The landscape of Portugal’s Golden Visa program has undergone a significant transformation with the recently approved “Pacote mais Habitação”. This move comes as the government seeks to protect and control the real estate market prices, primarily for the benefit of Portuguese citizens. 

While this new policy may shift investor preferences, it opens new opportunities for investment funds that focus on non-real estate ventures.

In this article, we explore the current available Golden Visa investment options, the growing trend of investment funds, the reasons behind increased interest from US clients, and the promising opportunities in sustainable funds.

October 2023 latest changes

The new law came into effect on Saturday, October 7, and real estate investments as well the capital transfers are no longer accepted as a qualifying investment for the Portugal Golden Visa. However, the good news is that there are several alternative ways of applying for the Golden Visa program.

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Portuguese Golden Visa Investment Options

With the recent changes, the Golden Visa program will continue with the current available investment options:

1. Investment funds

Contribution of €500,000 or higher, for the acquisition of units of investment funds or venture capital fund of funds under the Portuguese legislation, whose maturity, at the moment of the investment, is, at least, of five years and, at least, 60% of the investments is realized in commercial companies with head office in national territory.

2. Business Investment

Minimum investment of €500,000 for constitution of a company in Portugal, combined with the creation of five permanent working jobs, or for the reinforcement of the share capital of a company already existing in Portugal, with the creation of at least at least five permanent jobs or maintenance of at least ten job positions, with a minimum of five permanent employees, and for a minimum period of three years. 

3. Scientific research

Capital transfer with a value equal to or above €500,000 for investing in research activities conducted by public or private scientific research institutions involved in the national scientific or technologic system. If the investment is located in a designated ‘low-density’ area, then a 20 percent discount applies.

4. Cultural heritage contribution

Known as the Cultural Golden Visa, donation of a minimum of €250,000 for investing in artistic output or supporting the arts, for reconstruction or refurbishment of the national heritage, through the local and central authorities, public institutions or, private foundations of public interest. If the investment takes place in a ‘low-density’ area, then a 20 percent discount applies.

5. Job Creation

Incorporating a company and creation of at least, ten jobs positions. If the investment is located in a designated ‘low-density’ area, then a 20 percent discount applies.

Portugal Golden Visa Low Density Areas

Low-density territories, as per the stipulations of Ordinance No. 208/2017, enacted on July 13th, 2017, are geographic regions having a population density of fewer than 100 inhabitants per square kilometer or the per capita gross domestic product (GDP) falls below 75% of the national average

The future of the Portugal Golden Visa

The success of the Real Estate Route

The Golden Visa program, introduced in Portugal in 2012, quickly garnered attention from international investors seeking residency in a European country with a flourishing real estate market. 

The real estate route, with its relatively affordable investment threshold and the prospect of capital appreciation, became the preferred choice for many investors looking to diversify their investment portfolios and gain European residency benefits.

The allure of Portugal’s real estate market stemmed from several factors. First and foremost, the investment threshold for the real estate route was notably lower than other similar residency-by-investment programs in Europe (minimum of €280.000), making it more accessible to a broader range of investors. 

The Growth of Investment Funds Option

The surge in investment funds over the last few years, as a replacement for the real estate route, can be explained by several factors, such as:

Impact of COVID-19: The pandemic and travel restrictions made real estate investments less attractive to foreign investors, leading them to explore alternative options.

Changes in Golden Visa Program: The government’s decision to exclude residential real estate investments in high-density areas like Lisbon or Porto from the Golden Visa eligibility contributed to a shift towards investment funds.

Rise of US Clients: US investors have shown a growing interest in investment funds, as they are accustomed to investing in funds and appreciate the diversified nature of such investments. 

Why Americans are investing in Portugal Golden Visa Investment Funds

The rise of US clients’ interest in investment funds in Portugal’s Golden Visa program can be attributed to several key factors that have made investment funds an attractive option for American investors.

Familiarity with Investment Funds

US investors have a long-standing tradition of investing in funds. Mutual funds, exchange-traded funds (ETFs), and other types of investment funds are popular investment vehicles in the United States. 

Diversification Benefits

Investment funds inherently offer diversification benefits by spreading investments across various assets, industries, and regions. Diversification is a cornerstone of modern portfolio theory, and US investors recognize the advantages of reducing risk through diversifying their investments. 

Regulatory Confidence

The US financial market is known for its stringent regulatory framework overseen by agencies such as the Securities and Exchange Commission (SEC). Similarly, Portugal’s financial market is well-regulated, with the Comissão do Mercado de Valores Mobiliários (CMVM) overseeing investment activities. 

Global Economic Diversification

US investors recognize the value of global economic diversification to mitigate risk and enhance returns. Investing in Portugal, an EU member state with a stable economy and strategic geographical location, provides US clients with exposure to a different economic environment outside the United States. 

Higher Returns in Portugal Golden Visa Investment Funds

Investing is all about seeking opportunities that offer attractive returns and growth potential. Traditionally, real estate has been a popular choice for investors due to its tangibility, stability, and potential for appreciation. 

However, in recent years, investment funds have emerged as a compelling alternative, offering the potential for higher returns and diversification benefits.

Portuguese Real Estate Return

Real estate has long been considered a secure investment option, providing stable returns over time. Property investments often offer rental income streams, which, combined with property value appreciation, contribute to overall ROI. However, the ROI in real estate is generally modest, ranging from 2-4% per annum on average. 

Portuguese Investment Funds Return

Investment funds can yield significantly higher returns compared to real estate. Depending on the fund’s focus and investment strategy, returns can range from 5-8% per annum. Certain venture capital funds, which invest in startups and high-growth companies, have the potential to generate even more impressive returns, reaching 15-20% or more.

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Where to Invest in Portugal Golden Visa Investment Funds Now?

Considering the recent changes in the law and the resulting shift in investor preferences, some promising sectors for sustainable and socially responsible investments include:

Sustainable Funds: Investments that align with environmental, social, and governance (ESG) criteria, promoting responsible and sustainable business practices.

Renewable Energy: Investing in clean and renewable energy projects to support the transition to a greener future.

Farmland: Agriculture and farmland investments have proven to be stable and resilient, attracting investor interest.

Agrotech: The integration of technology and innovation in agriculture presents exciting opportunities for growth and returns.

Bluetechalso known as blue technology funds or ocean technology funds, refer to investment funds that focus on companies and projects related to marine or ocean-related technologies and innovations.

The Rise of Sustainable Investments

Sustainable investments, also known as socially responsible investments or impact investments, aim to generate positive environmental and social impacts while still providing financial returns to investors. 

In recent years, there has been a growing awareness of the need to address global challenges such as climate change, resource depletion, and social inequality. As a result, investors are increasingly seeking to align their investment decisions with their values and contribute to sustainable development.

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Dual Benefits: Residency and Sustainable Impact

The concept of dual benefits is at the heart of the growing trend in investment migration programs that merge residency and citizenship goals with sustainable impact. These programs, such as the Portugal Golden Visa, are designed to offer investors much more than just a legal pathway to reside in a new country. 

On one hand, investors achieve their aspirations of international mobility and the chance to experience life in a vibrant European nation, but the advantages extend far beyond personal convenience.

The sustainable impact is the second, equally compelling facet of this dual benefit. It signifies the alignment of investor goals with a commitment to environmental, social, and governance (ESG) principles. By integrating sustainable investments into residency or citizenship programs, investors play an active role in fostering positive change. 

The dual benefits of residence and sustainable impact are not just an investment; they are a legacy of responsible global citizenship that resonates with investors who seek to make a meaningful difference while pursuing their dreams of living abroad.

Advantages of investing in sustainable ESG Funds

Positive Impact

ESG funds provide investors with the opportunity to make a positive impact on society and the environment. By supporting companies that prioritize ethical and sustainable practices, investors can contribute to addressing pressing global issues such as climate change, social inequality, and responsible corporate governance.

Long-Term Viability

ESG investments often focus on the long-term sustainability of companies. By considering environmental risks, social responsibilities, and governance practices, ESG funds aim to select businesses that are well-prepared for future challenges, leading to potentially more stable and enduring investments.


ESG funds typically include a wide range of sectors and industries, providing diversification within the portfolio. This diversification can help spread risk and enhance the stability of the investment.

Growing Market

The ESG investment market is experiencing significant growth. As environmental and social concerns gain prominence, the ESG market is expanding to offer a diverse array of investment opportunities. This growth indicates a heightened demand for sustainable and responsible investing.

Application Process for the Portugal Golden Visa Investment Funds

Please note that while this summary provides a general overview, it is recommended to consult with a professional legal advisor for detailed guidance tailored to your specific situation.

  1. Select the desired Golden Visa investment fund(s) for your investment.
  2. Engage the services of a reputable law firm experienced in Golden Visa.
  3. Obtain a Portuguese NIF number and open a bank account in Portugal.
  4. Sign and complete the necessary subscription documents for the fund(s).
  5. The fund managers assess your eligibility and approve you as an investor.
  6. Transfer the invested funds from your bank account to the fund account.
  7. The fund manager provides you with the fund subscription declaration.
  8. Your law firm submits your application to AIMA (former SEF).
  9. Schedule a biometrics appointment with AIMA and attend in person.
  10. Upon approval, AIMA issues a residence permit valid for initial period of two years.
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Why choose with us for your Golden Visa investment?

Local Expertise

We know Portugal. Due to our extensive local knowledge, we believe that concentrating our services in a single country destination is the best way to give you the most thorough and useful information. 

Holistic Approach

One single channel of communication for the entire process. We provide you with a comprehensive service that covers all aspects of your investment and Golden Visa application. 

Transparent Service

We recommend what’s best for you based on an extensive process experience that saves time and money to clients. Our pricing is clear and competitive, and we don’t sell services that make us more money.

Simple Process

Technology plays a very important role in our company. We minimize our clients’ involvement in paperwork. We are customers ourselves and we know how to serve you.

Frequently asked questions about the Portugal Golden Visa Investment Funds

What are Sustainable Investment Funds?

ESG Investment Funds are focus on Environmental, Social, and Governance (ESG) criteria, ensuring that the investments align with positive environmental practices, social impact, and transparent corporate governance.

What returns can investors expect from investment funds compared to real estate?

Investment funds offer the potential for higher returns compared to traditional real estate investments. While real estate typically yields a return on investment (ROI) of 2-4%, investment funds can provide returns ranging from 5-8% or even higher, depending on the fund’s focus and risk profile.

How do investment funds benefit Golden Visa applicants?

Investing in non-real estate funds allows applicants to diversify their portfolios, reducing overall investment risk. Professional fund management ensures expert oversight, and greater liquidity compared to real estate provides access to funds when needed.

Are investment funds regulated in Portugal?

Yes, investment funds operating within the Portugal Golden Visa program are subject to strict regulatory oversight by the Comissão do Mercado de Valores Mobiliários (CMVM). This ensures transparency, safeguards investor interests, and complies with EU Directives and relevant financial regulations.

What sectors can investment funds target beyond real estate?

Investment funds can target various sectors, such as sustainable projects, renewable energy ventures, agrotechnology, and other non-real estate opportunities. The focus is on supporting initiatives contributing to environmental and societal well-being.

Can investors apply for the Golden Visa solely through investment funds?

es, investors can meet the Golden Visa’s financial requirements by investing solely in eligible investment funds beyond real estate. These funds offer a viable and attractive option for residency.

Can investors switch from real estate to investment funds if they already started the process for the Golden Visa?

The eligibility criteria change applies to new applications. Existing applicants who have already chosen the real estate route will not be affected and can continue with their initial investment plan.