Portuguese Citizenship by Investment 2026: What Is Left

Quick Answer: Portugal does not sell citizenship and never did. It sells residence, and since 19 May 2026 that residence has to be held for ten years before most foreign nationals can apply for the passport, up from five.

The phrase carries a promise Portugal has never made. Citizenship by investment, in the sense the Caribbean programmes use it, means paying a defined sum and receiving a passport at the end of a defined process. That is a product, and Portugal has never sold it.

What Portugal sells is a residence permit in exchange for a qualifying investment. Naturalisation comes later, from a separate law, on separate conditions, and in May 2026 those conditions changed more sharply than at any point since the Golden Visa began in 2012.

What Changed on 19 May 2026

Element	Before	From 19 May 2026
Residence required, EU and CPLP nationals	5 years	7 years
Residence required, all other nationals	5 years	10 years
Start of the clock	Date the permit was applied for	Date the permit is issued
What counts	Legal residence	Lawful residence under a valid permit only
Integration test	Language and basic conditions	Plus culture, history, symbols, civic duties
Declaration	Not required	Formal adherence to democratic principles

The instrument is Lei Orgânica n.º 1/2026, de 18 de maio, amending the Nationality Law of 1981. Parliament approved it on 1 April 2026 by 152 votes to 64, the President signed it on 3 May, and it applies to applications submitted on or after 19 May 2026.

The change to the clock deserves separate attention, because it is worth years on its own. A 2024 amendment had started the count at the date of application, which protected applicants from AIMA’s own processing backlog. The 2026 law reverses that. Since permits have taken 18 to 24 months to issue, the backlog now sits in front of the ten years rather than inside them.

Seven Years or Ten: Which Group You Are In

Nationality	Group	Residence required
Brazil, Angola, Mozambique, Cape Verde and other CPLP states	CPLP	7 years
Any EU member state	EU	7 years
United States	Other	10 years
United Kingdom	Other	10 years
Canada	Other	10 years
United Arab Emirates	Other	10 years

The United Kingdom is worth flagging. British applicants sat in the EU group until Brexit and sit in the ten-year group now, which for a British buyer weighing Portugal against Spain or Greece is a material difference that did not exist a decade ago. See moving to Portugal from the UK for the rest of the position.

Who Is Protected, and Who Is Not

Article 7 of the new law preserves the previous wording for administrative procedures pending on the date it entered into force. Read narrowly, and that is how it is being read, this protects a nationality application that was already filed on 19 May 2026.

It does not protect the larger group: people who hold a Portuguese residence permit, have accrued three or four years toward the old five-year mark, and had not yet reached the point of applying. For them the years already served do not carry across into a shorter route. They face the new period, counted from issuance.

Situation on 19 May 2026	Position
Nationality application already filed	Assessed under the previous law
Permanent residency already held	Unaffected; permanent residency is a separate status
Residence permit held, 4 years accrued	New period applies
Golden Visa approved, permit not yet issued	New period, counted from issuance
Application to AIMA pending, no permit	New period, counted from issuance

This is the part that generated litigation. A challenge to the retroactive effect was filed by Golden Visa investors in December 2025 and remains undecided. Separately, a decree treating loss of nationality as a criminal penalty is suspended pending preventive constitutional review, after the Constitutional Court struck down several provisions in December 2025. Neither outcome should be assumed in a financial model.

No EU Country Sells Passports Any More

No European Union member state now sells citizenship directly, and the date that changed is 29 April 2025. The context matters because buyers comparing Portugal against Malta or against a Caribbean programme are comparing three different products, only one of which still exists inside the EU.

On 29 April 2025 the Court of Justice of the European Union, sitting as the Grand Chamber, held in Commission v Malta that Malta’s investor citizenship scheme was incompatible with EU law. The Court found the scheme amounted to a commercialisation of Union citizenship and breached the obligation of sincere cooperation between member states. Malta’s programme closed that day, and with it the last genuine golden passport inside the EU.

That ruling is the reason the phrase “citizenship by investment” now means something different in Europe than it does in St Kitts or Antigua. In the EU there is investment migration, which buys residence, and there is naturalisation, which is earned. The two are joined only by time.

The Routes That Still Lead to Residence

Since October 2023 the Golden Visa has excluded real estate acquisition and capital transfer. Funds that themselves invest in Portuguese real estate are excluded too, which closed the obvious workaround. AIMA’s current guidance lists five qualifying routes: investment funds, company investment, arts and heritage support, research funding, and job creation.

Route	Capital	Physical presence	Best fit
CMVM investment fund	EUR 500,000	About 7 days a year on average	Capital-rich, staying abroad
Job creation	10 posts	Operational involvement	Founders and operators
D7	Passive income, no lump sum	Substantial, over 183 days	Retirees, landlords, dividend income
D8	Remote income threshold	Substantial, over 183 days	Remote employees and freelancers

The fund route is the one most investors mean when they say Golden Visa, and its mechanics are set out in Portugal Golden Visa investment funds. The full route list and what closed in 2023 sit in the Golden Visa real estate route, ended, and the non-investment alternatives in residency options without the Golden Visa.

The comparison worth making is not between routes to a passport, since they all end at the same nationality law. It is between the cost of getting the residence permit in the first place. A D7 applicant with a pension reaches the identical ten-year clock without locking half a million euros in a fund.

The Real Timeline, End to End

The honest end-to-end figure for a non-EU investor starting in 2026 is about 13 to 14 years, roughly double what the same calculation produced before May 2026. Two of the four stages are outside anyone’s control, and both of them sit at the ends of the sequence rather than in the middle.

For a non-EU, non-CPLP investor starting the fund route in 2026:

Stage	Duration	Cumulative
NIF, bank account, source of funds, subscription	2 to 4 months	4 months
AIMA processing until the permit is issued	18 to 24 months	22 to 28 months
Ten years of legal residence, counted from issuance	120 months	142 to 148 months
Naturalisation processing at the Conservatoria	12 to 24 months	154 to 172 months
Total		About 13 to 14 years

Two figures in that table are outside anyone’s control, and both sit at the ends. The AIMA wait is now purely dead time, because the clock does not start until it finishes. The Conservatória wait comes after the ten years are complete.

Permanent residency arrives far earlier, at five years, and the 2026 law left it alone. For most buyers that is the milestone that actually changes daily life: an indefinite right to live in Portugal, without the passport. Treating it as the objective and citizenship as an optional second stage is the realistic way to plan.

What Property Has To Do With It

Property has had nothing to do with Portuguese residency since October 2023, and saying otherwise is the most common misrepresentation in this market. A purchase is not an immigration step, does not shorten the 10-year clock, and qualifies for no Golden Visa route, including indirectly through funds that hold Portuguese real estate.

What buying does affect is where you live while the clock runs, and that is not trivial: the D7 and D8 both require substantial physical presence, so a residence to live in is a practical necessity rather than an immigration instrument. 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.

Buy the property because you want the property. Choose the residence route on its own arithmetic. Anyone selling the two as a single package is selling a product that stopped existing three years ago.

The Conditions Beyond the Clock

Time is necessary and not sufficient, and the other conditions tightened alongside it in May 2026. A certified A2 Portuguese test, a clean criminal record, documented residence under a valid permit throughout, a broadened integration test and a formal declaration of adherence to democratic principles all apply.

Time is necessary and not sufficient. The other conditions have also tightened.

• A2 Portuguese. A certified language test at A2 level of the Common European Framework, unchanged in level.
• Clean criminal record. Assessed against Portuguese sentencing thresholds, in Portugal and in every country of prior residence.
• Integration. The 2026 law added knowledge of Portuguese culture, history, national symbols, and civic rights and duties.
• Declaration. A formal affirmation of adherence to the democratic principles of the Portuguese state.
• Documented residence. Only periods covered by a valid permit count, so a gap between a permit expiring and a renewal issuing is a gap in the count.

That last point is administrative rather than legal, and it is where a decade-long plan is most easily lost. Renewal gaps caused by AIMA scheduling are common, and under the new counting rule they are no longer harmless.

What the Extra Five Years Cost

Doubling the naturalisation period from 5 years to 10 does not change the EUR 500,000 headline, and it does double most of what sits on top: management charges, renewal cycles, legal fees and the opportunity cost of the capital. That second layer is the part rarely priced at the outset.

Component	Over 5 years	Over 10 years
Capital locked	EUR 500,000	EUR 500,000, for twice as long
Fund management charges	Five annual cycles	Ten annual cycles
Renewal legal fees	Two renewals	Four or five renewals
Government and biometric fees	Per renewal cycle	Per renewal cycle, doubled
Opportunity cost on the capital	Five years	Ten years
Legislative exposure	Five years of risk	Ten years of risk

The last line is the one that has just proved itself. Anyone who subscribed to a fund in 2021 on a five-year plan is now looking at a ten-year one, without having done anything differently. The same could happen again between now and 2036, in either direction.

The practical response is to price the fund on its own investment merits rather than on the passport at the end. If a EUR 500,000 CMVM fund is a position you would hold anyway, the residence permit is a benefit on top. If it is only tolerable because of a passport a decade away, the plan carries a decade of legislative risk with no hedge.

Renewals Are Where Plans Break

Ten years of legal residence means ten years of unbroken documented residence, and the counting rule makes that stricter than it sounds. Permits are renewed on a statutory cycle, each renewal needs refreshed criminal checks, proof the qualifying investment is maintained, and evidence of the stay requirement.

A gap between one permit expiring and the next being issued is now a gap in the count, not an administrative inconvenience. Given AIMA’s scheduling record, the safe assumption is that renewals must be started early and chased, every time, for a decade. Budget legal representation for each cycle rather than for the initial application alone.

Pros and Cons

Portugal is the only one of the three main European programmes where a low-presence investor accrues a naturalisation clock at all, at roughly 7 days a year. What it now costs is time: 10 years for most non-EU nationals, with 18 to 24 months of AIMA processing sitting in front of that decade rather than inside it.

Advantages of the Portuguese route:

• Permanent residency at five years is unchanged and is what most households need
• The fund route requires about seven days a year of presence, the lightest in Europe
• Family members are included, spouse and minor children on every route
• The passport, when it arrives, carries full EU free movement
• The rules are published law rather than discretionary programme terms

Disadvantages:

• Ten years for most non-EU nationals, double the previous period
• Years already served under the old rule do not shorten the new one
• The AIMA wait is dead time, sitting in front of the clock
• Two live legal challenges mean the position may move again
• EUR 500,000 locked in an illiquid fund for a horizon that just doubled

Risks and Red Flags

The 2026 nationality law produced a specific set of expensive misunderstandings, and every one of them turns on the same mistake: treating the 5-year rule as still current. It ended on 19 May 2026, and material written before that date is now wrong.

• Any adviser quoting five years. That rule ended on 19 May 2026. It is the fastest way to identify material written before the change and not updated since.
• “Your existing years count.” They do not, unless your nationality application was already filed.
• Property sold as a residency route. Closed in October 2023, including through real estate funds.
• A timeline that omits AIMA. Eighteen to twenty-four months before the clock even starts is not a rounding error.
• A plan that only works if the law holds. It has moved twice in two years, in 2024 and again in 2026.

Checklist before committing capital:

• Which group your nationality falls in, seven years or ten
• Whether permanent residency at five years already meets your actual objective
• The fund’s CMVM registration, and its exclusion from Portuguese real estate
• Written confirmation of how renewal gaps will be handled and evidenced
• Your position if the constitutional challenge succeeds, and if it fails

Who This Suits

The right route depends entirely on whether the objective is a base or a passport, and most enquiries conflate the two. Permanent residency at 5 years is unchanged and meets what most households actually need; citizenship is a separate, longer and now less certain second stage that only some buyers genuinely require.

Households who want to live in Portugal. The five-year permanent residency milestone is intact, and it is the one that matters day to day. See the D7 visa if your income is passive.

Investors who want EU optionality with minimal presence. The fund route still does that, at EUR 500,000 and about seven days a year, provided you can hold the position for a decade. The mechanics are in the Golden Visa guide.

Americans weighing Portugal against alternatives. The ten-year clock changes the comparison materially, and the rest of the position is in moving to Portugal from the US.

Buyers who want a passport quickly. Portugal is not that, and since the Malta ruling no EU country is. Anyone promising otherwise inside the EU is describing a programme that no longer exists.

Frequently Asked Questions

Can you buy Portuguese citizenship? +

No. Portugal has never had a citizenship-by-investment programme in the strict sense, and no EU country has one now: the Court of Justice ruled Malta's scheme incompatible with EU law on 29 April 2025, closing the last one. What Portugal sells is residence. Citizenship is earned afterwards by holding that residence for the statutory period and meeting the language, integration and criminal-record conditions.

How long does Portuguese citizenship take in 2026? +

Since 19 May 2026, seven years of legal residence for EU and CPLP nationals and ten years for everyone else. American, British, Canadian and Emirati applicants fall in the ten-year group. Before that date the rule was five years for everybody. Add AIMA's wait for the permit at the front and the Conservatoria's processing at the end, and a Golden Visa investor starting in 2026 should plan for roughly thirteen to fourteen years.

What is Lei Organica 1/2026? +

The organic law published on 18 May 2026 that amended Portugal's Nationality Law of 1981. Parliament approved it on 1 April 2026 by 152 votes to 64 and the President signed it on 3 May 2026. It raised the residence requirement to seven and ten years, moved the start of the clock from the application date to the date the permit is issued, restricted counting to lawful residence under a valid permit, and broadened the integration test.

Am I protected if I already have a Golden Visa? +

Probably not. Article 7 preserves the previous wording only for administrative procedures pending when the law entered into force, meaning a nationality application already filed on 19 May 2026. Holding a residence permit, or years of residence already accrued, is not itself protection. A challenge to that retroactive effect was filed by Golden Visa investors in December 2025 and has not been decided.

Does buying property in Portugal lead to citizenship? +

It has not since October 2023, when the real estate and capital transfer routes were removed from the Golden Visa. Funds that invest in Portuguese real estate are excluded too. Buying a home is a purchase, not an immigration step. If you want both, you buy the property on its own merits and qualify for residence separately, through a fund, the D7 or the D8.

What is the difference between permanent residency and citizenship? +

Permanent residency still comes at five years and is what most buyers actually need: an indefinite right to live in Portugal, renewed periodically. Citizenship is the passport, with EU free movement, voting rights and no renewals, and it now takes seven or ten years. The 2026 law moved the second milestone and left the first alone, which makes them worth planning as separate goals.

Do children born in Portugal get citizenship? +

Under the 2026 law, a child born in Portugal to foreign parents qualifies only if at least one parent has completed five years of legal residence at the time of birth. The previous threshold was lower. Great-grandchildren of Portuguese citizens may now qualify after five years of legal residence in Portugal plus evidence of a genuine connection to the Portuguese community.

Which investment routes still lead to residence? +

AIMA's current Golden Visa guidance lists five: investment funds, company investment, arts and heritage support, research funding, and job creation. The fund route at EUR 500,000 is the one most investors use. Real estate and capital transfer were removed in 2023. Outside the Golden Visa, the D7 for passive income and the D8 for remote workers lead to the same residence permit at a fraction of the capital.