Spain vs Portugal Golden Visa: Spain closed, Portugal active

This guide compares the two routes on the points that actually decide an application: programme status, qualifying investments, family inclusion, the annual physical-stay rule, the path to permanent residence, the path to citizenship, indicative costs and timing, and the residence-vs-tax separation. Every benefit is paired with its current limit, because residence is not citizenship, and a closed route is not a renamed one.

The table is a summary. The sections below explain each line in context. Programme rules, fees and indicative timelines may change after publication; the verifier date on this guide is shown above the article.

Comparing the two for your own situation? Speak to a My Golden Visa adviser for a tailored read on Portugal's active route and on transitional Spain questions for existing holders.

What changed on 3 April 2025

Spain's investor residence route was created by Law 14/2013 to support entrepreneurs and qualifying investors. Organic Law 1/2025, published in the Boletín Oficial del Estado, repealed Articles 63 to 67 of Law 14/2013 — the investor-residence articles. From 3 April 2025, the Spanish authorities no longer accept new investor-residence applications under those articles.

The closure covers the full investor category, not only the real-estate option. Government bonds, financial assets, share capital and business-project investments under the same articles are equally closed to new applications. An investor visa requested before the cutoff may fall under transitional handling. That is decided on the rules in force at the time of the initial request, and it is a question for Spanish immigration counsel rather than a general statement.

Existing investor-residence holders

An existing holder of a Spain investor-residence permit is not in the same position as a new applicant. A valid authorisation keeps its issued validity. A renewal is assessed under the rules that applied when the initial authorisation was granted, provided the legal requirements continue to be met.

Long-duration residence in Spain may be available after at least five years of legal residence, if the separate Spanish requirements for that status are met. This is a Spanish national residence pathway, not a continuation of the investor route, and it does not lead automatically to nationality.

Other Spanish authorisations exist as separate routes under Spanish law — for entrepreneurs, highly qualified professionals, intra-company transfers, researchers, and remote workers. They are not a renamed version of the closed investor-residence route, and they each have their own eligibility, documentary and stay requirements.

Qualifying investment routes

Portugal's residence-by-investment programme operates under Article 90.º-A of the Portuguese foreigners' law and is administered by AIMA, the Portuguese Agency for Integration, Migrations and Asylum. The 2023 reform removed the real-estate route, so a Portugal Golden Visa choice today sits between non-real-estate qualifying investments.

The current Article 90.º-A options include:

• Investment funds — from EUR 500,000. A qualifying contribution from EUR 500,000 in eligible Portuguese venture-capital or private-equity funds that meet Article 90.º-A conditions, including the maturity and Portuguese-investment thresholds set in the legislation. This is the most settled of the current minima.
• Business with job creation. Incorporation of a Portuguese company or capital increase of an existing one, with the creation of the qualifying number of jobs required by Article 90.º-A. The exact capital and job thresholds for this route are subject to legal and database reconciliation. The named authority is AIMA, and an applicant should confirm the figure in force with AIMA and a Portuguese immigration lawyer at the time of application.
• Scientific research. A qualifying contribution to public or private research activities integrated in the national scientific and technological system. The exact minimum is also being reconciled. AIMA is the named authority, and confirmation by a Portuguese immigration lawyer is recommended before capital is committed.
• Artistic and cultural heritage. A qualifying contribution in support of artistic output, or the recovery and maintenance of national cultural heritage, under the conditions set by the responsible Portuguese authorities.

Real-estate purchases, real-estate-backed funds, and capital-transfer routes that previously existed are not available under the current framework. Any "Portugal Golden Visa property" pitch in 2026 is referring to a route that no longer exists.

Investment-funds route: what to check before committing capital

The investment-funds route is the most active path in 2026, and EUR 500,000 is only the entry ticket. Three further questions decide whether a specific fund fits a specific applicant, and an investor should expect a written answer to each before subscribing.

• Fund mechanics and term. What is the fund's investment period, the holding period, and the expected term to liquidation? Article 90.º-A funds typically run for several years, and the term — not the EUR 500,000 number — is what should be compared against the applicant's naturalisation timeline.
• Capital position. What protection (if any) does the fund structure offer for the subscribed capital, and what is the manager's track record on capital preservation? Venture-capital and private-equity funds carry market risk. "Capital safe" is not a default, and should be evidenced by the fund's offering documents rather than assumed.
• Distribution and exit. What is the dividend or distribution policy, and what does the redemption picture look like at fund maturity? If a fund is scheduled to mature before naturalisation eligibility, the applicant may need a planning conversation with the fund manager and a Portuguese immigration lawyer well in advance of the fund's wind-down.

These questions are not specific to one fund. They are the standard diligence headings for any Article 90.º-A investment-funds subscription, and they should be answered in writing by the chosen fund manager and reviewed independently by an investor's own counsel.

Annual physical-stay rule

Portugal's Article 90.º-A residence is conditional on the holder maintaining the qualifying investment and meeting a minimum annual physical-stay requirement. The minimum is assessed per application against the rules in force, and the residence card and renewal cycles follow the standard Portuguese residence-permit calendar.

Two questions decide what this means in practice for a specific applicant, and both should be confirmed with AIMA or a Portuguese immigration lawyer before relying on a number.

• How many days per year are required, on the rules applied to a new application. Public summaries of the stay rule do not consistently produce a single day count, and AIMA's per-application assessment is the position that controls. An applicant should ask AIMA — or have a Portuguese immigration lawyer ask on their behalf — for the day count that will be applied to their renewal cycle.
• Whether the day count is per main applicant or per family member. Family-inclusion rules and physical-stay rules sit under separate provisions, and the answer should be confirmed for each dependant on the application rather than generalised across the family.

A residence-by-investment plan that depends on "minimal presence" should be built on the answer to those two questions, not on a competitor article's headline number.

Family members who can be included

Portugal's family inclusion is broader than Spain's historical position. A main applicant may include:

• a spouse or partner under Portuguese family-reunification rules;
• dependent children, including children over 18 who are unmarried and studying;
• dependent parents of the main applicant; and
• dependent parents-in-law.

Each dependant must meet the documentary and dependency-evidence rules at the time of application. Including a parent-in-law is one of the more frequent reasons clients choose Portugal over other European routes. It is also one of the most frequently misunderstood, because dependency evidence is reviewed, not assumed.

Citizenship is not granted by either programme. It is a separate naturalisation process under each country's nationality law, with its own residence, language, integration and good-character requirements. A residence permit is a precondition for naturalisation in both countries; it is not naturalisation itself.

Spanish nationality by residence

Spain's general rule is that nationality by residence requires at least ten years of legal residence. Statutory exceptions reduce that period. For example, two years of legal residence applies to nationals of Ibero-American countries, Andorra, the Philippines, Equatorial Guinea, Portugal, and Sephardic Jews of Spanish origin who meet the documentary and integration requirements set by the Spanish Ministry of Justice.

Naturalisation in Spain also requires evidence of integration, including knowledge of Spanish, knowledge of Spanish society and constitutional values, and a clean criminal record. None of these conditions are guaranteed by holding a residence permit; a separate application is needed.

Portuguese naturalisation after Lei Orgânica n.º 1/2026

Portugal published Lei Orgânica n.º 1/2026 in the Diário da República n.º 95/2026, Série I, on 18 May 2026. The law entered into force on 19 May 2026.

For nationality applications filed from 19 May 2026 onward, the residence period required for naturalisation is:

• 7 years for nationals of Portuguese-speaking countries (CPLP) and EU nationals; and
• 10 years for other nationalities.

Administrative nationality procedures already pending when the law entered into force continue under the prior law, under Article 7.2 of Lei Orgânica n.º 1/2026. A Golden Visa holder who has not filed a nationality application should not be described as grandfathered. Whether the prior-law residence period applies depends on whether a procedure was already pending at IRN — the Portuguese Registry and Notary Institute — before 19 May 2026.

Portuguese naturalisation also requires evidence of effective ties to Portugal, Portuguese-language knowledge, and a clean criminal record under the conditions set by the Portuguese authorities. These are separate decisions, taken by separate authorities, on separate applications.

Planning around the new naturalisation clock

For an applicant who has not yet filed a nationality application, the practical effect of Lei Orgânica n.º 1/2026 is that the seven-year and ten-year clocks apply. The reform is honest news rather than a marketing gap to be papered over, and the planning frame is straightforward.

• Confirm the applicable clock by nationality. CPLP and EU nationals fall in the seven-year group; other nationalities fall in the ten-year group. The applicable clock should be confirmed for the main applicant and for any dependants who will eventually apply separately.
• Clarify what "pending at IRN" means in practice. Article 7.2 protects procedures already pending at IRN before 19 May 2026. The cut-off test — filing, fee payment, or IRN acknowledgement — is a question for a Portuguese nationality lawyer for an applicant who is close to filing. It should not be assumed from a general article.
• Plan the fund term against the naturalisation timeline. If the chosen investment-funds vehicle is scheduled to mature inside the seven- or ten-year window, the planning conversation needs to cover continuation, reinvestment, or replacement options before the fund's wind-down approaches, not after. This is a fund-manager and immigration-lawyer conversation, not a website question.

The intent of these three steps is not to promise a citizenship outcome — that decision sits with the Portuguese authorities — but to set the expectation that residence permit, fund term, and naturalisation application are three separate timelines that have to be planned together.

A residence-by-investment decision is a multi-line budget, not a single number. The headings below are the cost categories that apply across the current Article 90.º-A routes. The figure within each category is published by the responsible authority or quoted by the relevant service provider, and is best confirmed against the current schedule at the time of application.

• Qualifying investment. From EUR 500,000 for the investment-funds route. The figure for business with job creation and scientific research is set under Article 90.º-A and should be confirmed with AIMA before commitment.
• Government application and processing fees. Per applicant — main applicant and each dependant — under the AIMA fee schedule in force at the time of application.
• Investment due diligence and legal fees. Portuguese immigration counsel, fund-subscription due diligence, and corporate setup where relevant. These are quoted per engagement and depend on family size and route.
• Annual maintenance. Investment maintenance, residence-card renewals, and any tax obligations triggered separately by the applicant's personal position.

Indicative submission-to-card timing under Article 90.º-A varies materially with caseload at AIMA, completeness of documentation, and the chosen investment route. It is best framed by current AIMA processing experience and a Portuguese immigration lawyer's caseload, rather than by a fixed website range. An initial consultation can map the current expectation against an applicant's nationality, family composition and route choice.

Both routes carry the standard residence-by-investment risks: documentary issues, source-of-funds review, due-diligence outcomes, renewal conditions, and government processing variability. Four points are worth highlighting for this comparison.

• Programme stability and legal change. Spain's investor-residence closure happened by Organic Law 1/2025, not by administrative practice. Portugal's last major change — the 2023 removal of the real-estate route — also happened by law. A residence-by-investment decision should assume that the legal framework can change, and should be made on current published rules rather than legacy expectations.
• Naturalisation reform. Portugal's Lei Orgânica n.º 1/2026 reshapes the residence period required for naturalisation. The reform separates CPLP and EU nationals from other nationalities for the residence-period calculation. An applicant planning around a citizenship horizon should confirm the applicable residence period for their nationality before relying on a single timeline.
• Article 90.º-A threshold reconciliation. The exact minimum-investment figures for Portugal's scientific-research and business-with-job-creation routes are subject to legal and database reconciliation. AIMA is the named authority. An applicant should confirm the figure in force with AIMA and a Portuguese immigration lawyer before committing capital. The investment-funds minimum of EUR 500,000 is the most settled figure in the current Article 90.º-A framework.
• Fund-mechanics and term mismatch. A subscribed Article 90.º-A fund has its own term, holding period, and distribution policy. If the fund matures before naturalisation eligibility, the planning conversation needs to cover continuation, reinvestment or replacement before the fund's wind-down date, not after.

The closure of Spain's investor route is the most material change since the article was first published. The Portugal naturalisation reform is the second. The two other points stand regardless of whether the legal framework changes again.

A Spain or Portugal residence permit does not automatically make a person Spanish or Portuguese tax resident. Tax residence depends on physical presence, centre-of-vital-interests tests, and other rules in each country's tax legislation. It may also be affected by an applicable double-tax treaty.

Marketing shorthand that frames a Golden Visa as eliminating tax, or that says Portugal residence avoids taxes, or that Spain residence solves a tax position, does not reflect either country's tax framework and should not drive an application decision.

There is one tax question this guide does not answer, because it does not sit in Portuguese or Spanish law at all and should not be answered on a website. An applicant funding the qualifying investment out of a US 401(k), IRA, or other retirement account faces a US-side question about the tax treatment of moving capital out of that account into a Portuguese fund subscription. The answer depends on the applicant's US tax position, the structure of the source account, and current US rules. It is a US-qualified cross-border tax adviser question, taken in parallel with the Portuguese application and not after capital has already left the retirement account.

For Spanish and Portuguese tax positions, tax planning is taken separately, with qualified tax advice, against the applicant's broader profile.

The right answer depends on the applicant's starting position more than on a country preference.

Existing Spain investor-residence holders

A holder of a valid Spain investor-residence permit can continue to renew under the rules that applied when the authorisation was first granted, while the legal requirements continue to be met. The closure of the investor route does not retroactively invalidate an authorisation already issued. An investor in this position does not need to "switch" to Portugal. The next step is a separate legal review of renewal conditions and any long-duration residence option in Spain.

New applicants comparing European residence by investment

A new applicant comparing European residence-by-investment routes in 2026 cannot use Spain's investor-residence route. Portugal is one of the active comparable routes. Other European programmes — Greece, for example — operate under different qualifying-investment categories and different stay requirements, and may be more or less suitable depending on investment type, budget, and family composition.

The decision in this group is rarely "Spain or Portugal." It is more often "Portugal under non-real-estate Article 90.º-A routes versus other current European options," with Spain present only as a historical reference.

Investors planning a citizenship horizon

An investor who treats citizenship as the primary goal should treat the residence permit as a prerequisite, not as a guarantee. Portugal's reformed naturalisation framework now treats CPLP and EU nationals differently from other nationalities, with a seven-year residence requirement for the former and a ten-year residence requirement for the latter, for applications filed from 19 May 2026. Spain's nationality framework keeps the long-standing ten-year general rule and the two-year statutory exceptions.

For most clients, the practical implication is that residence-by-investment timing, residence-permit continuity, fund-term horizon, and the separate naturalisation eligibility test all need to be planned together. They do not follow automatically from the residence permit.

My Golden Visa is a licensed consultancy. We do not issue residence permits or grant citizenship — those decisions sit with the Spanish and Portuguese authorities. For this comparison specifically, our team supports clients with eligibility review, route selection between current Article 90.º-A options, documentation preparation, lawyer and fund-manager coordination, and realistic expectation setting on processing, naturalisation, fund-term and tax-residence questions.

An investor who held a Spain investor-residence permit before 3 April 2025 and is evaluating a renewal position, or a new applicant comparing current European residence-by-investment options for the first time, can use an initial consultation to map the practical next step against nationality, family composition, investment budget, fund-term horizon and citizenship horizon.

Talk to a My Golden Visa adviser. Get a tailored read on Portugal's current routes and on transitional Spain questions for existing holders.