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The Portugal Citizenship pathway is being extended from 5 years to 10 years – and this has triggered a large influx of new applicants for the Portugal residency program through investment (also known as the ‘Golden Visa’). All new applicants plan to lock-in their eligibility for the 5 years citizenship pathway, and not the 10 year – although it’s disputed it is unconstitutional in Portugal to apply regulations retroactively.
In today’s article we will cover the type of funds that are possible to invest and qualify for the Golden Visa and their realistic performance structures, risk profiles, and due diligence process. As well as the alternative investment options such as digital asset funds. We’ll talk about the commissions that are being paid by these funds….Yes you read correctly…..commissions! And how these commissions can help to offset most of your legal costs paid out by these Portuguese investment funds. As well we will cover hidden secrets on how to file a law-suit against the Portugal government to speed up your application processing when they have delayed processing your case which may lead you to be stuck for +2 years in their backlog.
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There is no specific list of Portuguese investment funds approved for the Golden Visa. Any investment funds which are approved by the CMVM (the Portuguese Securities Market Commission) and meet the qualifications of the Golden Visa program can become a financial investment vehicle for applicants to apply for their residency in Portugal. When they are registered with the CMVM, it means they are fully regulated under Portuguese laws. At least 60% of the fund’s portfolio must be invested in companies headquartered or operational in Portugal. The fund must not invest in directly or indirectly in real estate (this became a new regulation at the end of 2023 when the real estate option was removed from the Golden Visa program).
There are typically two types of fund options available currently for Portugal Golden Visa investors. Venture capital funds which are open-ended, and private equity funds which are close-ended. Typically, the latter will lock the investor in for 7-10 years with higher return expectations as there is less liquidity, higher risk investments, etc.
For the open-ended funds, they can have either a shorter lock-in period with early redemption admin fees applied. Several of the registered funds do allow daily or monthly liquidity windows to allow investors to exit the fund in case they either decide to give up their residency or have converted at that time to a Portuguese PR status or Citizenship.
Some of the funs offer annual returns forecasted at 3-5%, and some of the private equity funds with longer lock-in periods offer reinvestment in the fund, with potential payouts which are not on a regular frequency (under specific conditions). Typically the private equity funds require a higher risk profile for investors, and the venture capital funds expect a lower risk profile.
There are several Golden Visa investment funds which have an allocation of their portfolio for crypto currencies (can be anywhere from 15-25% of the entire fund allocation) for investors who have an appetite for digital assets investment options. These funds, although not as common, are becoming more and more popular, with more Portugal investment funds exploring options to diversify their portfolio into the digital asset space.
It is possible as a Portugal Golden Visa applicant to invest in multiple registered Portuese funds which qualify under the program. It is not mandatory to invest in only one fund, but it is possible to invest in multiple registered funds approved for the Golden Visa in Portugal. The advantage of this approach is that an investor can choose to invest partially in a private equity fund for higher potential returns, but longer timelines, but yet allocate more funds to open-ended funds with short-term liquidity windows and smaller but regular returns. This will provide the investor a better diversification of their investment. However the downside can be the additional paperwork required for the KYC and investment certificate that each fund needs to provide for the immigration step. The most challenging part would be if one of the funds can accept direct investment without a Portuguese bank account for the applicant, but the other funds would not have an international bank account to accept direct investment, hence forcing the applicant to open a local bank account in Portugal (which can be painstakingly slow).
All Golden Visa investment funds have a KYC and onboarding process:
You need to have a NIF (Portuguese Tax Identification number) which we, your legal representatives would receive within 24 hours after you sign up with our office and send us your Power of Attorney to represent you with the Tax authorities and immigration department in Portugal
You complete the KYC forms for the investment fund(s) you select (they can be from 15-20 questions to over 100 depending on which fund you select. Some of the publicly traded funds have a lot of questions). But we streamline them ALL for you in one shot so you don’t have to fill out 3-4 different KYC forms.
After the KYC is completed you will either make the investment directly from your current country where the funds are located OR open a Portuguese bank account remotely to make the payment to your account BEFORE flowing through to the investment fund in Portugal.
Not all nationalities and countries can invest directly in the fund – typically from USA, Canada and UK this is allowed but other countries this may be considered higher risk – which means you cannot skip the step of investing directly without a bank account in Portugal
In order to open the bank account in Portugal, one of the selected banks that we refer you to has to onboard you with their KYC. The entire process can take anywhere from 3 weeks to 12 weeks depending on WHICH bank you are referred to and your nationality and/or current country of residents. If you are from the Middle-East or Asia the KYC processing time is exceptionally high. However, we can assist you with this process and we have a wide enough bank network to refer you to the right institution to make this less painless for you and your family
After the Bank account is opened and the investment of €500,000 is made in full, the final certificate of investment is issued by the investment funds called the ‘ARI’. With this certificate you can then complete and submit your immigration application (assuming all the immigration supporting documents have been translated and apostilled). You will of course receive a detailed checklist from our office for your specific country and nationality, and this will ALL happen while you onboard with the investment fund and/or the bank – saving you time.
Voila ! You have completed the most difficult part of the whole process – i.e. the multiple financial KYC’s (Know Your Customer) required for the Portugal Golden Visa application process.
As per the Portuguese regulations, the government has to acknowledge the your application being received into their system within 10 days after submission. This never happens – due to the backlog in Portugal’s immigration system. Hence, this opens up the government for a lawsuit. This lawsuit does not create a bias or negatively affect your application. We recommend to apply around the 6 month mark after you have submitted your immigration application (which is after the KYC, and full €500,000 investment into the Golden Visa funds). Our legal team represents and handles these lawsuits for our Golden Visa clients. When we file this law suit on your behalf, your case can actually take the 12-14 months to be processed, which means you save at least +1 year in processing time. The lawsuit costs approx.. EUR 3,500 per application (family) and a small court fee approx. €306 for claims up to € 5000 – in case you lose the case.
Did you just apply for your Portugal Golden Visa and are stuck in the backlog for processing? Your representative did not advise you on the lawsuit option to fast-track your application with the Portugal government? You’re losing time, and we all know time = money.
The best kept secret in Portugal’s Golden Visa is that ALL the investment funds which qualify the applicant for the residency program pay commissions to the referral partners. This commission typically ranges 4-5% , with some funds paying in milestones (not all in one shot). Of course there are funds that also pay 10% commission, but those are the exception. What this means to you as the applicant? €20,000 to €25,000 is paid by the Portuguese investment funds as commission. Imagine you could use some of these funds to offset your legal and government fees. Wouldn’t that be great? This is what we can offer to our B2C and B2B applicants:
For our B2C clients, we can offer you a 50/50 split of the entire commission in order to offset/refund most of your legal fees for the immigration aspect of the Portugal Golden Visa. Typically, if you are a family of 2-3, this can offset 100% of the legal fees, although not all the government fees
For our B2B partners, you would receive 80% of the commission back as a our referral partner and can decide what to do with those funds.
Keep in mind, the Portuguese golden visa funds WILL not pay or OFFER or even mention to you a commission as a direct applicant for the program – you would need to be ‘referred’ by an approved and vetted B2B partner or legal firm. This is what our role is, we support your entire application from KYC, onboarding, offering you over +20 investment funds in Portugal to select from, and report to you the commissions they offer. We help you with the immigration preparation and the application process to the AIMA ( Agency for Integration, Migration and Asylum (AIMA) ) - i.e. the Portugal immigration department).
Do you want to access our full list of Portugal Golden Visa investment funds and their potential ROI’s, open-ended or closed structures, their track record, assets under management, and the commissions they offer us? Complete our short 60-second intake form here as a B2C applicant or B2B partner, from anywhere in the world, and our office will reach out to you and you can receive the FULL list of these vetted funds. See for yourself what ALL your options are in one master document!
Consider us as your partner in the whole process, not just a service provider. We can connect and provide you with the right tax advisors in Portugal, real estate developers and service providers, funds, legal work and much more.
The window for the most attractive programs is narrowing. Portugal's potential changes, Panama's growing popularity potentially leading to quota systems, and Uruguay's emerging recognition as a privacy haven suggest that early action provides maximum advantage.
Ready to secure your family's global future? Here's how we can help:
📞 Schedule Your Free Strategy Consultation Contact our citizenship planning specialists for a confidential assessment of your options: Message us on WhatsaApp and Answer a few questions to schedule a call to contact our office.
🎯 Request Your Customized Citizenship Roadmap Receive a personalized analysis comparing all viable options based on your:
• Timeline requirements
• Customized immigration checklist
• Consolidated KYC
• Rebate to offset some of your legal fees
• Comparison to +20 approved Portugal Golden Visa funds
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This analysis is based on current regulations as of August 2025. Immigration laws change frequently, and individual circumstances vary. Professional legal and tax advice is recommended but not mandatory for all international mobility planning.
