Portugal Golden Visa funds are Portuguese investment funds that qualify for the €500,000 fund route of the Golden Visa (ARI): you buy at least €500,000 of units in one or more non-real-estate funds set up under Portuguese law, which have a maturity of at least five years when you invest and put at least 60% of their investments into companies with a head office in Portugal. Since property purchases stopped qualifying in October 2023, the fund route is the main option for investors who want a passive investment rather than a donation or running a business.
This guide sets out the rules as AIMA states them (checked October 2026), what the funds charge, how to check one before you subscribe, and the questions US investors need answered. It does not list or rank individual funds. To compare funds side by side, use Movingto Funds.
Movingto is a Portugal-first immigration firm that puts a named, Bar-registered lawyer from its in-house legal team on your case and publishes its fees.
What are Portugal Golden Visa funds?
A Golden Visa fund is a collective investment undertaking (organismo de investimento coletivo) set up under Portuguese law, run by a management company and structured to meet the ARI fund rule. Many are private equity or venture capital funds that invest in Portuguese companies. You buy units in the fund, the manager invests the pooled money, and how and when you get money back depends on the fund's terms: closed-end funds pay out when they are wound down at the end of their term, while some funds allow redemptions on set dates. The value of your units can go down, and no qualifying fund guarantees the return of your €500,000.
The fund route is written into Portugal's immigration law, Lei 23/2007, at article 3(1)(d)(vii); the residence permit itself is granted under article 90-A. Lei 56/2023 (Mais Habitação), in force from 7 October 2023, closed the real-estate and capital-transfer routes to new applicants and limited the fund route to non-real-estate funds. For the full list of routes still open, see the Portugal Golden Visa guide.
What are the official rules for the Golden Visa fund route in 2026?
AIMA, the Portuguese immigration agency, repeats the legal wording of the fund route on its ARI page (checked October 2026). Each rule below comes from that page or from Lei 23/2007 as amended by Lei 56/2023.
| Rule | What the law and AIMA require | What to check in practice |
|---|---|---|
| Minimum amount | A capital transfer of at least €500,000 used to buy fund units | The total can be split across several qualifying funds, as long as it reaches €500,000 |
| Type of fund | Units in non-real-estate collective investment undertakings | Real-estate funds no longer qualify for new applications |
| Governing law | The fund must be constituted under Portuguese law | A fund set up in another country does not qualify, even if it invests in Portugal |
| Maturity | At least five years at the time of the investment | Check the remaining term on the date you subscribe, not the date the fund launched |
| Portuguese companies | At least 60% of the value of the investments made in commercial companies with a head office in Portugal | The management company must confirm this in a declaration for AIMA |
| Source of the money | The amount must come from an international transfer of capital | A bank authorised or registered in Portugal confirms the transfer in writing |
| Holding period | The applicant declares under oath that they will keep the investment for at least five years | Match the fund's term and exit rules to that five-year commitment |
| Low-density discount | None. The 20% reduction in Lei 23/2007 art. 3(2) applies only to the research, cultural and job-creation routes | Any offer of a fund route below €500,000 does not meet the law |
You can invest in your own name or through a Portuguese single-member company (sociedade unipessoal por quotas) that you own. In that case AIMA also asks for the company's commercial registry certificate showing you as the owner.
What documents does AIMA ask for on the fund route?
On top of the general ARI documents, AIMA lists three documents for the fund investment:
- A declaration from a credit institution authorised or registered with Banco de Portugal, confirming that at least the legal minimum was actually transferred.
- A certificate showing that you own the fund units, free of charges and encumbrances, issued by the entity that keeps the register of unitholders.
- A declaration from the fund's management company confirming that the capitalisation plan is viable, that the maturity is at least five years and that at least 60% of the investment goes into companies with a head office in Portugal.
The general documents include a valid passport, proof of legal entry, health cover, a criminal record certificate, tax and social security clearance, the sworn declaration on the five-year investment and the receipt for the analysis fee. AIMA's applied fees are €632.10 for the analysis and €6,314.20 for the first card, so €6,946.30 per person (fee table in force from 1 March 2026). The Portugal Golden Visa cost guide adds legal fees, renewals and family totals.
Is real estate still eligible for the Portugal Golden Visa fund route?
No. Buying property no longer qualifies for a new Golden Visa, and the fund route now requires a non-real-estate fund. A real-estate investment fund cannot be used for a new application. People who already hold a Golden Visa obtained under the earlier rules keep their renewal rights under the transitional rules of Lei 56/2023.
How many people use the Golden Visa fund route?
The fund route grew quickly before the 2023 reform. According to the SEF statistical maps, fund-route permits rose from 7 in 2019 to 352 in January to September 2023. AIMA has not published a split by investment route since September 2023, so no official figure exists for the fund route after that date.
| Year | Fund-route investor permits | Fund investment recorded |
|---|---|---|
| 2019 | 7 | €3.1M |
| 2020 | 48 | €17.3M |
| 2021 | 81 | €28.6M |
| 2022 | 235 | €86.3M |
| 2023 (January to September) | 352 | €125.5M |
For the full series, the other routes and the nationality data, see the Portugal Golden Visa statistics page.
What fees do Portugal Golden Visa investment funds charge?
Fund fees are taken from the fund rather than invoiced to you, so they reduce what you get back. The Golden Visa Fund Fee Index from Movingto Funds records the fees on 32 tracked fund profiles. As of 16 October 2026, the median annual management fee is 1.8% (31 of 32 profiles record one), the median performance fee is 20% (30 of 32) and the median subscription fee is 1.5% (28 of 32).
Look beyond the headline management fee. Ask for redemption fees, custody, depositary and audit costs, other fund expenses, and the hurdle rate and timing of any performance fee, then compare the total cost over the years you expect to hold the units. A fee that a document does not mention is not zero; ask the manager to confirm it in writing. Fund fees are separate from the Golden Visa application costs covered in the cost guide.
How to compare Portugal Golden Visa funds
Check eligibility and regulation first, then compare terms. These are the points to settle before you subscribe:
To compare these points across funds, use the fund comparison on funds.movingto.com, the directory of CMVM-registered fund managers and the data on the Movingto Funds research hub. You can also check registrations directly on the CMVM website.
This guide is not investment advice. Whether a fund suits you is a question for a regulated financial adviser. Movingto's lawyers check whether the investment meets the ARI rules for your application.
Can US citizens invest in Portugal Golden Visa funds?
Yes. US citizens are eligible for the Golden Visa, but each fund decides whether it accepts US persons, so get that confirmation in writing before you commit. A non-US fund may be treated as a PFIC (passive foreign investment company) under US tax law, which can bring Form 8621 reporting. A QEF election is only possible if the fund supplies a PFIC Annual Information Statement each year, so ask whether it does. Separately, if your foreign financial accounts, such as the Portuguese bank account used for the transfer, exceed $10,000 in total at any point in the year, you file an FBAR (FinCEN Form 114).
Movingto's in-house tax counsel advises on Portuguese and cross-border tax; your US CPA files PFIC/Form 8621 and FBAR, and we brief them.
For the questions to put to a fund manager, read why some Portugal Golden Visa funds reject US investors.
How the fund route fits into the Golden Visa application
- Get a Portuguese tax number (NIF) and open a Portuguese bank account.
- Transfer the money from abroad and subscribe to the fund units.
- Collect the bank declaration, the unit ownership certificate and the manager's declaration.
- File the ARI application with AIMA and pay the analysis fee.
- Keep the investment for at least five years and spend at least 7 days in Portugal in the first year and 14 days in each later two-year period.
Expect 12 to 24 months or more from filing to your first residence card (as of mid-2026); AIMA publishes no official average. The Portugal Golden Visa guide covers family members, renewals and the path to citizenship.
How Movingto is paid on the fund route
Movingto's fee for a fund-route Golden Visa is a flat €6,000, published on its pricing page. Movingto may receive a commission from some fund managers. That commission does not change your €6,000 flat fee, and how we get paid explains when it applies and what it cannot influence.