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Portugal Golden Visa 2025: The Truth About the Fund Route (Not Real Estate)

Real estate is no longer the star of Portugal’s Golden Visa. In 2025, CMVM-regulated investment funds lead the way. This guide separates myth from fact: how the fund route works, what changed, the data behind the shift, and the practical steps to secure EU residency - without buying property.

Portugal’s Golden Visa (residency by investment) has evolved. Following legal reforms that curtailed real-estate eligibility in key areas, the fund investment route has become the clearest, most compliant path. Below, you’ll learn the mechanics, the stats, and how institutional managers (e.g., Explorer Investments) fit into a diversified, professionally managed strategy.

Golden Visa in 2025: What Changed?

The Golden Visa - formally the Residence Permit for Investment Activity (ARI) - has operated since 2012. Recent reforms removed most real-estate paths for new applications in major regions, shifting focus to regulated fund subscriptions, capital transfer, research, and cultural support.

Core eligibility (high level)

  • Subscribe at least €500,000 to a CMVM-regulated fund
  • Maintain the investment for 5 years
  • Typical stay requirement around 7 days/year
  • Family inclusion: spouse, children, dependent parents
  • Pathway to permanent residency and (later) citizenship, subject to language and legal checks

How the Fund Route Works (Step by Step)

  1. Shortlist managers with CMVM-regulated vehicles and a clear Golden Visa track (e.g., diversified private-equity/hospitality).
  2. Due diligence: strategy, fees (management/carry), lock-up, liquidity windows, governance, auditor, custodian.
  3. Subscription of ≥ €500k; complete KYC/AML and receive fund proof for your ARI file.
  4. Submit ARI application (investor + eligible family) and track milestones until biometrics/residence issuance.
  5. Maintain the investment and stay requirements; reassess exit options as the 5-year mark approaches.

Key Numbers & Market Trends (2023-2025)

4,987

Golden Visa grants in 2024 (applicants + dependents)

~13,000

Total residence permits since inception

Where the capital flows

  • 2023 total ≈ €70.9M (≈ €50.08M real estate vs ≈ €20.82M funds/capital)
  • Funds ≈ 30% of Golden Visa permits by 2023; rising in 2024-2025
  • Geographic limits on property pushed applicants toward funds

Who’s applying?

  • China remains significant, share declining
  • Brazil consistently strong
  • U.S. applicants rising (some reports ~20%)

Myths vs Facts: Fund Route vs Real Estate

Common Myths

  • “Only property qualifies now.”
  • “Funds are riskier than a single apartment.”
  • “Fund exits are impossible.”

The Facts

  • The fund route is currently a primary path for ARI.
  • Diversification + governance can reduce single-asset risk.
  • Lock-ups exist, but funds define exit policies and windows up front.

Risks, Fees & Compliance Checklist

Key Risks

  • Illiquidity and lock-up periods
  • Performance depends on manager, cycle, sector
  • Regulatory changes and processing backlogs

Fees to Expect

  • Management fee & potential performance fee (carry)
  • Custody, audit, subscription/administration fees
  • Legal/immigration and translation costs

Compliance Checklist (quick)

  • CMVM-regulated fund with clear ARI eligibility
  • Independent auditor and custodian named
  • Transparent docs: PPM, KID/KIID, fees, liquidity policy
  • Proof of subscription for ARI file; keep records updated

Quick FAQ for Busy Investors

  • Minimum? €500,000 into a CMVM-regulated fund.
  • Stay requirement? 7 days per year on average.
  • Family? Spouse, children, dependent parents may be included.
  • Citizenship timeline? After maintaining residency for 5 years, subject to language and legal criteria.

Get Started - Free Strategy Session

André Bandeira

André Bandeira

ab@explorerinvestments.com
Maria Campos Silva

Maria Campos Silva

mcs@explorerinvestments.com
Book a Free Strategy Session

Why Choose Explorer Investments

Real Returns

Institutional-grade portfolio construction and value creation.

Secure & Regulated

CMVM oversight, independent audit and custody.

Minimal Stay

Maintain residency with roughly 7 days per year.

Family Inclusion

Spouse and dependent children under the same application.

Residency → Citizenship

Permanent residency after 5 years; citizenship thereafter.

Full EU Access

Live, work, and travel across the European Union.

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Your Investor Relations Team

André Bandeira

ab@explorerinvestments.com

Maria Campos Silva

mcs@explorerinvestments.com
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Copyright © 2025 Explorer Investments

It is recommended to consult Chapter V of Decree-Law nº 162/2014, of October 31st, published in the Official Gazette, as well as its revision by Law nº 2/2020, of March 31st. The information included here is of a general nature, and therefore each potential investor should seek independent advice (e.g., legal, financial, tax, etc.)