For most applicants in 2026, the investment-fund route is the simplest path to a Portugal Golden Visa. It dominates new applications because the documentation is standardised, the capital deployment is passive, and there is no business to run or project to administer. The cultural-heritage support route — €200,000 in designated low-density areas or €250,000 elsewhere — carries a lower capital threshold, but the qualifying-recipient list is narrow and the contribution is generally not recoverable. The other three routes (job creation, scientific research, company formation with jobs) are open but practically taken by very few applicants.
This guide compares the five routes that remain open under Article 90-A of Lei n.º 23/2007 after the 2023 Mais Habitação reforms removed the real-estate options. Updated 17 May 2026.
Which Portugal Golden Visa route is easiest in 2026?
The answer depends on what you bring to the application — capital, a Portuguese business, or specific institutional ties. For a default applicant with cash but no Portuguese operating presence, the fund route is the path of least resistance. For someone already running a Portuguese business, the job-creation route can be cheaper and faster. For a researcher already collaborating with a Portuguese institution, the scientific research route may be the natural fit.
| Route (Article 90-A sub-clause) | Capital required | Operational burden | Application share since 2023 |
|---|---|---|---|
| Investment fund (vii) | €500,000 in CMVM-regulated, non-real-estate collective investment fund | Low — passive after subscription | Appears to be the dominant route |
| Cultural / artistic-heritage investment or support (vi) | €250,000 (€200,000 in designated low-density territory) | Moderate — depends on the recipient and project sign-off | Material minority |
| Job creation (ii) | No minimum capital. 10 jobs general; 8 jobs in designated low-density territory | High — actual business operations | Small share |
| Scientific research (v) | €500,000 (€400,000 in designated low-density territory) to a qualifying research institution | Moderate — narrower eligibility, additional sign-off | Rarely used |
| Company formation with jobs (viii) | €500,000 plus creation of at least 5 permanent jobs | High — combines deployment, hiring, and ongoing operations | Rarely used |
The 20% reduced thresholds apply only to the cultural, research, and job-creation routes (sub-clauses vi, v, and ii of Article 90-A) when the activity is sited in a designated low-density territory as defined in Article 65-A of Decreto Regulamentar n.º 84/2007 (consolidated). The fund route (vii) and the company-formation route (viii) do not have a low-density discount.
Real-estate purchase and real-estate-fund investment were removed from Article 90-A by Lei n.º 56/2023 (Mais Habitação) on 6 October 2023. Pre-existing real-estate applications continue under the prior rules; any new application has to use one of the five routes above.
What does "easy" actually mean for an ARI application?
"Easy" is doing a lot of work in this question, because it can mean four different things to four different applicants. The five Article 90-A routes don't all optimise for the same one:
- Documentation burden. The fund route benefits from a standardised AIMA evidence pack: subscription confirmation, CMVM authorisation of the fund, source-of-funds documentation, manager information. Job creation requires employment contracts, payroll evidence, and social security registrations for each of the 10 (or 8) jobs.
- Operational involvement. Once you have wired your subscription to a fund, the day-to-day work is the fund manager's, not yours. The job-creation and company-formation routes require you to run a business in Portugal — hiring, payroll, regulatory compliance, the lot.
- Approval predictability. Fund-route applications have years of precedent. AIMA reviewers know what the evidence pack looks like. The rarer routes (scientific research, company setup) have less precedent and therefore more discretionary judgement in any single decision.
- Capital outcome. The fund-route contribution is held by a regulated vehicle and may be returned at fund maturity, subject to the fund's actual performance, fees, liquidity terms, and the specific fund agreement. The cultural and scientific-research contributions are not recoverable. The job-creation route has no upfront capital threshold but the underlying business carries normal commercial risk.
If you weight all four dimensions equally, the fund route wins on three of the four for an applicant without an existing Portuguese footprint. That is why it has come to dominate the post-2023 application mix.
How the fund route actually works
The fund-route process has six recognisable steps and is the most templated of the five:
- Obtain a Portuguese tax number (NIF) and open a Portuguese bank account. Allow four to eight weeks for both, longer if your jurisdiction adds AML friction.
- Select a CMVM-regulated, Golden-Visa-eligible fund. Movingto maintains a live fund directory with fees, redemption mechanics, manager track record, and verification status.
- Transfer the qualifying subscription (€500,000 at minimum) to the fund manager. The subscription confirmation becomes a central piece of evidence in the AIMA file.
- File the pre-application through Portal ARI. A Portuguese law firm assembles documents and submits — passport, current criminal record, address proof, source-of-funds documentation, health insurance valid in Portugal.
- Attend biometrics at AIMA when called. The concessão (initial approval) fee is paid at the appointment by card. The current AIMA fee table sets this at €8,060.20 per adult, with the application-processing (receção e análise) fee at €806.80 — both set under Portaria n.º 307/2023 and indexed annually each March. Always confirm the day-of figure with your law firm against the current AIMA fee table.
- Receive the residence card. Renew at year two and year four. At year five, apply for permanent residence or — if still eligible — for citizenship.
The reason this is the "easiest" route is not that it is intellectually simple. It is that almost every part of it has been done thousands of times, by thousands of applicants, in front of AIMA reviewers who recognise the pattern. For the full fee picture across the programme see our Portugal Golden Visa cost guide.
When the cultural-heritage route is the better fit
Article 90-A, sub-clause vi describes the route as an "investment or support" for artistic production or the recovery and maintenance of national cultural heritage. In practice it is most often described as a donation, because most qualifying contributions are made without expectation of return. The legal wording is broader than donation, and a small number of applicants have structured the contribution as a more formal support arrangement.
The route is structurally simpler than the fund route in two ways: lower upfront capital (€200,000 in designated low-density territory or €250,000 elsewhere) and no fund-selection diligence to do. It is harder in three others:
- The recipient has to be a qualifying entity in the cultural sector — typically a public-sector body, a public foundation, a private foundation with public utility status, an inter-municipal entity, a public cultural association, or similar — with attributions in artistic production or cultural-heritage recovery and maintenance. Private cultural ventures generally do not qualify.
- The contribution and the project usually require sign-off from the relevant cultural authority, which can add meaningful time to the front of the application timeline. Plan for additional weeks at minimum and, in some cases, longer.
- The contribution is not recoverable. Compared to a €500,000 fund subscription that may return principal at maturity, the cultural route's true 5-year cost is closer to the headline number.
The cultural route makes sense if (a) the lower capital threshold matters and you are comfortable treating the contribution as a programme cost rather than an investment, or (b) you have a specific cause in the qualifying universe that you would have considered supporting anyway.
When the job-creation route is the better fit
The job-creation route is the only one of the five with no minimum capital threshold. It requires creating and maintaining at least 10 full-time jobs in a Portuguese business owned (directly or indirectly) by the applicant, with the threshold reduced to 8 jobs if the business is sited in a designated low-density territory. The jobs must be sustained for the duration of the residence permit, not just at the moment of application.
For a founder who is already operating a Portuguese subsidiary that employs the threshold number of people, this route is essentially free. The same person filing a fund-route application would be parking €500,000 in a vehicle they did not otherwise need. For a person with no Portuguese business yet, the route is the hardest of the five — you have to set the company up, hire and pay the staff, satisfy Portuguese employment law, and document everything for AIMA on top of the visa process.
The route serves a real but small population. The majority of applicants taking it are existing business operators rather than people setting up a business expressly for the Golden Visa.
Why scientific research and company formation are rarely used
Both routes are technically open and neither is unusable, but together they account for a very small share of the post-2023 application mix.
The scientific research route requires a €500,000 contribution (reduced to €400,000 in designated low-density territory) to a qualifying research institution within Portugal's national scientific and technological system. The receiving institution and the research project itself typically need additional sign-off from the relevant scientific authority. The route is most natural for an applicant who already has a working relationship with a Portuguese research body; for most others it adds complexity that the fund route does not have.
The company-formation route combines all the difficulties at once: €500,000 in capital deployment, the creation of at least five permanent jobs, and the ongoing operational burden of a Portuguese commercial company. It exists for a serial founder who would have built a Portuguese company in any case and wants the ARI as a by-product, but for almost any other applicant it is a heavier path than the alternatives.
Common applicant profiles and the route that usually fits
Four sketches that cover most of the inbound profiles we see, with the caveat that the right answer depends on facts a guide cannot see — your tax residence, family configuration, source-of-funds picture, and target outcome.
The default investor: cash, no Portuguese footprint
Someone with €500,000 or more in liquid capital, no Portuguese business, no Portuguese property, no existing ties — this is the default applicant profile and the one the fund route is built for. The subscription goes into a regulated vehicle, the legal team assembles the AIMA file, the residence card arrives in due course. Most applicants we work with fall in this bucket.
The capital-constrained applicant: €250K available, willing to contribute
Someone who can deploy a quarter-million but not half a million, and is comfortable treating the contribution as a sunk programme cost rather than an investment. The cultural-heritage support route at €250,000 (or €200,000 in designated low-density territory) is the only one that matches the budget without compromise.
The Portuguese operating founder
Someone already running a Portuguese subsidiary that employs the qualifying number of people. The job-creation route turns an existing operational reality into an ARI qualification without new capital. The fund route would mean parking €500,000 they do not need to deploy.
The crypto-rich, income-light investor
Someone with significant crypto holdings but no active monthly income that would clear a D7 or D8 income test. The fund route is the natural choice — liquidate the required tranche into euros, subscribe to a qualifying CMVM fund, start the residence clock. The D8 visa would fail at the income-evidence stage because holdings do not count as monthly income. See our D8 vs Golden Visa comparison.
A fifth common case is the applicant who is optimising hard for low cost and does not actually need the optionality the Golden Visa provides. For that person the D7 (passive income) or D8 (remote work) visa is usually a better product than any Article 90-A route. See our Portugal visa types overview.
What the May 2026 nationality-law change means for route choice
On 3 May 2026, the President of the Republic promulgated Decreto da Assembleia da República n.º 48/XVII, which amends Lei n.º 37/81 (the Portuguese Nationality Law). The amendment would extend the minimum legal residence period for naturalisation from five to ten years for most applicants. The diploma had to be globally revised to overcome the constitutional issues identified by the Constitutional Court in Acórdão n.º 1133/2025; the revised text is what the President signed.
The change is not yet in legal effect. Promulgation is one step; entry into force depends on publication in Diário da República, the entry-into-force language in the diploma itself, and any transitional rules. As of this update, the consolidated Nationality Law on Diário da República still shows its latest alteration as 2024-03-05, with no May 2026 amendment incorporated yet. The President separately noted publicly the importance of protecting pending applications from being affected by the change and of ensuring that delays caused by the State do not count against citizenship timelines — but that is a presidential note, not a binding transitional rule. The actual treatment of in-flight applications will be set by the published text and any implementing regulation.
If the longer clock takes effect for new applicants, it does change the calculus between routes — but at the margin rather than the principle:
- Closed-ended fund subscriptions (typical fund life six to ten years) may mature inside the new ten-year residence clock, which forces a reinvestment decision mid-programme. Open-ended fund subscriptions avoid that mechanical problem. See the open-ended vs closed-ended fund guide on funds.movingto.com.
- The cultural-heritage contribution is one-time, so a longer residence clock does not create new contribution obligations.
- The job-creation route becomes substantially heavier — maintaining the qualifying job count for ten years is a different commitment from maintaining it for five.
Until the published text of the diploma is in force, the current five-year clock continues to apply as the law on the books.
Frequently asked questions
What is the easiest Portugal Golden Visa route in 2026?
For an applicant with capital but no Portuguese operating presence, the investment-fund route under Article 90-A sub-clause (vii) is the path of least resistance. Documentation is standardised, capital deployment is passive, and the route has the largest precedent base with AIMA. It appears to be the dominant route in the post-2023 application mix.
What is the cheapest Portugal Golden Visa route in 2026?
The cultural-heritage support route at €250,000, or €200,000 in designated low-density territory. The contribution is generally not recoverable, so the true 5-year programme cost is closer to the headline number than the fund route's nominal €500,000 — which may return principal at maturity. Cheapest in cash outlay; not necessarily cheapest in total non-recoverable cost.
How many Portugal Golden Visa investment routes are open in 2026?
Five: investment fund (€500,000), cultural / artistic-heritage investment or support (€250,000, reduced to €200,000 in low-density territory), job creation (10 jobs general or 8 in low-density territory, no capital minimum), scientific research (€500,000, reduced to €400,000 in low-density territory), and company formation with five permanent jobs (€500,000). Real-estate purchase and real-estate-fund subscription were removed in October 2023 under Mais Habitação.
Why is the investment fund route the most popular Portugal Golden Visa option?
Three structural reasons: standardised AIMA documentation pattern that reviewers recognise from thousands of prior approvals, passive operational profile after subscription, and capital that may be returned at fund maturity subject to the fund's actual performance and terms. It is the only route that combines a recoverable-capital structure with low day-to-day involvement.
Is the Portugal Golden Visa real-estate route still available?
No. Real-estate purchase and real-estate-fund subscription were removed from Article 90-A by Lei n.º 56/2023 (Mais Habitação) on 6 October 2023. Applications submitted under the prior rules continue under those rules; any new application must use one of the five routes that remain open.
How much are the AIMA fees for the fund-route Golden Visa?
The current AIMA fee table sets the receção e análise (application-processing) fee at €806.80 per applicant and the concessão (initial approval) fee at €8,060.20 per adult, both indexed annually each March under Portaria n.º 307/2023. Always confirm the day-of figure against the current AIMA fee table or with your law firm.
How long does the fund-route Golden Visa take in 2026?
Setting up NIF and Portuguese bank account: four to eight weeks. Fund subscription: 30 to 60 days from set-up. Pre-application: weeks. AIMA biometrics: typically two to nine months from pre-registration, though queue times vary materially. Card issuance: shortly after biometrics. Total: typically nine to eighteen months from start to residence card in hand. Cultural route adds time at the front of the process for cultural-authority sign-off.
Can I switch Golden Visa routes after starting an application?
Mechanically it is possible, but it usually means re-filing under the new route with new documentation. Pick the right route at the outset where possible. Where circumstances change materially mid-process, the law firm handling the file is the right party to advise on whether a switch makes sense.
Does the easiest route lead to citizenship faster?
No. All five routes accumulate residence years on the same clock, and the citizenship eligibility timeline (currently five years under Lei n.º 37/81 in force, with the May 2026 amendment extending this to ten years subject to entry-into-force and transitional rules) applies the same way regardless of which route the residence was acquired through. The route only affects how you qualify for residence in the first place.
What is the easiest Portugal residency option overall — Golden Visa or a different visa?
Depends on the applicant's profile. For an investor with €500,000+ in capital who does not want to relocate, the fund-route Golden Visa is the cleanest match. For someone earning at least €3,680 per month from remote work outside Portugal and willing to relocate, the D8 visa is materially cheaper (~€600 in government fees against €8,867 for the Golden Visa per adult under the current AIMA fee table). For someone with passive income at the D7 threshold (around €870 per month for the main applicant, with uplifts for family), the D7 is the natural fit.
What documents are needed for the fund-route Golden Visa?
The standard package: passport, recent criminal record (apostilled), proof of address, source-of-funds documentation, fund subscription confirmation, CMVM authorisation of the fund, Portuguese tax number (NIF), Portuguese bank account, and health insurance valid in Portugal. The law firm handles assembly and submission. Total document count is typically 15 to 25 items depending on the applicant's jurisdiction of origin.
If you want a route-fit assessment for your specific situation, book a Movingto Golden Visa consultation. We model the trade-offs against your capital position, family composition, and target outcome before any work begins.
Sources
- AIMA — Autorização de Residência para Investimento (Art. 90.º-A) — the five remaining routes, presence requirements, family reunification
- AIMA — Tabela de Taxas (current fee table PDF) — €806.80 análise / €8,060.20 concessão (ARI line)
- Diário da República — Lei n.º 56/2023 (Mais Habitação) — removal of the real-estate routes from Article 90-A
- Diário da República — Portaria n.º 307/2023 — underlying AIMA fee structure and annual indexation rule
- Presidência da República — Promulgação do Decreto 48/XVII — 3 May 2026 promulgation
- Diário da República — consolidated Lei n.º 37/81 (Nationality Law) — currently shows latest alteration as 2024-03-05
- Diário da República — consolidated Decreto Regulamentar n.º 84/2007 — Article 65-A low-density-territory thresholds for cultural, research, and job-creation routes
- Lei n.º 23/2007 de 4 de julho (REPSAE) — Article 90-A statutory framework
Last verified: 17 May 2026.
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