Golden Visa Comparison: How the Major 2026 Programs Actually Differ

Residence-by-investment programmes are often marketed as variations on a single product. On the official texts they are not. They differ in what the capital must be spent on, whether it has to stay in place and for how long, how much time the investor must physically spend in the country, which relatives can be added and at what price, and whether the permit sits inside the European Union at all. One of the best-known programmes is no longer available: Spain’s investor visa was abolished with effect from 3 April 2025.

What follows sets out the comparable features of the major programmes as their own official sources state them, with the figures attached to the instrument that creates them. Where a source is silent on a point, that point is not filled in here.

What each programme requires as a minimum

Portugal

Portugal’s Residence Permit for Investment Activity (Article 90.º-A), administered by AIMA, grants a temporary residence permit to third-country nationals for investment activity. The legislation sets out four capital-transfer routes:

€500,000 applied in research activities carried out by public or private scientific research institutions integrated in the national scientific and technological system.
€250,000 applied in investment in or support for artistic production, or the recovery or maintenance of national cultural heritage.
€500,000 for units in non-real-estate collective investment undertakings, where the maturity at the time of investment is at least five years and at least 60% of the investment value is realised in commercial companies headquartered in Portugal.
€500,000 to incorporate a commercial company headquartered in Portugal, combined with the creation of five permanent jobs.

A hard exclusion applies: the investment activity may not be destined, directly or indirectly, to real estate investment.

Malta

The Malta Permanent Residence Programme Regulations (S.L. 217.26) define two qualifying property routes. A qualifying owned property is a residential immovable purchased, or acquired by title of emphyteusis, for consideration of not less than €375,000 in Malta or Gozo. A qualifying rented property is a residential property leased at a rent of not less than €14,000 per annum in Malta or Gozo. The consolidated text carries a schedule note recording substitution by L.N. 310 of 2024 and L.N. 146 of 2025.

Greece

The Greek entry documented in the National Registry (mitos.gov.gr) covers investment in a listed real property. The applicant must hold full ownership and possession of real estate in Greece consisting of a listed building or part of a listed building to be restored or reconstructed, or real estate within which a listed building is situated, with a minimum value at the time of acquisition of €250,000.

Italy

Italy’s investor visa, run by the Ministry of Enterprises and Made in Italy, is a 2-year visa for non-EU citizens who invest in strategic assets for the Italian economy and society. It lists four qualifying investments: €2 million in Italian government bonds, €500,000 in an Italian limited company, €250,000 in an Italian innovative startup, and €1 million in a philanthropic initiative.

The United Arab Emirates

The UAE’s Golden visa is described by the government platform as a long-term residence visa enabling foreign talents to live, work or study in the UAE. It is a renewable residence visa valid for 5 or 10 years. For investors, the platform gives 10 years for public investments and 5 years for real estate investments, with the conditions stated as a minimum capital of AED 2 million, and property ownership or a contribution to an establishment paying at least AED 250,000 annually in taxes.

Spain

Spain’s consular page carries the notice: “Investor visas will be abolished from 3rd April 2025.” The former thresholds — an initial investment of at least €2 million in Spanish public debt securities, or €1 million in stocks or shares, or the purchase of unencumbered real estate for a minimum of €500,000 — remain on the page for transition purposes.

Where the money has to go, and for how long

The holding rules are where these programmes diverge most sharply, and they are the part most often glossed over.

Portugal imposes the most explicit structure. The applicant signs a declaration of honour undertaking to meet the minimum quantitative and temporal requirements of five years. Renewal is conditional on evidence that the investment is maintained. The permitted vehicles are also constrained by design: the fund route requires a minimum five-year maturity and a 60% Portuguese commercial company content test, and the company route carries a five permanent jobs condition. The permit itself is valid for two years from the date of issue, so the five-year commitment runs across renewals rather than inside a single permit.

Greece ties renewal to continued holding. The official documents state that the immovable property remains in the ownership and possession of the interested party, or that the leasing of immovable property remains in force.

Malta’s regulations set the property thresholds and the payment timetable, but the pages checked for this comparison do not state a holding period for the qualifying property or the capital assets route, so no duration can be given here.

Italy and the UAE describe the visa term — two years for Italy, five or ten years for the UAE — but the pages checked do not set out a post-issue holding condition on the investment.

Staying put: residence duties

Portugal is the only programme among these with a stated minimum presence. The AIMA legislation requires the holder to remain in Portugal for no fewer than 7 days in the first year and no fewer than 14 days in subsequent years. The AIMA FAQ restates the requirement as seven days during the first year and fourteen days during each subsequent two-year period. Both wordings appear in the official material, and the difference between them is a matter to raise with a practitioner rather than to resolve here.

The UAE frames the point as a benefit rather than a duty: holders have the ability to stay outside the UAE for more than the usual period of six months needed to keep a residence visa valid.

The Malta, Greek and Italian pages checked for this comparison do not set out a minimum stay requirement, so no presence figure can be stated for them.

Family members: who can be added, and at what cost

Malta is the most explicit on price. There is a non-refundable administration fee of €7,500 for each and every dependant, payable within two months of the issuance of the Letter of Approval in Principle. The regulations then carve out an exemption: dependants falling within paragraphs (a), (b) and (e) of the definition of “dependant” in regulation 3 are not subject to any non-refundable administration fee. Those paragraphs are the spouse, a child under 18, and an adult child certified as having a disability. The fee therefore falls on the two categories that carry an age-and-dependency test: an unmarried child over 18 but under 29 who is principally dependent on the main applicant, and a parent or grandparent who is not in full-time employment and is principally dependent on the main applicant.

Portugal’s ARI page lists no per-person dependant fee. That is an absence in the official material, not a stated zero. It does list the age conditions on the family categories themselves, including children up to age 17, single children over 18 and up to age 25 who are studying, and siblings up to age 17.

The UAE states the ability to sponsor family members, including spouses and children, without giving age limits or per-person costs in the material checked.

Age thresholds do appear in the Maltese and Portuguese official texts, and are given above for Malta; the Greek, Italian and UAE pages checked for this comparison publish no dependant age rules.

What you actually receive

Every programme here delivers residence, and the documents describe residence rights only.

Portugal grants the right to reside and work in Portugal and to circulate in the Schengen area without a visa. The European Commission’s Your Europe portal confirms the EU/Schengen travel-document framework underlying that benefit. Within the Portuguese material, the only onward status documented is permanent residence, which requires a separate application under the Foreigners’ Law.

The UAE visa allows the holder to live, work or study in the UAE, and to sponsor family members. Italy’s instrument is a 2-year visa. Greece’s is an investor residence permit, issued as an electronic residence permit on renewal.

Four of the programmes compared — Portugal, Malta, Greece and Italy — sit in EU member states; the UAE does not. With Spain’s investor visa abolished, those four are the EU-based routes covered here.

Cost layers beyond the investment

The headline threshold is rarely the whole outlay. Malta’s regulations set out the layers in the most detail:

A non-refundable administration fee of €60,000 for the main applicant, of which €15,000 is due within one month of submission and the remaining €45,000 within two months of the issuance of the Letter of Approval in Principle.
A government contribution of €37,000 in respect of the main applicant, payable within eight months — the same amount whether the title is a qualifying owned property or a qualifying rented property.
€7,500 per dependant, unless exempt.
€14,000 per annum rent, where the rented-property route is used.
The use of an agent is mandatory: “An individual making any application in terms of these regulations shall make use of the services of an agent.”

Greece sets two charges on the renewal pathway: an electronic fee amounting to €2,000 under Article 132 of Law 4251/2014, and a €16 fee for the printing of the separate document, the electronic residence permit.

Portugal’s renewal is conditional on payment of the applicable fees, among other items — a valid passport or travel document, a regularised tax and social security position, a criminal record certificate where applicable, evidence of healthcare cover, evidence the investment is maintained, compliance with the minimum stay periods, means of subsistence and proof of accommodation. The ARI page does not list an amount for those fees or any per-person dependant charge.

No fee figures for Italy or the UAE appear in the sources checked, and no total programme cost for any programme can be calculated from them.

Limits of this comparison

Three things are deliberately absent. No processing time is given for any programme, because none of the official pages checked states one. No total programme cost is given, because the sources do not support it. And no day-count is given for short stays in the Schengen area, because no official page checked in this exercise stated the rule verbatim.

Frequently Asked Questions

Can I still get a Portuguese golden visa by buying property?

No. The legislation states that the investment activity may not be destined, directly or indirectly, to real estate investment. The surviving routes are research funding, cultural production or heritage support, non-real-estate collective investment undertakings, and company formation with job creation.

Is the Malta administration fee refundable if the application fails?

The regulations describe the €60,000 main applicant administration fee and the €7,500 per-dependant fee as non-refundable. They are also staged: €15,000 within one month of submission and €45,000 within two months of the Letter of Approval in Principle for the main applicant, with dependant fees due within two months of that letter.

How long does the UAE golden visa last, and must I live there?

The visa is renewable and valid for 5 or 10 years. Investors are shown as 10 years for public investments and 5 years for real estate investments, with a minimum capital of AED 2 million. Holders may stay outside the UAE for more than the usual six-month period that would otherwise be needed to keep a residence visa valid.

Which documented entry threshold is the lowest?

On the figures in the official texts, the lowest minimum investment documented here is €250,000, appearing under both the Portuguese cultural route and the Greek listed-property route, alongside Italy’s €250,000 innovative startup route. The comparison is arithmetic only; the routes differ in what the money must be spent on and what holding duties follow.

Does any of these programmes lead to a passport?

The documents checked describe residence rights, not citizenship. The only onward status documented in them is Portugal’s permanent residence, which requires a separate application under the Foreigners’ Law. No source checked here sets out a passport outcome for any of the programmes.

Is Portugal’s five-year requirement a single permit?

No. The temporary residence permit is valid for two years from the date of issue. The five-year figure is the minimum quantitative and temporal commitment for the investment activity, given through a declaration of honour and tested again at renewal through evidence that the investment is maintained and that minimum stay periods have been met.

Official Sources Checked

Sources checked: 3 October 2026 (UTC). Consolidation note on the Maltese regulations records substitution by L.N. 310 of 2024 and L.N. 146 of 2025.

Disclaimer: This article is provided for general informational purposes only and is not legal, tax, investment or immigration advice. Every figure, threshold, fee and requirement should be verified against the current official source before any decision is taken, as programmes and their implementing rules change and official pages are updated without notice. The publisher is independent and is not affiliated with, endorsed by, or acting on behalf of any of the governments or authorities named on this page.