Property purchases
Not an eligible route for new ARI applications
Portugal still offers investment residence under Article 90-A, but property acquisition is no longer a new qualifying route. Compare the surviving categories, legal and financial risk, AIMA steps, and the separate nationality rules.
Last researched: 19 October 2026 · Primary legislation and AIMA reviewed · No approval guarantees
Since the 2023 reform, purchasing Portuguese real estate does not qualify a new ARI application; using an investment vehicle to channel funds indirectly to real estate also requires careful statutory exclusion analysis. AIMA currently lists employment creation, approved research and culture, qualifying non-real-estate collective investment, and company-capital/job options. See the AIMA source links below.
Not an eligible route for new ARI applications
At least €500,000 with additional statutory criteria
€250,000 general statutory route; verify low-density variants
Separate process under 2026 rules; never promise a five-year passport
A carefully verified guide to the surviving legal routes, investment diligence, AIMA procedure, residence obligations and the redesigned path to long-term status.
Golden Visa is not a real-estate purchase visa in 2026. The ARI residence scheme survives through qualifying alternatives; no investment guarantees a permit, capital preservation or nationality. G1, G4, G6
| Available statutory route | Headline condition | Evidence and caution |
|---|---|---|
| Job creation | At least 10 jobs | Evidence of actual employment, statutory qualifying conditions and maintenance; AIMA describes an eight-job low-density reduction where applicable. G1 |
| Scientific research | €500,000 transfer | Qualifying Portuguese research institution and documented capital application; AIMA describes €400,000 in eligible low-density areas. G1 |
| Arts & cultural heritage | €250,000 transfer | Through an eligible institution and official cultural certificate. Low-density reductions require case-specific verification; do not assume an advertised discount is correct. G1 |
| Non-real-estate collective investment | €500,000 fund units | Portuguese-law vehicle, at least five years to maturity at investment and at least 60% invested in Portuguese-headquartered companies; direct/indirect property investment prohibited. G1 |
| Company incorporation / capital reinforcement | €500,000 plus employment | Company with Portuguese registered office and required permanent jobs, or qualifying reinforcement and employment maintenance for the prescribed term. G1 |
This table maps requirements; it does not substitute for a case-specific immigration decision or current authority checklist.
Each chapter links a legal proposition to the evidence that would need to support it.
Portugal’s Autorização de Residência para Investimento (ARI), commonly called the Golden Visa, continues under Article 90-A of Law 23/2007. It is a residence-permit regime for eligible third-country investors undertaking statutorily defined activity. The real-estate acquisition options were removed for new applicants; older headlines about a €280,000 or €500,000 property route should not be used as a current eligibility statement. G1, G4
A qualifying investment is necessary but not sufficient. The investor must also meet personal, documentary, legal-stay and administrative requirements. The portfolio or institution must meet the precise statutory route—not merely claim to be “Golden Visa compliant” in a marketing brochure. G1
Earlier property-based applications and existing permits may raise distinct transition or renewal issues. Those cases require reviewing the date, legal basis and procedural stage of the original application rather than applying 2026 new-investment criteria mechanically.
The remaining categories are job creation; qualifying scientific research funding; specified artistic production or cultural-heritage support; Portuguese non-real-estate collective investment vehicles; and qualifying company capitalisation linked to employment. Thresholds and evidence differ materially. G1
The programme is not a one-size-fits-all “€500,000 payment”. A fund investment requires a fund-specific legal analysis. A cultural contribution needs confirmation from competent cultural authorities. Research relies on eligible institutional activity. Company-capitalisation routes include job creation or maintenance obligations. G1
For low-density projects, AIMA describes reductions for particular categories; qualification must be confirmed against the legally defined territory and the specific route. Never apply a generic 20% reduction to a fund investment without statutory support.
AIMA explicitly states that qualifying investment activity cannot be directed to real estate, directly or indirectly. This is important for investors considering funds with property subsidiaries, development exposure, financing arrangements or underlying assets marketed as “hospitality” or “infrastructure”. G1
The existence of a CMVM-registered fund, bank custodian, independent manager or legal opinion does not by itself prove ARI eligibility. Immigration criteria and investment regulation are different tests. A prospective investor should obtain an independent assessment of investment policy, look-through exposure, ownership, redemption constraints and reporting rights. G1, G7
The question should not be “Does the promoter sell Golden Visas?” It should be “Can the legal instrument, use of proceeds and supporting evidence withstand an AIMA review at filing and renewal?”
For the collective-investment route, AIMA lists a minimum €500,000 acquisition of units in non-real-estate Portuguese-law investment vehicles, a maturity of at least five years when the investment is made and investment of at least 60% into commercial companies with registered offices in Portugal. Multiple eligible funds may be used subject to statutory and evidentiary requirements. G1
Request the prospectus or regulations, investment policy, historical or projected composition, fees, conflicts disclosures, custodian confirmation, investor-unit ownership documents, manager declaration, liquidity provisions, sanctions policy and an independent tax review. Verify relevant registration and authorisation directly with the CMVM. G1, G7
Capital may be lost, locked up or returned later than anticipated. “Guaranteed returns”, “guaranteed buyback” and “guaranteed visa” are not credible substitutes for documented investment and immigration risk analysis.
Qualifying research requires money to be applied to specified Portuguese scientific or technological research activity; AIMA lists €500,000, with a €400,000 low-density route in qualifying circumstances. A supporting statement from the relevant research institution forms part of the documentary basis. G1
Cultural production and national-heritage support have a €250,000 baseline, subject to specified recipient types and a certificate confirming the relevant nature of the support. AIMA’s public page contains an internally inconsistent example for the 20% reduction; this page does not quote a reduced euro figure without independent legal and institutional confirmation. G1
Employment and company routes require genuine, documented jobs and statutory continuity. A dormant company, nominal payroll or a transaction structured chiefly to create paper compliance presents serious immigration and corporate risks. G1
ARI generally serves qualifying third-country nationals rather than EU/EEA/Swiss or Portuguese citizens. Identity, valid travel documents, legal entry or stay where relevant, health coverage, background certificates, fiscal identification and Portuguese tax/social-security clearance or proof of non-registration may form part of the evidence. Individual circumstances and the precise AIMA checklist determine the final pack. G1
Evidence for source of funds, sanctions and AML due diligence should be prepared in parallel with the investment. A clean bank transfer alone does not resolve tax-residence, regulatory or financial-source concerns. Legalisation and certified translations require planning because some official certificates have limited validity periods.
Where a company structure is used, documentary proof of beneficial ownership, control, capitalisation and the route-specific legal basis is essential; a complex cross-border chain increases the compliance burden.
A robust sequence is: eligibility screening; independent review of the proposed investment; KYC/AML and source-of-funds work; account and transfer arrangements; investment execution; collection of bank and institution/fund certificates; registration and submission via the ARI portal; payment; AIMA review; biometrics/appointment where required; decision and issuance. G1, G2
The ARI portal also supports family files and representation by a duly authorised legal representative. Family approval remains conditional on the underlying investor application being approved. Submitting a portal form or paying an analysis fee does not mean that the permit has been granted. G1, G2
Timeframes can vary materially. A commercial “fast-track” estimate is not a legally guaranteed AIMA processing date.
AIMA states a minimum stay of seven days in the first year and fourteen days in the following two-year periods under the applicable law. Keep robust travel evidence and verify how the requirement maps onto the issuance and renewal dates in each case. G3
Renewal is not automatic: investment maintenance, continued personal eligibility, tax/social-security status, insurance, accommodation or subsistence evidence and payments may be reviewed. From 16 February 2026, ARI renewal submissions are processed electronically through AIMA’s renewal portal, with attendance where biometrics are subsequently requested. G2, G3, G8
These physical-presence rules belong to Article 90-A ARI. AIMA warns that the separate Article 122(1)(r) investment-based authorisation is not equivalent and does not carry the same absence benefits. G10
Under the 2025 family-reunification reform, families of Article 90-A investors fall within a specific exception to the ordinary two-year sponsor waiting period. AIMA also permits family-related submissions within the ARI portal framework, subject to the relationship, documents, sponsor approval and current procedure. G1, G2, G9
Qualifying relationships can include spouses, dependent minor children and certain older dependants under the applicable provisions. Adoption, custody, financial dependency and student status must be evidenced where relevant. Do not treat every parent or adult child as automatically eligible.
Family status, fees and renewals must be budgeted per person. Investors should prepare marriage and birth records early because apostilles, recognition and translations may be time-consuming.
Holding an ARI permit can support a subsequent application for permanent residence if the legal conditions are met. AIMA describes a specific permanent investment-residence status with treatment of absence rules. Permanent residence remains an application with independent criteria, not an automatic ARI upgrade. G5
Citizenship follows a different statute. Organic Law 1/2026 (effective May 2026) sets general naturalisation residence periods at seven years for EU and Portuguese-speaking-country nationals, and ten years for other nationalities, alongside further language/culture, civic and substantive requirements, and transitional treatment for pending procedures. G6
Therefore “Portuguese passport in five years” must not appear in a new 2026 marketing page. Applicants should obtain an individual legal opinion on residence-time calculation, transitional rules, nationality category and the law applicable on the eventual filing date.
Separate the qualifying investment from taxes, AIMA administrative fees, legal fees, banking fees, investment fund subscription and ongoing charges, translation/attestation costs and family-file costs. Amounts and administrative fees may change and should be checked against current AIMA schedules before payment.
Request written disclosure of referral commissions, distribution agreements, fund-manager remuneration, custody, exit restrictions, redemption risk and responsibility if immigration criteria change. Independent immigration counsel and regulated investment advice should not be blurred into a single sales pitch.
A €500,000 commitment does not mean €500,000 will be returned. Tax advice is also required: ARI approval does not automatically determine Portuguese tax residence or guarantee tax exemptions.
An investor who applied under a real-estate regime before reform needs a transition audit, not instructions for a new property application. An investor with an indirect property fund exposure needs look-through legal review. A business investor who loses qualifying jobs may face ongoing compliance risk. G1
A fund with a five-year stated term may have extensions, illiquidity or exposure inconsistent with the statutory test. Another fund may be perfectly regulated but unsuitable for ARI. Fund regulation and immigration permission are separate questions. G1, G7
Families considering relocation for school need to distinguish low-stay residence rights from the practical requirements of actually living, paying taxes, enrolling children and obtaining healthcare in Portugal.
Stage 1 — legal route screening: nationality, family composition, immigration history and objective. Stage 2 — independent diligence: proposed investment, ownership, origin of capital and regulated-provider checks. Stage 3 — evidence architecture: statutory route mapping, document expiry dates and source-to-claim matrix. Stage 4 — filing coordination: clear responsibility across investor, lawyer, bank and manager. Stage 5 — renewal calendar and travel-evidence control.
The purpose is to identify weaknesses before capital is irreversibly committed. Portugal Path should clearly distinguish immigration guidance from independent legal, tax or regulated financial advice, using qualified external professionals where needed.
Our position is simple: never present an approval probability as a guarantee, never equate an advertised fund with verified statutory compliance, and never sell nationality as an automatic consequence of an investment.
Illustrative screening cases, not client testimonials, approval predictions or personalised legal advice.
Assessment: Not a current new-entry ARI route. Assess an appropriate alternative under present law.
Key risk
Property-era sales pitch mistaken for live eligibility. G1
Assessment: Commission an independent fund/immigration legal review; verify CMVM, structure and 2026 nationality rules.
Key risk
Financial loss, misleading nationality claim and property look-through exposure. G1, G6, G7
Assessment: Route cannot rest on incorporation alone; test job conditions, permanence and evidentiary continuity.
Key risk
Failure to create or maintain statutory employment. G1
Assessment: Screen ARI family process and dependency evidence; manage individual documentation and renewals.
Key risk
Assuming family approval is automatic or all adult children qualify. G1, G9
Citizenship; passports; immigration history; tax jurisdictions; family map; background compliance.
Statutory category; amount; no property use directly/indirectly; term and continuity; specific certificates.
Source of wealth/funds; banking route; provider authorisation; risk/fees; conflicts and custody.
Portal profile; identity and background records; transfer and ownership confirmations; legalisations; fee evidence.
Presence logs; renewal reminder; employment/investment continuity; family changes; nationality-law recheck.
Each factual assertion should be supported by a current, authentic document. Identity, chronology, legal basis, money flow and third-party verification must tell one consistent story. Specialist representation may be required.
Substantive answers, with references to the relevant primary source codes below.
No. The investment-residence permit (ARI) remains available under Article 90-A through specifically defined investments. It is incorrect to equate the removal of new property investment pathways with abolition of the entire programme. G1, G4
Property acquisition is not an eligible route for a new ARI application under the post-2023 framework. Older submissions and renewals may raise transitional questions and should be evaluated on their own legal history. G1
It depends on the route. The public AIMA guidance includes €250,000 for qualifying culture, €500,000 for specified research, funds and company-capital routes, and a job-creation option without the same headline capital transfer. Each has additional conditions. G1
No. The collective-investment vehicle must satisfy Portuguese-law, non-real-estate, maturity and Portuguese-company investment rules. The investor also must satisfy personal and documentary conditions. G1
For the qualifying collective investment route, AIMA describes at least 60% of investment allocated to commercial companies with registered offices in Portugal. This is a fund-level condition; independent legal review is needed to test the actual portfolio and governing documents. G1
AIMA discusses investment in units of multiple qualifying funds where the combined value and other applicable conditions are satisfied. It is not permission to combine qualifying and non-qualifying holdings indiscriminately. G1
No. Securities regulation is not the immigration eligibility test. Verify the fund and manager with CMVM, then independently assess the specific ARI criteria and indirect property exposure. G1, G7
No general capital-protection guarantee exists in the ARI law. Funds and company investments may decline, be illiquid or fail. Examine legal terms, fees and risks before subscribing.
Yes, through a qualifying route involving at least €500,000 applied to eligible scientific or technological research activities, subject to documented institutional requirements. AIMA identifies a potential €400,000 option in qualifying low-density circumstances. G1
No. The law specifies qualifying investment/support through designated public or public-interest channels with proper confirmation. General charitable giving or purchase of an artwork is not enough. G1
No. AIMA identifies reductions in particular pathways, such as eligible job creation and research. The cultural-page euro example is internally inconsistent; obtain route-specific written verification rather than relying on an advertised discount. G1
A qualifying corporate route includes company formation or capital increase coupled with legally prescribed permanent job creation or maintenance. Merely registering a company or moving €500,000 to its account is insufficient. G1
ARI has a comparatively limited minimum physical-presence requirement: AIMA states seven days in the first year and fourteen days in subsequent two-year periods. Correct individual-period calculations and travel evidence matter. G3
AIMA describes residence and work rights for valid ARI holders, subject to other applicable professional and tax rules. The permit is not a substitute for regulated-profession licensing. G1
AIMA describes ARI family procedures in its portal and notes family approval depends on the investor’s approval. Which relatives qualify requires checking the relationship, age, dependency and applicable law. G1, G2
The 2025 reform names Article 90-A investment-residence holders among exceptions to the ordinary waiting period. Other eligibility and documentation requirements still apply. G9
Sometimes, subject to the particular dependency, marital status, student and ARI-related conditions. Adult children are not automatically eligible simply because their parent holds ARI. G9
AIMA checks the digital submission and supporting documents, processes fees and, when appropriate, issues instructions for attendance and biometrics. Portal submission is not a positive residence decision. G2
If renewing on the original investment basis, AIMA expects evidence of continuing compliance and maintenance of the relevant investment as applicable. Exiting an investment prematurely may jeopardise status. G3
AIMA moved ARI renewal submissions to its renewal portal from 16 February 2026; an in-person visit may still be requested for biometrics. Current portal requirements take precedence over older generic renewal instructions. G2, G8
Not automatically, and the blanket five-year citizenship claim is outdated after Organic Law 1/2026. New naturalisation rules refer generally to seven years for EU/CPLP nationals and ten for other nationalities, with additional requirements and transitions for pending matters. G6
It can: permanent residence follows the distinct Article 80 framework, with additional legal requirements. Permanent residence should not be confused with nationality, and special ARI permanent-residence rules must be assessed in context. G5
Not by itself. Physical presence, habitual residence and other tax tests must be analysed separately. Keeping an ARI without living full-time in Portugal can have very different tax consequences from relocating permanently.
No. Commercial agents and legal advisers cannot guarantee decisions by AIMA, and a claimed “government pre-approved fund” should be verified against actual documentary evidence and official sources.
AIMA analysis/issuance/renewal charges, legal representation, document legalisation/translation, banking, fund fees, custody, tax and family charges may apply. Obtain current written quotes; we do not publish stale fixed figures.
Historical property-route applications and issued permits can have transition and renewal questions. Preserve proof of filing and investment maintenance, and commission a targeted legal audit rather than using 2026 new-application checklists. G1
No. AIMA explicitly distinguishes the two investment-related residence routes, including different rights concerning permitted absences. Ask for the actual article under which you would be authorised. G10
The proposed process separates eligibility, financial-investment diligence, document provenance and continuing compliance. Recommendations are evidenced and risks are disclosed; investment, legal and tax advice should come from appropriately qualified professionals.
No. The property acquisition option was removed for new ARI applications. A purchase may have other private or tax implications, but it does not by itself generate new Golden Visa eligibility. Historic cases under former rules require a different review.
No. The Article 90-A collective-investment route includes a €500,000 threshold, non-real-estate character, Portuguese-law structure, a minimum remaining maturity criterion at investment and a minimum share of investments in Portugal-based companies. An advertised “Golden Visa fund” label is not legal certification.
No. The cultural route involves legally specified bodies and support for artistic production or national cultural heritage. The amount alone is not enough. Any advertised low-density reduction requires an up-to-date legislative and AIMA check because public summaries can be inconsistent.
AIMA describes a simultaneous family submission mechanism conditional on granting the investor’s ARI. Family identity, relationship, dependence and the specific statutory ARI exception still require documentary analysis.
No. Naturalisation is a separate application under the nationality law in force when relevant, with legal-residence duration and other criteria. The May 2026 reform introduced a seven-year or ten-year ordinary threshold depending on nationality group, with transitional treatment for pending procedures; do not equate this with ARI card validity.
AIMA states that from 16 February 2026 ARI renewal applications are processed electronically via its renewal portal. A later in-person biometrics appointment can still be required in specific circumstances.
Reference labels in the copy map to these sources. Recheck live authority wording, implementing rules and portal instructions immediately before publication or filing.
This page is general educational information. It does not constitute legal, tax, regulated financial or investment advice. Only the competent authorities decide applications.
Authority documents may change. Verify the applicable consolidated law, live AIMA procedure and jurisdiction-specific consular instructions before submitting or making financial commitments.
Start with a route assessment, not a promise. We examine facts, documents, timing and real constraints before discussing the next step.