What changed, and when
Portugal’s revised Nationality Law is now in force. Enacted as Lei Orgânica n.º 1/2026, de 18 de maio, it was published in the Diário da República on 18 May 2026 and took effect the following day, 19 May 2026. The reform applies to naturalisation generally, across every category of legal resident, and not to Golden Visa holders as a class. Early coverage tended to merge two separate things: the route to citizenship and the residency programme that can lead to it. They remain distinct. The Golden Visa, as a residence vehicle, was not amended.
In short: the road to a Portuguese passport is now longer, and counted differently; the residence permit that puts an investor on that road is unchanged.
The longer qualifying period
The minimum period of legal residence required before a naturalisation application moves as follows:
- Nationals of other countries: from five years to ten.
- Nationals of EU member states and of Portuguese-speaking (CPLP) countries, including Brazil, Angola, Mozambique and Cape Verde: from five years to seven.
The law also sets the window within which residence periods may be aggregated. Continuous or intermittent periods of lawful residence are added together provided they fall within a maximum span that varies by category (broadly six, nine or twelve years for stateless persons, for CPLP and EU nationals, and for other nationals respectively).
Three integration conditions now accompany the longer clock: proof of Portuguese at level A2 or above (nationals of Portuguese-speaking countries who were born in and hold the nationality of such a country are exempt from documentary proof), an assessment of civic and cultural knowledge, and a formal declaration of adherence to the principles of the democratic rule of law.
How the law reached this point matters for the transitional rules. An earlier version, Decreto n.º 17/XVII, was partly annulled by the Constitutional Court in December 2025 (Acórdão 1133/2025), in part over an inadequate transitional regime, and was returned to Parliament by President Marcelo Rebelo de Sousa. A revised text was approved and promulgated by President António José Seguro on 3 May 2026, who observed that a reinforced-value law of this importance would have benefited from broader consensus. A related measure on loss of nationality as an accessory criminal penalty (Decreto n.º 49/XVII) remains subject to preventive constitutional review and is not part of Lei Orgânica 1/2026.
How the qualifying period is now counted
This is the change that bears most directly on Golden Visa investors, and it is the point on which most second-hand summaries are wrong.
Under the previous regime, the qualifying period was generally counted from the date the residence permit was applied for, so that the time absorbed by administrative processing still counted toward naturalisation. Lei Orgânica 1/2026 moves the starting point to the issuance of the first residence permit. The practical consequence is the reverse of the old position: time lost to AIMA’s processing backlog no longer counts toward the qualifying period.
For a programme in which the gap between application and the physical issuance of a first card has often run from twelve to twenty-four months or more, this is a material shift. It is also contested. A group of investors, reported to exceed five hundred, is understood to be preparing legal action against the State, arguing that the change defeats the legitimate expectations of those who applied under the prior counting method.
The transitional protection is narrower and simpler than some commentary suggests. Naturalisation procedures already pending on the date the new law took effect, that is, filed on or before 18 May 2026, continue to be governed by the prior version of Lei n.º 37/81, retaining both the previous five-year duration and the previous counting method. That is the protection. There is no separate “fee-date” rule preserving the old clock for investors who had merely paid submission fees.
The Golden Visa itself is unchanged
The residency programme is untouched by the Nationality Law reform.
- The investment routes remain open and unchanged, including the EUR 500,000 fund route and the EUR 250,000 cultural contribution route.
- Permanent residency remains available after five years of residence, counted independently of the naturalisation timeline.
- Holders keep full residency rights: renewal, family reunification, and Schengen travel.
- The physical presence requirement remains light, around seven days a year.
- The Portuguese passport, once obtained, still provides visa-free or visa-on-arrival access to more than 170 destinations.
The permanent residency point carries weight. Even with naturalisation extended to ten years for most nationalities, a Golden Visa holder can still apply for permanent residency after five, securing a durable right to live and work in Portugal and across the EU without having to keep the qualifying investment in place.
What this means for you
For most applicants, the practical change is limited. Where the decision rested on a European base, quality of life, Schengen mobility and family security, the programme continues to deliver precisely that.
The position shifts for those whose specific objective was a passport within five or six years. A ten-year route, counted from card issuance, is a different proposition. That does not make Portugal the wrong choice; it means the planning needs to be more precise and to account for both the longer duration and the new starting point. Investors who applied under the old regime, in particular, should take advice on where they stand and on the significance of the pending legal challenge to the counting change.
How Portugal compares across Europe
Portugal is not the only route into the EU, and where the citizenship timeline is decisive, the comparison should be made on the facts. Italy’s investor visa runs on a different structure and timeline; Greece offers a solid EU residency with its own long-term path; Malta operates a separate framework again. The useful question is not which programme ranks highest in the abstract, but which one fits a given objective.
Where things stand, and what to do now
Lei Orgânica 1/2026 is in force. The practical positions are these:
- Investors with a naturalisation application already filed on or before 18 May 2026. The prior Lei 37/81 regime applies in full, both the five-year duration and the former counting method.
- Investors who held residence but had not filed for naturalisation by that date. The new duration (seven or ten years) and the new counting from card issuance apply. The interaction with the old counting method is the subject of the pending challenge and should be reviewed individually.
- Prospective investors. The Golden Visa remains available and unchanged as a residency route; the naturalisation horizon is now longer and begins at card issuance, which should be built into the plan from the outset.
MCS can assist with eligibility assessment, application, and a review of an investor’s naturalisation position under the new law, subject to a case-by-case analysis. Specific legal advice on individual circumstances is essential before any decision is taken.
Portugal Golden Visa: residency and citizenship guide, 2026
The Portugal Golden Visa is among Europe’s established residency-by-investment routes. The 2026 reform of the Nationality Law (Lei Orgânica n.º 1/2026) has lengthened and re-timed the path to citizenship, but the Golden Visa as a residency vehicle is unchanged. It remains a route to long-term EU residency and, over a longer horizon, to a possible application for a Portuguese passport.
Key programme details at a glance
- Visa-free access on the Portuguese passport (after citizenship): more than 170 destinations.
- Schengen travel on the Golden Visa: yes.
- Processing time: typically 12 to 18 months.
- Cultural donation route: from EUR 250,000.
- Fund route: from EUR 500,000.
- Indicative total cost, single applicant: from about EUR 271,650.
- Indicative total cost, family of four: from about EUR 294,600.
- Permanent residency: available after five years of residence.
- Citizenship: under Lei Orgânica 1/2026, after seven years for EU and CPLP nationals and ten years for other nationalities, counted from the issuance of the first residence permit, subject to A2 language and civic-knowledge requirements.
- Investment holding period: five years, until permanent residency is obtained; the investment need not be held through the citizenship phase.
- Physical presence: an average of seven days a year (specifically seven days in the first year and fourteen days in each subsequent two-year period).
Eligible family members include a spouse or partner (formal marriage is not required), children under 18, unmarried adult children in full-time study and financially dependent, parents over 65, and parents under 65 where financially dependent on the main applicant or spouse.
Overview and purpose
Formally the Residence Permit for Investment Activity (ARI), the Golden Visa is aimed at non-EU nationals and is designed to attract foreign capital into Portugal. Its principal benefits are residency rights for the investor and family, visa-free movement within the Schengen Area, and, over a longer horizon, an eventual route to citizenship under the Nationality Law.
The programme launched in October 2012 as part of Portugal’s post-crisis strategy to draw in foreign investment. It has been amended repeatedly since, in step with economic priorities and EU law. The most significant change came in October 2023, when the property investment routes were withdrawn; the programme has continued through its remaining options, principally the regulated fund route and the cultural contribution route.
Eligibility
Main applicants must:
- Obtain a Portuguese tax number (NIF).
- Provide a clean criminal record from their country of residence and from Portugal.
- Make a qualifying investment, such as a fund subscription, a qualifying business investment, or a contribution to research activity.
- Spend an average of seven days a year in Portugal to maintain the permit.
Family inclusion follows the main application and is conditional on its success; included family members are also subject to the clean criminal record requirement.
Investment routes and indicative costs
| Investment option | Minimum | Nature |
|---|---|---|
| Investment fund | EUR 500,000 | Recoverable, with potential return |
| Cultural and artistic donation | EUR 250,000 | Non-recoverable donation |
| Scientific research contribution | EUR 500,000 | Non-recoverable contribution |
| Creation of 10 jobs | 10 jobs | Operational expenditure |
| EUR 500,000 plus 5 jobs | EUR 500,000 | Operational and investment cost |
Two routes most applicants choose
Cultural donation (EUR 250,000). The contribution is directed to an approved cultural-heritage organisation from a list approved by the Portuguese authorities and must be applied in full to the project.
Fund investment (EUR 500,000). The funds are placed in a government-regulated investment fund that allocates at least 60 per cent of its capital within Portugal. The market ranges from newer vehicles built primarily around Golden Visa demand to long-established funds with substantial assets, some above EUR 1 billion, often drawn from institutional sources.
Cost breakdown, single applicant (five-year period)
| Cost item | Fund route (EUR) | Donation route (EUR) |
|---|---|---|
| Investment or donation | 500,000 | 250,000 |
| Application/processing fee, per person | 605 | 605 |
| Initial issuance fee, per person | 6,045 | 6,045 |
| Renewal (after year 2), per person | 3,023 | 3,023 |
| Renewal (after year 4), per person | 3,023 | 3,023 |
| Total government fees, per person | 12,696 | 12,696 |
| Legal fees (five-year) | ~15,000 to 20,000 | ~15,000 to 20,000 |
| Fund subscription fee (1 to 3%) | ~10,000 | 0 |
| Document processing | ~1,000 | ~1,000 |
| Health insurance (five-year total) | ~0 to 2,000 | ~0 to 2,000 |
| Bank and miscellaneous | ~500 | ~500 |
| Total variable fees, estimated | ~28,500 | ~18,500 |
| Total excluding investment | ~41,196 | ~31,196 |
| Total capital required (with investment) | ~541,196 | ~281,196 |
Cost breakdown, family of four (five-year period)
| Cost item | Fund route (EUR) | Donation route (EUR) |
|---|---|---|
| Investment or donation | 500,000 | 250,000 |
| Application/processing fee, 4 persons | 2,420 | 2,420 |
| Initial issuance fee, 4 persons | 24,180 | 24,180 |
| Renewal (after year 2), 4 persons | 12,092 | 12,092 |
| Renewal (after year 4), 4 persons | 12,092 | 12,092 |
| Total government fees, family of four | 50,784 | 50,784 |
| Legal fees (five-year, family of four) | ~20,000 to 30,000 | ~20,000 to 30,000 |
| Fund subscription fee (1 to 3%) | ~10,000 | 0 |
| Document processing | ~2,000 | ~2,000 |
| Health insurance (five-year total) | ~0 to 8,000 | ~0 to 8,000 |
| Bank and miscellaneous | ~500 | ~500 |
| Citizenship application, 4 applicants | ~2,000 | ~2,000 |
| Total variable fees, estimated | ~34,500 | ~24,500 |
| Total excluding investment | ~85,284 | ~75,284 |
| Total capital required (with investment) | ~585,284 | ~325,284 |
The application process
The route to residency runs through a defined sequence of steps and substantial documentation. Applicants begin by obtaining a Portuguese tax number (NIF) and opening a Portuguese bank account. The supporting file includes proof of the investment, a valid passport, evidence of lawful entry, and the relevant personal and financial documents; all paperwork must be professionally translated into Portuguese. Dependent children under 18 may be included.
The stages are:
- Expression of interest and pre-approval. An online expression of interest is submitted to AIMA (Agência para a Integração, Migrações e Asilo), followed by verification of the investment activity.
- Submission and fee payment. After pre-approval, the complete application is filed and the submission fee paid.
- Biometric data. Once documents are confirmed, the applicant attends an AIMA appointment to provide biometrics.
- Review and approval. AIMA examines the application and biometrics and runs background checks. This stage can take several months.
- Issuance of the residence permit. On meeting all requirements, the applicant is issued the permit. Under Lei Orgânica 1/2026, this issuance date is the point from which the naturalisation qualifying period begins to run.
Rights, obligations and benefits
Freedom of movement. Holders may travel within the Schengen Area for up to 90 days in any rolling 180-day period, without further visas. The in-country stay requirement is light by comparison with other programmes: seven days in the first year and fourteen days in each subsequent two-year period.
Route to citizenship. After five years of maintained residency, holders may apply for permanent residency. Naturalisation is a separate process under the Nationality Law. Under Lei Orgânica 1/2026, the qualifying period is seven years for EU and CPLP nationals and ten years for other nationalities, counted from the issuance of the first residence permit. Applicants must also meet the A2 language requirement, the civic and cultural knowledge assessment, and the declaration of adherence to the democratic rule of law. Naturalisation procedures already pending on 18 May 2026 remain under the previous Lei 37/81 regime. A Portuguese passport carries the right to live, work and study anywhere in the EU.
Family reunification. The programme extends to a spouse or partner, dependent children, and dependent parents, with access to healthcare, education and employment in Portugal and across the EU.
Living in Portugal
Portugal offers a high standard of living, accessible healthcare and education, and an economy integrated within the EU market.
Quality of life. The country combines a safe environment with a comparatively moderate cost of living against much of Western Europe, and a mild climate suited to year-round outdoor life.
Healthcare and education. Healthcare is delivered through a mix of public and private provision, with generally high reported satisfaction. State schooling is free to residents, alongside private and international schools teaching in several languages.
Economy. Portugal’s economy is diversified and open to investment, and the Golden Visa has formed part of its strategy for attracting non-EU capital.
Financial considerations
Since the property route closed in October 2023, qualifying investment has centred on regulated funds, including venture capital and private equity vehicles. The minimum is EUR 500,000, the holding period at least five years, and at least 60 per cent of the capital must be invested in companies headquartered in Portugal.
- Venture capital funds: focused on start-ups and emerging companies, with higher risk and the potential for higher return.
- Private equity funds: generally invested in established companies, with steadier growth.
Applicants should weigh expected yield against risk and management fees, and align the choice of vehicle with their financial objectives while meeting the programme’s investment conditions.
Post-residency and citizenship
Permanent residency after five years. Holders may qualify for permanent residency after five years of legal residence, provided they maintain the investment and the minimum stays through that period. Permanent residency grants the right to live, work and study in Portugal and to travel visa-free within the Schengen Area, independently of any future citizenship application and without the need to keep the qualifying investment. Applicants must show ties to Portugal, basic Portuguese proficiency, and a clean criminal record.
Citizenship. Under Lei Orgânica 1/2026, a holder may apply for citizenship after seven years (EU and CPLP nationals) or ten years (other nationalities) of legal residence, counted from the issuance of the first residence permit. Naturalisation procedures already pending on 18 May 2026 will stay under the prior Lei 37/81 regime, with the former duration and counting method. Beyond the qualifying period, the applicant must hold a clean criminal record, demonstrate A2 Portuguese, pass the civic and cultural knowledge assessment, declare adherence to the democratic rule of law, and show ties to the national community.
A successful application confers an EU passport, with the right to live, work and travel across the Union, and extends citizenship to family members. The procedure involves an application to the IRN, proof of legal residence for the qualifying period, evidence of A2 Portuguese, a pass in the civic-knowledge assessment, and a statement of ties to Portugal.
Frequently asked questions
How long does processing take?
Usually 12 to 18 months, depending on AIMA’s workload. Note that, under Lei Orgânica 1/2026, the naturalisation qualifying period now runs from the issuance of the first residence permit, so processing time is no longer absorbed into that period.
What are the main benefits?
The right to live in Portugal, Schengen access without further visas, eligibility for permanent residency after five years, and a longer-term route to citizenship (seven years for EU and CPLP nationals, ten for others), conditional on the residency, language, civic-knowledge and minimum-stay requirements.
How is the visa renewed?
The permit is renewed every two years. Applicants must keep the investment in place and evidence the required minimum stays, along with other documents requested by AIMA.
Does Portugal offer citizenship by investment?
No. The Golden Visa is a residency-by-investment route. It can lead to citizenship after the qualifying period under the Nationality Law (seven years for EU and CPLP nationals, ten for others), provided the language and civic-knowledge requirements are met.
Can the Golden Visa lead to citizenship, and on what timeline?
Yes, on a longer timeline since Lei Orgânica 1/2026. EU and CPLP nationals may apply after seven years of legal residence, other nationalities after ten, counted from the issuance of the first residence permit. Naturalisation applications filed on or before 18 May 2026 keep the prior five-year regime. Permanent residency remains available after five years.
This guide is general information, not legal advice. It reflects Lei Orgânica n.º 1/2026, de 18 de maio, in force from 19 May 2026; the counting change is the subject of pending legal challenge, and implementing regulation on the civic-knowledge assessment is still being defined. MCS can advise on individual eligibility and on an investor’s naturalisation position, subject to a case-by-case review.
Lília has graduated in 2002 with a law degree from Universidade Nova de Lisboa. She joined MCS’s legal team in 2003, providing support to the legal department in corporate and shipping… Read more
