Golden Visa After the Real Estate Route: What Still Works

Law 56/2023 came into force 7 October 2023 and did two things at once: closed the property-purchase route to Portugal's Autorização de Residência para Actividade de Investimento (ARI, 'Golden Visa'), and tightened compliance on the routes that remained.

Three routes still qualify. First, investment fund subscription: a minimum €500,000 into a Portuguese regulated fund (CMVM-supervised) whose mandate is not real-estate-dominant. Most active funds are now private equity, venture, or infrastructure. Due diligence on the fund's 60% non-real-estate threshold is where most applications trip.

Second, cultural heritage contribution: €250,000 (reduced for low-density regions) to projects recognised under the Ministry of Culture's framework. Slower to process, irreversible, but straightforward once the target project is approved.

Third, job creation: establishing a Portuguese company that creates at least 10 jobs, or €500,000 into an existing Portuguese company that creates 5 jobs and maintains them for three years. This route was always the smallest — the operational bar is real.

What the reform killed: direct apartment purchase in Lisbon or the Algarve. The AIMA (the former SEF's successor) will no longer process ARI applications on that basis. Existing Golden Visa holders with property-based investments retain their residency provided annual renewals and minimum-stay requirements are met.