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One update worth knowing before anything else:
- The 5-year path to citizenship is no longer the rule for most applicants. Organic Law 1/2026, published 18 May 2026 and in force from 19 May 2026, raised the residence period required for Portuguese naturalisation from 5 years to 10 years for most nationalities, and to 7 years for EU and CPLP (Portuguese-speaking country) nationals. The law's transitional provision (Article 7(2)) protects nationality applications that were already pending with the IRN (the civil registry authority handling nationality, distinct from AIMA, which handles residence permits) on 18 May 2026: those continue under the previous 5-year regime regardless of how long they take to decide. For Golden Visa holders who hold a residence permit but had not yet filed a nationality application by that date, the law does not clearly state whether residence time already accrued before 19 May 2026 counts toward the new 7 or 10-year threshold; this question is currently the subject of ongoing legal challenge in the Portuguese courts, and the Government has 90 days from 19 May 2026 to publish updated implementing regulations.
The Golden Visa investment routes and the 5-year path to permanent residence are unaffected by this change. What changed is specifically the wait for citizenship. We explain both timelines below and confirm which one applies to a given client's file.
Portugal's Golden Visa is still active, and the investment routes have not changed since real estate was removed in 2023. What has changed, and changed substantially, is the citizenship timeline that made this programme famous in the first place. For years, marketing around this programme leaned heavily on "EU citizenship in five years." That claim is no longer accurate for most applicants, and any page still making it is describing a rule that stopped applying in May 2026.
As immigration lawyers with a Lisbon and Porto presence, advising on Portugal alongside other EU residency programmes, we position this correction at the centre of every Portugal conversation now, not as a footnote after the investment pitch.
A Residence Programme, With Citizenship Now a Longer Road
The Portugal Golden Visa, formally the Autorização de Residência para Investimento (ARI), grants a residence permit to non-EU, non-EEA, non-Swiss nationals who complete a qualifying investment, along with visa-free travel across the Schengen Area. Permanent residence remains available after 5 years of legal residence, unchanged by the 2026 reform. Citizenship is the step that changed: it now generally requires 10 years of residence for most nationalities, or 7 years for EU and CPLP nationals, and for new applicants that period runs from the date the residence permit is issued. Whether time already accrued by existing permit holders before the law changed counts toward that period is a live legal question, addressed below.
Two Separate Laws, Both Recently Amended
The residence-by-investment framework rests on Law 23/2007, Portugal's immigration law, with the ARI route set out in Article 90-A, as amended by Law 56/2023 (which removed real estate as a qualifying investment, in force from October 2023) and Law 61/2025 (in force since 23 October 2025, which restructured several residence-permit categories). Citizenship is governed separately by the Portuguese Nationality Law (Law 37/81), most recently amended by Organic Law 1/2026, in force since 19 May 2026. Residence-permit applications, including ARI, are administered by AIMA, the Portuguese agency for integration, migration, and asylum, which absorbed the former SEF's immigration functions in 2023. Nationality applications are handled separately by the IRN (Instituto dos Registos e do Notariado), Portugal's civil registry authority.
The Investment Routes, Now All Non-Property
Direct real estate investment has not qualified since October 2023. Current routes are:
| Route | Minimum Investment | Details |
|---|---|---|
| A: Fund Investment Most Popular | €500,000 | A CMVM-regulated Portuguese fund, minimum 5-year maturity at the time of investment, with at least 60% of the fund's value in Portuguese commercial companies, and no direct or indirect real estate exposure. |
| B: Cultural and Artistic Donation | €250,000 | A donation supporting arts, culture, or national heritage preservation, generally requiring approval from the relevant Ministry of Culture body before the funds are committed. |
| C: Research Donation | €500,000 | Capital transfer supporting research activity conducted by public or private scientific institutions forming part of Portugal's scientific and technological infrastructure. |
| D: Job Creation | 10 jobs | Creation of at least 10 permanent positions in Portugal, with a reduced job count generally available in designated low-density areas. |
| E: Company Formation or Capitalisation | €500,000 | Capital transfer to incorporate a Portuguese company or capitalise an existing one, combined with creating at least 5 permanent jobs, or sustaining at least 10 jobs (5 of them permanent) over a 3-year period. |
Practical Note: Fund Investment
This has become the default route since real estate closed, precisely because it offers professional management and clear regulatory oversight through the CMVM rather than the operational demands of direct property ownership. Not every fund on the market qualifies or performs the same way, so we verify a fund's current CMVM registration, real-estate-exposure exclusion, and Portuguese-company allocation before recommending a subscription, and we treat fund performance and fees as a genuine investment decision, not a formality on the way to a residence card.
Practical Note: The Non-Investment Routes
The donation, research, job-creation, and company routes suit different profiles: philanthropically minded applicants, those already running a Portuguese business, or investors who prefer to put capital directly into a company rather than a fund. Donation routes in particular are genuinely non-refundable, which is worth weighing honestly against the fund route's investor-owned structure before a client chooses on cost alone.
Not Sure Which Route Fits Your Situation?
Our legal team will review your circumstances and confirm current fund options and route requirements, at no obligation.
Get in Touch Call Us: +90 532 132 92 33From Fund Subscription to Residence Card
Our team manages the process end to end, coordinating with the fund manager or receiving institution and AIMA on your behalf:
- Initial eligibility review and selection of the qualifying investment route
- Portuguese tax identification number (NIF) and bank account opened, generally through a fiscal representative if the applicant is not yet resident
- Completion of the investment: fund subscription, donation, or company capitalisation, as applicable
- Application filed with AIMA, including background checks and supporting documentation
- Biometric appointment in Portugal
- Issuance of the initial residence permit, and renewal in line with AIMA's schedule as the file progresses
Application Timeline
The statutory legal target for ARI processing is 90 days from a complete application. In practice, AIMA inherited a substantial backlog when it absorbed the former SEF's immigration functions in 2023, and reports place pending ARI-related cases, including family members, above 55,000. Actual average processing time from submission to issuance of the first residence card is commonly cited at around 34 months, far beyond the statutory target. We set this expectation with clients from the outset rather than quoting the 90-day legal target alone.
What the Golden Visa Actually Gives You
- Residence permit for the investor and included family members, with the right to live, work, and study in Portugal
- Visa-free travel within the 29-country Schengen Area
- Physical presence requirement of just 7 days in the first year and 14 days in each subsequent 2-year period, 35 days total over 5 years
- Eligibility for permanent residence after 5 years of legal residence, unaffected by the 2026 citizenship reform
- A route to citizenship, now on a 7 to 10 year timeline depending on nationality rather than the previous 5
- No language or education requirement for the residence permit itself
The Investor, and Who Rides Along in the Family Group
Applicants must be non-EU, non-EEA, non-Swiss nationals, hold a clean criminal record, and complete one of the qualifying investment routes.
- Main applicant
- Spouse or partner
- Dependent children, including unmarried adult children in full-time education, subject to dependency conditions
- Dependent parents, subject to age and dependency conditions in force at the time of application
Family reunification applications and renewals for existing Golden Visa holders continue to be processed under the applicable rules; the 2026 reforms affect the citizenship timeline specifically, not the underlying residence or family-inclusion structure.
Ten Years, Seven for Some, Not Five
Naturalisation as a Portuguese citizen now generally requires 10 years of legal residence for most nationalities, reduced to 7 years for nationals of EU member states and CPLP (Community of Portuguese-Speaking Countries) states. Applicants who already had a nationality application pending with the IRN, the civil registry authority that handles nationality (a separate body from AIMA, which handles residence permits), on 18 May 2026 continue under the earlier 5-year rule regardless of how long that application takes to decide. The position is genuinely unresolved for Golden Visa holders who hold a residence permit but had not yet filed a nationality application by that date: the law does not clearly state whether residence time already accrued before 19 May 2026 counts toward the new threshold, and this question is currently being litigated. We do not present this as settled either way, and we track the ongoing legal challenge and the Government's implementing regulations, due within 90 days of the law's entry into force, before advising a client on their specific timeline.
Under Article 6(1) of the amended Nationality Law, naturalisation now requires applicants to prove, through a test or certificate, sufficient knowledge of the Portuguese language and culture, history, and national symbols, and sufficient knowledge of the fundamental rights and duties of Portuguese citizens. This is a statutory requirement under the law now in force, not a proposal still under discussion, and it goes beyond the simple A2 language test that applied previously. The reform also tightened rules for citizenship by descent for great-grandchildren of Portuguese citizens and for children born in Portugal to foreign parents, each now requiring a demonstrated period of parental residence. None of this affects the Golden Visa's investment routes or the 5-year path to permanent residence, which remain as they were.
Tax Considerations, Beyond the Old NHR Pitch
Portugal is not a tax haven, and its favourable tax treatment for new residents has changed materially in recent years from the non-habitual resident regime that older Golden Visa marketing often referenced. Current tax treatment for new residents depends on the specific regime in force and the applicant's circumstances, and should be confirmed with a tax adviser rather than assumed from legacy NHR descriptions still circulating online.
Portugal Against the Other EU Routes
Portugal's minimal physical-presence requirement remains one of the lowest among EU residency-by-investment programmes, even after the citizenship timeline extended.
Minimal Physical Presence
35 days over 5 years is markedly lower than most comparable EU programmes, even with the longer citizenship wait.
No Real Estate Requirement
Fund and donation routes avoid the property-management burden that comes with a direct real estate purchase elsewhere.
Permanent Residence Unaffected
The 5-year route to permanent residence, distinct from citizenship, was not changed by the 2026 reform.
Family Inclusion
Spouse or partner, dependent children, and dependent parents can generally be included on the same application.
Established Programme
Running since 2012, Portugal's programme has a longer operating history and larger caseload than several newer EU alternatives.
Honest Citizenship Timeline
We present the current 7 to 10 year citizenship path plainly, rather than the 5-year figure that no longer applies to new applicants.
Ready to Begin Your Portugal Golden Visa Application?
Speak with our legal team today. We confirm the current investment routes and realistic timeline before you commit any funds.
Start Your Application [email protected]Why Clients Trust Us With the Portugal File
With over 40 years of senior legal experience and a presence in Lisbon and Porto, Ketenci & Ketenci has advised hundreds of clients through the Portugal Golden Visa, which is why we lead with the citizenship-timeline correction rather than let a client discover it after committing funds.
- Citizenship-timeline honesty: we explain the current 7 to 10 year path clearly, not the outdated 5-year figure still used across much of the market
- Fund verification: we check a fund's CMVM registration and structure before any client subscribes
- Realistic processing expectations: we set timelines against AIMA's actual current pace, not only the official target
- Cross-programme perspective: we advise on Portugal alongside Greece, Malta, and Hungary, so a client can compare routes rather than seeing Portugal in isolation
- End-to-end coordination: NIF, bank account opening, fund subscription, and AIMA filing managed directly with our Lisbon and Porto contacts
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This page is provided for general informational purposes only and does not constitute legal advice. Investment thresholds, residency requirements, and citizenship rules are subject to change by the Portuguese authorities. For advice specific to your circumstances, please contact our legal team directly.