, Social Security and Migration, underscoring the programme’s scale before the closure. The property route drew sustained demand concentrated in high-demand urban markets, with significant participation from non-EU investors.

Transitional provisions

Applications submitted before 3 April 2025 are processed under the original rules. Existing Golden Visa holders retain their right to renew — the repeal is not retroactive. The three-month transition window from publication to effective date gave investors time to finalize pending applications.

Post-repeal, Spain still offers non-investor residence routes: the entrepreneur/startup visa for innovative business projects and the digital nomad visa for non-EU remote workers.

EU Tightening: Greece, Portugal, Malta and Beyond

Across the EU, investor-residence pathways are shifting away from passive property purchases toward instruments with clearer economic impact — private equity and venture funds, business creation, and job support — while minimum investments and fees continue to rise.

Greece — zone-based thresholds replace flat minimum

Greece initially raised its Golden Visa minimum from EUR 250,000 to EUR 500,000 in select municipalities in August 2023. Subsequent reforms in 2024 and 2026 introduced a zone-based system under Law 5038/2023 (as amended by Law 5100/2024):

• Tier 1 (Attica, Thessaloniki, Mykonos, Santorini, and islands with more than 3,100 residents): EUR 800,000 minimum, single property, at least 120 square metres.
• Tier 2 (rest of Greece): EUR 400,000 minimum, single property, at least 120 square metres.
• Niche category: EUR 250,000 for commercial-to-residential conversions and listed building restorations (exempt from the 120 square metre requirement).

Portugal — fund and job-creation routes replace real estate

Law 56/2023 (“Mais Habitação”) removed direct real-estate eligibility from Portugal’s Golden Visa effective 7 October 2023. The remaining investment routes include:

• Venture capital / private equity fund subscription: EUR 500,000 (CMVM-regulated, 5+ year maturity, 60% Portugal allocation, no real-estate exposure)
• R&D institution investment: EUR 500,000
• Cultural and arts heritage: EUR 250,000 (EUR 200,000 in low-density areas)
• Business creation: job-sustainment threshold raised to 10 full-time positions (8 in low-density areas)

Portugal also extended its citizenship pathway from 5 to 10 years for most Golden Visa holders — affecting the timeline to naturalisation but not residency rights or investment requirements.

Malta — higher costs and CBI struck down

Effective January 2025, Malta’s Permanent Residence Programme (MPRP) requires:

• Property purchase minimum: EUR 375,000 (5-year holding period)
• Government fees (purchase route): EUR 80,000 total (EUR 50,000 administrative + EUR 30,000 government contribution)
• Government fees (rental route): EUR 110,000 total
• NGO donation: EUR 2,000
• Asset requirement: EUR 500,000 total, of which EUR 150,000 must be financial

Separately, the EU Court of Justice struck down Malta’s citizenship-by-investment (CBI) scheme in April 2025, finding that the commercialisation of EU citizenship breached treaty obligations. Malta’s residency programme remains available.

Hungary, Cyprus and other active programmes

Beyond the four main markets, other EU investor-residence programmes remain active in 2026:

• Hungary (Guest Investor Programme): EUR 250,000 invested in a government-accredited real-estate investment fund (registered with the Hungarian National Bank) or a EUR 1,000,000 non-refundable donation to a public trust. Direct property purchase was removed in January 2025. The permit is renewable for 10 years.
• Cyprus: EUR 300,000 in new residential property, commercial real estate, Cypriot company shares, or licensed investment funds, plus EUR 50,000 in annual income from abroad. Grants permanent residency.
• Italy (Investor Visa): EUR 250,000 for innovative startups, EUR 500,000 for Italian company shares, EUR 1,000,000 for philanthropic purposes, or EUR 2,000,000 for government bonds.

EU investor-route snapshot (2025–2026)

Why Governments Moved: Housing Pressures and Weak Returns

Spain framed the termination within its housing policy agenda, signalling a priority to protect affordability amid sustained price increases in cities such as Madrid, Barcelona, and Málaga. Similar concerns drove reforms in Greece, Portugal, and Malta, where policymakers concluded that property-led investor residence inflated local markets without contributing meaningfully to long-term productivity or housing supply.

Macroeconomic assessments support this view. Portugal’s Golden Visa programme generated approximately EUR 7.3 billion in gross investment, with its actual impact on national GDP estimated at around 0.4%. For Spain, some analyses suggest the figure may have been below 0.1% of GDP, although no official government or central bank report has confirmed a specific percentage. These modest returns, combined with housing affordability pressures, sharpened the shift toward performance-linked investment criteria across the bloc.

Immediate Market Impacts

The removal of Spain’s property route, combined with Greece’s sharply higher tiered thresholds, Portugal’s elimination of real estate, and Malta’s cost increases, compresses the EU pipeline for property-anchored investor residence. For investors and advisors, this means higher capital requirements, more complex documentation, longer due-diligence cycles, and a structural shift toward fund-based and job-creation instruments across remaining routes.

Action Checklist for Law Firms and Investors

• Pipeline triage: Identify clients whose EU plans depended on Spain’s property route and reassess viability under Greece’s tiered system (EUR 800,000 or EUR 400,000), Portugal’s fund routes (EUR 500,000), or Malta’s MPRP (EUR 375,000+).
• Pivot to non-property options: Prioritise regulated fund subscriptions, business creation, or job-support pathways that align with current legislative intent across the EU.
• Recalibrate developer partnerships: Reassess revenue-sharing tied to property-led migration and shift toward institutional product providers and job-creation vehicles.
• Revise client messaging: Set expectations for higher costs, longer timelines, and portfolio diversification across multiple jurisdictions.
• Diversify geography: Include non-EU alternatives for mobility, asset protection, and lifestyle objectives. Armenia offers pathways for residency, business formation, competitive tax planning, and real estate.

Practical Pivots for 2026 Planning

• Model higher capital budgets: EUR 800,000 for Greece Tier 1, EUR 500,000 for Portugal funds, EUR 375,000+ for Malta, or EUR 250,000 for Hungary’s fund route.
• Strengthen documentation workflows: Enhanced AML/KYC and source-of-funds packages are now standard across EU investor-residence applications.
• Broaden mobility planning: Combine EU routes with alternative residency bases. Armenia provides cost-effective residence permits, fast company formation, and a regional hub for clients managing cross-border interests.

Where Armenia Fits

While EU investor residence is tightening and costs are rising, Armenia remains a cost-effective option for establishing a regional base. Key advantages include:

• Flexible residence permits with a straightforward application process
• Residence-by-investment pathways for qualifying investors
• Fast business registration — typically 1–3 business days for most structures
• Competitive tax rates, including a flat 20% personal income tax for residents
• A clear path to citizenship through sustained residency
• Growing real-estate opportunities in a developing market

For clients priced out of EU property-led migration or seeking to diversify their residency portfolio, Armenia can anchor a resilient, non-property strategy alongside EU fund or business-creation options.

The Spain Golden Visa closure marks a structural turn in EU property-based migration. With thresholds rising, routes redirecting to fund and job-creation instruments, and fees increasing, investor-residence planning for 2026 requires a broader and more flexible approach — supplemented by cost-effective alternative bases such as Armenia.

For a tailored plan aligned with the new rules and your mobility goals, contact our team.

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