After Portugal’s recent national elections, prospective investors and would-be citizens are being urged to act promptly if they wish to apply for  Portugal’s Golden Visa programme,  amid growing political scrutiny and possible changes to the country’s naturalisation rules. While the legal framework for Portugal’s Golden Visa – officially known as the Autorização de Residência para Investimento (ARI) – remains stable, recent political developments have placed a renewed focus on the future of eligibility for citizenship.

Current Legal Framework: Legally Stable, Operationally Strained

According to Tomás Assis Teixeira, a lawyer at CCA Law Firm in Lisbon, the Golden Visa underwent substantial reforms in 2023. Real estate investment was largely removed from the list of qualifying routes, shifting the focus towards more socially responsible and capital-driven alternatives. The current qualifying investment options include:

• Capital transfers of at least €500,000 into eligible Portuguese investment funds;
• Investment of €500,000 in a Portuguese company, with the creation or maintenance of jobs;
• Direct creation of at least ten jobs in Portugal;
• Donations of €250,000 or more to cultural heritage or €500,000 to scientific research.

These changes are now fully integrated into Portuguese legislation, with no further amendments expected in the near future. The framework is seen as legally sound, and the criteria for eligibility remain unchanged under Portugal’s new centre-right government.

However, Teixeira notes that while legislative stability is intact, the system’s operational side – particularly at Portugal’s immigration authority AIMA – is facing significant delays. “We hope the new government will prioritise structural reforms within AIMA to improve efficiency and reduce processing times,” he said.

Citizenship Rules Under Review: A Potential Game-Changer

Although no changes to the Golden Visa rules themselves are currently in motion, there is increasing concern over a possible extension of the minimum residency period currently required for naturalisation. At present, ARI holders may apply for Portuguese citizenship after five years of legal residence, without the need to reside in the country full-time – a key advantage for globally mobile investors.

Mark Penney, Director at SunCap Visa, stressed that the five-year rule is now under active review. “A change by the government from five to seven years before you can apply for citizenship could set people back significantly,” he warned. “Our advice? Better to be one day early than two years too late.”

Portugal’s recent political developments are playing a major role. After its May 2025 elections, the third snap elections in as many years, Prime Minister Luís Montenegro now leads a minority government, meaning he must work in coalition with other, smaller parties. While he has ruled out any alliance with the far-right Chega party, pressure from other potential coalition partners such as the Liberal Initiative (Iniciativa Liberal) has brought new proposals to the table. These include demands for stricter naturalisation criteria, such as extended residency requirements, and stronger cultural or language integration conditions.

With the parliamentary 2025 summer recess due to begin on 16 June, and the 2026 State Budget expected to be approved in October, many observers anticipate that any legislative changes could emerge as early as this autumn.

No Legal Amendments – Yet Time is of the Essence

CCA’s Teixeira confirms that “no legislative amendments are currently foreseen” regarding the eligibility or structure of the ARI regime. Nevertheless, he notes that the reintroduction of real estate options – especially through socially responsible avenues such as affordable housing or build-to-rent initiatives – could be a logical and beneficial evolution of the programme, aligning overseas investment with pressing domestic needs.

Still, both Teixeira and Penney caution that even if the ARI regime remains intact, the path to citizenship – which is often the ultimate goal for many investors – could become lengthier and more complex. 

Strategic Action Recommended for Investors

With rising interest in Portugal from high-net-worth individuals, particularly from the UK and the US, the sense of urgency is growing. “Many of our clients are accelerating their applications,” says Penney. “They understand the advantages Portugal offers – security, lifestyle, and tax efficiency – and they don’t want to be caught out while politicians deliberate.”

While alternative residential visa options such as the D7, D2, and digital nomad visas are becoming more popular, they generally require a more substantial physical presence in Portugal – a limitation for many internationally mobile investors. “The Golden Visa remains uniquely flexible,” Penney adds. “Our clients don’t just want residency – they want certainty and a route to citizenship without being tied to one country full-time.”

Conclusion: Portugal Remains Open

There are now more than 1.6 million foreign residents in Portugal, in a country of 10 million population, and immigrants contribute around 12% to the national social security system. Any reforms to naturalisation timelines will therefore have far-reaching implications, both economically and socially.

The message from legal experts and investment advisors is clear: while the Golden Visa programme remains stable, those seeking citizenship should act without delay. “Portugal is still open for business,” Penney concludes, “but the smart money is already moving – and fast.”

Interested in exploring Portugal’s Golden Visa?

For expert guidance on the application process, eligible investment options, and the latest legal developments, we encourage interested individuals to reach out to:

CCA Law Firm and SunCap Visa – both proud Chamber members – who are ready to provide tailored legal and advisory support throughout every stage of the process.

Contact:

Mark Penney – mark@suncapvisa.com

Tomás Assis Teixeira – tat@cca.law