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Golden Visa • Regulated Funds • Due Diligence

From Real Estate to Regulated Funds: The New Golden Visa Playbook (Portugal 2025)

The property era ended. In its place, a rule-based approach under CMVM supervision now anchors the Golden Visa route. Here’s how regulated funds work, how to diligence them, and how they fit a 5-year residency-to-citizenship plan.

Shift from property to CMVM-regulated funds for Portugal Golden Visa, illustrated with compliance and governance visuals
The fund route: regulated, diversified, and built for transparent reporting.

Why the property route ended

Portugal aligned its residency framework with long-term policy goals, redirecting capital from passive property buying into productive vehicles that finance real projects. The result: CMVM-regulated funds became the primary, compliant path. For investors, that means documented governance, audited reporting and clear mandates instead of fragmented property management.

What “CMVM-regulated” means

  • Supervision: Funds operate under Portugal’s securities regulator (CMVM) with rule-based oversight.
  • Governance: Independent depositary/custodian, board controls and formal valuation policies.
  • Transparency: Audited financials and scheduled reporting, so you can track mandate execution.
  • Risk controls: Diversification rules, liquidity mechanics and conflict-of-interest policies.

Funds vs. Property (2025)

DimensionRegulated FundsProperty (legacy)
EligibilityCurrent GV pathEnded
OversightCMVM supervision, auditedNone beyond notary/deeds
DiversificationMulti-asset/sectorConcentrated (single unit)
AdministrationProfessional managerDIY landlord/agents
ReportingPeriodic, standardizedAd-hoc

Due diligence checklist

  • Match the fund’s mandate & duration to your family plan.
  • Confirm auditor independence and valuation policy.
  • Review fees, liquidity windows and exit mechanics in writing.
  • Assess team track record through different cycles.
  • Ensure custody/depositary and risk controls align with best practice.
Prefer a guided path? Read our primer: Secure Steps: CMVM-Regulated Golden Visa Funds.

Residency & citizenship timelines (at a glance)

  1. Invest via a qualifying regulated fund and submit your application.
  2. Plan for low average presence (often ~7 days/year; verify at application).
  3. Reassess at ~5 years for Permanent Residency; evaluate citizenship eligibility thereafter.

Rules can change. Cross-check presence requirements and naturalisation criteria before you commit. For a broader context, see: Portuguese Citizenship: Legacy & EU Mobility.

Common pitfalls & red flags

  • Non-standard fee disclosures or unclear incentive structure.
  • Vague mandate; no evidence of risk budgeting or liquidity planning.
  • Infrequent reporting or opaque valuation methodology.
  • Unproven team without independent references or audited history.

Dive deeper: Golden Visa Fund Pitfalls & Red Flags (Investor Guide)

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