The Portugal Golden Visa, officially the Autorização de Residência para Atividade de Investimento, or ARI, is not what it was three years ago. The property routes that made it famous were removed in October 2023. What remains is a narrower programme centred primarily on investment funds (fundos de investimento), venture capital, and a small number of other qualifying activities.
For many non-EU nationals looking at the ARI today, the fund route is the most practical remaining option. It is not the only legal route, but it is the one most applicants compare first because the alternatives usually involve job creation, research, culture, or company-capital requirements. This guide covers what that route actually requires, what the application process looks like from the very first administrative step, and where it regularly goes wrong.
Quick Answer: The Portugal Golden Visa investment fund route requires a minimum of €500,000 into a qualifying non-real-estate collective investment vehicle, with at least a five-year maturity and at least 60% of the investment value allocated to commercial companies headquartered in Portugal. You apply through AIMA after making the investment. The official processing target is 90 days; in practice, plan for 12–24 months. The residency requirement is just 7 days in the first year and 14 days per two-year renewal period. After five years of legal residence, you may be eligible for permanent residence or citizenship, but citizenship timing should be checked against the current nationality-law position.
What Changed in October 2023
Before the law changed, most Golden Visa applications were filed on the basis of property purchases typically a residential property above a set threshold. That route no longer exists.
Lei n.º 56/2023, de 6 de outubro, commonly known as the Mais Habitação (More Housing) law, removed real-estate-based ARI investment routes for new applicants with effect from 7 October 2023. Applications already submitted before that date were not affected, but no new property-based ARI applications have been accepted since.
The change was politically contentious and caused uncertainty for applicants who were already mid-process. Thousands of applicants were mid-process when it passed. Most of those pending files have since resolved one way or another, but the legacy explains why a large proportion of guides you find online still describe the property route as though it is available. For a new applicant in 2026, it is not.
If buying property in Portugal remains a goal independent of the visa, that’s a separate decision entirely the visa is no longer part of that equation.
Who Can Apply
The ARI is open to non-EU, non-EEA, and non-Swiss nationals. EU citizens already have the right to reside in Portugal and have no use for it.
There is no income threshold to meet as a personal condition; the qualifying bar is the investment itself. You don’t need to have lived in Portugal before, have Portuguese ancestry, or speak the language at the point of application (though language is required later for citizenship). Most applicants apply from outside Portugal and travel in only for the biometric appointment once the file has been approved.
You must not have a negative entry in the Schengen Information System (SIS) and must not be subject to an entry ban from any EU member state. Politically exposed persons (PEPs) face additional scrutiny at both the fund subscription stage (the funds run their own KYC know your customer checks) and within the AIMA review.
The Investment: €500,000 Into a Qualifying Fund
The minimum investment amount is €500,000, transferred from a Portuguese bank account into the fund. That number is fixed; there is no reduced threshold available for low-density areas or for funds focused on particular sectors.
The fund must meet several conditions:
- Registered and supervised by CMVM (Comissão do Mercado de Valores Mobiliários the Portuguese securities regulator)
- Minimum five-year maturity at the moment of investment (your capital is normally locked in for at least five years)
- At least 60% of the investment value allocated to commercial companies headquartered in Portugal
- Not a real estate collective investment vehicle; funds with indirect property exposure can raise eligibility questions and should be reviewed carefully
Venture capital funds (fundos de capital de risco) are the most commonly used vehicle. Private equity funds and other regulated collective investment schemes that meet the above criteria are also used. There is no official government list of “approved Golden Visa funds.” CMVM publishes a full register of licensed funds and fund managers, which your lawyer should verify against your specific choice.
The 5-year lock-up clock starts when you subscribe to the fund, not when AIMA approves your residency. If AIMA takes 18 months to process your file, your money has already been locked for 18 of those months. Keep track of both timelines separately. Some applicants arrive at the renewal stage expecting to exit the fund shortly after only to find the maturity date is still a year away.
Finding a Fund That Actually Qualifies
This is where the most expensive mistakes happen. A fund being “marketed for the Golden Visa” is not evidence that it legally qualifies.
Fund managers know the ARI audience and market to it heavily. That creates a crowded field where presentation quality varies enormously from actual legal eligibility. Before committing €500,000, you need to verify independently:
On the fund’s eligibility:
- Confirm it appears in the CMVM register with an active authorisation
- Read the prospeto (fund prospectus) specifically the investment policy section showing the Portugal allocation percentage and the minimum fund term
- Get a legal opinion from Portuguese counsel specifically one confirming ARI eligibility under Artigo 90-A of Lei n.º 23/2007, not just a generic regulatory opinion
On fees: Management fees (comissões de gestão) typically run between 1% and 2.5% per year on committed capital. Some funds charge a subscription fee (comissão de subscrição) on entry. These are deducted from your invested amount over time you are investing €500,000, from which fees reduce the effective return. Some fund managers also charge performance fees above a hurdle rate.
On the fund’s actual track record: Many Golden Visa funds have limited operating histories some were created specifically to capture ARI-eligible investors and have no meaningful portfolio performance data. Others have genuine multi-year track records in sectors such as healthcare technology, sustainable infrastructure, or SME lending. The level of due diligence appropriate here is the same as for any illiquid private equity investment.
The fund manager’s legal team will confirm the fund meets ARI criteria from the fund’s perspective. That is not independent legal advice for your specific situation. Engage your own Portuguese advogado (lawyer) before committing capital. Their role and the fund’s legal team’s role serve different interests.
Fund Due Diligence Checklist
Before wiring money, ask your lawyer to review at least these items:
- CMVM registration and active fund-manager authorisation
- Prospeto / fund prospectus, especially the investment policy
- Written explanation of how the fund meets the ARI rules
- Minimum five-year maturity and lock-up terms
- Evidence that at least 60% is allocated to commercial companies headquartered in Portugal
- Confirmation that the fund is not a real estate collective investment vehicle
- Full fee schedule: subscription, management, depositary, performance, and exit fees
- Depositary bank, auditor, and fund administrator details
- Redemption terms, transfer rules, and what happens if AIMA processing is delayed
- Independent legal opinion for your file, not only the fund manager’s marketing material
This checklist does not make a fund safe or profitable. It simply helps you separate a serious ARI-eligible investment from a fund that is mainly relying on Golden Visa marketing.
Fund Red Flags to Treat Seriously
Be careful if a fund pitch focuses more on the visa than the investment. Slow down if the manager cannot quickly provide the prospeto, CMVM registration details, maturity terms, fee schedule, depositary information, and a clear explanation of how the 60% Portugal-headquartered-company requirement is met. A glossy deck is not due diligence.
The Application Process Step by Step
Step 1: Get your NIF (Número de Identificação Fiscal)
You cannot open a Portuguese bank account without a NIF. You cannot invest in a CMVM fund without a Portuguese bank account. The NIF is the absolute first administrative step and can be arranged before you travel to Portugal through a representante fiscal (fiscal representative). The full process is covered in the NIF guide for foreigners.
Step 2: Open a Portuguese bank account
Most CMVM-registered fund managers require investment via a Portuguese bank account for KYC reasons and fund mechanics. Opening a Portuguese bank account as a non-resident takes more time than bank websites suggest documents required vary by institution, and compliance teams can slow things down. What actually works in practice is covered in the guide to opening a bank account in Portugal as a foreigner. Caixa Geral de Depósitos, Millennium BCP, and Novo Banco are commonly used by ARI applicants.
Step 3: Choose and subscribe to the fund
Once the bank account is open and funded, you transfer the €500,000 investment amount and complete the fund subscription. Get written confirmation of the subscription the certificado de participação (or equivalent subscription confirmation) is a core document for the AIMA file.
Step 4: Compile the AIMA application file
The application is filed through the ARI portal on AIMA’s website. A Portuguese lawyer typically handles this, but you supply the documents. Expect this stage to take several weeks of coordination, particularly for documents sourced from outside Portugal.
Step 5: Pay the AIMA analysis fee and submit
AIMA charges an analysis fee at submission, paid through the ARI process, usually via a Documento Único de Cobrança (DUC). ARI fees are much higher than ordinary residence-permit fees, and AIMA updated its fee table from 1 March 2026. Check the current AIMA fee table before filing, especially for family applications where fees apply per person.
Step 6: Wait for AIMA’s decision
After submission, AIMA reviews the file. The legal processing target is 90 days. In practice, 12 to 24 months is a realistic working assumption for 2026 applications. There is no official fast-track option.
Step 7: Complete the biometric appointment in Portugal
When AIMA approves the file, you receive an appointment to attend in person in Portugal to provide fingerprints and biometric data. The appointment may be several months after the approval decision, depending on slot availability. You must have a valid right to enter Portugal for this appointment a valid Schengen visa if required by your nationality.
Step 8: Receive the Título de Residência
The residence card (Título de Residência) is issued after the biometric appointment and sent according to the address/details in your AIMA file. Allow several weeks and make sure your Portuguese contact/address details are correct. The first card is valid for two years. Renewal is then in two-year periods, with a further renewal before the five-year mark when permanent residence becomes available.
Document Checklist
| Document | Notes |
|---|---|
| Valid passport | All pages; certified copies typically required |
| Certificado do Registo Criminal | Criminal record from country of residence; apostilled; certified translation into Portuguese; valid for 90 days from issue |
| NIF certificate | Issued by Finanças via Portal das Finanças |
| Portuguese bank statement | Showing the investment transfer |
| Fund subscription certificate | Issued by the fund manager on subscription |
| Fund prospectus (Prospeto) | Showing 60% Portugal allocation and 5-year term |
| Legal opinion on fund ARI eligibility | From Portuguese counsel; confirms compliance with Artigo 90-A |
| Health insurance (seguro de saúde) | Valid in Portugal for the full application period |
| Certidão de não dívida das Finanças | Confirms no outstanding tax debts in Portugal; requires an active NIF |
| Certidão de não dívida da Segurança Social | Confirms no outstanding Social Security debts in Portugal |
| AIMA application form | Completed in Portuguese |
| Passport photographs | Per current AIMA specification |
The criminal record certificate causes the most delays. Applicants from countries with multi-level criminal records systems including the United States (state plus federal), India, and some other countries should confirm with their lawyer which level or levels AIMA expects. Get the most complete version available and apostille it. And get it last: the 90-day validity window means obtaining it too early is a common and expensive mistake.
Costs to Plan For
| Item | Cost (€) | Notes |
|---|---|---|
| AIMA analysis / submission fee | Check current AIMA table | Per applicant; ARI fees are updated by AIMA and are higher than ordinary residence fees |
| AIMA residence card issuance | Check current AIMA table | Per applicant, usually due after approval / before issuance |
| AIMA renewal fee | Check current AIMA table | Per applicant, per renewal period; confirm the amount before each renewal |
| Fund investment (minimum) | €500,000 | Locked for minimum 5 years from subscription |
| Fund management fees (comissões de gestão) | 1%–2.5% per year | On committed capital; deducted from fund assets |
| Fund subscription fee (comissão de subscrição) | 0%–2% | Varies by fund; some charge, some do not |
| Portuguese lawyer fees | €3,000–€10,000+ | Varies by firm, complexity, and family size |
| Document translation and apostille | €300–€900 | Varies by documents and issuing country |
| Health insurance | €600–€2,500+ per year | Varies significantly by age and insurer |
AIMA government fees are a real part of the budget, but they change and should be checked against the current AIMA table before filing. Budget for analysis, issuance, and renewal charges separately from the €500,000 investment itself. For families, multiply the government fees by the number of applicants.
Timeline: Law vs Reality
| Stage | Official Position | Practical Reality |
|---|---|---|
| AIMA file review | 90 days | 12–24 months in current conditions |
| Biometric appointment after approval | Not specified | 1–5 months after decision notice |
| Título de Residência after biometrics | Not specified | 3–8 weeks |
| First renewal (year 2) | Before card expires | Start process 3–6 months before expiry date |
| Permanent residence eligibility | After 5 years of legal residence | The practical clock and evidence should be checked with your lawyer; citizenship counting rules may differ and are affected by nationality-law changes |
Do not build any plan around the 90-day statutory window. Applicants who have pressing work authorisation, travel, or other visa dependencies should treat the Golden Visa as a long-term investment in residency, not a short-term fix.
What the Golden Visa Does Not Give You
Tax residency separate process, separate decision
The ARI is a residency permit. With only 7 days per year in Portugal, you almost certainly do not trigger tax residency under the standard 183-day rule. This matters because many applicants assume the Golden Visa automatically bundles a favourable tax position. It does not.
If you want access to Portugal’s IFICI regime (Incentivo Fiscal à Investigação Científica e Inovação the regime that replaced NHR for new applicants from 2024), you need to separately establish tax residency in Portugal and apply through Portal das Finanças. These are two entirely separate decisions with separate tax and legal implications. The NHR replacement guide covers the IFICI eligibility and application process.
Citizenship possible after 5 years, not automatic
After five years of legal residence under the ARI, you may become eligible to apply for Portuguese citizenship or permanent residence. Eligibility is not citizenship. You still need to pass the CIPLE exam at A2 level in Portuguese, pass background checks, demonstrate ties to Portugal through the effective connection (ligação efetiva à comunidade nacional) requirement, and complete the IRN process.
Portugal’s nationality law is under active review in 2026, and the residence-counting rules for citizenship have changed in recent years. It is worth understanding where that law actually stands before building your long-term plan around a fixed five-year passport timeline.
Tax treatment of the fund at exit not exempt by default
When your fund matures and distributes gains, Portuguese income tax may apply depending on your tax status at the time. This is not a minor detail on a €500,000+ investment. The interaction between IFICI rates, standard Portuguese rates, your country of tax residency, and any applicable double taxation treaties needs careful planning well in advance of the fund’s maturity date. The capital gains tax guide covers how investment income is taxed in Portugal.
Common Mistakes
Mistake: Assuming “CMVM-registered” confirms ARI eligibility
A fund appearing in the CMVM register means it is a licensed collective investment vehicle. It does not automatically confirm it meets the ARI’s specific criteria: minimum five-year maturity, 60% allocation to commercial companies headquartered in Portugal, and exclusion of real estate collective investment structures. Files have been rejected because the fund chosen did not actually satisfy one of these conditions. Get a specific legal opinion on ARI eligibility, not just a general CMVM authorisation reference.
Mistake: Taking the fund manager’s timeline for AIMA as accurate
Fund managers sometimes tell potential investors that AIMA takes “six to eight months” because that was roughly true in earlier years. In 2025–2026 conditions, 12 to 18 months from submission to card is a more honest baseline. Some files have taken longer. Plan your fund maturity expectations, any planned relocation, and your family’s visa arrangements around the longer estimate.
Mistake: Getting the criminal record certificate before the file is ready to submit
The certificado do registo criminal typically has a 90-day validity window from the date of issue. Applicants who obtain it early while still selecting a fund, waiting for a bank account to open, or collecting other documents often find it has expired by the time the AIMA file is ready to submit. Get it last, not first.
Mistake: Relying on the fund manager’s legal team for independent advice
The fund manager’s legal counsel confirms that the fund structure meets ARI criteria. They are advising the fund, not you. Your interests as an investor and ARI applicant are not necessarily the same as the fund’s interests. Retain your own Portuguese advogado to review the full file independently before you subscribe.
Mistake: Missing the 7-day minimum in year one
The residency requirement is low, but it is not zero. Some applicants invest, wait 12–18 months for AIMA to process the file, and realise they haven’t entered Portugal at all during the first year of the ARI because they were waiting for the card and assumed no obligations applied until approval. The 7-day requirement runs from the start of the ARI’s validity period. A single trip to complete the biometric appointment can satisfy it, but only if that trip happens within the first year.
Frequently Asked Questions
Is the Portugal Golden Visa still available in 2026?
Yes. The Autorização de Residência para Atividade de Investimento (ARI) remains open to non-EU nationals in 2026. The real estate investment routes were removed in October 2023, but the investment fund route at a minimum of €500,000 is still open and accepting new applications.
How much do you need to invest for the Portugal Golden Visa fund route?
The minimum is €500,000 into a qualifying fund registered with CMVM (Comissão do Mercado de Valores Mobiliários). The fund must have a minimum maturity of five years and at least 60% of the investment value must be allocated to commercial companies headquartered in Portugal. It cannot be a real estate collective investment vehicle.
How long do you have to stay in Portugal for the Golden Visa?
The minimum is 7 days in the first year and 14 days in each subsequent two-year renewal period. You don’t need to live in Portugal full-time. Many holders visit once per renewal period to satisfy the requirement.
Can you still use the Golden Visa to buy property in Portugal?
No. The property investment routes were removed by Lei n.º 56/2023, de 6 de outubro, commonly known as the Mais Habitação law, which took effect on 7 October 2023. New applicants must use one of the remaining ARI categories. For many applicants, the fund route is the most practical remaining option, but it is not the only legal route.
How long does AIMA take to process a Golden Visa application?
The law sets a 90-day processing target. In practice, AIMA takes between 12 and 24 months from initial file submission to card issuance. That includes the biometric appointment and card delivery.
Does the Golden Visa give you NHR or IFICI tax status automatically?
No. The ARI is a residency permit, not a tax status. If you want to access Portugal’s IFICI regime, you need to separately establish tax residency in Portugal and apply through Portal das Finanças. The two processes are entirely independent.
Can your family join you on a Golden Visa?
Yes. The ARI allows family reunification for a spouse or civil partner, dependent children, and dependent parents. Each family member requires a separate AIMA application, filed on the basis of your approved ARI. Government fees apply per person.
When can Golden Visa holders apply for permanent residence or citizenship?
After five years of legal residence under the ARI, you may be able to apply for permanent residence or Portuguese citizenship, subject to language requirements and other conditions. The clock for permanent residence, renewals, and citizenship may not be treated in exactly the same way, and Portugal’s nationality law is under active review in 2026. Check the current position before building plans around a fixed five-year passport timeline.
Do I need a Portuguese NIF before investing in a Golden Visa fund?
Yes. You need a NIF (Número de Identificação Fiscal) to open a Portuguese bank account, and a Portuguese bank account is typically required to invest in CMVM-registered funds. Getting the NIF is the first practical step before anything else can move.
How are capital gains from the fund taxed when it matures?
Gains distributed at fund maturity may be subject to Portuguese income tax if you have established tax residency in Portugal by then. Even without tax residency, some withholding at source may apply. The interaction with IFICI rates or standard rates depends on your situation; review this with a Portuguese contabilista certificado well before the fund’s exit date.
The ARI fund route has clear rules on paper. The practical reality AIMA timelines, fund due diligence, document coordination across multiple countries consistently takes longer and costs more than first-time applicants expect. Start the NIF and bank account steps earlier than feels necessary. Commission independent legal advice before choosing or subscribing to a fund. And treat the visa and the tax planning as two separate decisions, because conflating them is the most common reason people feel surprised later.