01
€500,000 or more
The investment is a capital transfer used to acquire units in one or more qualifying collective investment undertakings. There is no 20% low-density reduction for this route.
Portugal · ARI fund route · 2026 guide
Portugal Golden Visa investment funds
The fund route starts with a €500,000 investment, but legal eligibility is only the first test. The harder questions are what the fund owns, what it charges, when you can exit, and whether the investment works for your tax position.
- Minimum investment
- €500,000
- Fund test
- Non-real-estate OIC
- Minimum stay
- 7 days, then 14 per 2 years
- Planning range to first card
- 12–24+ months
Bottom line
A qualifying fund can support Portuguese residence with a low physical-presence requirement. It is still a long-term, illiquid investment whose value can fall. CMVM regulatory status does not amount to AIMA approval, and immigration eligibility does not make a fund suitable for you.
01 · Eligibility
The four-part legal test
Lei 56/2023 defines the current fund route. Its wording matters more than a sales deck or an informal “Golden Visa eligible” label.
02
Portuguese, non-real-estate structure
The vehicle must be a non-real-estate collective investment undertaking constituted under Portuguese law. Direct or indirect property exposure can undermine eligibility.
03
At least five years' maturity
The fund's maturity must be at least five years at the time you invest. That statutory floor does not guarantee you can redeem after five years.
04
At least 60% invested in Portugal
At least 60% of the fund's investments must be made in commercial companies with their head office in Portugal.
The old passive capital-transfer route stood at €1.5 million when it was closed to new applications in 2023, rather than €1 million. Property acquisition also stopped qualifying for new applications. Read the current wording in Lei 56/2023 and the prior threshold in Decree-Law 14/2021.
CMVM status is not an immigration approval
Use the official funds and asset-management information service to check the vehicle, its management company and the documents or data made public. Then have counsel test the signed fund regulation, subscription agreement and route declarations against the ARI law.
These checks answer different questions. CMVM information confirms the regulatory position; the immigration analysis asks whether your exact investment and evidence satisfy Article 90-A. Neither answers whether the expected return justifies the risk.
02 · Profile comparison
Compare Portugal Golden Visa fund profiles
AIMA does not publish a list of “approved” funds. This non-ranked explorer compares public profiles marked open and intended for the Golden Visa route in the source dataset. Use it to find disclosure gaps and questions—not to determine ARI eligibility, investment quality or suitability.
Profile data source: funds.movingto.com public fund profiles. GVL publishes a release-dated snapshot and preserves missing or conflicting source fields rather than filling them in.
Public profile dataset
Profiles marked open
30
Current review date
6/30
Median headline management fee
1.8%
29 disclosed profiles
Profiles with conflicts
5
Calculated only from the 30 profiles in this release—not the entire Portuguese fund market. The fee median is unweighted and uses heterogeneous source-profile figures; it is not normalized for share class, fee base, VAT, hurdle, calculation method or source date. 6 profiles have all five route-comparison fields recorded without a conflict; 9 report accepting US persons. Neither measure is a recommendation or eligibility conclusion.
Review-date coverage: 6 within 90 days, 15 due and 9 not dated. “Open” is the source status at extraction, not a claim that subscriptions remain available today.
Showing 30 of 30 · committed dataset extracted 11 Aug 2026
Choose up to three profiles for a side-by-side view. At three, clear a selection before choosing another. Scroll horizontally to see route fields, US-person status and review dates.
| Compare | Fund and manager | Strategy and fund minimum | Headline fees | Term and liquidity | Route fields | US persons | Data review |
|---|---|---|---|---|---|---|---|
| 3CC Atlantic Bond Fund3 Comma CapitalCMVM 182126 | CreditFund subscription minimum €100,000 | Subscribe: 1.5%Manage: 1.5%Performance: 10% | Not disclosedRedemption: Daily | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Fund-reported yes | Current review date1 Jul 20262 source documents | |
| 3CC Portugal Golden Income Fund3 Comma CapitalCMVM 2108 | OtherFund subscription minimum €100,000 | Subscribe: 1.5%Manage: 1.2%Performance: 20% | Not disclosedRedemption: Daily | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Fund-reported yes | Current review date1 Jul 20263 source documents | |
| Alpha FundActiveCap - Capital PartnersCMVM 2181 | Private EquityFund subscription minimum €100,000 | Subscribe: 2%Manage: 2%Performance: 20% | 10 yearsRedemption: Not Available | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Fund-reported yes | Review due17 Apr 20260 source documents | |
| Capital Green III – Fundo Fechado de CréditoFinprop Capital, SGOIC, SACMVM 2347 | CreditFund subscription minimum €200,000 | Subscribe: Not disclosedManage: Not disclosedPerformance: Not disclosed | 5 yearsRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | Current review date29 May 20260 source documents | |
| Corporate Bond FundActiveCap - Capital PartnersCMVM 2273 | CreditFund subscription minimum €100,000 | Subscribe: 1.5%Manage: 1.5%Performance: 0% | Source conflict: lock-up 0 months recorded vs minimum holding 1 monthRedemption: Weekly | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Fund-reported yes | Current review date13 Jul 20260 source documents | |
| Explorer VExplorer InvestmentsCMVM 2199 | Private EquityFund subscription minimum €250,000 | Subscribe: Not disclosedManage: 2%Performance: 20% | 10 yearsRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | No review dateNo review date0 source documents | |
| Flex Space FundInsula Capital SGOICCMVM 2103 | Private EquityFund subscription minimum €100,000 | Subscribe: 0%Manage: 1.5%Performance: 20% | 8 yearsRedemption: not recorded | 5/5 disclosed4 pass · 0 missing1 conflict | Not confirmed | Review due1 Dec 20251 source document | |
| Fortitude Portugal Special Situations II – Fundo de Capital de Risco FechadoFortitude CapitalCMVM 2257 | Private EquityFund subscription minimum €100,000 | Subscribe: 5%Manage: 2%Performance: 20% | 4 yearsRedemption: End of Term | 5/5 disclosed3 pass · 0 missing2 conflicts | Not confirmed | Review due4 Dec 20253 source documents | |
| Greenpower FundBiz Capital SGOICCMVM 1530 | Private EquityFund subscription minimum €100,000 | Subscribe: Not disclosedManage: 2%Performance: 0% | 68 monthsRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | No review dateNo review date0 source documents | |
| Greytech III FundIberis CapitalCMVM 2267 | Private EquityFund subscription minimum €100,000 | Subscribe: Not disclosedManage: 1.75%Performance: 22.5% | 10 yearsRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | Review due6 Apr 20260 source documents | |
| Growth Blue FundGrowth Partners Capital, S.A. | Private EquityFund subscription minimum €50,000 | Subscribe: 0%Manage: 2%Performance: 20% | 10 yearsRedemption: not recorded | 3/5 disclosed3 pass · 2 missingNo recorded conflict | Not confirmed | Review due6 Dec 20250 source documents | |
| Heed Top Investment FundHeed CapitalCMVM 115 | DebtFund subscription minimum €100,000 | Subscribe: 2%Manage: 1.5%Performance: 20% | Not disclosedRedemption: Daily | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Not confirmed | Review due7 Dec 20255 source documents | |
| Horizon FundOctanova SCRCMVM 2122 | CryptoFund subscription minimum €100,000 | Subscribe: 2%Manage: 2%Performance: 20% | 5 yearsRedemption: Monthly | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Fund-reported yes | Review due11 May 20260 source documents | |
| IMGA Ações Portugal FundIM Gestão de Ativos (IMGA)CMVM 184 | OtherFund subscription minimum €500 | Subscribe: 0%Manage: 2.175%Performance: 0% | Not disclosedRedemption: Daily | 2/5 disclosed2 pass · 3 missingNo recorded conflict | Not confirmed | Review due7 Dec 20255 source documents | |
| IMGA Futurum Tech FundIM Gestão de Ativos (IMGA)CMVM 2041 | Venture CapitalFund subscription minimum €500,000 | Subscribe: 0%Manage: 2%Performance: 0% | 8 yearsRedemption: not recorded | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Not confirmed | No review dateNo review date2 source documents | |
| IMGA GV Portuguese Corporate DebtIM Gestão de Ativos (IMGA)CMVM 2346 | DebtFund subscription minimum €100,000 | Subscribe: 1.75%Manage: 1.7%Performance: 0% | Not disclosedRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | Review due11 May 20260 source documents | |
| IMGA GV Portuguese EquitiesIM Gestão de Ativos (IMGA)CMVM 2345 | OtherFund subscription minimum €100,000 | Subscribe: 2.5%Manage: 1.95%Performance: 0% | Not disclosedRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | Review due11 May 20260 source documents | |
| IMGA Portuguese Corporate Debt FundIM Gestão de Ativos (IMGA)CMVM 1985 | DebtFund subscription minimum €500,000 | Subscribe: 1.75%Manage: 1.7%Performance: 0% | 5 yearsRedemption: Daily | 3/5 disclosed3 pass · 2 missingNo recorded conflict | Not confirmed | Review due7 Dec 20257 source documents | |
| IMGA Silver Domus FundIM Gestão de Ativos (IMGA)CMVM 2275 | Venture CapitalFund subscription minimum €50,000 | Subscribe: 0%Manage: 1.5%Performance: 0% | Not disclosedRedemption: not recorded | 3/5 disclosed3 pass · 2 missingNo recorded conflict | Not confirmed | No review dateNo review date2 source documents | |
| INZ FundSTAG Fund Management | Private EquityFund subscription minimum €150,000 | Subscribe: 1%Manage: 1.6%Performance: 15% | Source conflict: lock-up 8 years vs minimum holding 5 yearsRedemption: End of Term | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Not confirmed | Review due7 Dec 20250 source documents | |
| LXL VenturesLXL VenturesCMVM 2330 | Venture CapitalFund subscription minimum €250,000 | Subscribe: Not disclosedManage: 2%Performance: Not disclosed | 6 yearsRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | No review dateNo review date0 source documents | |
| Mercúrio Fund II, FCROxy CapitalCMVM 1851 | Private EquityFund subscription minimum €100,000 | Subscribe: 2%Manage: 2%Performance: 20% | 8 yearsRedemption: End of Term | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Not confirmed | Review due12 Dec 20250 source documents | |
| New Frontiers Energy Fund IINew Frontiers Energy FundCMVM 2358 | Private EquityFund subscription minimum €100,000 | Subscribe: 1.25%Manage: 1.5%Performance: 25% | 7 yearsRedemption: End of Term | 3/5 disclosed3 pass · 2 missingNo recorded conflict | Fund-reported yes | Current review date10 Jun 20261 source document | |
| Optimize Portugal Golden Opportunities FundOptimize Investment PartnersCMVM 1093 | OtherFund subscription minimum €500,000 | Subscribe: 1%Manage: 1.8%Performance: 0% | 0 months recordedRedemption: Daily | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Not confirmed | Review due12 Dec 20255 source documents | |
| PEEIF III - Portuguese Energy Efficiency Investment Fund IIIQuadrantis CapitalCMVM 2227 | Clean EnergyFund subscription minimum €100,000 | Subscribe: 0%Manage: 2.5%Performance: 30% | Source conflict: lock-up 10 years vs minimum holding 5 yearsRedemption: Quarterly | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Fund-reported yes | No review dateNo review date0 source documents | |
| Pela Terra II Regenerate FundSTAG Fund ManagementCMVM 1816 | Private EquityFund subscription minimum €500,000 | Subscribe: 2%Manage: 2%Performance: 20% | 8 yearsRedemption: End of Term | 4/5 disclosed4 pass · 1 missingNo recorded conflict | Not confirmed | Review due12 Dec 20250 source documents | |
| Portugal Investment 1Saratoga CapitalCMVM 12445 | Private EquityFund subscription minimum €150,000 | Subscribe: 0%Manage: 1.5%Performance: 20% | 6 yearsRedemption: Annually | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Fund-reported yes | Current review date4 Jun 20260 source documents | |
| QUADRANTIS PRIVATE EQUITY IIQuadrantis CapitalCMVM 2222 | Private EquityFund subscription minimum €100,000 | Subscribe: 0%Manage: 1.5%Performance: 20% | 10 yearsRedemption: Quarterly | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Fund-reported yes | No review dateNo review date0 source documents | |
| RYSE Golden Opportunities FundRYSE Asset ManagementCMVM 2434 | Venture CapitalFund subscription minimum €100,000 | Subscribe: Not disclosedManage: 0.5%Performance: 20% | 8 yearsRedemption: not recorded | 1/5 disclosed1 pass · 4 missingNo recorded conflict | Not confirmed | No review dateNo review date0 source documents | |
| Ventures.eu Fund IVentures.EU, SCR, SACMVM 2085 | Venture CapitalFund subscription minimum €150,000 | Subscribe: 1%Manage: 2%Performance: 20% | 8 yearsRedemption: not recorded | 5/5 disclosed5 pass · 0 missingNo recorded conflict | Not confirmed | No review dateNo review date1 source document |
How this profile comparison is built
- Inclusion: GVL does not independently select the rows. A profile appears only when Movingto marks it public, open and intended for the Golden Visa route. A missing profile can reflect Movingto's coverage, not absence from the market. This is not an official AIMA list.
- Ordering: alphabetical by default. Search, filters and user-selected sorts change the view; GVL does not assign ranks.
- Evidence: “disclosed” includes every populated source field, including a conflict. “Pass” means the populated value did not trigger this narrow threshold check. “Conflict” means it appears inconsistent with the stated route threshold and requires document-level investigation. None confirms legal eligibility.
- Missing data: blanks remain “not disclosed” or “not recorded.” GVL does not infer a favourable answer.
- Validation: this release selects named public database fields and validates text length, numeric ranges, dates and document URLs before publishing. Lock-up and minimum-holding fields are reconciled only when they agree or one is absent; mismatches remain visible as source conflicts. GVL does not independently verify each field against source documents.
- Fund minimum: the displayed amount is the profile's fund subscription minimum. It does not reduce the €500,000 statutory route requirement, which may be invested in one or more qualifying vehicles.
- Freshness: the dataset is fixed to this editorial release. “Open” is the source status at extraction. Review labels use each profile's recorded source date; dates older than 90 days are marked due. Recheck status and documents before acting.
Movingto shares common ownership with GVL's publisher and is shown separately from the directory listings. Movingto may receive a commission from some managers after client-requested coordination leads to a subscription. Movingto states that commercial relationships do not control verification, fund-data presentation or directory ordering; read how Movingto gets paid. GVL has not independently audited whether commercial relationships affect which manager profiles are created or kept current. Read the full ownership methodology.
03 · Investment
Fund type changes the risk; the legal test stays the same
A strategy label never proves ARI eligibility. It does tell you where losses could come from and which claims deserve pressure-testing.
| Strategy | Returns depend on | Questions to pressure-test |
|---|---|---|
| Private equity | Company growth, operational improvement and eventual exits | Concentration, valuation judgement, exit timing and leverage |
| Venture or growth capital | A smaller number of portfolio companies producing outsized gains | High failure rates, follow-on funding, dilution and long exits |
| Private credit | Interest and principal payments from borrowers | Default, collateral quality, refinancing and borrower concentration |
04 · Verification
Due diligence before the bank transfer
Get the answers in the signed documents or in a written professional opinion. A presentation and a manager's email are not substitutes.
ARI eligibility
- Does the fund regulation expressly exclude direct and indirect real estate?
- Where do the five-year maturity and 60% Portuguese-company rules appear?
- Who will issue each declaration required by AIMA, and when?
- What happens to eligibility if the fund term, strategy or holdings change?
Governance
- What are the fund and manager's current regulatory details?
- Who is the depositary, auditor, administrator and valuation agent?
- How are conflicts, related-party deals and valuation disputes handled?
- Can you inspect audited accounts, portfolio reports and material notices?
Portfolio and exit
- How concentrated is the portfolio by company, sector and stage?
- How much capital is deployed, reserved or still awaiting investment?
- What evidence supports the valuation of assets that do not trade publicly?
- Who can extend the term, for how long, and on what investor vote?
Your position
- Can you leave €500,000 unavailable through the stated term and extensions?
- What reporting and tax treatment applies in every relevant jurisdiction?
- Does the adviser, lawyer or introducer receive any payment connected to placement?
- What would make you reject this investment even if it qualifies for ARI?
05 · Economics
Fees, lock-up and the exit you may not control
Published fee percentages can be misleading without their calculation base, timing and exclusions. Compare the signed terms line by line.
| Cost | Find in the documents | Ask explicitly |
|---|---|---|
| Subscription | Subscription agreement and fee schedule | Is it deducted from, or added to, the €500,000? |
| Management | Fund regulation and annual cost disclosure | Is it charged on committed, invested or net asset value? |
| Performance | Distribution waterfall and hurdle terms | Is there a hurdle, catch-up, high-water mark or clawback? |
| Fund expenses | Operating-expense provisions and accounts | Which audit, depositary, legal and transaction costs reach investors? |
| Exit or transfer | Redemption, transfer and extension clauses | Who must consent, what can be extended and is there a buyer? |
Illustrative model
See how headline fees compound
Adjust the assumptions for a €500,000 subscription. This isolates subscription and annual management fees; it is not a return forecast.
- Value with no modelled fees
- €703,550
- Value after modelled fees
- €629,778
- Modelled fee drag
- €73,772
Simplified assumptions: the subscription fee is deducted on day one and the management fee reduces the entered annual return once per year. The model excludes performance fees, fund expenses, tax, distributions, cash drag, fee-base differences and losses. Actual documents control, and invested capital is at risk. For ARI, confirm the fee does not reduce the units acquired below €500,000; it may need to be paid on top.
Five years is a legal floor, not a cash-back date.
A fund can run longer, extend its term, delay exits or return less than you invested. Assume the units are illiquid unless the signed documents and a credible market show otherwise.
For the separate government and legal costs, use the Portugal Golden Visa cost calculator and the lawyer-fee guide.
06 · Advice
One decision, three separate jobs
Immigration lawyer
Tests ARI eligibility, checks route evidence, prepares the application and handles AIMA procedure. Ask for the eligibility conclusion in writing before subscribing.
Investment professional
Assesses suitability, risk, portfolio construction and the manager. Verify the person's authorisation for the service and ask how they are paid.
Cross-border tax adviser
Models tax and reporting in Portugal and your other jurisdictions. Engage them before choosing the vehicle, because structure can change the result.
07 · AIMA
From fund subscription to first residence card
-
01
Set up and evidence the money
Obtain a Portuguese NIF, arrange a Portuguese bank account where required, and prepare the source-of-funds evidence the bank, fund and AIMA will ask for.
-
02
Test the fund before subscribing
Have the investment assessed on two separate questions: whether it fits your financial circumstances, and whether its signed documents satisfy the ARI legal test.
-
03
Subscribe and collect the route evidence
Transfer the capital and obtain the bank declaration, proof that you own the units free of liens, and the management company's declaration covering the plan, maturity and 60% rule. A company investor needs additional registry evidence.
-
04
Submit the mandatory online pre-registration
Register the application in AIMA's Portal ARI, upload the required documents and pay the analysis fee. This is an ARI application, not an ‘expression of interest’. Your lawyer can register as your representative.
-
05
Validate, schedule and attend biometrics
After AIMA validates the online file, use the portal to schedule the in-person appointment. Bring the requested originals for checking and biometric collection.
-
06
Decision, card and renewals
AIMA completes its checks and, if the application is approved, issues the residence card. Keep the qualifying investment and meet the stay requirement through each renewal period.
AIMA's Portal ARI instructions describe the online submission, payment, validation and scheduling sequence. Its fund-route document list sets out the investment evidence. Our document checklist puts those items in one place.
2026 AIMA fees: charged per applicant
The applied “presencial e digital” rates effective 1 March 2026 are below. They sit outside the €500,000 investment and apply separately to family members unless AIMA confirms a specific exemption.
| ARI stage | Analysis | Card step | Applied total |
|---|---|---|---|
| Initial concession | €632.10 | €6,314.20 | €6,946.30 |
| Renewal | €632.10 | €3,157.80 | €3,789.90 |
Source: AIMA's current fee table (PDF) and 2026 update notice. Check the table again immediately before filing.
Planning assumption
12–24+ months to the first card
This is a planning range, not an AIMA service standard. A published April 2026 practitioner update described 18–24 months; individual cases can run beyond that. Document corrections, validation and appointment capacity all move the date.
Sources: Fragomen, 14 April 2026 and the official AIMA process pages.
For backlog strategy and when delay becomes actionable, read the AIMA delays and appeals guide. For evidence planning, use the source-of-funds guide.
08 · Long term
Residence first; citizenship is a later, separate application
Under Lei Orgânica 1/2026, Portugal requires seven years of legal residence for EU and CPLP nationals and ten years for most other foreign nationals. The clock is counted from when the residence permit is issued. Citizenship applications already pending on 18 May 2026 continue under the previous law.
Whether time spent waiting before a permit was issued can be credited to existing holders is contested and subject to ongoing legal challenge. Do not build a plan on that time being counted. The other naturalisation requirements still apply.
The ARI stay requirement remains a minimum of seven days in the first year and 14 days in each subsequent two-year period. See the complete renewal and citizenship guide and the text of Lei Orgânica 1/2026.
Tax: determine, do not assume
Owning fund units and holding an ARI do not, by themselves, settle your tax result. Residence, domicile, fund classification, distributions, disposals, treaty position and your home-country rules can all matter. Model the full holding period and exit before investing.
US taxpayers: ask about PFIC before selecting a fund
A Portuguese fund may be a passive foreign investment company for US purposes. IRS Form 8621 reporting and the choice of tax treatment can be material. A QEF election requires annual information from the fund; confirm in writing whether it will provide it, then take US advice. See the official Form 8621 instructions and our US-citizen Golden Visa guide.
09 · Decision
Who the route may fit
Potentially suitable when
- You want Portuguese residence with limited physical presence.
- You can tolerate a long, uncertain and potentially loss-making investment.
- Your family and tax position have been mapped before subscription.
- You accept citizenship as a later option, not a promised outcome.
Usually a poor fit when
- You may need the €500,000 back on a known date.
- You are choosing solely because a promoter calls a fund “safe”.
- Your plan depends on a quick first card or a fast passport.
- You have not resolved cross-border tax and reporting consequences.
Immigration counsel
Compare the lawyer, not the fund pitch
Look for a written scope covering eligibility review before subscription, the AIMA application, dependants, biometrics, corrections and renewals. Ask the firm to disclose any fund-placement or introducer payment.
10 · Evidence
Sources and editorial method
The sources below were checked on 11 August 2026. We use legislation for the legal test, AIMA for procedure and documents, official regulatory information for fund checks, Movingto Funds for the public profile comparison, and the IRS for US PFIC mechanics. The processing range is explicitly an estimate because AIMA publishes no dependable end-to-end average for new ARI files.
- Lei 56/2023, Article 44: current €500,000 fund-route wording and closure of the former property and passive capital-transfer routes.
- AIMA: ARI overview: benefits, stay requirement, mandatory online pre-registration and legal framework.
- AIMA: Portal ARI instructions: online filing, document upload, fee payment, validation and appointment scheduling.
- AIMA: fund-route document list (PDF): bank, unit-ownership and management-company evidence.
- Official funds and asset-management information service: fund, manager, document, cost and portfolio information made available through CMVM.
- AIMA: current fee table (PDF): applied 2026 ARI analysis, initial-concession and renewal charges.
- Movingto Funds public profiles: the market explorer's fund, manager, fee, term, document, review-date and route-field source data. GVL preserves missing values and does not treat a profile label as legal approval.
- Lei Orgânica 1/2026: current nationality periods, counting rule and transitional protection for pending applications.
- Consolidated Article 98 of Lei 23/2007: family-reunification waiting-period exception for ARI holders.
- IRS: Form 8621 instructions: PFIC reporting and the annual information required for a QEF election.
Research and update responsibility
Dean Fankhauser is the named research editor for this page. He leads product and marketplace strategy and is responsible for source selection, data presentation and the update cadence. This responsibility is editorial and does not represent a professional legal, tax or investment credential.
Change log
- 11 Aug 2026
- Expanded the limited product sample into a full public-profile explorer with search, filters, side-by-side comparison, source-date labels and route-field conflicts.
- 11 Aug 2026
- Added the interactive fee-drag model and applied 2026 AIMA fees; corrected the former €1.5 million route, Portal ARI procedure, first-card range and nationality periods.
This is general information, not legal, immigration, tax or financial advice. It does not recommend any fund, forecast performance or guarantee an immigration outcome. Rules, regulatory records, processing conditions and tax treatment can change.
11 · Answers
Portugal Golden Visa fund FAQs
How does the Portugal Golden Visa fund route work?+−
You acquire at least €500,000 of units in a qualifying Portuguese non-real-estate collective investment undertaking, collect the investment evidence and submit the ARI application through AIMA's Portal ARI. The investment supports an application for Portuguese residence; it does not buy a visa or guarantee approval.
How much do I need to invest?+−
The legal minimum is €500,000. The fund route has no low-density discount. Fund charges, AIMA fees, legal work, banking, translations and tax advice sit outside that investment amount.
Which Portugal Golden Visa funds are open in 2026?+−
There is no official AIMA list of approved funds, and subscription status changes. Our release-dated comparison covers public profiles marked open and intended for the Golden Visa route in the source dataset. That source status is not a claim of current availability, a ranking or an eligibility conclusion. Check the manager's current documents, CMVM information and signed ARI evidence before transferring money.
What makes a fund qualify?+−
The law requires a non-real-estate collective investment undertaking constituted under Portuguese law, a maturity of at least five years at the time of investment, and at least 60% of its investments in commercial companies headquartered in Portugal. The investor must acquire at least €500,000 of units and provide AIMA's route-specific evidence.
Does CMVM registration mean a fund is Golden Visa approved?+−
No. Regulatory status and ARI eligibility are different questions. CMVM information helps you verify the vehicle, manager and published documents, but it is not an AIMA approval stamp. A Portuguese immigration lawyer should test the signed fund documents against the current ARI law before you subscribe.
How long does the Portugal Golden Visa take now?+−
Use 12–24+ months from online application to first card as a planning range, not a service promise. Cases can be shorter or materially longer depending on document corrections, AIMA validation, appointment capacity and case-specific checks. AIMA does not publish a dependable end-to-end average for new ARI cases.
Can I get my €500,000 back after five years?+−
Not necessarily. Five years is the statutory minimum maturity at the time you invest, not a guaranteed redemption date. The fund's term, extension rights, asset exits and redemption rules control when cash can be returned, and the value may be more or less than you invested.
What did the 2026 citizenship law change?+−
For applications under the law effective 18 May 2026, the residence period is 7 years for EU and CPLP nationals and 10 years for most other nationals, counted from the issue of the residence permit. Citizenship applications already pending when the new law took effect continue under the previous law. The treatment of pre-May 2026 queue time for existing permit holders remains legally disputed.
What fees should I compare?+−
Compare the subscription charge, annual management fee, performance allocation or carried interest, fund-level operating expenses, depositary and audit costs, and any exit or transfer charge. Check the calculation base, timing, VAT treatment and who receives each payment in the signed documents.
What should a US taxpayer check?+−
A Portuguese fund may fall within the US PFIC rules. Before investing, ask a US cross-border tax adviser whether Form 8621 applies, which election (if any) is appropriate, and whether the fund will provide the annual information a QEF election requires. Do not rely on a fund's general tax summary.
Can my family apply with me?+−
Qualifying family members can apply through family reunification without a second €500,000 investment. Each person still has their own documents, checks and AIMA fees. Article 98(3)(c) exempts family members of ARI holders from the general two-year waiting period introduced in 2025.