In short
The fund route needs at least €500,000 in units of collective investment undertakings that are not real-estate funds. At the time you invest, the fund must have at least 5 years to maturity and at least 60% of its investments in commercial companies with their registered office in Portugal; since Law 56/2023 it may not invest in real estate, directly or indirectly. You keep the investment for at least 5 years. AIMA checks a declaration from the fund manager confirming these conditions — there is no separate "CMVM golden visa certification". Government fees in 2026 are €842.80 and €8,418.90 per person for the first permit and €4,210.30 per renewal; funds typically charge 1.5–2.5% a year. For Americans, Portuguese funds are PFICs: without a fund PFIC statement for a QEF election, gains face punitive US tax. Citizenship now needs 10 years from the permit.
Portugal funds route: key facts
Last verified 28 September 2026| Golden visa (ARI) | Five routes in 2026: €500,000 in qualifying non-real-estate funds, €500,000 research, €250,000 culture, €500,000 company capital with 5 jobs, or 10 jobs; real estate and €1.5M capital transfer closed since October 2023# Source: Lei 23/2007 consolidated text (PGD Lisboa) art. 3 · Lei 56/2023: Diário da República |
|---|---|
| Golden visa minimum stay | 7 days in the first year and 14 days in each later 2-year period# Source: Global Citizen Solutions: Portugal Golden Visa Oct 2026 |
| Golden visa government fees | Per person in 2026: €842.80 application analysis, €8,418.90 permit issuance, €4,210.30 per renewal# Source: Global Citizen Solutions: Portugal Golden Visa Oct 2026 · Grow in Portugal: AIMA fees 2026 |
| Golden visa processing | Often 12–24 months or more in 2026; the government has said investors are processed after other cases# Source: Grow in Portugal: GV filers face 12-month wait for biometrics (Aug 2026) |
| Funds and US tax | Portuguese investment funds are PFICs for US investors: Form 8621 each year and punitive default tax unless the fund provides a PFIC statement for a QEF election# Source: IRS Instructions for Form 8621 |
| Permanent residence | After 5 years of temporary residence, with A2 Portuguese, means of support and accommodation# Source: Lei 23/2007 art. 75 (PGD Lisboa) |
| Citizenship | Since 19 May 2026: 10 years of legal residence (7 for EU and Portuguese-speaking countries), counted from when the first permit is issued; applications pending before then keep the old 5-year rule# Source: Lei Organica n.o 1/2026: Diario da Republica · Portugal Citizenship Law Published: LiveinPT |
| Tax number (NIF) | Non-EU residents can get a NIF without a fiscal representative (one is needed once tax activity starts); since July 2025 a lawyer can request it online# Source: Ofício-Circulado 90054/2022 (Informador) · Observador: Imigrantes sem cartão de cidadão já podem pedir o NIF no Portal das Finanças |
| US tax treaty | Signed 1994, in force since 1996; the saving clause keeps US taxation of citizens# Source: Portugal tax treaty documents: IRS |
| US reporting | FBAR if foreign accounts exceed $10,000 at any time; Form 8938 from $200,000 at year-end ($300,000 at any time) for a single filer living abroad# Source: Comparison of Form 8938 and FBAR: IRS |
Not American?
Canadians, Australians, Brits and other non-EU citizens: the same rules apply
The fund route is the same for every non-EU investor. What differs for Americans:
- Canada
- Australia
- New Zealand
- United Kingdom
- Japan
- South Korea
- + other visa-free countries
| US tax | Portuguese funds are PFICs for US investors — Form 8621 each year and harsh default tax unless the fund supports a QEF election. |
|---|---|
| Citizenship | 10 years for Americans; 7 for citizens of Portuguese-speaking countries. |
| Documents from abroad | Need an apostille; the US, Canada (since 11 Jan 2024), the UK, Australia and NZ issue them.Source: HCCH: Apostille Convention status table |
Eligibility
What Makes a Fund Eligible?
Not a real-estate fund
Since Law 56/2023 the investment may not go into real estate, directly or indirectly.
At least 5 years to maturity
Measured at the time you invest; many funds mature between 2031 and 2035, some are open-ended.
60% in Portuguese companies
At least 60% of the fund's investments must be in commercial companies with their registered office in Portugal.
Manager's declaration
AIMA asks for a declaration from the fund management company confirming maturity and the 60% rule. The CMVM registers and supervises funds, but there is no special CMVM golden visa certificate.
The fund route was added by Decree-Law 14/2021; Law 56/2023 then closed the real estate and capital transfer routes and barred funds from real estate.
How It Works
How the Process Works for Americans
Choose a fund and check its US tax reporting
Ask for a PFIC Annual Information Statement before you subscribe.
Get a NIF and Portuguese bank account
Non-EU residents can get a NIF without a fiscal representative (one is needed once tax activity starts); since July 2025 a lawyer can request it online.
Subscribe €500,000
Obtain the fund manager's declaration for AIMA.
Apply online to AIMA
Analysis fee €842.80 per person; biometrics often about 12 months later in 2026.
Receive your permit
Issuance fee €8,418.90 per person; 2-year permit, then 3-year renewals.
Costs
What Your €500,000 Investment Costs
| Cost | Typical amount |
|---|---|
| Investment | €500,000 (at risk — not guaranteed) |
| AIMA fees per person, first 5 years | about €13,500 (analysis, issuance, one renewal) |
| Fund management fee | about 1.5–2.5% a year |
| Subscription fee | about 0–3% |
| Performance fee | often 10–20% above a hurdle |
AIMA fees 2026; fund fees from practitioner surveys. Source: Grow in Portugal: AIMA fees 2026
Family
What You and Your Family Receive
Residence for the family
Spouse, minor children, dependent adult children who are single and studying, and dependent parents.
No 2-year wait
Golden visa holders are exempt from the 2025 rule delaying family reunification.
Schengen travel
Up to 90 days in any 180 in other Schengen countries.
Permanent residence and citizenship
Permanent residence after 5 years with A2 Portuguese; citizenship after 10 years from the permit.
Risks
Risks You Must Understand
Investment risk
Fund units can lose value, and many funds are illiquid until maturity.
US tax (PFIC)
Portuguese investment funds are PFICs for US investors: Form 8621 each year and punitive default tax unless the fund provides a PFIC statement for a QEF election.
Long processing
Often 12–24 months or more in 2026; the government has said investors are processed after other cases.
Changing rules
Citizenship rules changed in May 2026; it is unclear whether golden visa time already accrued counts towards the new 10 years.
The fund route is NOT right for you if…
- You need the money back within 5–10 years.
- Your US tax adviser cannot handle PFIC reporting.
- You expected Portuguese citizenship in 5 years.
- You plan to buy property to qualify.
FAQ
Frequently asked questions
What is the minimum investment for the fund route?
€500,000 in qualifying non-real-estate funds, kept for at least 5 years.
Can a golden visa fund invest in real estate?
No. Since Law 56/2023 the investment may not go into real estate, directly or indirectly.
Do I pay US tax on fund gains?
Yes. Portuguese funds are PFICs for US investors. Ask the fund for a PFIC statement so you can make a QEF election; otherwise the default regime adds an interest charge on gains.
Can I work in the US while holding a Portugal golden visa?
Yes. You only need 7 days in Portugal in the first year and 14 days in each later 2-year period.
Can my children get citizenship through the golden visa?
Citizenship now needs 10 years of legal residence, counted from when the permit is issued (7 for EU and Portuguese-speaking nationals).
Portugal
Everything about moving to Portugal
Investor routes · other countries
Other investor-visa routes in Europe
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