Greece vs Portugal Golden Visa: 2026 Programme Comparison

All amounts and conditions are subject to change. Re-verify before committing to an investment.

Eligible investment routes

Real-estate route (tiered):

Greece uses a three-tier real-estate threshold based on property type and location.

• EUR 250,000 — Available only for qualifying exceptions: commercial or industrial property converted to residential use, or listed buildings undergoing full restoration. Not applicable to standard residential or tourist-accommodation purchases.
• EUR 400,000 — Standard threshold for real-estate investment outside the prime zones listed below. Applies to residential property, long-term tourist accommodation, and commercial property in most areas of Greece.
• EUR 800,000 — Required for real estate in prime zones: the Attica regional unit (greater Athens), Thessaloniki, Mykonos, Santorini, and islands with a registered population above 3,100.

New real-estate investments are subject to property-size minimums and restrictions on short-term rental or sublease of the qualifying asset.

Investment fund route:

A minimum of EUR 350,000 in qualifying mutual fund units or Alternative Investment Fund (AIF) shares registered in Greece qualifies for the residence permit. Check current eligibility criteria and qualifying fund categories with the Hellenic Ministry of Migration and Asylum or a qualified adviser.

Other qualifying routes:

• EUR 500,000 in Greek government bonds, listed corporate bonds, or a fixed-term bank deposit.
• A company-capital investment route exists but is under ongoing legal-reconciliation review. Do not rely on a specific threshold or category description without checking with the Hellenic Ministry of Migration and Asylum or a qualified adviser.

Minimum stay

The Greece Golden Visa does not impose a minimum physical-presence requirement to maintain the permit. Investors may spend the majority of their time outside Greece, and the permit remains valid while the qualifying investment is held.

One thing worth being clear on: the absence of a minimum stay does not count toward naturalisation. Citizenship requires 183 days of physical presence per year for 7 consecutive years — see the naturalisation section below.

Family inclusion

The Greece Golden Visa typically covers:

• Spouse or registered partner
• Dependent children (age limits apply — check current conditions with the Hellenic Ministry of Migration and Asylum)
• Dependent parents of both the main applicant and their spouse (conditions apply)

Age limits and dependency definitions can change; verify with migration.gov.gr before relying on family-inclusion eligibility for your specific situation.

Permit validity and renewal

The initial Greece Golden Visa grants a 5-year residence permit. Renewals are for further 5-year periods while the qualifying investment is maintained at the required level.

Work rights

The Greece Golden Visa does not grant the right to work in Greece as an employee, freelancer, sole trader, legal representative, or executive manager. Property management as a non-executive corporate shareholder is permitted. An investor who wants to work remotely in Greece for a non-Greek employer needs a separate Digital Nomad Permit under Article 18 of Greek immigration law.

Path to naturalisation

Greek citizenship through this route requires all of the following:

1. 7 years of legal and continuous residence in Greece
2. Minimum 183 days of physical presence in Greece in each of those 7 years
3. Greek language proficiency
4. Integration, criminal-record, and tax-compliance requirements

Holding the Golden Visa while residing primarily outside Greece satisfies neither of the first two conditions. Investors who want Greek citizenship need to plan for genuine physical residence from year one — the permit alone will not get you there.

What changed: real estate removed

Direct real-estate investment no longer qualifies for the Portugal Golden Visa following the Mais Habitação reform (effective late 2023). Existing ARI holders who obtained their permit before the reform are not affected for renewal purposes — but the route that enabled their initial application is closed to new applicants. For a full account of what changed, see our Portugal Golden Visa changes guide.

Eligible investment routes

The current qualifying routes under AIMA Art. 90-A include:

• Qualifying investment funds (venture capital, private equity, real-estate investment funds listed on Portuguese exchanges)
• Capital contribution to existing or new Portuguese-headquartered companies meeting job-creation or other conditions
• Scientific or technological research investment
• Cultural heritage and arts investment

Note on specific amounts: Portugal ARI investment thresholds are not published here because specific route amounts are pending internal legal-reconciliation review. Verify current thresholds with AIMA (aima.gov.pt/pt/viver/autorizacao-de-residencia-para-investimento-art-90-o-a) or a qualified ARI adviser before committing to an investment.

Minimum stay

The Portugal ARI imposes a minimum physical-presence requirement:

• 7 days in the first year
• 14 days in each subsequent 2-year renewal period

These are among the lowest minimum-stay requirements in Europe, which makes the programme workable for investors who do not plan to live full-time in Portugal. These conditions have been subject to legislative review; verify current requirements with AIMA before relying on them.

Family inclusion

Portugal ARI allows the main applicant to include:

• Spouse or de-facto partner
• Minor children
• Adult children who are dependent and enrolled in study
• Dependent parents

Specific age limits and dependency definitions are set by AIMA — check current requirements before applying.

Permit validity and renewal

The initial ARI card is issued for 2 years and is renewable. Subsequent renewal cards are typically issued for 2-year periods while the qualifying investment is maintained.

Work rights

Portugal ARI holders are entitled to live, work, and study in Portugal as residents. The permit does not restrict employment — holders may be employed, self-employed, or operate businesses in Portugal. Check current work-rights conditions with AIMA, as terms may change.

Path to permanent residence and naturalisation

Permanent residence: After 5 years of legal residence, ARI holders may apply for permanent residency under standard Portuguese immigration law, subject to income, accommodation, and language requirements.

Naturalisation — the post-2026-05-19 framework:

Under Lei Organica n. 1/2026 (in force 2026-05-19), nationality applications filed from that date are subject to:

• 7 years of legal residence: applies to CPLP nationals (Portuguese-speaking countries) and EU/EEA nationals
• 10 years of legal residence: applies to all other nationalities, including most non-EU investors

“5 years for Portuguese citizenship” no longer applies to new ARI holders or to applicants who have not already filed a nationality application. Permanent residency (available at 5 years) and citizenship (7 or 10 years, depending on nationality) are separate milestones with different requirements.

Applications already pending before 2026-05-19 are governed by the prior law, per Article 7.2 of Lei Organica n. 1/2026.

Greece

Government fees cover a filing fee per adult applicant, plus stamp duties, legal fees, and any property-related costs if real estate is the investment vehicle. Schedules are set by the Hellenic Ministry of Migration and Asylum and change periodically — check migration.gov.gr or speak to a qualified Greece Golden Visa adviser for current figures.

Processing typically spans several months from application submission to permit issuance, though timelines vary by route and individual case. Do not plan around a fixed date without checking migration.gov.gr for the current picture.

Portugal

Government fees cover a processing fee for the main applicant and a lower fee per additional family member, with legal fees and investment costs on top. For current fee schedules, see aima.gov.pt or the Portal ARI.

AIMA has invested in digital processing in recent years and average timelines have improved. For where things stand today, the Portal ARI is the most current source.

Holding a residence permit — Greek or Portuguese — does not automatically make you a tax resident of that country. Tax residence is determined separately under each country's domestic law, typically based on physical presence (usually 183 or more days in a tax year) and other lifestyle connections.

Greece — special regimes: Greece offers alternative-taxation arrangements for qualifying new tax residents under Articles 5A, 5B, and 5C of the Greek Income Tax Code, administered by AADE (aade.gr). Eligibility, application conditions, and tax outcomes depend heavily on individual circumstances — do not treat any Greek tax regime as automatic without specific tax-adviser analysis for your situation.

Portugal — IFICI: Portugal's non-habitual-resident regime transitioned to the IFICI framework. The Autoridade Tributária e Aduaneira issued Ofício-circulado n. 20276/2025 clarifying IFICI conditions. As with Greece, eligibility and outcomes are case-specific; a qualified Portuguese tax adviser should review your position before you rely on any special regime.

This section describes the general framework only. It is not tax advice. Individual results depend on your personal circumstances, country of current residence, and applicable tax treaties. Consult a qualified tax adviser.

Greece: The qualifying investment must be maintained for the duration of the permit. Selling or disposing of the qualifying asset removes eligibility for renewal. Investors who need to exit must either replace the investment before the renewal date or accept that the permit lapses.

Portugal: The qualifying investment must be maintained for 5 years from the date of the first ARI card. After that period, investors may divest while retaining their residence status — but the interaction with permanent-residency applications is worth confirming with AIMA or a qualified adviser before any disposal decision.

The choice turns on a handful of priorities.

Greece is the route for investors who want real estate as the qualifying vehicle. With a EUR 400,000 entry threshold across most of the country, it remains one of the few European residence programmes that still offers a real-estate path at accessible levels — and it requires no minimum stay, which suits investors who plan to spend most of their time elsewhere. The limits matter too: the permit does not cover employment or operating a business as a principal, and naturalisation requires seven years of genuine physical residence at 183 days per year. Holding the permit without living in Greece builds no path to citizenship.

Portugal serves a different investor profile. The real-estate route is gone, so the programme is now fund and capital-based. In return, it grants full work and employment rights from day one. The minimum-stay requirement is low — approximately seven days a year in the initial period — manageable alongside an active international life. CPLP nationals or EU/EEA applicants who qualify for the 7-year naturalisation path still have a relatively clear route to Portuguese citizenship. For most other nationalities, Lei Organica n. 1/2026 extended that period to 10 years from 2026-05-19 — investors who were planning around a 5-year citizenship horizon need to revisit their timeline.

For investors whose primary requirement is a confirmed low investment threshold for Portugal, note that specific ARI amounts are not published here pending internal legal review. A qualified ARI adviser will be able to confirm the applicable minimums.

Both programmes are well-established, but the right fit is specific to you — your budget, your nationality, where you actually want to spend time, and what you want European residence to do for your family over the next decade. My Golden Visa's advisers work with both programmes and can map your situation to the most suitable route. Get in touch to start the conversation.