Portugal Golden Visa vs Greece Golden Visa: A 2026 Reality Check

On April 1, 2026, the Portuguese Parliament passed amendments to the Nationality Law by a 152-64 vote. The President promulgated the decree on 3 May 2026. The headline planning change is that investors should no longer treat Portugal as a simple five-year citizenship route; the reform sets ordinary naturalisation at ten years for most non-EU nationals and seven years for EU/CPLP nationals. It was published as Lei Orgânica 1/2026 and entered into force on 19 May 2026; applications filed with the IRN on or before 18 May 2026 remain under the previous five-year regime. For a full breakdown of the new timeline, see our Portugal Golden Visa citizenship timeline.

The previous version of the law was struck down in part by the Constitutional Court in December 2025; this version was rewritten to address those concerns, promulgated by the President, and is now in force as Lei Orgânica 1/2026. Investors should work from current Portuguese legal advice rather than older articles that still describe a clean five-year passport timeline.

What did not change:

• The Golden Visa program itself remains open. A qualifying €500,000 fund-route investment can still support a residency application — CMVM registration is a securities-regulation status, not Golden Visa eligibility, which is determined under the immigration rules (AIMA) and must be confirmed with Portuguese legal counsel.
• Permanent residency is still available at year five. PR has no minimum stay requirement for Golden Visa holders, and each family member receives an independent PR card.
• The ~7 days/year physical presence requirement to maintain the Golden Visa is unchanged.
• All Schengen travel rights, family inclusion rules, and renewal mechanics are unchanged.
• The treatment of existing holders, pending files, and transition cases should be checked against the final official text and with Portuguese counsel.

What this actually means in practice:

If you start the Golden Visa process today, your timeline is now: residence card in year 1, permanent residency in year 5 (no stay required), citizenship eligibility in year 10. Permanent residency is the meaningful milestone — it's the point at which you have a renewable, family-independent EU residence permit that you don't need to keep paying fund management fees on (you can exit the fund) and that doesn't require you to live in Portugal.

This is genuinely worse than the old five-year passport route. It is not "the program is dead." Most of the European Union requires longer than ten years of actual residence for naturalisation. Portugal's program remains one of the more flexible routes for low-stay investors; the right choice depends on your goals — the marketing has just lost its biggest headline.

Greece's Golden Visa has always been a residence permit, not a passport route. The seven-year citizenship eligibility timeline that brokers cite has always required 183+ days per year of actual physical residence in Greece, language proficiency, integration, and a passing grade on a citizenship exam. The number of Golden Visa investors who have ever converted Greek residency into Greek citizenship without actually relocating to Greece is essentially zero.

What did change in Greece, in 2024:

• Investment thresholds rose to €800,000 in Athens, Thessaloniki, and any island with more than 3,100 residents
• €400,000 in other mainland regions
• €250,000 only for commercial-to-residential conversions, historic restoration, or qualifying startup investments through the Elevate Greece registry (launched January 2026)
• Properties must now be at least 120 m²
• Short-term and Airbnb-style rentals are explicitly banned for Golden Visa properties under penalty of €50,000 fine and permit cancellation

The €250,000 number every comparison page still quotes is real, but it applies to a small slice of the available stock that almost no investor actually buys.

Same starting date (April 2026), same exit (April 2036), single investor. For a deep dive into how fund fees affect these returns, see our breakdown of the math behind Golden Visa fund fees.

These are illustrative model outputs, not forecasts; funds can lose money and a negative scenario would reduce proceeds below the amount invested. Capital is at risk.

Scenario A: €500,000 in a Portugal Golden Visa fund

Entry costs

• Subscription fee: 1.0% — €5,000
• Visa application + legal: ~€15,000
• NIF, bank account, ancillary: ~€1,500
• Total: ~€21,500

Annual costs

• Management fee: 1.5% on NAV
• Custodian, audit, regulatory: ~0.3%
• Performance fee: 20% over a 6% hurdle (varies by fund)

Returns (base case: 8% gross IRR, ~6% net)

• €500,000 compounding at 6% net for 10 years = ~€895,000

Year 10 outcome

• Net proceeds: ~€895,000
• Permanent Residency: Year 5
• Citizenship eligibility: Year 10 (under new law)
• Days spent in Portugal over 10 years: ~70
• Net gain: ~€395,000, plus permanent residency at year 5 and citizenship eligibility at year 10.

Sensitivity: 3% net annual return → ~€672,000. 9% net → ~€1,184,000.

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Scenario B: €800,000 Athens apartment

Entry costs

• Property transfer tax 3.09%: €24,720
• Notary, registration, legal ~2.5%: €20,000
• Agent commission ~2%: €16,000
• Furnishing and immediate works: ~€20,000
• Golden Visa application and legal: ~€10,000
• Total: ~€90,720 (≈11.3% of purchase price)

Annual costs

• ENFIA property tax: ~€3,200
• Building maintenance / common charges: ~€2,500
• Property management (remote): ~10% of rent
• Insurance: ~€600
• Income tax on rental income (Greek + home country)

Rental income

• Long-term only — short-term banned
• Athens gross yield: ~4.4% — ~€35,200/year
• Net of management, maintenance, taxes, vacancy: ~€18,000–22,000/year
• 10-year net rental income: ~€200,000

Capital appreciation

• Greek residential prices grew ~7% in 2025 and are decelerating
• Base case: 3% annual appreciation → €800,000 grows to ~€1,075,000
• Less ~6% selling costs at exit → ~€1,010,000 net

Year 10 outcome

• Net proceeds from sale: ~€1,010,000
• Plus 10 years rental income: ~€200,000
• Less entry costs: -€90,720
• Total net position: ~€1,119,000
• Citizenship: None (would require physical relocation)
• Residence permit: Yes, renewable as long as you keep the property
• Net gain: ~€319,000 and a renewed residence permit.

1. The "€250,000 Greece minimum" is mostly fiction in 2026

Since August 2024, the €250,000 threshold applies only to commercial-to-residential conversion projects and historic restoration. In Athens, Thessaloniki, and any island with more than 3,100 residents — meaning every island you've heard of — the minimum is €800,000. In the rest of mainland Greece it's €400,000. The €250,000 number is quoted constantly because it makes Greece look cheap. It hasn't been the realistic entry point for most investors for over 18 months.

2. Greece banned short-term rentals on Golden Visa properties

Properties acquired under the Greek Golden Visa cannot be used for short-term rentals. No Airbnb, no Booking.com, no holiday lets. Long-term tenancy only. Violators face a €50,000 administrative fine and cancellation of the residence permit.

Every site selling Greek property still quotes "8–10% rental yields" sourced from short-term rental data. Those yields no longer apply to Golden Visa investors. The actual long-term yield in Athens is around 4.4% gross and falling, because purchase prices climbed faster than rents through 2024–25. Net of costs you're at 2.5–3%.

3. Portugal's "5-year passport" is dead — but most comparison pages don't know yet

As of April 1, 2026, Portugal extended naturalisation from five to ten years. Almost every other Portugal vs Greece comparison currently online still cites the five-year figure. They are all out of date. Some of the brokers running those pages know and haven't updated. Others genuinely don't.

What they also won't tell you: Portuguese permanent residency at year five is still intact and still requires no minimum stay. PR is the meaningful five-year milestone now, not citizenship. For a non-resident investor, PR delivers most of what citizenship delivers — except voting rights, an EU passport, and full freedom of movement to live and work elsewhere in the EU.

4. Greek "7-year citizenship" is essentially unreachable for Golden Visa investors

Read this slowly. The Greek Golden Visa has zero stay requirement to maintain residency. But to convert that residency into Greek citizenship, you must demonstrate physical residence of 183+ days per year for seven years, pass a Greek language and history exam, and prove integration. The vast majority of Greek Golden Visa investors never relocate, never trigger the residency clock, and never become Greek citizens.

So when comparison pages say "Greece offers citizenship in 7 years vs Portugal's 10," they are comparing a theoretical Greek timeline that almost no one achieves against a practical Portuguese timeline that most Golden Visa holders actually complete.

5. Liquidity is asymmetric and badly explained

Portugal funds are illiquid for the lock-up period (typically 6–10 years) but redemption is structured. You know in advance when you can exit and how — we cover the most common traps in our Golden Visa fund liquidity guide. Greek real estate is theoretically liquid every day — list tomorrow — but you're selling into whichever local market exists at that moment. Athens is reasonably deep. Most of the rest of Greece is not. Properties bought at the new €800,000+ thresholds in 2024 are now competing with local buyers who never had to pay €800k for them.

6. The Greek processing backlog is enormous

As of November 2025, Greece had over 42,000 Golden Visa applications pending and was approving roughly 7,000–9,000 per year. The math on wait times is obvious. Portugal's AIMA backlog is also real but is being actively cleared, and processing has improved through 2026.

7. The tax bill nobody mentions

Greek rental income is taxed in Greece (15–45%) and again in your home country, with foreign tax credits to offset. US investors get hit with FIRPTA on exit. For a full breakdown of US-specific considerations, see our guide on whether American citizens can invest in Portugal Golden Visa funds. Portuguese fund returns can be simpler to administer, especially if you become Portuguese tax resident under the IFICI/NHR successor regime. For US investors holding Portugal funds, PFIC rules apply and need active planning — but the surface area is typically smaller and more predictable than Greek property income plus capital gains plus FIRPTA. Confirm your own position with a qualified tax adviser.

Greece may be relevant if you fit one of these profiles:

• You want to live in Greece. Not "be a tax resident on paper" — actually live there. The investment thesis is "I love Greece," not "I'm optimising EU residency."
• You strongly prefer tangible assets over financial instruments. Some investors will never be comfortable with a fund. Buy a building.
• You don't care about EU citizenship. You already hold a strong passport, you want optionality and Schengen access, and a passport upgrade is irrelevant.
• You want a holiday home that earns its keep. You'll use it 4–8 weeks a year, rent long-term the rest of the time, and you're modelling the return as "lifestyle plus modest yield" rather than as a financial investment.
• You're allergic to Portuguese legislative volatility. Portugal has changed the Golden Visa rules three times in three years. If watching another reform proposal would break you psychologically, Greece's rules are genuinely more stable.

Portugal may still be relevant if any of these describe you. If you're weighing the fund route against the cultural donation, we compare them in detail in Golden Visa funds vs cultural donation.

• You want a credible EU passport route without relocating. Even at ten years, it's the only major Golden Visa in Europe that delivers this for non-residents. Greece's seven-year route requires you to actually move there.
• Year-five permanent residency is enough for you. PR gives you a renewable EU residence card with no stay requirement, independent for each family member. Many investors never need to convert to citizenship at all.
• You're hands-off. You don't want to own a building in a country where you don't speak the language, deal with tenants, or worry about a roof.
• You're a US citizen. Portugal funds with proper PFIC planning can be simpler to administer than Greek property plus FIRPTA on exit. AIMA publishes Golden Visa nationality statistics; the US has been one of the larger non-EU nationalities for the program in recent years, but the published rankings shift period to period, so confirm current figures before quoting them.
• You're a tech founder, executive, or HNWI with lumpy liquidity events. A €500,000 fund subscription is operationally simple. An €800,000 cross-border real estate purchase is not.
• You're optimising for family. Portugal includes spouse, dependent children, and dependent parents on a single application. Each gets their own PR card at year five.

1. Do you want EU citizenship at the end of this? If this matters most to you, that may point toward Portugal (10 years), the more realistic path of these two for non-residents.
2. Do you want to physically move to the country? If staying put matters most, Portugal's structure may fit.
3. Are you comfortable with a managed financial product? If you would rather avoid one, Greece's may.
4. Is capital deployment efficiency important? If this matters most to you, Portugal's structure may fit.
5. Do you specifically want to live in Greece? If this matters most, Greece's may — and not because of the visa.

If several of these point the same way, it may be worth shortlisting funds — with your own advisers. If several point toward Greece, the equivalent step is to engage a Greek property lawyer.

The Portugal fund scenario uses fee structures from the Movingto fund directory, a database of CMVM-regulated Golden Visa funds in Portugal where verification is a documentation check, not an endorsement, rating, or eligibility/quality determination. Returns are modelled at base, pessimistic, and optimistic cases against the historical performance distribution of the private equity and venture capital funds in the directory. These are illustrative model outputs, not forecasts; funds can lose money and a negative scenario would reduce proceeds below the amount invested. Capital is at risk.

The Greece scenario uses purchase prices and rental yield data from Bank of Greece statistics, Greek Ministry of Migration and Asylum reporting on 2024–2025 application volumes, and current ENFIA and transfer tax rates. Property appreciation assumptions are based on the post-2024 deceleration in Greek residential real estate growth.

Tax assumptions are illustrative and do not constitute tax advice. Every situation needs review by a qualified tax advisor in both countries. Movingto is not authorised by CMVM, the SEC, or any financial regulator to provide investment advice.