Finally.

Finally, there is some degree of certainty around the future of the Portuguese Golden Visa program.

After a year of rumors and ever-changing semi-official announcements, on February 12, 2021, the actual updates to the law were published. It takes effect on January 1, 2022.

You may not like the new rules, but at least now they are official. Let’s take a look at what’s changing and what you should do about it.

What’s changing in 2022

No more real estate investments in Lisbon, Porto, or along the coast

If you want to qualify for the Portuguese Golden Visa through direct real estate investment, you can no longer invest in the two largest cities of Portugal, nor anywhere else along the coast of the mainland. That includes the Algarve, the “silver coast”, Sintra, and so on.

From January 1, 2022, you can only make qualifying investments in the interior of mainland Portugal (the exact municipalities are listed on pages 2-4 in this document), as well as in the autonomous regions of Madeira and the Azores.

Note: The law specifically only refers to real estate meant for housing (“habitação”), which some take to mean that investments in commercial real estate—such as hotels—will still be allowed in these regions in 2022 and beyond. Personally, I would not want to rely on this exception until there is more legal clarity on this point.

⚠️ Webinar alert: On February 18, 2021, OptylonKrea hosted a webinar for those still interested in going the real estate route in Lisbon, where they also covered the 2022 Golden Visa changes and what they mean for you.

📼 Watch the webinar

Increased minimum investments for funds: €500,000

While the limitations on real estate investments along the coast have been expected for over a year, many had hoped that the investment fund route would prove to be a good alternative for those wanting a high-quality investment at a reasonable entry price.

It may still prove to be a popular path, but the increase from €350,000 to €500,000 minimum investment may put some people off the idea.

Luckily there are still plenty of funds to pick from that you can invest in from just €350,000 in 2021.

Increased minimums for other capital transfer routes

While less popular than the fund and real estate routes, it’s worth noting that the other capital transfer options are also seeing their minimums increase. The R&D route and company formation options are increasing from €350,000 to €500,000, and the pure “transfer a bunch of money to a Portuguese bank account and let it sit there” option will now require a €1.5 million commitment rather than the previous €1 million.

What is not changing?

If you had plans of launching a Portuguese company employing at least 10 locals or making a €250,000 investment in support of the arts, well, then you’re in luck: Nothing will change for these options.

None of the changes will apply retroactively to anyone who submits their Golden Visa application before December 31, 2021.

In other words, if you apply for the GV in 2021, you’ll be grandfathered into the current rules, including for any future renewals of your status.

What should you do about the announced changes?

If you are planning to invest in real estate in Lisbon, Porto, or along the coast, well, then you better hurry. You still have time, of course, but the sooner you get started, the better.

The December 31, 2021 deadline refers to when you will need to have submitted your Golden Visa application. So to be on the safe side, I’d recommend finalizing your investment as soon as possible.

Better yet, consider making an investment with a reputable company such as Mercan who will buy back your investment in case your application is denied.

Also, get started on collecting the information needed for your application. In many countries (e.g. the United States), it may take a few months to get a copy of your criminal records, for example.

The same goes if you would like to qualify for the Golden Visa by making a €350,000 investment into an investment fund. While applications based on this type of investment typically result in less paperwork needing to be collected from the Portuguese side, it may still take a while to get your tax number, open a bank account, etc.

Or perhaps you don’t mind the increased investment amounts—in which case there is no need to rush things.


What will you do? Join the discussion in the Nomad Gate community.