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Advisor Strategy & Legal Update

Portugal Citizenship Law 2025: Investor Action Guide - What Changed, What Seems Stable, and How to Prepare Now

A practical, investment-first briefing based on current public proposals and market commentary. It outlines proposed changes, constitutional review steps, what appears stable in the Golden Visa, and advisor-grade actions for families in three scenarios: eligible for citizenship now, filed and pending, or preparing to file.

Lisbon courts and financial district - symbolism for Portugal citizenship law changes and investment planning.
Legal debate may evolve; investment quality and timing remain within your control.
Planning model
5 + 5 years
Flagship route
€500k CMVM fund
Presence
Historically low
Mobility
Schengen access

What Changed (Proposals)

Based on current public debate and draft language discussed in late October 2025, the proposal includes:

  • Minimum residence period for citizenship eligibility framed at 7 years for CPLP/EU nationals and 10 years for others.
  • Residence counting from the date of residence permit issuance rather than the application date.
  • Language & civic knowledge demonstration (Portuguese language/culture and fundamentals of the constitutional system).
  • Aggregation of non-consecutive legal residence periods within a 10-year window for counting purposes.

Important: Treat these as proposals until the final text is promulgated. Verify the version in force at your filing date.

Constitutional Review: Why Timing Still Matters

After the final parliamentary vote, the President has up to 20 days to promulgate, veto, or request a Constitutional Court review. Market practitioners expect scrutiny on transitional protections and legitimate expectations, especially for applications in flight.

This path can delay enforcement and often results in clarifications or transitional regimes. For investors, that creates aplanning window to file under current mechanics while maintaining optionality if outcomes change.

“Don’t outsource your timeline to politics. Control what you can: investment quality, documentation readiness and filing cadence.” - André Bandeira, Explorer Investments

What Appears Stable in the Golden Visa

  • Program availability: the Golden Visa remains in operation.
  • Routes: €500k CMVM-regulated funds, research, culture and job creation paths.
  • Residential real estate: excluded from qualifying routes.
  • Presence: historically low physical-stay averages; verify exact periods in force.
  • Schengen mobility as a practical benefit of residency.

Investor Decision Matrix (Three Scenarios)

Scenario A - Eligible for Citizenship Now (≥5 years)

  • Prepare and submit the citizenship application under the current regime.
  • Ensure language/civics certification readiness.
  • Maintain documentary evidence of legal residence continuity.

Scenario B - Filed & Pending (awaiting permit)

  • Monitor final text and any transitional/grandfathering guidance.
  • Keep KYC/AML and proof of funds updated; be biometrics-ready.
  • Plan travel for AIMA scheduling as soon as slots open.

Scenario C - Preparing to File

  • Proceed with NIF & bank account setup and fund due diligence.
  • Target file submission before potential enforcement; maintain optionality if outcomes shift.
  • Align with cross-border tax counsel early (PFIC/QEF for US persons).

Why the CMVM Funds Route Leads

The investment-first route emphasizes governance, custody and productive capital allocation.

  • Governance: CMVM supervision, audited reporting, third-party administration and regulated custody.
  • Diversification: private equity, growth, credit and multi-asset strategies beyond residential real estate.
  • Lifecycle fit: typical 8-10 year fund lives align with residence planning horizons.
US Investor Note (PFIC): Non-US funds are generally PFICs. Request an annual PFIC Information Statement to enable a QEF election; coordinate with US tax advisors.

Step-by-Step: NIF → Bank → Subscription → AIMA

  1. Objectives: define diversification, family and liquidity needs.
  2. NIF & Banking: obtain tax numbers; open Portuguese bank accounts.
  3. Diligence & Subscription: review PPM/KID; complete KYC/AML; execute documents; wire funds.
  4. Declaration: obtain manager/custodian declaration confirming a qualifying investment.
  5. AIMA Submission: submit the file; schedule biometrics; receive residence cards.

Risks, PFIC/QEF & Best Practice

  • Regulatory risk: rules may change; monitor official sources and plan contingencies.
  • Fund risk: strategy, liquidity and valuation risks; diversify; use audited vehicles.
  • Tax coordination: integrate home-country and Portuguese tax; US persons address PFIC/QEF early.
  • Documentation: maintain KYC/AML, proof of funds/source of wealth and clean records.

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Extended FAQs

Is the Golden Visa being shut down?

No - the debate targets citizenship timelines, not the availability of the Golden Visa. Always verify the rules in force when you file.

If the law changes, will there be transitional rules?

Historically, significant changes often include transitional mechanics, especially after constitutional review. Wait for the final text and AIMA guidance.

How much time in Portugal is required?

Historically low physical presence; confirm the precise periods at the time you apply and renew.

What’s the first action I should take?

Define objectives, engage counsel and begin due diligence on CMVM-regulated funds aligned to your risk profile and timelines.

About Explorer Investments

Founded in 2003, Explorer Investments is Portugal's leading independent private equity management company, with approximately €1.8B+ under management. Fully regulated by the CMVM.

Press/Investor Contact:

André Bandeira - Investor Relations

Email ab@explorerinvestments.com

Website https://goldenvisashub.com/

 
   

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