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 large parts of 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 preliminary municipalities are listed on pages 2-4 in this document), as well as in the autonomous regions of Madeira and the Azores. There may be some changes to this based on litigation, but to be on the safe side it’s better to assume that this list is correct.

The law specifically only refers to real estate meant for housing (“habitação”), which means that investments in commercial real estate—such as hotels—will still be allowed in these regions in 2022 and beyond.

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It may help to know that in case you don’t have time to receive the deed for your property purchase in time for submitting your application by December 31, 2021, you may apply with a promissory contract (registered at the land registry)—as long as you’ve already transferred the full investment amount.

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.

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⚠️ Webinar Alert: Golden Visa through professional investments in real estate or R&D, or diversifying into both

Hosted by: Lince Capital

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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, then you might have missed the train already. Especially, if you don’t have a NIF and Portuguese bank account yet.

The December 31, 2021 deadline refers to when you will need to have submitted your Golden Visa application, and by that time the investment amount has to be transferred and received.

To be an the safe side, 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.

If you still want to submit your application within this year, I would highly recommend getting in touch with an experienced lawyer asap, so that they can advise you on the most efficient way of proceeding. Here, you will find a list of the most popular law firms among our readers.

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.