Residency & Investment

Portugal Golden Visa Fund Route for U.S. Investors (2025 Guide)

The definitive guide to the €500k CMVM-regulated fund route — eligibility, timeline, costs, U.S. tax notes (FATCA/PFIC), risks, and how to move from research to residency.

By André Bandeira, CFA • Updated 2025

Portugal Golden Visa fund route — CMVM regulated funds

What is the Portugal Golden Visa fund route?

The Golden Visa (ARI) grants residency to non-EU nationals investing €500,000 in a qualifying CMVM-regulated private equity or venture capital fund that meets the legal criteria for the program.

Schengen mobility ~7 days/year presence Pathway to PR/Citizenship Family included

Data & context: Portugal Golden Visa — Data & Statistics (2012-2023).

Why U.S. investors choose funds

Real estate path closed — funds are now the primary route.
Professional oversight and audited reporting under CMVM.
Diversified exposure vs. single-asset property risk.
Cleaner accounting and exit mechanics.
Alignment with long-term residency goals.

Eligibility & family members

Non-EU/EEA/Swiss nationals.
Clean criminal record and source-of-funds/wealth documentation.
Family aggregation: spouse/partner, dependent children, and—subject to proof—dependent parents.
~7 days per year physical presence requirement.

Golden Visa fund requirements (CMVM)

Registered and supervised by CMVM.
Defined strategy with Portuguese economic exposure (commonly >60% in PT companies).
Appropriate maturity (≥5 years) and compliant offering docs.
Independent depositary / auditor; periodic reporting.
No guaranteed returns; risks disclosed and monitored.

Learn more: How CMVM-regulated funds safeguard investor goals.

Timeline — from investment to citizenship

Pre-check: KYC/AML, fund selection, subscription docs.
Investment: €500k into a qualifying fund (proof issued).
Application & biometrics with AIMA.
Initial 2-year residency; two renewals across ~5 years.
Eligibility for PR/citizenship (verify current rules before filing).

Note: Processing times evolve as AIMA digitizes workflows.

U.S. tax notes (FATCA, PFIC, IRA)

FATCA reporting and foreign account disclosures may apply.
PFIC rules can impact fund taxation; seek specialist advice.
Self-Directed IRA usage may be possible with careful structuring; avoid prohibited transactions.
Coordinate with U.S./PT tax counsel to optimize timing and reporting.

Risks & governance — what to check

Strategy concentration and sector risk.
Manager track record and governance.
Liquidity & redemption gates timing.
Fees and performance alignment.
Regulatory and policy updates.

Costs & working estimates

Cost Type	Estimate	Notes
Fund Subscription	€500,000	Minimum required for eligibility
Legal Fees	€5,000-€10,000	Depends on family size & complexity
Application Fees (AIMA)	~€533 per person	As published by AIMA
Residency Permits	~€5,325 per person	Initial issuance

Ready to evaluate qualifying funds?

Our team at Explorer Investments can share a short-list of CMVM-regulated vehicles aligned with your timeline and risk profile.

Frequently Asked Questions

Is real estate still valid for Golden Visa?

No — the property route was removed. The fund route is now the primary investment pathway.

How long to citizenship?

Historically 5 years of legal residency. In 2025, amendments may affect certain timelines; confirm the rule in force with counsel before filing.

Can I use a Self-Directed IRA?

Sometimes, via specialist custodians. Ensure compliance to avoid prohibited transactions and unintended U.S. tax events.

What about AIMA backlogs?

AIMA is digitizing processes to reduce wait times; check current SLAs at the time of filing.

Continue reading

Talk to a Portugal Golden Visa Specialist

Explore a curated list of CMVM-regulated funds that qualify for the €500k Golden Visa route — aligned with U.S. investor needs and timelines.

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