The window for a Golden Visa remains open

The window for a Golden Visa remains open

7th July 2023

Adviser Column #3 - David Moura-George, Portugal Director

Despite six months of news stating it is over, Portugal’s Golden Visa programme hasn’t closed yet. In fact, right now this market is probably as busy as it’s ever been. Non-EU investors are capitalising on the open window created by a Government that as expected continues to deliberate over the Mais Habitação legislation.

In some ways, our Government has already achieved what it really wanted to; a general understanding both domestically and internationally that the programme will close soon. In politics, however, ‘soon’ is a term that can mean almost anything. We’re now almost five months since the mid-February announcement, which suggested immediate closure of the programme along with a list of retroactive changes that put investors and the sector generally into a spin.

Read our Golden Visa Guide here.


The legal community raised concerns about the unconstitutional nature of these changes. Real estate associations in Portugal, including the Portuguese Association of Real Estate Developers and Investors (APPII), exerted significant pressure on the government to reconsider the measures, highlighting the potential for extensive legal disputes arising from the abrupt termination of the Golden Visa programme.

The wave of protests had an impact, and the programme remains open to non-EU investors, who still enjoy the same benefits as before. The only difference is that the final closure of the programme will be determined by a law to be passed this year, offering an opportunity for those wishing to apply.


So the question is still ‘when’ but the exact timeline remains uncertain. For new applicants or those already in the application process, the good news is that everything remains practically unchanged until the new regulations are approved but investors must move fast to secure an investment and make the application. There are still opportunities out there, but property investment options are obviously finite, so investors need to move quick.

Some nationalities are in a better position than others too as they can get criminal record checks faster. These include British, Turkish and many Asian countries.

When the new law eventually passes, there will still be some changes. The final version of the bill to be presented and discussed in Parliament will include the following points:

• New applications for residence permits will be accepted until the new law is published. Applications and renewal applications that are pending a decision by the competent authorities at the time the new law comes into force will remain valid.

• Pending applications and future renewals will be converted to the D2 Entrepreneur Visa, which allows non-EU nationals to reside in Portugal with their families by opening a company or business in the country.

• Contrary to the initial announcement, the requirement to stay in Portugal for seven days per year for Golden Visa holders will be maintained under the D2 visa. This is positive news, as the short residency period in Portugal has always been a major incentive for the programme.

• Furthermore, the government's plan to compel investors to use the properties for their own permanent residence or long-term rentals during visa renewals has been abandoned. This significant step backward will help restore investors' confidence in the Portuguese property market in general.


Given these changes compared to the measures announced in February, we advise all applicants, whether in the initial or final stages of the application process, to proceed with the necessary procedures and expedite any pending actions whenever possible.

For new investors who are still considering participating in the programme, there is now a fresh opportunity after months of uncertainty. If they are ready to begin the application process immediately to obtain a residence permit leading to European citizenship, there is still sufficient time to gather all the necessary requirements.

David is available to guide you through the market, identify exclusive opportunities, and ensure a seamless property purchasing experience across Portugal. With our extensive portfolio or property, on the ground insight and personal approach to advising individuals on their property investment journey, we offer a truly end-to-end service. You can read more about our services here or fill in the form below to speak to David.


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