Portugal Golden Visa: what investors need to know about possible citizenship law changes

Since 2012, the Portugal Golden Visa programme has attracted over €7 billion in investment and issued more than 12,700 residence permits to main applicants. The programme itself is not being targeted by the proposed amendments. However, if changes to the Nationality Law are enacted as per the original proposals, most applicants aiming for Portuguese citizenship could face longer residency requirements, potentially extending from five to 10 years.

Why citizenship law changes are delayed

On 23 June, 2025, the government approved proposals to amend the Nationality Law. After parliamentary debate, the initial proposals were rejected and sent back to the government for further discussion. Constitutional experts also raised concerns, particularly regarding retroactive rule changes and how the residency period is calculated. A formal constitutional challenge was lodged on 22 September, 2025, pausing progress.

The proposals are scheduled for discussion again in October, but the timeline could be pushed back. Legislative changes in Portugal often take months of negotiation, and constitutional concerns may slow this process further. There is also the possibility that different residency timelines could apply depending on visa type – for example, maintaining five years for Golden Visa holders while extending requirements for other visa categories.

Portugal Golden Visa investors: potential longer residency timelines

Golden Visa applicants should be prepared for the possibility of longer timelines before citizenship eligibility. Future applicants may need to remain invested in their Golden Visa fund for up to 10 years. Choosing a fund that allows flexibility – such as early withdrawal or long-term maintenance – is now more critical than ever.

The real estate investment route is closed. The main route now is a minimum €500,000 investment in eligible funds.

How the legislative process works

Passing a law in Portugal involves several steps:

• Debate and committee review: Parliamentary committees examine and discuss proposals.
• Coordination: Political parties negotiate compromises.
• General vote: Parliament votes; the government cannot pass the law alone.
• Promulgation: The President of the Republic signs the law.
• Publication: The law is published in the official national gazette and comes into effect.

The process is expected to take at least three to six months, likely longer due to constitutional concerns.

Portugal Golden Visa remains secure 

The good news for Golden Visa applicants is that the residency-by-investment programme itself is secure and robust. Recent court rulings have confirmed that investors retain enhanced family reunification rights, covering spouses, minor children, and qualifying extended family members.

Applicants should consider:

• The proposed nationality changes are not yet law – the five-year citizenship timeline still applies today.
• Be prepared to adapt to a longer 5–10-year timeline in the future.
• Choose a CMVM-regulated fund with flexibility for long-term investment and/or early withdrawal in case of a change in personal circumstances.
• Acting now under current rules to ensure an application submission date prior to any changes, in order to benefit from any grandfathering clauses that may be made.

Secure your current citizenship timeline

Since 2012, Portugal’s Golden Visa programme has welcomed applicants from around the world, offering a streamlined path to EU residency. Non-Europeans can still apply through a minimum €500,000 investment in eligible funds, and under current law, citizenship applications remain possible after five years.

With ongoing discussions around potential changes to the nationality law, now is an ideal time for investors to apply. While future legislation may introduce new rules, the government has expressed its support for the Golden Visa programme and so it is feasible that certain dispensations may be afforded to Golden Visa investors. The programme continues to offer a dependable path to EU residency and eventual citizenship.

Join us for one-on-one Golden Visa consults in Johannesburg from 27 -28 October and in Durban from 29 - 30 October. Our investment migration specialists will be on hand to give you expert advice on EU residency-by-investment programmes or citizenship-by-investment programmes in the Caribbean.

Protect your path to EU residency – contact our advisory team today to explore your options. Get in touch with Sarah Young our Investment Migration Manager at [email protected] or call her on +44 (0) 20 7759 7552 / +27 (0) 21 657 1584