How to Evaluate a Golden Visa Fund: 7 Due Diligence Questions Every Investor Must Ask
Dean Fankhauser
Founder and CEO
Most Golden Visa content focuses on visa requirements, timelines, and country comparisons. Almost nobody teaches you how to evaluate the fund itself — the financial product you are locking EUR 500,000 or more into for five to seven years.
That is a problem. Because choosing the wrong fund does not just mean poor returns. It can mean frozen capital, delayed visa renewals, or in the worst cases, a qualifying investment that fails to qualify at all.
At MovingTo, we have processed over 2,500 Golden Visa applications across Portugal, Spain, Italy, and Greece with a 98% approval rate. We have seen investors choose funds based on a glossy brochure and a persuasive sales call. We have also seen what happens when they skip the due diligence.
These seven questions give you a repeatable framework for evaluating any Golden Visa fund, in any country. They are the same questions our advisory team works through with every client.
At a Glance
| Question | What You Are Really Asking | Walk Away If... |
|---|---|---|
| 1. Is it regulated? | Is my capital legally protected? | No verifiable registration number |
| 2. What is the strategy? | Where does my money actually go? | Vague or shifting investment thesis |
| 3. Who manages it? | Do these people know what they are doing? | No audited track record or prior fund exits |
| 4. What are the real fees? | What will I actually keep? | Total annual cost exceeds 3% |
| 5. When can I exit? | Am I locked in beyond my visa timeline? | No redemption mechanism before year 8 |
| 6. What could go wrong? | What is the realistic downside? | Fund cannot articulate its own risks |
| 7. Is the paperwork bulletproof? | Will this actually get my visa approved? | No proven track record of successful visa approvals |
Is This Fund Properly Regulated?
A Golden Visa fund must be registered with the national securities authority of its domicile country. In Portugal, that is the CMVM. In Spain, the CNMV. In Italy, CONSOB alongside Banca d'Italia. In Greece, the HCMC. If a fund cannot provide a verifiable registration number, it should be disqualified immediately.
Regulation means the fund is subject to mandatory rules around asset custody, independent audits, investor reporting, and capital adequacy. A regulated fund must hold your assets with an independent depositary bank. It must produce audited financial statements. An unregulated fund offers none of these protections.
You can browse verified, regulated funds on our platform, or use the Fund Finder to filter by regulator.
How to Verify Registration Yourself
Do not take the fund's word for it. Each regulator maintains a public search tool:
| Country | Regulator | Full Name | What to Search For |
|---|---|---|---|
| Portugal | CMVM | Comissão do Mercado de Valores Mobiliários | Fund registration number and licensed SGOIC |
| Spain | CNMV | Comisión Nacional del Mercado de Valores | Fund registration and authorised SGIIC |
| Italy | CONSOB / Banca d'Italia | Commissione Nazionale per le Società e la Borsa | Fund registration and authorised SGR |
| Greece | HCMC | Hellenic Capital Market Commission | Fund registration and licensed AEDAK |
Red Flags
- •The fund is domiciled offshore (Luxembourg, Cayman Islands) but marketed as Golden Visa eligible without clear regulatory oversight in the target country.
- •The registration number provided does not appear in the regulator's public search tool.
- •The management company was formed less than twelve months ago with no prior fund management history.
- •The fund claims to be "in the process" of obtaining regulatory approval but is already accepting subscriptions.
"Can you provide your regulator registration number and confirm your management company's current licence status? I will be verifying both independently."
What Is the Fund's Investment Strategy?
Golden Visa funds deploy capital across four main strategies: private equity, real estate portfolios, fixed income and credit, and venture capital. Each carries a fundamentally different risk-return profile. There is no universally "best" strategy — only the one that aligns with your financial objectives and risk tolerance.
Understanding the strategy matters because it determines what happens to your money for the next five to ten years. A fund labelled "diversified" might invest 80% of its capital in a single real estate development. The label on the brochure is not the strategy. The underlying portfolio is.
Compare strategies across 34+ funds on our platform or see our best funds ranking.
| Strategy | Typical Return Target | Risk Level | Liquidity | Best Suited For |
|---|---|---|---|---|
| Private Equity | 8-15% IRR | Medium to High | Low | Growth-oriented investors comfortable with illiquidity |
| Real Estate | 4-8% IRR | Medium | Low to Medium | Investors seeking tangible asset backing and stability |
| Fixed Income / Credit | 3-6% IRR | Low to Medium | Medium to High | Conservative investors prioritising capital preservation |
| Venture Capital | 15%+ IRR (high variance) | High | Very Low | Investors with high risk tolerance and long time horizons |
| Balanced / Diversified | 5-10% IRR | Medium | Medium | Most Golden Visa investors seeking a middle ground |
Red Flags
- •The fund projects returns above 15% while describing itself as "low risk" or "conservative."
- •The investment strategy description changes between the website, the pitch deck, and the conversation with the sales team.
- •The fund is concentrated in a single asset, single sector, or single geography with no diversification.
- •There is no clear explanation of how the fund plans to generate returns.
"Can you walk me through three specific investments you have made or intend to make, and explain the investment thesis behind each one?"
Who Is Managing This Fund?
The fund manager's track record is the single strongest predictor of fund performance. A management team that has completed at least one full fund cycle — meaning they have raised capital, deployed it, managed the portfolio, and returned capital to investors — has been tested in ways that a first-time team has not.
When evaluating the team, understand the three distinct roles: the fund manager (SGOIC in Portugal, SGIIC in Spain, SGR in Italy, AEDAK in Greece) makes investment decisions; the depositary bank holds assets independently; the investment advisor provides recommendations. All three should be independent of each other.
Look for a management team with demonstrated sector expertise. Check how long the core team has worked together. Governance matters as much as talent — look for an investment committee, independent board, clear conflict of interest policies, and defined reporting obligations.
Red Flags
- •The management team has never managed a fund to completion.
- •A single individual controls all investment decisions with no investment committee oversight.
- •The fund manager also acts as the investment advisor and the fund administrator.
- •There is no independent depositary bank, or the depositary is a related entity.
- •High turnover in the management team.
"How many funds has your team managed to completion, and what was the net return to investors after all fees?"
What Are the Total Costs?
Golden Visa funds typically charge a management fee of 1% to 2% per year, a performance fee of 10% to 20% of profits, and a one-time subscription fee. But the number that matters most is the Total Expense Ratio (TER), which captures all costs as a single annual percentage. A TER above 3% should trigger serious scrutiny.
You can compare fund fees side-by-side on our platform — every fund listing includes management fees, performance fees, and subscription costs.
The Concept of a Hurdle Rate
A hurdle rate is the minimum return threshold the fund must exceed before it can charge performance fees. A fund with no hurdle rate charges performance fees from the first euro of profit.
| Fee Type | Typical Range | When It Is Charged | What to Watch For |
|---|---|---|---|
| Management Fee | 1-2% per annum | Annually, on total AUM | Charged regardless of performance |
| Performance Fee | 10-20% of profits | At exit or annually, above hurdle rate | Does a hurdle rate apply? |
| Subscription Fee | EUR 2,000 - EUR 5,000 | Once, at the time of investment | Sometimes negotiable |
| Depositary / Custody Fee | 0.1-0.3% per annum | Annually | Usually non-negotiable |
| Administrative Fees | 0.1-0.5% per annum | Annually | Sometimes bundled, sometimes separate |
Red Flags
- •The fund only quotes gross returns in its marketing materials.
- •There is no hurdle rate or preferred return before performance fees are charged.
- •The fee schedule is difficult to find in the fund documents.
- •The Total Expense Ratio exceeds 3% annually.
- •The fund charges both a high management fee (2%+) and a high performance fee (20%+).
"What is the fund's Total Expense Ratio, and can you provide a net-of-fees return projection alongside the gross return figures in your marketing materials?"
What Is the Exit Strategy and Liquidity Structure?
Golden Visa funds are either open-ended (allowing periodic redemptions), closed-ended (capital locked until maturity at 6-10 years), or semi-open (limited redemption windows after an initial lock-up).
The Five-Year Trap
This is one of the most common misalignments we see. An investor's Golden Visa requires a qualifying investment maintained for five years. They subscribe to a closed-ended fund with an eight-year term. After five years, they have their citizenship — but their capital is locked for another three years.
Before subscribing, map out the timeline explicitly.
| Structure | How It Works | Typical Term | Redemption Options | Best For |
|---|---|---|---|---|
| Open-Ended | Continuous subscriptions, periodic redemptions | Ongoing | Quarterly or semi-annual windows | Investors who want flexibility |
| Closed-Ended | Fixed capital raise, deploy, harvest, exit | 6-10 years | Only at maturity | Investors comfortable with full illiquidity |
| Semi-Open | Hybrid with defined redemption windows | 7-8 years | Annual windows after 3-5 year lock-up | Balanced approach |
Red Flags
- •No clear redemption mechanism is described in the fund documentation.
- •The fund term extends three or more years beyond your visa requirement with no early exit option.
- •Redemption is described as being "at the discretion of the fund manager" with no defined schedule.
- •Gate provisions could delay your exit indefinitely.
"If I obtain citizenship after five years and want to redeem my investment, what is the exact process, the expected timeline, and are there any penalties, restrictions, or gate provisions I should be aware of?"
What Are the Risks, and Does the Fund Acknowledge Them?
Every Golden Visa fund carries investment risk, regulatory risk, and currency risk. A credible fund will have a detailed risk section in its prospectus and will openly discuss downside scenarios.
Investment risk — the underlying assets may lose value. Regulatory risk — Golden Visa programmes can be modified or discontinued (Portugal already eliminated direct real estate). Currency risk — relevant for non-EUR investors. Liquidity risk — you cannot exit when you want. Counterparty risk — a key party fails or acts improperly.
For US investors, additional considerations around PFIC classification and FATCA reporting apply — our dedicated guide covers these in detail.
Many Golden Visa funds market "capital preservation" focus. This is a legitimate philosophy, but not a guarantee. No fund can guarantee the return of your capital.
Red Flags
- •The fund's marketing materials make no mention of risk whatsoever.
- •Claims of "guaranteed returns" or "capital guaranteed."
- •No independent valuation process for the fund's underlying assets.
- •The risk section of the prospectus is entirely generic.
"Walk me through your worst-case scenario. If the market turns or a key investment fails, what happens to my capital, and what specific downside protections are built into the fund structure?"
Will This Fund Actually Get My Visa Approved?
A fund can be a sound financial product and still fail as a Golden Visa vehicle if it does not produce the correct compliance documentation. Before subscribing, confirm that the fund provides proof of regulatory registration, a subscription certificate confirming your qualifying investment amount, and ongoing compliance statements.
A fund's marketing may claim "Golden Visa eligible," but this is a self-designation, not a regulatory certification. There is no official list of "approved Golden Visa funds" in most countries. This is why your immigration lawyer should review the fund before you commit capital.
| Country | Immigration Authority | Key Documents Required |
|---|---|---|
| Portugal | AIMA | CMVM registration declaration, subscription certificate confirming EUR 500,000 minimum, annual compliance statements |
| Spain | Spanish Immigration Office | CNMV registration, investment certificate with qualifying amount, renewal documentation |
| Italy | Italian Immigration Authority | CONSOB registration, investment confirmation letter, proof of maintained investment |
| Greece | Greek Ministry of Migration | HCMC registration confirmation, subscription certificate, annual statements |
Red Flags
- •The fund has no track record of investors successfully obtaining Golden Visas through it.
- •Compliance documentation is produced internally without independent verification.
- •The fund cannot confirm its current Golden Visa eligibility status.
- •Your immigration lawyer has not reviewed and approved the fund's documentation before you commit.
"How many investors have successfully obtained their Golden Visa through this fund, and can you connect me with an immigration lawyer who has processed applications using your fund's documentation?"
The 7-Question Checklist
Before committing to any Golden Visa fund, confirm that you can answer "yes" to all seven of the following:
Regulation. The fund is registered with the relevant national securities authority, and I have independently verified its registration number.
Strategy. I understand the fund's investment thesis, the specific assets it targets, and how these align with my risk profile.
Team. The management team has completed at least one prior fund cycle and has a verifiable, audited track record.
Fees. The Total Expense Ratio is below 3%, and I have compared the fund's net-of-fees returns against alternatives.
Exit. I can redeem my investment within a timeframe that aligns with my visa and citizenship objectives.
Risk. The fund openly discloses its specific risks and has articulated its downside protection mechanisms.
Compliance. The fund has a proven record of investors successfully obtaining Golden Visas, and my immigration lawyer has reviewed its documentation.
If you cannot confidently answer "yes" to all seven, proceed with extreme caution — or continue looking.
Frequently Asked Questions
Your EUR 500,000 Deserves This Level of Scrutiny
A Golden Visa fund is both a financial commitment and an immigration instrument. It should be evaluated with the same rigour you would apply to any investment of this magnitude.