Portugal’s Golden Visa remains one of Europe’s most resilient residency-by-investment programmes. Yet, the landscape in 2025 looks very different from just two years ago.

Since the introduction of the Mais Habitação Law (2023), Portugal has undergone a profound policy shift — one that redefines how foreign investors can contribute to the country’s economy. Real-estate purchases and pure capital transfers have been removed as eligible investment routes, marking a decisive turn toward productive, regulated, and innovation-driven sectors.

From Property to Productive Capital

The government’s objective is clear: move away from speculative housing investment and channel foreign capital into areas that create long-term economic value. That includes private-equity and venture-capital funds, research & development initiatives, job-creation projects, and cultural or heritage preservation programmes.

This transition not only supports Portugal’s broader housing-affordability goals but also aligns the Golden Visa programme with the European Union’s sustainability and transparency directives.

SEF to AIMA: A New Administrative Framework

In late 2023, Portugal replaced its long-criticised immigration authority — the Serviço de Estrangeiros e Fronteiras (SEF) — with a new body: Agência para a Integração, Migrações e Asilo (AIMA).

By 2025, AIMA has begun to stabilise operations and reduce the backlog of pending applications. Applicants from 2022–2024 are now being scheduled for biometrics appointments, and the agency has announced plans for a fully digital submission system expected to launch in early 2026.

Under AIMA, applications will be processed end-to-end online — from document upload to biometrics scheduling — a long-awaited improvement that promises greater transparency and shorter wait times.

Government Objectives for 2025

The reformed programme now reflects a government-wide strategy to:

• Promote sustainable investment aligned with Portugal’s 2030 development goals.

• Channel foreign capital into innovation, renewable energy, education, and healthcare.

• Improve compliance, governance, and transparency under CMVM supervision.

• Enhance digital efficiency in immigration processing through AIMA’s platform.

For investors, these updates create both opportunity and complexity. The Golden Visa remains active — but its success now depends on informed decision-making and strategic alignment with the new rules.

Legal Changes and Their Impact on Golden Visa Applicants

June 2025 brought the most significant legal development in a decade: a proposed reform to Portugal’s nationality law, which directly affects the citizenship pathway available to Golden Visa residents.

The Citizenship Timeline Extension

Under the reform approved by Parliament on 28 October 2025 (and now under Presidential review), the residency period required for citizenship will increase from five years to ten years for most applicants.

• CPLP nationals (from Portuguese-speaking countries) and EU citizens will face a shorter, seven-year requirement.

• The period will begin from the issuance date of the first residence card, rather than the date of application.

For current Golden Visa holders, this distinction is critical. Many who believed they were approaching the five-year mark for citizenship eligibility will need to reassess their timeline under the new counting method.

Other Key Nationality Reforms

The new law also introduces:

• A civic knowledge test assessing understanding of Portuguese culture, rights, and duties.

• Mandatory declaration of adherence to democratic values.

• Requirement to demonstrate sufficient means of subsistence and a clean criminal record (threshold lowered to two years).

• Termination of the Sephardic Jewish ancestry route for automatic naturalisation.

While these updates bring Portugal’s naturalisation framework closer to European averages, they also introduce uncertainty for thousands of residents and investors who entered under the previous five-year rule.

Transitional Protection for Existing Applicants

According to legal precedent and government briefings, citizenship applications submitted before the new law’s entry into force - and deemed complete - should proceed under the current five-year regime.

However, any incomplete or “tick-box” submissions may fall under the new timeline once the law is enacted. The absence of a clear grandfather clause has raised constitutional questions and could be subject to review by the Constitutional Court.

Until promulgation, the law remains pending - but investors are strongly advised to plan for longer naturalisation horizons.

Mitigating Risk During Transition

Given the fluid legislative environment, applicants should:

• Secure comprehensive legal representation from licensed Portuguese immigration lawyers.

• Ensure document completeness and authenticity before submission.

• Keep records of application submission dates and residence-card issuance for future eligibility proof.

• Monitor official AIMA and Parliament announcements for updates on the law’s promulgation.

The next months are pivotal: once the President signs the decree or refers it to the Constitutional Court, implementation details will follow within weeks.