Residency & Citizenship by Investment: Portugal vs Spain, Malta & Greece
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Explore how Portugal, Spain, Malta and Greece compare in investment requirements, timelines, residency obligations and citizenship pathways. Find the right EU plan for you.
For investors seeking a European residency or citizenship plan, choosing the right country means balancing investment cost, stay requirements, family inclusion and ultimately, how quickly you can get an EU passport.
In this guide, we compare four major programmes: Portugal, Spain, Malta and Greece. We break down investment thresholds, residency obligations, citizenship timelines, and recent policy changes so you can decide which path suits your goals.
At Golden Visa Funds Portugal (GVFP) we specialise in fund-based residency programmes (especially in Portugal). Explore our Portugal Golden Visa Funds Complete Guide 2025 for full details and fund-shortlist support.
Country | Main Investment Route | Minimum Investment* | Stay Requirement | Citizenship Timeline | Recent Changes |
|---|---|---|---|---|---|
Portugal | Regulated funds/capital transfer (real-estate route closed) | ~€500,000 minimum fund route | 7 days in 1st year, 14 days every 2 years | 5 years to citizenship (proposal to 10 not yet law) | Real-estate exit; fund route dominant |
Spain | Real-estate investment (until programme ended) | €500,000 real-estate minimum | Higher stay requirement; previous requirement ~183 days/year | 10 years to citizenship (active period) | Programme terminated April 2025 |
Malta | Permanent Residence / Investment + property/donation | Property + contribution, e.g. €300k+ property or €350k+ | No minimal stay in some schemes | Variable; citizenship programme ruled illegal in 2025 | “Golden passport” scheme ended by EU Court |
Greece | Real-estate investment starting from ~€250k | ≈ €250,000 minimum real-estate in many zones | Minimal stay requirement | ~7 years to citizenship | Remains active but subject to possible route restrictions |
H3 Investment Routes & Thresholds
Portugal: Real-estate option has been effectively closed; now the dominant route is fund investment or capital transfers.
Spain: Investment mainly via property (€500k+), but programme ended April 2025.
Malta: Requires a combination of property (purchase or rent), donation/contribution, and liquidity.
Greece: Real-estate investment option remains, with lower thresholds (~€250k) compared to other countries.
H3 Residency & Stay Requirements
Portugal: Extremely flexible — only 7 days in Year 1, then 14 days every 2 years.
Spain: Required more substantial physical presence; with the program ending, new entrants are no longer possible.
Malta: Residency rules vary by specific route. Many programmes focus on maintaining property and fund investment rather than minimum days.
Greece: Minimal stay required; allows investors to hold residency with limited physical presence.
H3 Citizenship & Long-Term Outlook
Portugal: Fastest path—5 years to citizenship under current law. Proposal to extend to 10 years is under discussion but not yet law.
Spain: 10 years to citizenship historically; with programme termination, not a viable new route.
Malta: Citizenship by investment programme abolished following EU ruling (April 2025).
Greece: Typically ~7 years of residency before citizenship eligibility.
H3 Programme Stability & Risk
Portugal: Still active, though investment routes changed (real estate closed). Fund route now primary.
Spain: Risky for new applicants; programme ended.
Malta: Citizenship investment scheme struck down; caution recommended.
Greece: Active but may face changes (especially in the real estate route) as EU dynamics evolve.
Internal Links
For full details, see our Portugal Golden Visa Complete Guide 2025 for routes, fund listings, and updates.
FAQs
Q1. Can I still apply for Spain’s Golden Visa?
A: No - as of April 2025, Spain has terminated its real estate-based Golden Visa route.
Q2. Does Portugal still allow real estate investments?
A: No - Portugal has shifted its Golden Visa programme away from residential real estate, focusing on fund or capital transfer routes.
Q3. What are the tax implications if I choose one of these programmes?
A: Tax regimes differ greatly. Portugal offers flexibility with minimal physical stay; Greece offers residency but not immediate citizenship; Malta’s programme has changed. Always consult a tax adviser.
Q4. Which country offers the fastest route to an EU passport?
A: Currently, Portugal -5 years to citizenship -offers the fastest path of the four.
Q5. Is family inclusion possible in all these programmes?
A: Generally, yes — spouse and dependent children (and sometimes parents) can be included. But exact rules vary by country and route; check each programme’s requirements.
Choosing the right residency or citizenship programme is a strategic decision. At GVFP, we specialise in fund-based routes - especially for Portugal’s Golden Visa - helping you evaluate funds, timelines, and legal stability.
👉 Contact us today for a tailored fund shortlist or download our 2025 Investor Guide to take the next step with confidence.
Pedro Lopes
Partner at goldenvisafundsportugal.com
Pedro Lopes is a seasoned real estate professional with over a decade of entrepreneurial experience. As a partner at goldenvisafundsportugal.com, Pedro brings extensive expertise in the Portuguese Golden Visa program, with a particular focus on the fund investment route.
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