Posted on: 17th December 2025

Portugal’s Golden Visa: What Three Years of Change Tell Global Citizens About 2026

Over the past three years, Europe’s investment‑migration landscape has undergone a quiet reset. Political pressure, EU scrutiny, and domestic concerns (particularly around housing and fairness) have pushed governments to re‑shape — and in some cases close — their residency and citizenship-by-investment routes. Portugal’s Golden Visa is a useful case study because it has evolved rather than disappeared.

In 2023, Portugal removed direct residential real estate from its Golden Visa options, redirecting applicants towards other routes such as regulated fund investment, business/job creation and certain donation pathways. Multiple market guides and programme summaries continue to list these “post‑2023” routes — but investors should always verify eligibility against official rules and their legal advisers, as qualifying criteria can be technical and can change with little notice.

In 2024–2025, the debate shifted to nationality law. In mid‑December 2025, Portugal’s Constitutional Court issued decisions finding several provisions of proposed nationality‑law amendments unconstitutional, including a rule that would have assessed nationality applications by reference to the residence‑permit issuance date rather than the date of the nationality application. Reporting on the ruling indicates the Court’s concerns were rooted in constitutional principles such as legal certainty and protection of legitimate expectations. Importantly for investors, those sources also state that the reforms, as drafted, could not enter into force in that form and that further parliamentary steps would be required.

What this means for 2026 is best framed in two layers: (1) the residency programme, and (2) the citizenship timeline.

On residency, Portugal remains structurally attractive for globally mobile families because the stay requirement is low by European standards. Several leading programme descriptions note an “average of seven days per year” concept (often expressed as 14 days in each two‑year period), though applicants should confirm the exact counting method used on their permit and renewal cycle.

On citizenship, investors should be cautious about definitive claims. Public reporting in late 2025 described parliamentary proposals that would lengthen the residence period required for naturalisation (including references to a ten‑year timeline for certain non‑EU nationals), but the final shape, transitional protections and the precise start date for counting residence have been subject to legal and political debate and require continued monitoring. For planning purposes, families should base decisions on the law currently in force, but treat forward-looking timelines as “under review” until confirmed in enacted legislation and guidance.

How does Portugal compare with other European options in 2026?

Italy

Italy’s Investor Visa is not a “citizenship by investment” programme. It is a residence route based on approved investments (including government bonds, companies, innovative start‑ups, and philanthropy) and tends to suit those considering deeper relocation and tax planning, rather than those seeking a low‑touch Schengen residence path.

Greece

Greece’s residence-by-investment route remains heavily property‑led, but published summaries indicate the minimum investment levels vary by area and property type, with higher thresholds in high‑demand zones and special rules for particular categories (such as conversions or restorations). This can be compelling for lifestyle buyers, but it is not generally marketed as a predictable, quick citizenship pathway.

Malta

Malta has historically offered the closest thing to an explicit fast‑track EU citizenship route. However, in April 2025 the Court of Justice of the European Union ruled against Malta’s investor citizenship framework. Malta has since moved towards alternative approaches (often described as merit‑based or contribution‑based), and families considering Malta should treat any “citizenship by investment” claims as requiring careful verification against the current regime and legal advice.

Cyprus

Cyprus suspended its citizenship-by-investment programme in 2020. Cyprus still offers residency-by-investment/permanent residence routes, but citizenship is generally only via standard naturalisation rules rather than an investment‑linked, accelerated pathway.

So, is Portugal still “the best” citizenship-by-investment programme in Europe? In strict terms, the EU has been moving away from “cash‑for‑passport” models, and the remaining options differ sharply in cost, scrutiny, and political sensitivity. Portugal’s appeal is less about speed and more about balance: Schengen access, comparatively low stay requirements, and an institutional system that (as seen in late 2025) applies constitutional checks to major legal changes.

Holborn positioning

At Holborn, we view programmes like Portugal’s Golden Visa as one component of a wider international strategy — sitting alongside cross‑border tax planning, estate structuring, currency diversification, and family education/lifestyle planning. The key is not simply selecting a country, but selecting a pathway that remains credible over time, fits the family’s mobility realities, and is executed with disciplined documentation and renewal management.

Because the legal and political environment continues to evolve, our approach in 2026 is simple: plan conservatively, verify every material claim against current rules, and build optionality into the family’s long‑term map — so that headlines do not dictate outcomes.

Note: This article reflects publicly reported updates as of December 2025 and common programme summaries published by major residency-by-investment providers and legal/industry outlets. Certain forward-looking points — especially around nationality timelines — require ongoing verification as legislation and guidance evolve.