Na de sluiting van Spanje: Herpositionering van de portefeuilles van EU-reservebankinitiatieven voor 2026

Spain abolishes the Golden Visa

Spain formally abolished its investor residency permit under Organic Law 1/2025, effective 3 April 2025. The Twenty-First Final Provision of the law deletes Articles 63–67 of Law 14/2013, removing the entire investor residence category. No new property-based or capital-based applications have been accepted since that date.

Applications submitted before the cutoff are being processed under the old rules, and existing permit holders can still renew. A constitutional challenge has been filed but no suspension or reversal has been ordered by mid-2026.

Over its 12-year lifespan, Spain’s Golden Visa issued roughly 16,000 permits — about 0.3% of national real-estate transactions. The market impact of the closure has been modest and localized. Applicants who previously targeted Spain now have several remaining routes in the country, including the Digital Nomad Visa, the Non-Lucrative Visa, and the Entrepreneur Visa, though none replicate the investment-for-residency model.

Greece Golden Visa: tiered thresholds for 2026

Greece’s Golden Visa no longer operates on a single flat threshold. Since Law 5100/2024 introduced a tiered system, the minimum investment depends on both the property location and type.

Investment tiers (real estate)

Properties purchased under the €400,000 and €800,000 tiers cannot be used for short-term rentals such as Airbnb. Violations carry a €50,000 fine and potential permit revocation. Long-term leases of six months or longer and personal use are permitted.

Non-real-estate routes

Greece also offers qualifying investment routes that do not involve direct property purchase: approximately €350,000 in qualifying mutual funds, €500,000 in a Greek bank fixed-term deposit (12-month rolling), or €500,000 as a capital contribution to a Greek company with at least five employees. A newer €250,000 startup route through the Elevate Greece registry was introduced under Law 5162/2024, targeting real estate-tech, finance, and defense tech ventures.

Key program details

There is no minimum stay requirement — the investment must simply be maintained. Permit holders receive 90/180-day Schengen visa-free travel but no work rights in other EU states. Family members covered include a spouse or registered civil partner, children up to 21 (or up to 24 if financially dependent full-time students), and parents of both the investor and their spouse, with no age limit or financial dependency requirement for parents.

Realistic processing time is three to nine months. Over the past 12 months, Greece has issued approximately 3,500 new permits. The application backlog stands at around 42,390 but is declining at roughly 3–4% per month. Law 5275/2026 changed the permit validity start date to the card issuance date rather than the investment date. The path to citizenship requires seven years of legal residence plus a B1-level Greek language and integration exam.

Portugal: funds-only route with new citizenship timeline

Portugal eliminated all real-estate purchase routes in October 2023 under the Mais Habitação legislation. The dominant qualifying pathway is now a €500,000 investment in a private equity or venture capital fund with a minimum five-year maturity and at least 60% allocated to Portuguese companies, with zero real-estate exposure.

Alternative routes include €500,000 in a company incorporation plus at least five permanent jobs (maintained for three or more years), creation of a minimum of 10 jobs with no capital minimum, €500,000 into public or private scientific research institutions, and €250,000 (or €200,000 in low-density areas) as a cultural or heritage donation.

Processing backlog and timelines

The application backlog has grown to more than 55,000 combined, with over 20,000 stalled at the biometrics stage. While the legal processing requirement is 90 days, actual average processing time is approximately 34 months based on a 2026 study of 127 applications. The government’s previous target to clear the backlog by 2025 was missed, and the realistic planning horizon for a new application is two to three years to approval, with six to seven years to citizenship.

The minimum stay requirement is seven days per year (14 days per two-year renewal period). Family members eligible include a spouse or partner, minor children, adult dependent children in full-time education, and dependent parents aged 65 or older. Portugal’s Golden Visa program is not being cancelled — the post-2023 framework remains stable with no enacted abolition plan.

Other EU programs — Hungary, Malta, and Italy

Beyond Greece and Portugal, three other EU member states now offer viable residency-by-investment programs that merit consideration in a post-Spain portfolio.

Hungary — Guest Investor Program

Relaunched in 2024, Hungary’s GIP offers a 10+10-year residence permit through two routes: a €250,000 real-estate investment fund or a €1,000,000 education donation. There is no minimum stay requirement, and processing typically takes four to six months. Family coverage includes a spouse, minor children, and adult children up to 25 if enrolled in full-time higher education. The permit grants Schengen travel rights. Citizenship follows the ordinary Hungarian rules — eight or more years of continuous physical residence, plus Hungarian language and constitutional exams. There is no investor fast-track to nationality.

Malta — Permanent Residence Programme (MPRP)

Malta’s MPRP grants permanent residence from the outset. Accommodation requires either a property purchase of at least €375,000 or a rental commitment of €14,000 per year for a minimum of five years. Non-property costs total approximately €99,000: a €60,000 administrative fee (split €15,000 on application and €45,000 on approval), a €37,000 government contribution, and a €2,000 NGO donation. Processing takes roughly four to eight months. Family members — including spouse, children, and ascendants — are covered. Schengen travel rights apply. For those seeking citizenship, Malta’s separate MEIN program requires €600,000 to €750,000 in additional investment plus real estate and donations, with a 12- to 36-month timeline. Malta’s RBI framework is considered the most stable in the EU.

Italy — Investor Visa

Italy’s Investor Visa, active since its January 2025 updates, offers four routes: €250,000 into an innovative startup, €500,000 into company equity, €1,000,000 as a philanthropic donation, or €2,000,000 in government bonds. The initial two-year visa converts to a residence permit. Italy’s concurrent “accompanying family member” procedure allows family reunification without the standard two-year waiting period. Schengen travel rights apply. Permanent residency is available after five years, and citizenship after 10 years under standard rules. Note that Italy’s flat tax for new residents (Article 24-bis) increased from €100,000 to €300,000 per year effective 1 January 2026.

EU residency-by-investment comparison

All programs grant Schengen 90/180 visa-free travel. Family inclusion varies by program. None confer EU-wide permanent residency or work rights. Government fees are subject to change.

How to reposition your portfolio for 2026

With Spain off the board and the remaining programs evolving rapidly, a structured repositioning approach is essential. Start by defining the jurisdictional split — Greek real estate versus Portuguese funds versus newer programs in Hungary, Malta, or Italy — based on each client’s objectives, risk tolerance, and liquidity profile.

Front-load compliance documentation. Compile source-of-funds evidence, banking trails, tax returns, and settlement proofs before selecting an asset. Portugal’s multi-year processing backlog means documents must remain valid for extended periods; Greece’s shorter timeline requires tighter coordination on property closings.

Pre-screen qualifying assets carefully. For Greece, verify that the property meets the correct tier threshold and 120 m² minimum for the target region. For Portugal, diligence the fund vehicle to confirm it satisfies post-2023 rules — in particular, the zero real-estate exposure requirement and minimum five-year maturity. For Hungary, Malta, and Italy, confirm the specific qualifying conditions for the chosen route.

Model tax and holding structures early. Italy’s flat tax increase to €300,000 per year for new residents affects high-net-worth planning. Coordinate with cross-border tax counsel on implications of property versus fund holdings. Sequence applications to manage family needs and consider parallel pathways for residence planning en Schengen visa strategy.

For clients considering Armenia as a complementary base — whether for verblijf door investering, bedrijfsregistratieof tax planning — a multi-jurisdiction approach can strengthen both compliance posture and mobility options.

Veelgestelde vragen

Ready to rebalance your EU residency strategy or explore complementary options in Armenia? Our team advises on multi-jurisdiction planning across investment thresholds, tax structures, and family mobility goals. Learn about citizenship pathways or reach out for a tailored consultation.