Portugal Golden Visa After 2026: Residency Unchanged, Citizenship Delayed and a Total Nobody Updates

Testing the title: what changed and what did not

Residency unchanged. ECO reported on 14 May, 19 May and 20 July 2026 that the nationality law left the ARI regime alone. Our researchers found no 2026 bill, decree-law, budget provision, CMVM rule or government statement ending or reforming it. Lei 62/2026 of 10 September, which applies the EU Migration Pact and Directive 2024/1233, was read only as an excerpt and showed no change to article 3(1)(d) or article 90-A of Lei 23/2007. Coverage of the 2027 budget was checked through a press summary, not the proposal text. The search tools were US-only, so a missing result is not proof, and the title's first half is a finding with that caveat.

The last real change was Lei 56/2023, published on 6 October 2023 and in force the next day. It revoked the routes for buying property (€500,000), rehabilitating property (€350,000 to €500,000 depending on date) and transferring €1.5 million in capital. Existing permits keep renewing under the old regime and pending requests were reported to stay valid, according to law-firm summaries from SRS and NFS. We confirmed the revocation heading and the pending-requests article heading in the Diário da República, not the bodies.

Citizenship delayed. Three qualifications apply. The delay covers nationality applications filed from 19 May 2026, because article 7(2) leaves procedures pending on that date under the old text. The law does not single out ARI holders. Article 15(3) counts any legal residence, so golden-visa time counts like any other title. And the clock changed because parliament repealed article 15(4), which Lei Orgânica 1/2024 had inserted to count residence "desde o momento em que foi requerida a autorização de residência temporária desde que a mesma venha a ser deferida", that is, from the application if it was later granted.

The government's stated position is that the scheme was never about citizenship. A presidency source told ECO on 19 May 2026 that the regime "nunca teve como finalidade a atribuição da nacionalidade" and rested on a minimum presence of about 14 days per two years. Minister António Leitão Amaro told a parliamentary committee that advisers who sold an investment permit as a route to a passport had misled clients (Observador, 27 May 2026; IMI Daily dates the remarks to 24 May, a conflict we could not resolve).

The routes still open, and the stay rule

Nothing in the open routes needs a property. The fund route dominates in practice. ECO reported on 24 January 2024 that 352 of the first nine months of 2023's titles, about 30%, came from fund units, and that fund titles totalled 723 and about €261 million over five years. The cultural-donation route is the fastest-growing: transfers reached €46.8 million in 2025 against €11.7 million in 2024, from 211 declarations against 50, according to Ministry of Culture data reported by Diário de Notícias on 13 April 2026. If each 2025 declaration maps to one principal, donations were about 7.9% of the year's 2,685 titles, which is our derivation under that assumption.

The stay rule is the shortest obligation in European residence law. Holders must spend 7 days in Portugal in the first year and 14 days in each later two-year period, under article 65-C of Decreto Regulamentar 84/2007 as amended in 2015, which we read through the informador.pt aggregator and Legispédia. Over five years that is 7 + 14 + 14 = 35 days, a derived total that also applies to each family member. Portugalist gives the same total split as 14 plus 21, which conflicts with the regulation. Permits are granted first for one and then renewed in two-year periods, and permanent residence is available at five years (SRS, a summary).

Grants by year: a record, if 2023 was 2,091

SEF's series, relayed by Lusa and idealista on 9 January 2023, shows the programme peaking at 1,526 in 2014, falling to 865 in 2021 and recovering to 1,281 in 2022. The 2012 to 2022 values sum to 11,535, which matches the cumulative SEF reported. ECO gives 2,091 for 2023, the first year above 2,000, then 2,081 in 2024 (AIMA's 2024 report, published 16 October 2025) and 2,685 in 2025, up 29.0%, citing AIMA's annual report as quoted by Público on 25 September 2026. The cumulative total reached 18,254, which is 12,718 to September 2023 plus 5,536 since.

The 2023 figure does not reconcile. Taking 12,718 to September 2023 and 11,535 through 2022 leaves 1,183 for the first nine months. Subtracting 2024 and 2025 from the 5,536 leaves 770 for the last quarter. The two sum to 1,953, which is 138 below ECO's 2,091 (all derived). A summary of AIMA's 2023 report and a Diário de Notícias piece of 13 April 2026 give 2,901. If 2,901 is right, 2025 is not a record. We could not open AIMA's 2025 report, so we also cannot confirm that 2,685 counts principal investors only. It is the likelier reading, because family members sit under a separate article and 2024 had 2,909 family-reunification titles beside 2,081 ARI (derived sum 4,990).

Family members have always outnumbered investors. SEF counted 18,808 family titles against 11,535 principals to December 2022, about 1.6 relatives per investor (derived). The programme therefore adds more residents than its headline count suggests, and the 1,585,854 foreign residents AIMA counted at the end of 2025 include an unknown share of them.

The money: two totals and then silence

The investment series is the part of the programme the state has stopped reporting. SEF counted €646 million in 2020, about €460 million in 2021 and €654.2 million in 2022, up 41.9%. At December 2022 the cumulative total was €6,754 million. Property accounted for 10,593 titles and €6,041 million of it, including 1,485 rehabilitation titles worth €534.1 million, and capital transfers for 920 titles and €712 million. On those numbers property was 89% of the capital and 92% of the titles (both derived).

Then the totals diverge. Observador's fact-check of 14 February 2024 and ECO's report of 25 September 2026 give €6,450 million and €6,451 million for the 12,718 titles to September 2023. ECO's report of 24 January 2024, citing the same SEF file, says those titles came with more than €7.3 billion. Our nationality article repeated the €6.451 billion pairing. The cumulative at December 2022 was already €6,754 million, and a cumulative cannot fall, so €6.45 billion cannot be an all-route total nine months later. It is consistent with the property series: €6,041 million at December 2022 plus 2023 purchases. Subtracting leaves about €867 million outside property at September 2023, against €713 million at December 2022. The extra €154 million fits fund inflows of more than €125 million that ECO reported for the period (all derived). We therefore read more than €7.3 billion as the all-route total and €6.45 billion as property. That is an inference from arithmetic, not a statement by SEF.

Since then AIMA has published nothing. The best proxies are partial. APFIPP data reported by ECO on 26 June 2026 show redemptions from ARI-eligible funds of €94.7 million from January to May 2026, against €45.3 million in all of 2025, while subscriptions were €283 million for the period and €732 million for 2025 (IMI Daily, 29 June 2026). Net inflows for January to May were about €188 million (derived), so the sector is still growing. The Bloomberg figure we flagged in the nationality article, about €20 million, covers roughly 40 investors at one manager, Optimize (Washington Post syndication, 12 June 2026), which settles that discrepancy as a difference of scope. Subscriptions in eligible funds are not all visa applicants, so none of these numbers is investment by ARI holders.

Who buys: the US leads each year, China leads overall

Americans led in 2023, 2024 and 2025, with 535 of the 2,685 titles last year, about 19.9% (derived). Chinese investors had 5,247 grants to 2022 against 537 for Americans, so adding the three later years gives roughly 6,241 for China and 2,045 for the US (derived). The claim that the US is the top golden-visa nationality is therefore true for each recent year and false over the programme's life. Our US and Spain comparison sets the American market against the other source markets.

Russia fell from 248 in 2024, third, to 160 in 2025, down about 35% (derived), while Turkey rose from 128 to 188 and the United Kingdom from 147 to 252. Those moves came in 2025, before the law was in force. The June 2025 proposal could have prompted applications ahead of it, a possibility no source tests.

The citizenship clock in practice

Under the old rule a two-year wait for AIMA to decide a permit still counted toward the five years. Under the new one the same wait is dead time before a ten-year clock starts. The windows for adding interrupted periods shrink with it, to 12 years for the 10-year track and 9 for the 7-year track (art. 15(3)). The statute does not say the clock begins when the card is printed. The repeal means counting starts from the grant of the permit, and the date a grant counts from, decision or card, has not been tested by IRN.

The size of the wait matters because AIMA's queue is not measured. AIMA's Paulo Henriques put pending ARI processes at 50,000 on 14 January 2025, including family members, some stalled more than two years (Público Brasil). A law-firm executive relaying an AIMA meeting said more than 55,000 on 6 February 2025, which covered investors, family, first grants and renewals (IMI Daily). The minister promised on 29 October 2025 to resolve most cases in 2026 (Observador). On 8 October 2026 he reportedly told parliament 46,000 were pending and 6,000, about 13%, had been processed, but we could not find that in a parliamentary record. A Brazilian site citing Público gave about 29,000 investors pending in August 2026. Commercial advisers quote 12 to 24 months to biometrics and 9 to 12 more to the card. None of these figures share a date or scope.

The cutoff line is the filing date. An ARI holder with five counted years who filed for nationality before 19 May 2026 keeps the old rules, because article 7(2) protects procedures pending when the law entered into force. The Portugal News writes "on or before 18 May", while the statute says pending on entry into force, which was 19 May. Nobody addresses a filing made on 19 May itself, and a lawyer should confirm that edge case. The regulation of the law was due about 16 August 2026 under article 4, and DN Brasil reported on 19 August that it had not appeared. We found nothing after 20 August and no format for the new culture and history test.

Courts have not helped investors yet. The Constitutional Court struck four norms in Acórdão 1133/2025, none of them the ten-year period according to our nationality article, although The Portugal News and IMI Daily describe the Court as having examined or upheld the periods. We could not reread the ruling for this piece. Investor complaints grew from more than 500 holders, mostly American, planning a collective action (Expresso via Observador, 7 to 8 May) to a complaint to the Ombudsman by ten law firms on 24 June reported at more than 1,200, then 1,260 and a forecast 2,000 (ECO, 24 June and 20 July). Lawsuits were threatened for September. We found no confirmed filing by 25 October, which is not proof that none exists. The industry association PAIIR, with Vieira de Almeida, was studying collective claims and treaty arbitration in May (Executive Digest).

Funds under review

Funds are where the golden visa meets financial regulation. Managers told ECO on 14 May 2026 that IMGA held more than €500 million globally from over 1,000 investors, Optimize about €350 million from about 800 clients, 3 Comma €130 million from about 400, and Heed more than €100 million from 370. These are unaudited self-reports. IMGA also warned that activity could fall 30% to 40% if the uncertainty lasted, a conditional projection by an interested manager, and said interest had started to recover.

On 21 October 2026 the CMVM issued Circular 007/2026, with 28 recommendations to venture-capital fund managers after thematic supervision found irregularities. It limits referral agents to passing investors on, requires key information documents, a two-thirds venture-capital asset test and cost disclosure (Jornal Económico). The reporting does not name golden-visa funds, and we found no fund failure. No official census of eligible funds exists: a commercial site lists 36, 31, 14 and "50+" on different pages, and confirms only six as CMVM-registered.

Europe: Portugal against Spain and Greece

Spain closed its route on 3 April 2025 under Organic Law 1/2025. It had issued 14,576 property visas from 2013 to early 2024 (La Moncloa, 9 April 2024), and its final count and pending cases are unpublished. Ireland closed in February 2023. Greece stayed open, with tiers of €800,000, €400,000 and €250,000, and recorded 8,879 initial investor permits in 2025 against 4,535 in 2024. Its applications fell to 7,021 from 9,372 and the pending stock dropped from 9,958 at the end of 2025 to 6,315 by July 2026, which suggests approvals reflected backlog clearance. China held 47.9% of Greece's roughly 20,732 active initial permits (Aegalis, 6 October 2026).

EU pressure has fallen mainly on citizenship schemes. The Court of Justice found against Malta on 29 April 2025 (Case C-181/23). The Commission's 2022 recommendation asked for strong checks on residence schemes, and its proposal to recast the Long-term Residents Directive would monitor physical presence in investor permits. We found no adopted measure and nothing aimed at Portugal's ARI.

Property, tourism and what nobody counts

Closing the property route was followed by weaker foreign demand for homes. INE recorded 8,471 purchases by non-residents in 2025, down 13.3%, worth €3.4 billion, or 5.0% of transactions (derived from 161,341 resident purchases, 95% of the total). The Algarve took 29.7% of non-resident purchases and 42.4% of their value, and Greater Lisbon 22.2% of value (press reproductions of INE; ine.pt was blocked). Observador put golden-visa money at about 3.1% of residential investment to September 2023, an approximation that mixes periods. The decline began after October 2023, but nothing separates the end of the route from interest rates and prices, so no effect can be assigned. See our Algarve and Lisbon statistics for the markets involved.

The visitor angle is a blind spot. A holder who meets the 35-day minimum over five years is a resident on paper and a short-stay guest in practice. INE counts guests and nights in registered accommodation, so a holder in an owned home or an unregistered rental does not appear. No source we found measures holders' actual stays or second-home use, which leaves the ARI's tourism footprint unknown.

Ten claims tested

Most pages ranking for golden-visa queries were written before May 2026 or sell the product. The first and fourth claims in the panel matter most. The five-year line is a three-year-old fact, and the €6.451 billion pairing came from our own article.

What this means for travelers, businesses and analysts

Travelers. Nothing in the golden visa or the nationality law changes how tourists enter Portugal or how long they stay. People using trips to test a move should know the legal minimum is a week in the first year and two weeks every two years, and that a passport now needs a decade. Our Lisbon travel guide and Algarve guide cover where relocators usually start.

Tourism businesses and investors. The residence product survives and the passport promise does not. Fund managers, advisers and relocation firms should expect demand to move on price and certainty rather than disappear: net fund inflows were still positive in 2026. Three thresholds would change that read. Grants for 2026 below the 2,000 to 2,100 of 2023 and 2024 would show the law costing demand. A CMVM follow-up naming golden-visa funds would hit the dominant route. A published AIMA pending count far above 46,000 would show the residence leg is the bottleneck.

Journalists and analysts. Safe to cite: Lei 56/2023 closed the property routes on 7 October 2023; Lei Orgânica 1/2026 applies from 19 May 2026 with 10 years, or 7 for EU and CPLP nationals, and does not mention the ARI; 18,254 ARI granted since 2012 and 2,685 reported for 2025; 12,718 to September 2023; 35 days of required presence over five years (derived). Do not repeat: €6.451 billion as the all-route total, "€7 billion raised" as a current figure, a "55,000 backlog" without its date, "citizenship in five years", or "the golden visa ended". The series finding this article adds is that the one official investment series stopped in 2023, and its two totals differ by more than €800 million.