For new applicants, Portugal no longer accepts real-estate Golden Visa applications. Law 56/2023 kept the Residence Permit for Investment Activity (ARI) and its non-property routes. It also preserved qualifying property applications that were already pending when the law took effect and renewal treatment for existing holders. The EUR 500,000 non-real-estate fund route is therefore one current option, not the only surviving route or a replacement for every applicant. Law 56/2023 · AIMA ARI guidance

AIMA currently lists five route families: job creation, scientific research, arts or cultural heritage, non-real-estate collective investment and qualifying company capitalization with employment conditions. For the fund route, the applicant must invest at least EUR 500,000 in units of non-real-estate collective investment undertakings established under Portuguese law. At the time of investment, the undertaking must have a maturity of at least five years, and at least 60% of the value of its investments must be made in commercial companies headquartered in Portugal. Portugal Golden Visa guide · AIMA route list

The practical change is that a fund subscription requires two separate decisions. The first is legal: does the investment satisfy the ARI route and remain compliant? The second is financial: are the manager, strategy, fees, valuation, liquidity, term and tax consequences suitable for this investor? Evidence for one decision does not answer the other.

What changed for property applications

Before 7 October 2023, qualifying real-estate routes were open to new ARI applications. Law 56/2023 closed those routes to new applications, but it did not erase qualifying files already pending when the law entered into force or the statutory treatment of existing holders and renewals. Anyone relying on a pre-October 2023 property file should obtain case-specific legal advice rather than use the rules for a new fund application. Transitional rules

European scrutiny also needs precise language. The European Commission's 2019 report identified security, money-laundering, tax-evasion and corruption risks in investor citizenship and residence schemes. Its March 2022 recommendation urged Member States to repeal investor-citizenship schemes, while calling for strong checks on investor-residence schemes and specific measures concerning Russian and Belarusian nationals. It did not recommend repealing investor-residence programs as a category. Commission 2019 · Commission 2022

Law 56/2023 entered into force on 7 October 2023. It ended new applications under the simple capital-transfer and real-estate sub-routes and retained job creation, scientific research, arts or cultural heritage, the pre-existing non-real-estate fund route, and qualifying company capitalization with employment conditions. The current AIMA page should be checked again before an applicant commits capital. Law 56/2023 · Current AIMA routes

The fund route asks where the money goes

The current fund route is more technical than the old property route. Investors are no longer simply checking whether a property hits a threshold. They are looking at fund structure, maturity, asset allocation, legal documentation, depositary, auditor, and underlying investments — and whether all of that satisfies immigration rules in addition to financial ones.

A qualifying fund investment is part of both an immigration file and an investment portfolio. The ARI investment must be maintained for at least five years counted from the date the residence permit is granted. A fund's own term, extensions and redemption restrictions may keep capital committed for longer. The applicant must also prove the transfer and ownership of the units and meet the personal, criminal-record and other ARI requirements that apply to the file. ARI maintenance and proof · AIMA guidance

Investor risk has shifted, too. Property risk is visible and familiar: location, valuation, rental demand, maintenance, taxes, and resale. Fund risk is harder to see and harder to model. It involves a manager's track record, investment strategy, underlying portfolio exposure, valuation policy, redemption rules, gates, side pockets, fund extensions, and whether the fund's investment activity remains compatible with the post-2023 ARI rules over a multiyear holding period that may outlast the underwriting team.

The statute directs the remaining ARI routes away from real estate: the covered investment activities may not be intended directly or indirectly for real-estate investment. It also requires a two-year evaluation of their effects on science, culture, foreign direct investment and job creation. Those design goals do not prove that a particular fund is productive, suitable or likely to deliver a return. Law 56/2023

Portugal's startup economy gives the shift context

AICEP's current 2025 ecosystem page reports 5,091 active startups, growth of about 8% from 2024, approximately EUR 2.85 billion in turnover and around 28,000 workers. It reports a contribution above 1% of Portuguese GDP and says about 75% of startups were founded within the previous five years. These are national ecosystem figures, not evidence about the holdings or returns of any Golden Visa fund. AICEP 2025 data

AICEP, Portugal's trade and investment agency, describes the country's startup ecosystem as rapidly expanding, internationally oriented, and concentrated around technology hubs such as Lisbon, Porto, and Braga. AICEP also highlights ICT, artificial intelligence, fintech, biotechnology, and renewable energy as the sectors driving growth.

Not every Golden Visa fund is a startup fund. Strategies can include private equity, credit, listed securities, operating companies or diversified portfolios. The Movingto funds directory supports side-by-side comparison, but an investor must still verify the current documents and underlying exposure of the specific fund. The legal boundary is direct or indirect real-estate investment; the fund label alone does not establish compliance. Funds directory · Statutory real-estate restriction

'Golden visa eligible' does not mean 'appropriate'

Funds can provide diversification and professional management, but they can also be illiquid, difficult to value and expensive to exit. CMVM authorization or registration is an important regulatory check; it is not an AIMA eligibility opinion, an assessment of investment quality or a guarantee of capital return. Verify regulatory status and ARI eligibility separately. Official fund-information service · AIMA ARI guidance

Eligibility answers one narrow question: whether the investment can support the residency application under current ARI rules. It does not answer whether the investment is fairly priced, whether the manager has a credible record of returning capital, whether the fee stack is reasonable, whether the exit is realistic, or whether the investment makes sense for a U.S. taxpayer, a family office, or an investor who may need liquidity before the fund matures.

Portugal's official fund and asset-management information service directs users to CMVM information. Check the current manager and fund record, then read the constitutive documents, offering terms and reports. Regulatory status is a starting point for due diligence, not a substitute for legal, tax or investment analysis. Gov.pt / CMVM fund information

What investors should actually ask now

For a new application, the useful question is no longer whether a property purchase qualifies. It is whether a chosen non-property route satisfies ARI law and whether the investment is suitable. A qualifying investment must be maintained for at least five years from permit grant, while the fund's commercial term, extensions and redemption rules may create a longer lock-up. Pending pre-October 2023 property cases require their own legal analysis. Maintenance period · Property transition

Before subscribing, ask whether the fund is open- or closed-ended, when redemptions are possible, whether its term can be extended, how net asset value is calculated, who the depositary and auditor are, what every fee covers, and what evidence exists of realized exits. Ask for a documented analysis of direct and indirect real-estate exposure because the statute prohibits both. The ARI opinion should come from independent Portuguese immigration counsel, not only from fund marketing. Direct and indirect restriction

U.S. taxpayers need a fund-specific review before subscribing. PFIC treatment depends on the foreign entity's classification and the statutory income or asset tests; Form 8621 applies when its ownership and filing rules are met. Form 8938 uses separate specified-foreign-asset and threshold rules, while FBAR applies only when there is a reportable foreign financial account and the aggregate account threshold is exceeded. A QEF election requires prescribed information, including an annual information statement from the PFIC or an eligible intermediary, so availability must be confirmed before investment. IRS Form 8621 · IRS Form 8938 · FinCEN FBAR

The bottom line

Treat a Portugal Golden Visa fund subscription as two decisions made in parallel: an investment decision covering manager, strategy, fees, valuation, exit, tax and redemption; and an immigration decision covering current ARI eligibility, family documentation, the maintenance period, renewals and source of funds. Use independent regulated advisers where required, check current AIMA guidance and CMVM information, and do not treat a fund's Golden Visa marketing as proof of either suitability or eligibility. AIMA · CMVM information

This story was produced by Movingto and reviewed and distributed by Stacker.