Portugal Golden Visa Reform (2025): Legal And Constitutional Debate — What It Means for Fund Investors

Explorer Investments
Tue, 28 Oct 2025 09:00:00 GMT
Portugal Golden Visa, Citizenship & Nationality Law, Residency by Investment, Private Equity Funds, CMVM, AIMA, Schengen Mobility, Legal & Constitutional

Proposed changes to Portugal’s Nationality Law have ignited a legal and constitutional debate. Here’s what may change for citizenship timelines — and what remains stable for the €500k CMVM-regulated Golden Visa fund route.

Portugal’s legislature is debating reforms to the Nationality Law, including a potential extension of residence requirements for citizenship. While legal scrutiny continues, the fund-based Golden Visa route (€500k, CMVM-regulated) remains open and operational.

What’s Being Proposed

Discussion of extending residence required for citizenship to 10 years (and 7 years for CPLP nationals).

Additional integration criteria under review; subject to presidential and Constitutional Court scrutiny.

Potential questions around retroactivity and legitimate expectations.

What Hasn’t Changed for the Golden Visa (Funds)

Minimum investment of €500,000 in CMVM-regulated funds.

Low physical presence requirement (~7 days/year on average).

Schengen mobility and family inclusion under existing rules.

Residential real estate route remains excluded.

Two Clocks: Investment vs. Residency/Citizenship

1. Investment clock: starts at subscription; many vehicles run 8-10 years.

2. Residency/citizenship clock: begins with the first residence card (post-biometrics); administrative timelines affect the start date, not the statutory period.

Explorer’s View

“Investors want predictability. The fund route remains open — focus on impeccable documentation, careful CMVM fund selection and a tight AIMA schedule.” — André Bandeira, Explorer Investments

Action Plan

Prepare KYC/AML, source-of-funds and civil documents.

Obtain NIF, open a Portuguese bank account.

Select a CMVM-regulated fund; review PPM/KID, governance and fees.

Subscribe and obtain the Manager/Custodian Declaração for AIMA.

Read the full reform analysis »