Golden Visa Portugal — Lawyer for Investment Residency

The Portugal Golden Visa (officially the Residence Permit for Investment Activity, ARI) is the regime in Article 90.º-A of Lei n.º 23/2007. The October 2023 reform (Lei n.º 56/2023, the Mais Habitação law) removed the real-estate routes: under Article 3.º(1)(d) the qualifying investment activities may not be directed, directly or indirectly, at real estate (AIMA ARI page (Art. 90.º-A)).

Two things distinguish a clean Golden Visa engagement: (a) understanding which qualifying route fits your liquidity and risk profile, and (b) structuring the investment in a way that AIMA accepts without challenge. Some agencies and fund promoters in this space earn commissions on the investment product they push, so ask any adviser how they are paid.

Qualifying investment routes (post-2023 reform)

The routes below are the investment activities listed in Article 3.º(1)(d) of Lei n.º 23/2007, as published on the AIMA ARI page (Art. 90.º-A). The investment must be made for a minimum period of five years. Real estate is excluded. For the routes that allow it, the amount or requirement can be reduced by 20% in low-density territories; AIMA lists the territories under Portaria n.º 208/2017. Check the current text before you decide: the rules have changed several times.

• Qualifying investment funds — €500,000 minimum. Units in non-real-estate collective investment undertakings set up under Portuguese law, with a maturity of at least five years at the time of investment and at least 60% of the investments made in companies based in Portugal (sub-paragraph vii).
• Job creation — at least 10 jobs. No minimum capital is specified; the requirement can be reduced by 20% (to 8 jobs, per AIMA) in low-density territories (sub-paragraph ii).
• Scientific research — €500,000 minimum. Capital applied to research carried out by public or private institutions in the national scientific and technological system (sub-paragraph v). AIMA gives €400,000 as the amount in low-density territories.
• Cultural patronage — €250,000 minimum. Capital applied to artistic production or to the recovery or maintenance of national cultural heritage, through the public and non-profit entities listed in the law (sub-paragraph vi). The 20% reduction can apply in low-density territories.
• Capitalisation of Portuguese companies — €500,000 minimum. Capital for setting up a company with its seat in Portugal and creating five permanent jobs, or for increasing the capital of an existing one while creating at least five permanent jobs or keeping at least ten jobs (at least five permanent), for a minimum of three years (sub-paragraph viii).

There is no longer a capital-transfer route and no real-estate route. If an adviser quotes you one, ask them for the legal basis. If you plan to live in Portugal, compare the Golden Visa with the D7, D8 and D2 before you commit capital.

Who the Golden Visa is for

The programme exists for third-country investors who want residence in Portugal and a path to permanent residence or citizenship without moving full-time. It does not apply to Portuguese nationals or to nationals of the EU, EEA, Andorra or Switzerland (AIMA ARI page (Art. 90.º-A)). The key feature is the low minimum-stay requirement: AIMA states at least 7 days in Portugal in the first year and at least 14 days in the following years; the Decreto Regulamentar sets the 14 days per subsequent two-year period (Decreto Regulamentar n.º 15-A/2015).

Profiles for whom the Golden Visa is typically considered:

• Investors who want EU residence as a second option without relocating
• Entrepreneurs from outside the EU looking for a long-term path to EU residence and, eventually, citizenship
• Families positioning for their children's education and freedom of movement
• Investors with diversified portfolios looking for a productive EU allocation
• Professionals planning eventual retirement in Europe but not ready to move now

Presence, timeline and what the permit leads to

Below the headline amount, several practical points shape every Golden Visa engagement:

• Minimum presence: see the figures above, from AIMA and the Decreto Regulamentar. Keep travel records so you can show you met them when you renew.
• Application processing: we do not quote a processing time because we cannot tie one to an official source. AIMA requires online pre-registration on the Portal ARI before filing, and processing times change; ask for the current position before you invest.
• Validity: AIMA states that the temporary residence permit for investment is valid for two years from issue. Renewal requires you to show the investment has been maintained. Since 16 February 2026 AIMA takes ARI renewal requests and fees only through its Portal de Renovações; you attend in person only if AIMA schedules biometrics (AIMA notice on ARI renewals).
• Permanent residence: holders and family members who meet Article 80.º of Lei n.º 23/2007 can ask for permanent residence (AIMA ARI page (Art. 90.º-A)).
• Portuguese citizenship: ARI holders can apply for naturalisation if they meet the requirements of the Nationality Law. The rules changed in May 2026 (Lei Orgânica n.º 1/2026; Ministry of Justice notice on the new Nationality Law), including the period of legal residence: seven years for nationals of EU Member States and Portuguese-speaking countries and ten years for others. For applications filed since 19 May 2026, the time spent waiting for a residence permit decision no longer counts on its own, because the rule that counted residence from the permit request (Article 15(4)) was repealed.
• Family inclusion: AIMA lists as family members the spouse, children up to 17 or incapable and dependent, unmarried dependent children aged 18 to 25 who are studying, dependent parents and grandparents in the direct line (first degree, per AIMA), and siblings up to 17 under the applicant's guardianship. Dependency must be proved.

Documents typically required

AIMA publishes the documents required for each sub-paragraph on its AIMA ARI page (Art. 90.º-A). In general they include:

• Valid passport or other travel document and proof of legal entry and stay in Portugal
• Proof of the qualifying investment: bank statement of the transfer, fund-unit certificate and management-company declaration, cultural or research entity declaration, or employment contracts for job creation, depending on the route
• Criminal-record certificate from your country of origin, or the country or countries where you have lived for more than a year, issued shortly before filing and translated into Portuguese as AIMA specifies
• Honour declaration that you will meet the quantitative and time requirements of the investment (five years)
• Proof of regular tax and social security position (AT and Segurança Social certificates)
• Proof of health coverage: SNS or recognised health insurance for the period of residence
• Tax identification number (NIF), a Portuguese bank account in your name and, where you use a lawyer, a power of attorney
• Proof of the source of funds. Banks and AIMA can ask for it, so prepare it before you invest.

Process and timeline

1. 01

   Pre-engagement

   Lawyer assesses your profile and which qualifying route fits. AML/KYC review of source of funds. NIF and Portuguese bank account opened in your name via power of attorney.

2. 02

   Investment execution

   Investment is made into the qualifying instrument (fund subscription, donation, company capital, etc.). Confirmation of receipt from the receiving entity is obtained.

3. 03

   AIMA submission

   Pre-registration and file submission on AIMA's Portal ARI, with the documents required for your route and the application fee. Ask AIMA or your lawyer what the current stage means for your qualifying date.

4. 04

   Biometric appointment

   When AIMA schedules it, you travel to Portugal for biometrics. Check what AIMA asks for in your notice.

5. 05

   Card issuance

   Residence permit valid for two years (AIMA). Renewals require proof that the investment is maintained.

6. 06

   Later milestones

   Apply for permanent residence or for naturalisation when you meet the legal requirements. For naturalisation, see the current Nationality Law.

Why you need a Portugal Golden Visa lawyer

The law does not make a lawyer compulsory. A lawyer earns the fee on four points:

• The route. The investment must fit one of the routes in Article 3(1)(d) of Lei n.º 23/2007 and may not be directed at real estate, directly or indirectly.
• The source of funds. The file must show where the money comes from and how it reached Portugal.
• The AIMA file. The application, the biometrics and the documents AIMA asks for, for you and each family member.
• Renewals and what comes next. Keeping the investment and the stay requirements through each renewal, and then permanent residence or citizenship.

Where a lawyer earns the fee

Investing from the United States? Read our guide to choosing a Portugal Golden Visa lawyer as a US citizen: how to check a lawyer’s registration, the US documents AIMA asks for and the US tax points to raise.

The Golden Visa is unusual in that the investment is the dominant cost and the legal fee is small in proportion. That asymmetry can attract intermediaries paid by the investment provider rather than the investor. Points to watch:

• Fund brokers may receive commissions from the funds they recommend. That is paid out of the investor's economics, so ask whether any commission applies and how much.
• Advisers selling anything that depends on real estate. The real-estate routes were removed, so ask for the legal basis of what you are offered.
• Source-of-funds files need to survive bank-grade review. Prepare the documents before you invest.
• Fund quality varies. Ask for the management company's declaration and check the fund meets the maturity and 60% conditions listed above.

A lawyer who is paid only by you has no economic interest in which qualifying route or fund you pick. Ask any adviser how they are paid.

Common Golden Visa mistakes

• Picking a fund on the broker's pitch rather than on legal due diligence. Check the fund's maturity, the 60% condition and the documents AIMA requires.
• Underestimating source-of-funds documentation. Gaps here cause delay.
• Treating the residence permit as a passport. Citizenship needs a separate application and the conditions of the Nationality Law.
• Missing the minimum-stay requirements. Keep records of your days in Portugal for each period.
• Disposing of the investment too early. The law requires the investment activity to be kept for a minimum of five years.
• Choosing the wrong family structure. Including parents, siblings or adult children requires proof of dependency, so plan this at the start.