Portugal Golden Visa (ARI) 2026: The Fund, Research, and Cultural Heritage Routes After the Real Estate Ban

ARI Is Open, but Real Estate Is Not

Portugal’s Autorização de Residência para Investimento (ARI), commonly called the Portugal Golden Visa, has operated since 8 October 2012 and remains open to new applicants in 2026 — one of only three principal EU golden visa programs still accepting applications, alongside Greece and Malta, following Spain’s closure on 3 April 2025. But the program that exists today is structurally different from the one most third-party marketing content still describes. Law 56/2023, of 6 October, removed real estate investment from ARI’s qualifying routes entirely, and the program’s administering authority, AIMA (Agência para a Integração, Migrações e Asilo), now processes ARI applications exclusively under non-property investment categories.

Any content describing a Portugal Golden Visa “starting at €280,000 for property in a low-density area” is describing the pre-October-2023 program and should not be relied upon for a 2026 application.

The Four Remaining Investment Routes

Per AIMA’s current official guidance under Article 90-A of the applicable legislation, ARI applicants may qualify through one of the following:

1、Job creation — incorporation of a company creating at least 10 full-time jobs (or 8 jobs, an automatic 20% reduction, if located in a designated low-density territory). This route has no fixed minimum capital requirement, but carries substantial administrative and ongoing operational burden, making it impractical for most passive investors.

2、Scientific research — capital transfer of at least €500,000 (reduced to €400,000, a 20% discount, in low-density territories) applied to research activities carried out by public or private scientific research institutions integrated into Portugal’s national scientific and technological system.

3、Cultural heritage and artistic production — capital transfer of at least €250,000 (reduced to €220,000 in low-density territories) directed to artistic production, or to the recovery or maintenance of national cultural heritage, channelled through designated public or public-interest cultural entities.

4、Investment fund subscription — capital transfer of at least €500,000 into units of Portuguese-law non-real-estate collective investment undertakings, with a minimum fund maturity of at least five years at the time of investment, and at least 60% of the fund’s investment value deployed into commercial companies headquartered in Portugal.

A fifth route — company incorporation with at least €500,000 in capital, combined with the creation of five permanent jobs, or capital reinforcement of an existing Portuguese company with the creation of at least five permanent jobs (or maintenance of at least ten jobs, five of them permanent, for a minimum of three years) — is also listed by AIMA. None of the four capital-based routes may be directed, directly or indirectly, toward real estate investment; AIMA’s guidance states this restriction explicitly for each qualifying capital-transfer category.

Why the Investment Fund Route Dominates Investor Interest

Among sophisticated investors, the investment fund route has become the default ARI pathway, for a structural reason distinct from Greece’s or the UAE’s real-estate-anchored options: it is the only ARI route offering genuine portfolio diversification and professional fund management rather than a single concentrated capital deployment, donation, or direct property holding. Because the qualifying funds must be CMVM-regulated (Portugal’s securities market regulator) and maintain at least five years of maturity with the 60%-Portugal-deployment rule, investors are effectively buying exposure to a basket of Portuguese private companies through a regulated collective-investment wrapper rather than picking a single asset. This carries genuine fund-manager selection risk, redemption-timing risk tied to the fund’s own liquidity terms, and fee-drag risk that a direct real estate purchase would not carry — due diligence on the specific fund manager’s track record, fee structure, and portfolio composition is a materially different exercise from the property due diligence ARI applicants performed before 2023.

Physical Presence, Family, and the Path to Citizenship

ARI’s minimum physical presence requirement remains among the lowest of any residency-by-investment program: AIMA requires a minimum stay in Portugal of seven days in the first year and fourteen days in each subsequent two-year period. This low-presence structure is central to ARI’s appeal relative to programs requiring substantial annual residence.

Family reunification can be requested simultaneously with the main applicant’s ARI application, though it remains conditional on approval of the main application. Eligible family members include the spouse, dependent children and adopted children under 17 (or under 25 if unmarried, dependent, and enrolled in education), ascendants of the applicant or spouse in the direct first-degree line who are dependent on them, and dependent siblings under 17 under specific guardianship conditions. ARI does not apply to Portuguese nationals or to nationals of the EU, EEA, Andorra, or Switzerland, since those groups already hold separate rights of establishment.

ARI holders may apply for Portuguese permanent residence under the general Foreigners’ Law, or apply for Portuguese nationality by naturalisation under the Nationality Law, once they separately satisfy the requirements each of those regimes independently imposes — commonly summarised as a five-year holding period plus an A2-level Portuguese language requirement for naturalisation, though applicants should confirm the complete current naturalisation criteria with AIMA or a licensed Portuguese immigration lawyer rather than relying on ARI eligibility alone, since AIMA’s own guidance is explicit that these are separate legal outcomes each requiring independent qualification, not automatic consequences of holding ARI status.

The Investment Fund Timeline and Permit Validity

An ARI residence authorization, once granted, is valid for a two-year period from the date of issue of the corresponding title, subject to any special renewal-period rules that may apply. ARI holders and family members who meet the requirements of the general Foreigners’ Law framework and apply for permanent residence receive an “Authorization of Residence for Permanent Investment Activity” instead, under a modified set of provisions relative to the standard temporary permit.

The State of Portugal’s New-Resident Tax Regime

Portugal’s original Non-Habitual Resident (NHR) tax regime — long cited in ARI marketing material for its broad remittance-basis exemptions on foreign-source income — closed to new applicants at the end of 2023, per Portugal’s 2024 State Budget legislation. It has been succeeded by a narrower successor regime widely referred to as NHR 2.0 or IFICI (Incentivo Fiscal à Investigação Científica e Inovação), which, according to third-party tax-advisory summaries (this article does not treat these as an official government source and readers should confirm current terms directly with AIMA, the Portuguese Tax and Customs Authority, or a licensed Portuguese tax adviser), applies a 20% flat tax specifically to Portuguese-source employment or self-employment income earned in designated high-value-added activities — including scientific research, higher education, healthcare, engineering, and technology roles, and requires at minimum a bachelor’s-level qualification plus relevant experience, or a doctorate.

This is a materially different, and materially narrower, benefit than the original NHR’s broad foreign-income exemption, and it is activity-linked rather than investment-linked: a passive ARI fund investor who does not personally work in one of the designated high-value-added professions in Portugal does not automatically qualify for IFICI merely by holding ARI status. Applicants whose Portugal decision has been substantially influenced by expectations of a broad NHR-style tax exemption should independently reverify their personal eligibility for IFICI, or evaluate their Portuguese tax position under ordinary Portuguese tax residence rules, before assuming any specific tax outcome.

How Portugal Compares to Greece and Malta in 2026

With Spain closed, Portugal’s principal points of differentiation from Greece and Malta are its uniquely low physical-presence requirement (7 days in year one versus Greece’s zero-presence but also zero-path-to-permanence-without-separate-compliance, and Malta’s residence obligations tied to its own framework) and its explicit five-year, language-conditioned path to citizenship, which neither Greece’s seven-year, high-presence naturalisation route nor Malta’s separate naturalisation framework replicates on the same terms. Portugal’s minimum capital entry point (€250,000 for cultural heritage) is comparable to Italy’s lowest investor-visa threshold and below Malta’s headline non-refundable contribution-plus-property structure, but Portugal’s fund route in particular carries capital-markets risk that a government-contribution structure like Malta’s does not.

Frequently Asked Questions

Can I still get a Portugal Golden Visa through real estate?

No. Law 56/2023 removed real estate investment from ARI’s qualifying routes with effect from October 2023. The four routes currently open are job creation, scientific research (€500,000), cultural heritage (€250,000), and investment fund subscription (€500,000), none of which may be directed toward real estate.

What is the minimum investment for Portugal’s ARI in 2026?

The lowest capital threshold is €250,000, for the cultural heritage and artistic production route (reduced to €220,000 in low-density territories). The investment fund route, which draws the most sophisticated-investor interest, requires at least €500,000.

Does ARI still offer Portugal’s famous NHR tax benefits?

The original broad NHR regime closed to new applicants at the end of 2023. Its narrower successor, commonly called IFICI or NHR 2.0, is tied to specific professional activities (research, technology, healthcare, and similar high-value-added roles) rather than to investment or residency status alone, and a passive ARI fund investor does not automatically qualify. Confirm personal eligibility with a licensed Portuguese tax adviser.

How much time do I need to spend in Portugal to keep my ARI status?

AIMA’s minimum physical presence requirement is seven days in the first year and fourteen days in each subsequent two-year period — one of the lowest minimum-presence requirements among comparable EU residency-by-investment programs.

Official Sources Checked

• Portugal AIMA — Autorização de Residência para Investimento, Art. 90.º-A
• Portugal AIMA — Viver (general immigrant-support portal)
• Lei n.º 56/2023, de 6 de outubro (removed real estate from ARI)

Sources checked 31 August–1 September 2026. The IFICI/NHR 2.0 tax summary in this article is drawn from third-party tax-advisory publications, not an official AIMA or Portuguese Tax Authority source, and is flagged as such; verify directly before relying on it.

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Disclaimer: This article is published by GoldenVisa.Help for general informational and educational purposes only. It does not constitute legal advice, tax advice, investment advice, or immigration advice. Portugal’s ARI investment thresholds, low-density-territory discounts, and family-inclusion rules are set by Portuguese law and AIMA regulation and may change; every figure here should be independently verified against AIMA’s current published guidance or a licensed Portuguese immigration lawyer before any commitment of funds. Tax treatment, including eligibility for IFICI/NHR 2.0, is separate from ARI eligibility and must be confirmed with a licensed Portuguese tax adviser. GoldenVisa.Help is an independent editorial platform and is not affiliated with AIMA or the Government of Portugal. No attorney-client or advisory relationship is created by reading this article.