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Portugal vs Spain Golden Visa in 2026: Which Route Still Makes Sense?

Portugal's Golden Visa remains fully operational while Spain's has been completely abolished. As of February 2026, Portugal continues to attract record numbers of applicants through fund-based and donation investment routes — issuing nearly 5,000 approvals in 2024 alone — while Spain terminated its entire investor visa regime on April 3, 2025, through Organic Law 1/2025. For professionals and small business owners seeking European residency, Portugal is now the clear Iberian option, though its own regulatory landscape has grown more complex following contested citizenship law reforms and the end of its generous NHR tax regime.

Portugal vs Spain Golden Visa in 2026: Which Route Still Makes Sense?

Portugal's Golden Visa: open, evolving, and hitting record numbers

Portugal's Residence Permit for Investment Activity (ARI) entered a new chapter after the October 2023 "Mais Habitação" law eliminated all real estate routes. Rather than declining, the program hit a record 4,987 total approvals in 2024 — a 72% increase over the prior year. The government has explicitly stated it intends to make the program more attractive, not less.

Four investment routes remain open, all requiring a minimum five-year holding period with funds sourced from outside Portugal:

Fund subscriptions — €500,000

This has become the dominant pathway. Qualifying venture capital or private equity funds must be regulated by Portugal's CMVM (Securities Market Commission), with at least 60% of assets invested in Portuguese-headquartered companies. Funds cannot invest directly or indirectly in real estate. This route attracted €260.85 million between 2019 and 2024, and demand continues accelerating.

Cultural and heritage donations — from €250,000

The lowest-cost entry point (reduced to €200,000 for low-density areas). Projects supporting artistic production or national heritage must be pre-approved by GEPAC under the Ministry of Culture. This route saw a 165% increase in 2024, attracting nearly €12 million. The key caveat: these are typically non-refundable donations, not investments with expected returns.

Scientific research contributions — €500,000

Funds research at institutions within Portugal's national scientific and technological system. Reduced to €400,000 in low-density areas.

Company creation or capital transfer — €500,000

Requires creating at least five permanent jobs or establishing a new company generating ten or more full-time positions with no fixed investment floor.

Processing and presence requirements

Processing times currently range from 12 to 18 months from application to biometric appointment, with an additional four months to receive the residence card. AIMA (which replaced the former SEF immigration authority) faces a broader backlog of approximately 400,000 immigration cases, though Golden Visa processing has notably improved. A new online renewal portal launched February 16, 2026, further streamlined the system.

The program's minimal physical presence requirement remains unchanged: seven days in the first year, then 14 days total across each subsequent two-year renewal period — effectively about one week per year in Portugal.

Portugal's citizenship timeline: political limbo

The most consequential recent development for Golden Visa holders isn't about the visa itself — it's about what comes after. On October 28, 2025, Portugal's Parliament approved amendments to the Nationality Law that would double the citizenship residency requirement from 5 to 10 years for most non-EU nationals (seven years for EU and CPLP citizens). The amendments also proposed counting residency from the date of first residence card issuance rather than application date and adding a civic knowledge test alongside the existing A2 Portuguese language requirement.

The backlash was immediate. The Socialist Party referred the law to the Constitutional Court, which on December 15, 2025, declared four of seven provisions unconstitutional — including retroactive application to pending cases and vague fraud provisions. The Court did not strike down the 10-year timeline itself, as that specific provision wasn't challenged. President Marcelo Rebelo de Sousa vetoed the decree on December 19, returning it to Parliament.

The current 5-year citizenship rule remains fully in effect. Parliament is on recess following the February 8, 2026, presidential election, won by Socialist António José Seguro with 66.8% of the vote. His election is widely seen as favorable for investor stability. Permanent residency after five years remains unaffected by these debates, and once obtained, the underlying investment no longer needs to be maintained.

Spain's entire Golden Visa program is gone

Spain didn't just restrict its Golden Visa — it eliminated the entire program. Organic Law 1/2025, published January 3, 2025, repealed Articles 63–67 of Law 14/2013, abolishing all investor visa categories after a three-month grace period ending April 3, 2025.

Every investment route is now closed to new applicants:

  • Real estate (formerly €500,000 minimum)
  • Government bonds (formerly €2,000,000)
  • Company shares (formerly €1,000,000)
  • Bank deposits (formerly €1,000,000)
  • Investment funds (formerly €1,000,000)
  • Business projects of general interest

Notable confusion persists across some sources claiming only the real estate route was eliminated. This is incorrect. Authoritative Spanish legal sources — AGM Abogados, KPMG, the government's Plataforma One portal, and the BOE text itself (reference BOE-A-2025-76) — all confirm the full repeal.

Existing Golden Visa holders retain all rights and can renew indefinitely, provided they maintain their original investment, visit Spain at least once annually, and carry valid health insurance. Approximately 22,430 Golden Visas were issued over the program's 12-year lifespan, with 94% granted through real estate investment.

What alternatives exist in Spain?

For non-EU nationals still interested in Spain, viable pathways include:

  • Digital Nomad Visa — requires approximately €2,849/month income for 2026, with Beckham Law tax eligibility. Fastest-growing pathway, particularly popular among American, British, and Canadian tech professionals.
  • Non-Lucrative Visa — for retirees and passive income holders. Minimum €28,800/year income, no work permitted in Spain.
  • Entrepreneur Visa — for innovative business founders with a validated business plan.

Head-to-head comparison

Factor

Portugal

Spain

Program status

Active

Abolished (April 2025)

Lowest investment

€250,000 (cultural donation)

N/A — no investment route exists

Most common route

€500,000 fund subscription

N/A

Processing time

12–18 months

N/A for new applicants

Physical presence

~7 days/year average

N/A (was 1 visit/year)

Permanent residency

5 years

5 years (via alternative visas)

Citizenship

5 years (currently; 10-year proposal stalled)

10 years (2 for Ibero-American nationals)

Dual citizenship

Allowed

Generally requires renouncing prior nationality

Special tax regime

IFICI (20% flat rate, restrictive eligibility)

Beckham Law (24% flat rate, 6-year duration)

Tax residency trigger

183+ days or habitual home

183+ days

Tax regimes: IFICI vs Beckham Law

Portugal's NHR regime ended for new applicants on January 1, 2024 (with transitional provisions through March 31, 2025). Its replacement, IFICI, offers a 20% flat rate on qualifying Portuguese income and broad foreign income exemptions — but eligibility is far more restrictive, requiring a university degree, three-plus years of professional experience, and work in approved sectors like technology, healthcare, or green energy. Most Golden Visa holders who spend only the minimum seven days annually remain non-tax residents and owe no Portuguese tax on worldwide income, making the IFICI question largely academic for them.

Spain's Beckham Law remains fully active, offering a 24% flat rate on Spanish-sourced income up to €600,000 for six years, with foreign income largely exempt. The 2023 Startup Law expansion means digital nomad visa holders, startup founders, and family members can now also qualify. The key limitation: it lasts only six years, after which standard progressive rates of up to 47–54% apply.

Key risks and what to watch

For Portugal, the primary risks are regulatory unpredictability (as the citizenship law saga demonstrated), processing delays within AIMA's overburdened system, and fund investment illiquidity — capital is locked for five-plus years in vehicles targeting 4–10% IRR with management fees of 1–3% annually. US investors face additional FATCA, FBAR, and PFIC reporting obligations that require specialised cross-border tax planning.

For Spain, the investment-based residency path simply no longer exists. A proposed 100% property transfer tax surcharge on non-EU non-resident buyers (announced January 2025, submitted to Parliament May 2025) remains only a proposal as of February 2026 and faces significant parliamentary hurdles.

The broader European trend points toward continued restriction. The European Parliament voted 595–12 to limit golden visas and ban citizenship-by-investment outright. Greece doubled its minimum to €800,000 in prime areas. Hungary has emerged as a new entrant with €250,000 fund investments and zero physical presence requirements.

WorldPath View

The Iberian Golden Visa landscape has fundamentally split into two. Portugal offers a functioning, increasingly popular program centred on fund investments and donations — but with heightened political risk around citizenship timelines and a less generous tax regime than in previous years. Spain offers no investment-based residency, though its Beckham Law remains one of Europe’s most attractive emigration tax regimes for those who qualify through employment or entrepreneurship.

For professionals and small business owners weighing European residency:

  • If your priority is residency with minimal presence, Portugal’s Golden Visa is the clear choice. Treat permanent residency as the reliable deliverable and citizenship as a potential bonus, not a guarantee on a fixed timeline.
  • If your priority is living and working in Spain, explore the Digital Nomad Visa paired with Beckham Law. It’s not an investment-based route, but the tax benefits are substantial for the first six years.
  • If you want optionality, consider that Portugal’s Golden Visa grants Schengen-wide travel and doesn’t require you to live there — meaning you could hold Portuguese residency while spending most of your time elsewhere in Europe, including Spain on a visitor basis.

The era of straightforward European Golden Visas is ending. What remains demands more careful planning and lower expectations of permanence.

Frequently Asked Questions

Author

Sarah Mitchell
Senior Immigration Advisor
WorldPath AI