Portugal Golden Visa After the Real Estate Ban: What Actually Qualifies in 2026

Real estate no longer qualifies for the Portugal Golden Visa. That has been the rule since Law No. 56/2023 came into force on October 7, 2023, and nothing in 2025 or the first half of 2026 has reopened the door. Any agent currently pitching a Lisbon apartment as a Golden Visa path is selling a product that does not exist.

The Golden Visa itself is alive and growing. Portugal granted a record 4,987 Golden Visas in 2024, a 72 percent increase year-on-year, and 2025 numbers are tracking similarly. The investment routes are now financial and philanthropic rather than property-backed. Investors who came to Portugal for a beachfront apartment in the Algarve are now placing capital in venture funds, scientific research grants, and cultural donations.

What Law 56/2023 actually changed

Law No. 56/2023, the "Mais Habitação" (More Housing) package, was a response to Portugal's housing affordability crisis. The law removed the following routes from Article 90-A of the Foreigners Act (Law No. 23/2007):

- Direct property purchase of EUR 500,000 (EUR 350,000 in low-density areas, EUR 280,000 for rehabilitation in low-density areas)

- Investment funds with real estate exposure

- Property purchase combined with rehabilitation

The legislative intent was explicit: the government wanted to redirect foreign capital out of the residential property market and into productive sectors. Applications filed before October 7, 2023 under the real estate route are being processed under the prior rules, with the Agência para a Integração, Migrações e Asilo (AIMA) working through a backlog that grew through 2024.

What still qualifies in 2026

Under the current version of Article 90-A and the corresponding regulatory framework, the qualifying investment categories are:

Investment funds, EUR 500,000. Subscription of units in qualifying Portuguese venture capital or private equity funds, with a maturity of at least five years, and at least 60 percent of the fund's portfolio invested in companies with headquarters in Portugal. Funds with direct or indirect real estate exposure are excluded by the Comissão do Mercado de Valores Mobiliários (CMVM) qualification rules.

Scientific research, EUR 500,000. Transfer of funds to a public or private scientific research institution forming part of the national scientific and technological system.

Cultural and artistic heritage donation, EUR 250,000. Donation to support artistic production, recovery, or maintenance of national cultural heritage through eligible public or private foundations.

Business creation, EUR 500,000. Incorporation of a commercial company combined with the creation of five permanent jobs, or a capital increase of EUR 500,000 in an existing Portuguese company with the same job-creation requirement.

Job creation, no minimum capital. Creation of at least ten permanent jobs in Portugal.

The most popular route in 2024 and 2025 by application volume has been the EUR 500,000 venture capital fund. The route works for investors who want exposure to Portuguese growth companies and do not have a specific charitable or research focus.

What the Golden Visa still buys

The visa itself is a five-year residency permit with minimal physical presence requirements: seven days in Portugal in the first year, fourteen days in each subsequent two-year period. After five years, holders are eligible to apply for permanent residency and Portuguese citizenship, subject to the standard language and integration tests under the Nationality Act.

Family reunification covers a spouse, dependent children, and dependent parents. The investor and family receive Schengen-area travel rights during the residency period.

Tax treatment is a separate question. The Non-Habitual Resident (NHR) regime was substantially curtailed by the 2024 State Budget, and the replacement "Incentivized Tax Status for Scientific Research and Innovation" (IFICI) regime is narrower and targets specific high-skill professions. Most new Golden Visa investors no longer get an NHR-equivalent tax holiday.

What real estate buyers should do instead

For investors whose primary goal was a Lisbon or Porto property rather than the residency itself, the property market remains open. Foreigners can buy Portuguese real estate without restriction under general civil law. The purchase simply does not generate residency rights.

For investors whose primary goal is European residency, the alternatives in 2026 are Greece (still permits real estate at EUR 250,000 to EUR 800,000 depending on zone), Spain (the Golden Visa was discontinued in April 2025), Cyprus (permanent residency by investment, real estate at EUR 300,000), and Malta (residency by investment with mandatory property purchase or lease). Each comes with its own residency obligations and tax positioning.

For investors evaluating any of these property-backed alternatives, developer due diligence matters more than the visa marketing. Bektu maintains developer profiles across the Mediterranean, useful when committing capital to a pre-construction project where delivery risk affects both the investment and the visa timeline.

For related reading on developers active in the region, see Bektu's coverage of property developers in Greece for foreign buyers in 2026 and property developers in Turkey for foreign buyers in 2026.

The bottom line

Property and the Portugal Golden Visa are now separate products. Buy property if you want Portuguese exposure. Subscribe a EUR 500,000 venture fund or commit EUR 250,000 to cultural heritage if you want the residency. Anyone telling you otherwise is working from a 2022 playbook.