Portugal Golden Visa by investment funds: how the main route works

Since the real estate routes were closed to new applications, subscribing to eligible investment funds is one of the principal current routes to the Portugal Golden Visa. The minimum investment is €500,000, the capital must be maintained for the required holding period, and the resulting residence permit entails only a reduced minimum stay in Portugal: seven days in the first year and fourteen days, consecutive or not, in each subsequent two-year period.

This article explains how this route works, what you need to assess before subscribing, the lawyer's role, the risks to weigh, and the most realistic processing times today.

Key points

• The Golden Visa route through investment funds remains fully valid in Portugal.
• The minimum legal investment is €500,000.
• The fund must be non-real-estate, established under Portuguese law, have a minimum maturity of five years, and invest at least 60% of its capital in commercial companies headquartered in Portugal.
• The minimum stay in Portugal is seven days in the first year and fourteen days, consecutive or not, in each subsequent two-year period.
• AIMA processing and biometric scheduling vary according to administrative capacity and the circumstances of the application; any operational estimate should be dated, sourced and presented as non-binding.

Why funds are now the main route

Until 2023, many investors chose to acquire property. That route — both residential and commercial — is no longer eligible for new applications, shifting the regime's focus towards other investment options provided by law.

Among those options, investment funds attract most of the demand. Unlike the certified cultural donation, which has a lower threshold but is definitive in nature, funds represent an investment with an expectation of return. The choice of route must be made before the application is submitted, making the initial analysis a decisive step.

How subscribing to a qualifying fund works

The funds used for this visa route are collective investment undertakings regulated in Portugal. For Golden Visa purposes, the law requires the investment to consist of the acquisition of units in non-real-estate collective investment undertakings, incorporated under Portuguese law, with a maturity of at least five years, and with at least 60% of their investments made in commercial companies headquartered in Portugal.

In practice, the investor needs a Portuguese tax number (NIF) and a bank account in Portugal, subscribes to the participation units with the fund manager, and gathers the documentary evidence to support the visa application. Because each fund sets its own subscription terms, fee structure, redemption policy and internal rules, reading the contractual and regulatory documentation is not a mere formality.

Legal due diligence

This is precisely the stage where legal due diligence becomes paramount. The eligibility of a specific fund should not rely on generic marketing material, but rather on an analysis of the vehicle's actual documentation, its regulatory framework, its compliance with Golden Visa criteria, its redemption and transfer rules, and the documentary proof that AIMA will require.

The lawyer's role is not to pick the fund for you as a financial adviser would. It is to protect you through the legal review of the management regulations, confirming the legal basis of eligibility, analysing entry and exit conditions, liaising with the fund manager, and preparing the evidence of the lawful origin of funds and other supporting documents.

What to assess in a fund

Before subscribing, several points should be scrutinised carefully.

• Actual eligibility: does the fund demonstrably meet the legal criteria for the route, and will it maintain them throughout the holding period?
• Regulation and supervision: who is the management entity, who is the depositary, and what is the applicable regulatory framework?
• Investment policy and term: what assets does the fund invest in, what is its expected maturity, and how does that timeline align with the legal minimum holding horizon?
• Fees and exit conditions: subscription, management and performance fees; redemption rules; and the consequences of early exit.
• Tax alignment: the tax treatment of the investment in Portugal and in the investor's home country, which should be validated with independent tax advice.

Risks to consider

The invested capital is at risk. An investment fund is not a bank deposit; the value of participation units can rise or fall, and returns are never guaranteed.

There is also liquidity risk, as the capital tends to be tied up for several years, and regulatory risk, should the fund fail to maintain the criteria required for this route. The purpose of the preliminary legal analysis is not to eliminate these risks — which would be impossible — but to understand them, document them, and allow you to decide with full legal and economic awareness.

The step-by-step process

• Preliminary legal assessment: investor profile, source of funds, family structure and an informed choice of route.
• Practical preparation: obtaining a Portuguese NIF and opening a bank account in Portugal.
• Due diligence and subscription: legal review of the fund's documentation and execution of the investment.
• Application filing: gathering, translating, legalising and uploading the required documents to the official platform.
• Biometric data collection: in-person appointment at AIMA for the main applicant and family members.
• Card issuance: followed by renewals and, eventually, a path to citizenship if the legal requirements are met.

AIMA processing and biometric scheduling vary according to administrative capacity and the circumstances of the application; any operational estimate should be dated, sourced and presented as non-binding.

Note for US citizens

US citizens remain fully eligible for the Portuguese Golden Visa. However, investing in a non-US fund may raise significant tax issues under US law. Subscription should always be coordinated with independent tax advice in the United States. Aligning an immigration lawyer, a tax adviser and, where applicable, a wealth adviser from the outset tends to reduce structuring errors down the line.

FAQs

Is the Golden Visa by investment funds still valid in Portugal?

Yes. What ended in 2023 were the real estate routes for new applications, not the eligible investment funds route or the other options provided by law.

How much do I need to invest in a fund for the Golden Visa?

The legal minimum is €500,000. This investment must be made in non-real-estate collective investment undertakings incorporated under Portuguese law that meet the remaining legal criteria.

How long do I have to stay in Portugal?

The minimum stay is reduced. The permit holder must spend at least seven days in Portugal in the first year, and at least fourteen days, consecutive or not, in each subsequent two-year period.

How long does the Golden Visa process take?

AIMA processing and biometric scheduling vary according to administrative capacity and the circumstances of the application; any operational estimate should be dated, sourced and presented as non-binding.

Does the lawyer choose the fund for me?

No. The lawyer's role is to conduct legal due diligence, verify the legal compliance of the route, review documentation, identify contractual and evidentiary risks, and protect the client before the investment decision is made.

Will I get my capital back at the end?

That depends on the fund's rules and the investment's performance. Unlike a donation, the fund route carries an expectation of return, but it does not offer a capital guarantee or a minimum financial result.

Is Portuguese citizenship automatic after the Golden Visa?

No. A residence permit holder may apply for citizenship once the applicable legal residence period is met, under certain conditions, but attribution is not automatic. It depends on meeting the requirements of the Nationality Law.