Golden Visa Compared: Portugal, Spain and Greece 2026

Quick Answer: Spain closed its golden visa on 3 April 2025. Greece still accepts property at EUR 400,000 outside the premium zones. Portugal removed property in 2023 and now requires ten years of residence for citizenship, but is the only one of the three where a low-presence investor accrues that clock at all.

Three years ago this comparison had a simple answer: buy property in whichever of the three you liked, collect a residence permit, and wait five years. All three parts of that sentence are now wrong.

Spain abolished its programme. Portugal removed property from its own. And in May 2026 Portugal doubled the naturalisation period for most foreign nationals. What follows is where each of the three actually stands, and which question each one answers.

Where the Three Stand

	Portugal	Spain	Greece
Programme status	Open	Closed 3 April 2025	Open
Property qualifies	No, since October 2023	Not applicable	Yes
Entry investment	EUR 500,000 fund	Not applicable	EUR 250,000 to EUR 800,000
Minimum stay	About 7 days a year	Not applicable	None
Residence for citizenship	10 years, 7 for EU and CPLP	Not applicable	7 years
Stay needed for that clock	The programme minimum suffices	Not applicable	183 days a year
Language for naturalisation	A2 Portuguese	Not applicable	B1 Greek

Spain: The Programme Is Gone

Organic Law 1/2025 was published in the Boletín Oficial del Estado on 2 January 2025 and eliminated the investor residence permit with effect from 3 April 2025. Applications were accepted until 2 April. The political argument was the same one Portugal used in 2023: investor visas were held to be adding pressure to housing markets in Madrid, Barcelona and the coastal costas.

Existing holders were not stripped of anything. Investors who applied before the cut-off keep their permits and their renewal rights, and their path to permanent residence and naturalisation is unaffected by the abolition itself.

For anyone deciding now, Spain simply is not on the list. The routes that remain are the non-lucrative visa, which requires proven passive income and does not permit work, and the digital nomad visa for remote earners. Both require you to live in Spain, which is a materially different proposition from an investment permit.

The practical consequence for this comparison is narrower than it looks. Spain’s departure removed the largest property-based competitor to Greece, and the demand that used to split three ways now splits two.

Greece: Property Still Works, at a Price That Depends on the Map

Greece kept the structure Portugal abandoned in 2023: a qualifying property purchase still produces a residence permit, and that permit carries no minimum stay at all. The threshold depends entirely on where the property sits, ranging from EUR 250,000 for a conversion to EUR 800,000 in Attica.

Zone	Threshold
Attica, including Athens and the Athens Riviera	EUR 800,000
Greater Thessaloniki	EUR 800,000
Mykonos, Santorini, and islands above 3,100 population	EUR 800,000
Everywhere else in Greece	EUR 400,000
Commercial-to-residential conversion, anywhere	EUR 250,000
Listed-building restoration, anywhere	EUR 250,000

Two conditions sit underneath the headline numbers and both bite. The EUR 400,000 and EUR 800,000 tiers require a single property with a minimum living area of 120 square metres, which rules out the small high-yield apartment that would otherwise be the obvious qualifying purchase. And the EUR 250,000 conversion tier requires the conversion to be completed, which is a construction project rather than a purchase.

The 120 square metre floor deserves particular attention from anyone modelling rental income. Yield per square metre falls as unit size rises in almost every Mediterranean market, so the rule pushes the qualifying investor into the lower-yielding class of stock by design. A quoted city yield is usually a one-bedroom yield, and a compliant 120 square metre property will not achieve it.

Portugal: No Property, and a Clock That Just Doubled

Portugal removed the real estate acquisition and capital transfer routes in October 2023 under the Mais Habitação package, and excluded funds that themselves invest in Portuguese real estate. The full account is in the Golden Visa real estate route, ended.

What remains, per AIMA’s current guidance, is five routes: investment funds, company investment, arts and heritage support, research funding, and job creation. In practice almost all volume goes through the EUR 500,000 CMVM-regulated fund, whose selection criteria are set out in Portugal Golden Visa investment funds.

The stay requirement remains the lightest in Europe at roughly seven days a year on average. The processing is not light: AIMA has been taking 18 to 24 months to issue permits.

Then came the second change. Lei Orgânica n.º 1/2026, published on 18 May 2026 and in force from 19 May, raised naturalisation from five years to seven for EU and CPLP nationals and ten for everyone else, and moved the start of the clock from the application date to the date the permit is issued. Parliament passed it on 1 April 2026 by 152 votes to 64. The detail, including who the transitional rule protects, is in Portuguese citizenship by investment.

The Comparison That Actually Matters

Put the two open programmes side by side on the question most investors are really asking, and the answer is not the one the headline thresholds suggest. Greece is cheaper at EUR 400,000 and asks nothing of your calendar. Portugal costs EUR 500,000 and is the only one that builds a citizenship clock.

Objective	Greece	Portugal
A residence permit without moving	Yes, and no stay at all	Yes, at about 7 days a year
Own a property with the capital	Yes	No, a fund unit
Lowest entry cost	EUR 400,000 outside premium zones	EUR 500,000
Schengen travel from day one	Yes	Yes
A citizenship clock while living abroad	No	Yes
Time to citizenship if you do move	7 years at 183 days	10 years for most non-EU nationals

That fifth row is the structural difference and it is rarely stated plainly. Greece’s golden visa has no stay requirement, and Greek naturalisation requires seven years of physical residence at 183 or more days a year. A Greek permit held for a decade by someone living in London or Dubai produces renewals and nothing else: no accrued time toward a passport.

Portugal’s programme minimum, seven days a year, is itself sufficient to maintain legal residence, and legal residence is what the naturalisation clock counts. The clock is now ten years long for an American, British, Canadian or Emirati applicant, but it runs.

So the choice separates cleanly. If the objective is a European base, an asset you control, and Schengen mobility, Greece is cheaper, admits property, and asks nothing of your calendar. If the objective is eventually a passport without relocating, Portugal is the only one of the three that offers a route, and it is a ten-year one.

No EU Country Sells a Passport

Worth stating because the phrase persists in marketing. On 29 April 2025 the Court of Justice of the European Union held in Commission v Malta, case C-181/23, that Malta’s investor citizenship scheme breached EU law, describing it as a commercialisation of Union citizenship. Malta’s programme closed.

That was the last direct citizenship-for-investment scheme in the European Union. Every remaining programme, Portugal’s and Greece’s included, sells residence. Citizenship is a separate national process with its own conditions, and both countries have tightened those conditions rather than loosened them.

Anyone quoting a European passport in exchange for a defined sum is describing a product that ceased to exist in April 2025.

The Other Markets Buyers Ask About

Portugal, Spain and Greece are the three compared directly, and buyers routinely ask about six more. Their positions differ enough that treating them as one category is the mistake: Cyprus opens at EUR 300,000, Turkey sells citizenship outright at USD 400,000, and the United Kingdom closed its route in 2022.

Market	Status in 2026	Entry	Citizenship
Cyprus	Permanent residency by investment, open	EUR 300,000 plus EUR 50,000 annual income	After 8 years of legal residence
Malta	Citizenship scheme closed 29 April 2025	Residency programme only	No investment route
Turkey	Citizenship by investment, open	USD 400,000 property, 3-year no-sale rule	Direct, within months, but not EU
UAE	Golden visa, open	AED 2 million property	No route at all
Italy	Investor visa open, thresholds vary by route	Startup, company, bonds or philanthropy	Ordinary naturalisation, 10 years
United Kingdom	Tier 1 Investor closed 17 February 2022	Not applicable	Not applicable
France	No investor visa	Talent passport routes only	Ordinary naturalisation

Three of those deserve a sentence each, because they answer genuinely different questions.

Cyprus is the closest structural match to what Greece offers, at a lower threshold, with an income test attached and a visit obligation of once every two years rather than a stay requirement. Its citizenship-by-investment scheme closed in 2020 and naturalisation now takes eight years of legal residence, so the same physical-presence problem applies as in Greece.

Turkey is the only one on this list that still sells a passport directly, at USD 400,000 in property held for three years. It is also outside the European Union, which is usually the whole point of the exercise, so it answers a mobility question rather than an EU one.

The UAE grants a renewable residence visa against AED 2 million of property and removed its 50 per cent upfront payment rule in February 2026, opening the route to staged off-plan purchases. It offers no naturalisation path of any kind, which makes it a base rather than a passport plan.

France and the United Kingdom have no investment route to residence at all, and a comparison that presents them as alternatives is comparing a programme against its absence.

What the Capital Is Doing

The immigration comparison is only half the decision and usually the less consequential half. A EUR 500,000 fund unit and a EUR 400,000 Greek property are different asset classes with different risk, liquidity and control, and the question of which you would hold without a permit attached decides more than the programme rules do.

	EUR 500,000 Portuguese fund	EUR 400,000 Greek property
What you own	Units in a CMVM-regulated vehicle	Freehold real estate
Control	None over asset selection	Full
Income	Fund distributions, if any	Rent, subject to local rules
Liquidity	Locked for the hold period	Saleable, subject to the permit
Ongoing charges	Management and performance fees	IMI-equivalent taxes, maintenance, management
Exit	Fund wind-up or secondary sale	Property sale, which may end the permit
Currency and market risk	Fund strategy dependent	Greek residential market

Neither column is safer. A fund diversifies away single-asset risk and hands you no control; a property gives control and concentrates the risk in one building in one market. What the comparison should settle is whether you would hold the position on its investment merits alone. If a EUR 500,000 fund is something you would own anyway, the permit is a benefit on top. If it is only tolerable because of a passport a decade away, the plan is carrying ten years of legislative risk with no hedge, and 2023 and 2026 both showed that risk is real.

Where Buying Portuguese Property Still Fits

Portuguese property has no place in the immigration decision, which is the point most often lost. Since October 2023 a purchase has no bearing on any residence route, directly or through real estate funds. It still costs 7.5% IMT plus 0.8% stamp duty, and it still has to be bought on its own merits.

It still fits everywhere else. Non-residents completing on or after 1 September 2026 pay a flat 7.5% IMT plus 0.8% stamp duty, set out in IMT for non-residents, and the regional picture is in property for sale in Portugal. If you intend to live in the country, the D7 visa reaches the same permit and the same clock without the fund, and the wider route map is in the Portugal Golden Visa guide.

Pros and Cons

The two open programmes fail in opposite directions. Greece admits property and asks no presence, but its 7-year naturalisation needs 183 days a year that the visa does not provide. Portugal counts a 7-day year toward naturalisation, but that count now runs for 10 years rather than 5.

Greece, in favour:

• Real estate still qualifies, so the capital buys an asset you control
• EUR 400,000 outside the premium zones, below Portugal’s fund
• No minimum stay at all
• EUR 250,000 tier for conversions and listed restorations

Greece, against:

• 120 square metre floor pushes you into lower-yielding stock
• Naturalisation needs 183 days a year for seven years, which the visa does not build
• B1 Greek is a materially higher language bar than A2
• Selling the qualifying property can end the permit

Portugal, in favour:

• Seven days a year maintains legal residence, and that residence counts
• The only one of the three with a citizenship route for a non-resident investor
• A regulated fund removes single-asset and single-building risk

Portugal, against:

• Ten years for most non-EU nationals, doubled in May 2026
• AIMA takes 18 to 24 months before the clock even starts
• EUR 500,000 illiquid for a horizon that just lengthened
• No property route, directly or through real estate funds

Risks and Red Flags

• Any comparison that still lists Spain. The programme closed on 3 April 2025.
• A Greek five-year or seven-year passport claim. Seven years of physical residence, not seven years of permit.
• Portuguese property sold as a residency route. Closed in October 2023, funds included.
• A Greek EUR 400,000 yield model on a small apartment. The 120 square metre rule forbids it.
• A Portuguese timeline that omits AIMA. Eighteen to twenty-four months sit in front of the ten years, not inside them.

Before committing capital:

• Confirm which naturalisation group your nationality falls in
• Decide whether permanent residency, not citizenship, already meets the objective
• Price the position as an investment you would hold without the permit
• Confirm the family composition rules for your specific dependants
• Model what happens if the rules change again, because they have twice in three years

Who Each One Suits

The right programme follows from one question: is the objective a base or a passport. Buyers who want an asset and European mobility should look at Greece at EUR 400,000. Buyers who want eventual citizenship without relocating have exactly one option among these three, and it takes 10 years.

The investor who wants an asset and no calendar obligation. Greece, at EUR 400,000 outside the premium zones, with the 120 square metre rule priced into the yield expectation.

The investor who wants a passport without relocating. Portugal, and only Portugal of these three, at ten years and EUR 500,000. See Portuguese citizenship by investment before committing.

The household that intends to move to Portugal. Neither golden visa. The D7 or the D8 reaches the same destination for a fraction of the capital.

The buyer who just wants a Portuguese home. Buy it on its own merits. It has not been an immigration instrument since 2023, and pretending otherwise is how people overpay.

Frequently Asked Questions

Does Spain still have a golden visa in 2026? +

No. Organic Law 1/2025, published in the Spanish official gazette on 2 January 2025, eliminated the programme with effect from 3 April 2025. Applications were accepted until 2 April 2025. Investors who applied before that date keep their permits and renewal rights, but no new applications are possible. Spain now offers the non-lucrative visa and the digital nomad visa, neither of which is an investment route.

Can you still buy property for a golden visa in Greece? +

Yes, and it is the main reason the Greek programme still draws property buyers. The thresholds are tiered: EUR 800,000 in Attica, greater Thessaloniki, Mykonos, Santorini and islands above 3,100 population; EUR 400,000 elsewhere; and EUR 250,000 for conversions of commercial buildings to residential use and for listed-building restorations. The two higher tiers also require a minimum living area of 120 square metres.

Why did Portugal remove real estate from its golden visa? +

The Mais Habitacao package removed the real estate acquisition and capital transfer routes in October 2023, on the argument that the programme was adding to housing pressure in Lisbon and Porto. Funds that themselves invest in Portuguese real estate were excluded at the same time, which closed the indirect route. What remains is the EUR 500,000 CMVM fund route plus company investment, arts and heritage, research and job creation.

Which programme leads to citizenship fastest? +

Neither Greece nor Portugal is fast, and they are slow for different reasons. Portugal now requires ten years of legal residence for non-EU and non-CPLP nationals, but its stay requirement is roughly seven days a year, so a low-presence investor does accrue the clock. Greece requires seven years at 183 or more days a year plus B1 Greek, and its golden visa has no stay requirement at all, so a holder who does not actually live there accrues nothing.

What happened to Malta's citizenship by investment? +

The Court of Justice of the European Union ruled in Commission v Malta, case C-181/23, on 29 April 2025 that Malta's investor citizenship scheme was incompatible with EU law, describing it as a commercialisation of Union citizenship. The scheme closed. Malta retains a residency programme, but no EU member state now sells citizenship directly.

Is Greece cheaper than Portugal? +

At the entry point, usually. Greece at EUR 400,000 outside the premium zones is below Portugal's EUR 500,000 fund, and a Greek investor owns a property rather than a fund unit. The comparison changes if you weigh what the capital does: a Greek qualifying property is an asset you control and can let, while a Portuguese fund is an illiquid financial position for at least five years. Neither is obviously better, and the difference is investment structure rather than immigration.

Can family members be included? +

On both programmes, yes. Portugal includes spouse, minor children, dependent adult children in education and dependent parents. Greece includes spouse, children under 21 and the parents of both spouses. The details and age cut-offs differ enough that a family with adult children or dependent parents should confirm the position for its specific composition before choosing.

Which route suits a buyer who wants to live in Portugal? +

Probably none of these. If you intend to live in Portugal, the D7 for passive income or the D8 for remote work reaches the same residence permit and the same naturalisation clock without locking EUR 500,000 in a fund. The golden visa exists to solve the opposite problem: residence rights for someone who does not intend to move.