PSD and CDS-PP have proposed changes to Portugal’s Golden Visa investment routes through an amendment to the 2027 State Budget bill. The proposal has not yet been approved.
Portugal’s proposed Golden Visa fund changes go beyond raising a percentage. They would change how qualifying funds must invest in Portuguese companies, making the structure of those investments an important part of the discussion.
For investors considering Portugal, the practical question is what the proposed requirements mean and how they relate to the investment strategies available.
The proposal is not yet law. Its final wording and implementation will determine how the changes apply in practice.
The €500,000 minimum would remain. How the fund invests would change.
The current framework requires at least 60% of a qualifying fund’s investments to be made in companies headquartered in Portugal.
The proposal would increase that requirement to 80% and introduce a more specific condition: that investment must reinforce the share capital of those companies.
This distinction is fundamental.
When a fund buys existing shares on the stock market, the money generally goes to the investor selling those shares. It does not provide fresh share capital to the company.
When a fund participates in a qualifying capital increase, the money goes into the company itself.
Under the proposed wording, purchasing existing shares in the secondary market would not satisfy the new 80% capital-reinforcement requirement. Being invested in Portuguese companies would no longer be sufficient on its own.
How the proposal would affect fund strategies
If adopted as drafted, the proposal would change the eligibility requirements for funds serving new Golden Visa applicants.
A fund built around purchasing existing listed shares could not rely on those purchases to meet the new 80% requirement. It would need a compliant investment structure, potentially requiring substantial changes to its strategy.
That does not mean all listed investments would be prohibited, or that every open-ended fund would automatically be excluded. Equally, a venture capital label would not automatically establish eligibility.
Eligibility would depend on the fund’s underlying investments and how they meet the applicable legal requirements.
For prospective applicants, this makes fund selection more than a comparison of returns, fees or fund categories. The investment strategy must also be assessed against the immigration requirements that would apply to their application.
What should investors consider?
The proposal concerns eligibility requirements. It does not, by itself, establish whether an investment would offer better returns or be more suitable for a particular investor.
That assessment should consider the fund’s strategy, underlying assets, investment horizon, liquidity, fees and risks, alongside the investor’s objectives.
Understanding these elements helps distinguish the immigration requirements from the investment decision itself. Both matter when assessing a Portugal Golden Visa plan.
When would the changes apply?
The 2027 State Budget proposal specifies 1 January 2027 as its entry-into-force date. That date remains subject to the final approved legislation.
Under the proposed transitional provision, the new requirements would apply only to ARI applications submitted after the law enters into force. Investors should therefore not assume that completing an investment before that date would, on its own, secure assessment under the current rules.
Other proposed routes also deserve attention
The draft would reduce the standard scientific research threshold to €250,000 and introduce a €250,000 route supporting qualifying social facilities.
These changes could broaden the available choices. However, the use of the word “investment” should not be interpreted as a promise of repayment or financial return. The final legislation, any implementing rules and the terms of each arrangement will determine how those options work in practice.
Discuss what the proposal could mean for your plans
If you are considering Portugal’s Golden Visa, a conversation can help clarify what is being proposed, which questions remain open and what to consider when assessing your options.
João Villa-Lobos at The Blue Portugal can help you understand the questions to resolve and coordinate the relevant discussions with fund managers and legal advisers.
Speak with João Villa-Lobos to discuss your Golden Visa plans.This article discusses proposed legislation. Approval, final wording and implementation remain subject to change. Investment returns and capital recovery are not guaranteed.
Sources: proposed amendment dated 6 November 2026, Articles 135-A and 138(8) (PDF copy); Portuguese Parliament, 2027 State Budget bill, Article 139; AIMA, current ARI requirements.
