Portugal may introduce new rules for Portugal Golden Visa program. The changes could affect investment funds and people who have already invested under the current system.
On November 6, the governing Social Democratic Party (PSD) and CDS–People’s Party (CDS-PP) submitted an amendment to the proposed 2027 State Budget. It would increase the required investment allocation to Portuguese companies from 60% to 80%. The proposal would also require these investments to increase the companies’ share capital.
Two other changes are included. The first is a new €250,000 contribution route for social-care projects. The second would reduce the minimum contribution for scientific research from €500,000 to €250,000.
We spoke with Portuguese law firms EDGE and MMT to understand how these proposals could affect investors and fund managers. Legal experts explain the possible changes and the questions that remain unanswered.
How Could the Fund Rules Change?
The proposed 80% requirement would limit the investment options available to Portugal Golden Visa funds. The new share capital condition could create further difficulties.
According to EDGE, the wording may allow only investments made through company capital increases. This means purchases of existing shares, listed shares bought on the stock market, bonds and shareholder loans might no longer qualify.
There is also a question about how the authorities would calculate the share capital requirement. When a company raises money, only part of the investment may be officially recorded as share capital. As a result, some investments in Portuguese companies might not meet the new rules.
Maria Margarida Torres of MMT also highlights this issue. She explains that investing in a Portuguese company is different from buying newly issued shares. Some funds may need to change their investment strategies and update their documentation.
What Does This Mean for Open-Ended Funds?
Both law firms believe open-ended funds could face particular difficulties.
These funds need access to cash to manage investor withdrawals. However, shares in private companies are often harder to sell quickly.
EDGE explains that funds investing mainly in listed shares or debt could lose eligibility for new Golden Visa investors unless they change their strategies. Closed-ended funds that invest directly in Portuguese companies may find it easier to meet the proposed rules.
The amendment does not directly ban open-ended funds. Their future eligibility will depend on the final law and how regulators apply it.
EDGE also notes that fund managers have adjusted to earlier Golden Visa reforms. They may be able to make similar changes again.
What Happens to Existing Investors?
The proposal also raises questions for people who have already invested.
According to EDGE, the new rules would apply to Golden Visa applications submitted after the law takes effect. Applications submitted before that date should remain under the current rules.
However, the investment date and the application date are different. Someone may have invested in a fund but still be preparing their Golden Visa application. In this situation, the investment date alone may not protect them from the new requirements.
Torres believes the law should clearly protect investors who committed money under the existing rules. However, she warns that protection should not be taken for granted. The final legislation will decide how different situations are handled.
Both law firms also point to unanswered questions about residence permit renewals and family reunification.
EDGE expects existing permit holders to remain under the current renewal rules but wants this confirmed in the legislation. Torres also calls for clear protection for pending applicants and investors who have already committed funds.
If the changes take effect on January 1, 2027, investors may have limited time to prepare after the final vote.
What Are the New €250,000 Routes?
The proposed social-care route (Although it has not officially been announced yet) would support the construction or renovation of facilities for children, young people, older people and people with disabilities. It would also cover certain projects that help foreign residents and people receiving international protection.
The minimum contribution for scientific research would also fall to €250,000.
These options could make the Golden Visa program accessible at a lower financial threshold. However, they work differently from investment funds.
EDGE explains that the proposed social-care route would involve a non-refundable contribution. Investors should therefore not expect to recover this money.
Torres also stresses the need to explain the financial conditions clearly.
Several details still need clarification. These include which projects will qualify, how contributions will be checked and what documents applicants must provide to the Agency for Integration, Migration and Asylum (AIMA).
Why Does Legal Stability Matter?
The proposed changes have also raised concerns about investor confidence.
EDGE believes the fund market may be able to adapt, as it has done after earlier reforms.
Torres is more concerned about frequent changes to Portugal’s immigration and nationality rules. She believes these changes could make investors less confident about long-term commitments.
“Attracting long-term international capital requires consistent rules and confidence that investment commitments will be respected,” Torres says.
She supports investment options that bring clear benefits to Portugal. However, she believes the rules should be easy to understand and practical to follow.
Torres also suggests bringing back a limited real estate investment route for affordable housing or build-to-rent projects. This is her own recommendation and is not included in the current proposal.
What Happens Next?
The proposed changes have not become law. The current Golden Visa rules still apply.
PSD and CDS-PP do not have enough parliamentary seats to approve the changes alone. They will need support from other parties.
Committee votes are scheduled for November 18–23. The final State Budget vote is expected on November 24.
The proposal could still change or be rejected. If approved, AIMA and the Portuguese Securities Market Commission (CMVM) may need to explain how the new rules will work.
Investors should pay attention to the final fund requirements, the protection of existing applications and the date when any changes would take effect.
Get Golden Visa will continue to follow the legislative process and share updates as more information becomes available.
This article is based on preliminary legal assessments from Portuguese law firms EDGE and MMT. The proposed changes still require parliamentary approval and may be revised.
