Portugal’s Golden Visa has changed. Are investors looking at it the right way?
7 MAY, 2026
Portugal’s Golden Visa has changed fundamentally. Real estate is no longer part of the program. Today, investors are entering through regulated investment funds, turning what was once seen as a property transaction into a private markets allocation decision.
As international demand continues to grow, understanding fund structures, manager quality and long-term risk has become far more important than simply obtaining residency.
We speak with João Cunha, Founder & CEO of MFG Consultants, about how the Portuguese Golden Visa works today, what investors continue to misunderstand, and why fund selection now sits at the centre of the conversation.
The Portuguese Golden Visa is still often associated with real estate. What has actually changed?
That version of the program is gone. Real estate has not been eligible since 2023. What remains is a €500,000 allocation into CMVM-regulated investment funds or, alternatively, a €250,000 cultural donation option.
This is not a small adjustment. It changes the nature of the decision completely. Investors are no longer choosing an asset. They are allocating capital into private markets.
The issue is that much of the market still communicates the Golden Visa as if it were a property play. It isn’t. And that gap between perception and reality is where most mistakes start.
So what is the investor really deciding today?
They are making a capital allocation decision inside a regulated framework.
Which managers to trust, how capital is deployed, what the liquidity profile looks like, where downside risk sits, and how returns are expected to materialise over a 5 to 7 year horizon.
Two investors can both commit €500,000 and end up in completely different positions. One locked into a single strategy with no visibility on distributions. Another with a structured portfolio combining income, growth and staggered exits.
Same investment amount. Completely different outcomes.
How do you approach that at MFG Consultants?
We don’t select products. We structure allocations.
There are today more than 60 CMVM-regulated funds eligible for the Golden Visa. We work across a catalogue of over 65. That breadth is not about volume. It’s what allows us to remain independent.
Most of the market operates with a narrow set of options, which naturally biases the recommendation. Our role is to build portfolios that combine different strategies and timelines, aligned with the investor’s objectives.
This is not about finding “the best fund”. It’s about building something that actually works over time.
What are the main risks investors tend to underestimate?
Two in particular.
First, manager risk. Many decisions are still made based on presentation rather than execution. How capital is actually deployed and returned is what matters.
Second, structural risk. Golden Visa eligibility is not a label. It is a structure that needs to hold over time.
A fund must remain compliant with specific requirements throughout the investment period. If that is not properly understood, the investor carries that risk, often without realising it.
Why does local expertise matter in this context?
Because this is about control, not access.
Understanding how funds are structured under Portuguese regulation, how capital flows, and how eligibility is maintained requires direct exposure to the market.
We often see international distribution channels focusing on getting clients into the program, without fully understanding the underlying structures.
Being on the ground allows us to validate what is actually happening behind the scenes. That is where most of the risk sits.
You’ve been working in this space since 2012. What advantage does that give you today?
Perspective.
We’ve seen the program evolve from a real estate-driven model to a private markets framework. Many of the assumptions still used today come from the old version of the program.
Having structured investments for hundreds of families across that transition gives us a clear view of what tends to go wrong. Not in theory. In execution, timing and alignment.
We didn’t enter when funds became popular. We adapted as the market changed.
How attractive is Portugal today from an investment standpoint?
It’s not a hype story. It’s a structural one.
Portugal has been growing at around 1.5% to 2% in real GDP terms, with inflation stabilising close to 2%. But the real opportunity is at sector level.
Renewables have reached close to 75% to 80% of electricity generation in certain periods, creating a strong pipeline in energy. Tourism represents roughly 15% of GDP, supporting hospitality and related sectors.
At the same time, the SME landscape remains fragmented, which creates opportunities for private equity and credit strategies to generate returns through consolidation and operational improvement.
This is where private markets extract value.
What role does international capital play in this shift?
A decisive one.
Foreign capital has been a dominant force in Portugal for years. In Lisbon, international buyers have represented close to 40% of transactions. That capital did not disappear when real estate was removed from the Golden Visa. It moved into funds.
Today, investors from the US, UK, Middle East and Asia are actively allocating into these structures. That is influencing how funds are built, how they communicate, and how they structure liquidity.
It is also increasing dispersion. Not all funds are equal. Selection matters more than ever.
What is Portugal’s role for investors using the Golden Visa today?
It’s a positioning tool. Not a relocation requirement.
The program gives access to European private markets within a regulated framework, combined with a residency structure that is operationally flexible.
Physical presence requirements are minimal. Investors don’t need to relocate to benefit from it.
For most families, this is about diversification. Of capital, jurisdiction and long-term access.
What would you say to an investor currently considering the Golden Visa?
Don’t approach it as a residency purchase.
Approach it as a capital allocation decision with a residency outcome attached to it.
If you get the investment wrong, the residency won’t compensate for it. If you get the investment right, the residency becomes an added layer of value.
That’s the order in which this should be thought through.
