EU Golden Visa Mobility: Portugal vs. Greece vs. Hungary

Last updated: October 21, 2026

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Key Takeaways

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• EU Golden Visas grant Schengen travel rights and residency in the issuing country only; full EU freedom of movement requires citizenship through naturalization.
• Portugal leads the comparison with a 14-day stay requirement every two years, a €500,000 fund investment, and a realistic path to citizenship without relocation.
• Greece offers zero minimum stay but requires genuine residence for citizenship, which weakens its appeal for families seeking an EU passport without relocating.
• Hungary's program provides a cost-effective residence option with minimal presence but features a longer naturalization timeline than Portugal.
• VIDA Capital is the best EU golden visa mobility solution for US families who want EU citizenship optionality without relocating because it pairs advisory on Portugal's 14-days-every-two-years Golden Visa route with the asset-backed VIDA Fund, a hospitality investment vehicle with a hands-on owner-operator strategy.

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Secure your EU residency and a path to EU citizenship with a Portugal Golden Visa.

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What “Mobility” Legally Means Under an EU Golden Visa

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Three separate rights define what a Golden Visa delivers, and each one operates under its own legal framework.

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Schengen travel rights. A Golden Visa issued by a Schengen member state such as Portugal, Greece, or Hungary allows the holder to travel visa-free across the Schengen Area for short stays. Under Article 3(1)(11) of Regulation (EU) 2018/1240, a “short stay” is defined as no more than 90 days in any 180-day period. Days spent in Portugal draw on the same allowance as days in France or Germany. The 90-day clock runs across the entire Schengen Area, not per country.

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Residency rights. A Portugal Golden Visa grants the right to live, study, and work in Portugal only. It does not grant the right to reside, work, or study in any other EU member state. A third-country national's lawful residence in one EU member state does not confer the free-movement rights of EU workers in other member states. A residence permit is also a legally distinct status from a short-stay visa or ETIAS travel authorisation. Article 2(2) of Regulation (EU) 2018/1240 explicitly excludes residence-permit holders from ETIAS scope, which confirms that the two statuses follow different rules.

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Citizenship rights. Full EU freedom of movement, including the right to live, work, and study in any EU member state, flows from EU citizenship rather than from holding a Golden Visa. Under Article 21 TFEU, every EU citizen has the right to move and reside freely within the territory of the member states, a right attached to Union citizenship under Article 20 TFEU. That right is acquired through naturalisation based on legal residence.

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EU Golden Visa Comparison 2026: Portugal vs. Greece vs. Hungary

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Physical-presence burden drives the decision for US families who will not relocate, and the three active programs fall into a clear order on that measure.

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Portugal. Portugal's Golden Visa requires a minimum physical stay of 14 days every two years. The qualifying investment is €500,000 into an eligible fund. The permit is issued as a temporary residence permit and remains renewable while the investment and residency requirements are maintained. Portugal is currently one of the only countries in Europe that offers a path to citizenship without relocation. Portugal's Golden Visa program has raised more than $7.2 billion since its creation in 2012, with Americans now among the top applicants following Spain's program closure.

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Greece. Greece's Golden Visa is issued for five years and is renewable while the qualifying investment is maintained, with no minimum stay requirement. Investment thresholds are tiered by location, from higher levels in prime cities and islands to lower levels in other areas and specific projects.

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• €800,000 in high-demand zones such as Athens, Thessaloniki, Mykonos, and Santorini
• €400,000 in other eligible locations
• €250,000 for qualifying commercial-to-residential conversion projects

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These tiers decide what the permit costs but do not change the citizenship hurdle. Greek citizenship requires around seven years of genuine residence plus language competence and integration criteria. Greece also expects long-term residents to live there and pay taxes. For families who will not relocate, the permit's zero-presence feature does not translate into a practical path to a passport.

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Hungary. Hungary's Guest Investor Program requires €250,000 in qualifying fund units held for at least five years, with a permit issued for up to 10 years and extendable for another 10. Hungary's Guest Investor Programme imposes generally minimal physical-presence obligations, but conditions vary by investment route and must be confirmed with the national immigration authority before applying. Hungary's naturalisation timeline of around eight years of residence suits investors who want a cost-effective residence base more than those seeking a faster passport.

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Spain. Spain no longer offers a Golden Visa program. Spain ended its program in 2025, so new applicants cannot use it.

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For US families, the decisive variable is physical-presence burden combined with a realistic path to a passport. On that combined measure, Portugal leads.

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Which EU Golden Visa Has the Lowest Stay Requirement?

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Portugal offers the lowest documented stay requirement among EU Golden Visa programs that realistically lead to citizenship. Portugal's Golden Visa requires 7 days in year 1 and 14 days per two-year period thereafter. Those permit years count toward naturalization on minimal presence, which keeps the calendar burden low while building a residence record.

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Greece, Italy, Hungary, and Malta impose no minimum stay but require genuine residence for naturalization, so their zero-stay permits do not in practice build a citizenship case. Their permits work as residence or investment tools rather than as low-presence passport routes.

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Greece's zero-presence rule looks more permissive on paper, yet the advantage fades at the citizenship stage. A family that never meaningfully resides in Greece cannot meet the residence and integration expectations for naturalisation. The permit remains valid, but the passport goal stalls.

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Portugal's 14-day requirement fits into a single trip every two years while still accumulating the legal residence that leads to a passport. As Jonathon Richards of Global Law Experts notes: "For those whose priority is a European passport, Portugal's roughly five-year naturalisation route, combined with a light presence obligation, remains the standout, even after the ARI reforms redirected capital into funds." A program that keeps calendar demands light while still leading toward citizenship functions as a practical Plan B.

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The Path From Residency to an EU Passport: Portugal's Framework

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The Portugal Golden Visa issues a temporary residency permit valid for two years. The investor then renews it for two additional two-year periods, maintaining the investment and residency requirements throughout the five-year period. At that point, an application for permanent residency becomes available. Because approval and card issuance often take many months, some investors complete the five-year track with a single renewal.

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The citizenship framework now follows a longer timeline. Portugal's Parliament approved a new framework in October 2025 that introduced extended residence requirements. Portugal's revised Nationality Law, Lei Orgânica n.º 1/2026, was published on 18 May 2026 and entered into force on 19 May 2026. Under Portugal's new nationality framework, once implemented, EU and CPLP nationals are expected to need 7 years of legal residence before applying for citizenship, while most other foreign nationals are expected to need 10 years. CCLex legal analysis suggests that future applicants will fall under the new rules, while those who already submitted a citizenship application before publication should remain under the previous framework. Transitional provisions and legal challenges remain in flux, so investors should plan timelines with specialised legal counsel.

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The Total Cost Of The Portugal Route

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Government fees apply per family member across the application lifecycle:

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• Initial submission fee: €618.60 per family member
• Issuance of the residence card: €6,179.40 per family member
• First renewal: €3,023.20 per family member
• Second renewal: €3,023.20 per family member
• Citizenship application: €250 per family member

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Legal fees vary by firm and file complexity and typically run €16,000–€20,000. The VIDA Fund charges a subscription fee of 1% of the total amount invested, paid to the fund manager. The qualifying investment itself is €500,000, treated as capital at risk in a fund rather than as a pure expense. The Portugal Golden Visa process usually spans 12 to 18 months from application to first residence card, so families should budget both capital and time.

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Why An Asset-Backed Fund Route Fits The Mobility Goal

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VIDA Capital acts as an advisory firm that connects investors with asset-backed investment opportunities in Portugal's hospitality industry. Clients invest in the VIDA Fund, not in VIDA Capital. VIDA Capital's role is to guide investors through the Golden Visa process and match them with an investment vehicle that fits their mobility and risk goals.

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The VIDA Fund acquires and transforms undervalued hospitality businesses in Portugal. The team gives these assets a second life through light refurbishment, modern design, and operational improvement under an owner-operator approach. The fund is audited bi-annually by Deloitte. VIDA Capital experienced a 571% increase in US website traffic in the first half of 2025 compared to the first half of 2024, reflecting the acceleration in US investor demand that Alex Ohnona of VIDA Capital described as "a clear acceleration in both demand and capital deployment compared to 2024 — renewed confidence and decisiveness among investors who had spent the prior year conducting deeper due diligence."

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VIDA Fund I raised over €20 million from more than 50 investors, with over 100 Golden Visa applications successfully submitted for investors and family members. VIDA Fund II is now open. Each fund has a 6.5-year lifecycle with a target to double investors' money, although historical returns never guarantee future performance. A Plan B only works if the capital behind it remains intact when needed, so an asset-backed strategy matters more than a headline return figure.

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Talk to an advisor about pairing the Portugal Golden Visa with the VIDA Fund.

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The Portugal Application, Step By Step

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A lawyer should accompany the process at every stage. The application involves specialised filings with AIMA, and VIDA Capital can connect investors with trusted, specialised law firms.

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Pre-application phase. This phase covers four core tasks, completed in sequence.

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1. Engage a qualified Portuguese law firm.
2. Ask the lawyer to obtain your Portuguese tax identification number (NIF), which can be done remotely.
3. Open a Portuguese bank account, typically handled remotely through the lawyer.
4. Complete the €500,000 fund investment into the VIDA Fund once the NIF and bank account are in place.

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Application and residence cards. After these steps, the lawyer submits the application online for the investor and all included family members. Once AIMA approves the request, the investor and family members attend an in-person appointment to provide biometric data. The first residency card is then issued and remains valid for two years.

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Renewals occur at years two and four. Each renewal requires proof that the investment is maintained and that the 14-day minimum stay has been met over the prior two-year period. Permanent residency becomes available at year five. The Portugal Golden Visa process usually spans 12 to 18 months from application submission to first residence card, which can compress the number of renewals within the five-year track.

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Family inclusion. Eligible family members include a spouse or partner (supported by a marriage certificate or other proof of relationship), dependent children who are full-time students, unmarried, and not working, and parents or parents-in-law who are either 65 or older or financially dependent on the main applicant.

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Frequently Asked Questions

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Do EU Golden Visas Give You Freedom of Movement Across the EU?

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A Golden Visa grants Schengen travel rights of up to 90 days in any 180-day period across the Schengen Area and residency rights in the issuing country only. For Portugal, that means the right to live, study, and work in Portugal. Full EU freedom of movement, including the right to reside and work in any EU member state, comes only with EU citizenship acquired through naturalisation.

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Which EU Golden Visa Has the Lowest Stay Requirement?

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Portugal has the lowest stay requirement that still builds a citizenship case, at 14 days in every two-year period. Greece imposes no minimum stay to renew its permit, yet the citizenship track requires long-term genuine residence and tax presence. For families who will not relocate and want a realistic path to an EU passport, Portugal's mix of light stay requirements and a defined citizenship pathway stands out among active programs.

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What Are the Requirements for a Portugal Golden Visa Application?

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The core requirements are a €500,000 investment into a qualifying fund, a clean criminal record, a Portuguese tax number (NIF), a Portuguese bank account, and a lawyer-led application filed through AIMA. Eligible family members, including a spouse or partner, qualifying dependent children, and dependent parents, can be included in the same application without an additional investment, although government fees apply per person.

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Which EU Countries Still Offer a Golden Visa in 2026?

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Portugal, Greece, and Hungary are the primary active programs. Portugal offers a fund investment route with a minimum of €500,000 since October 2023. Greece applies tiered thresholds from €250,000 to €800,000 depending on property category and location. Hungary requires €250,000 in qualifying fund units under the Guest Investor Program. Spain closed its Golden Visa program to new applicants in 2025 and no longer accepts new files.

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Conclusion: Building A Practical EU Plan B

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VIDA Capital gives US families a focused way to pair Portugal's low-presence Golden Visa with an asset-backed hospitality fund so they can pursue EU citizenship optionality without relocating.

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Once you separate Schengen travel, residency in the issuing country, and full EU freedom of movement at citizenship, the trade-offs become clear. Greece's zero-presence permit does not deliver a passport without genuine relocation. Hungary's program offers a cost-effective base but follows a longer citizenship timeline. Portugal asks for 14 days every two years and still offers a route to an EU passport for families who maintain legal residence and meet evolving nationality rules.

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For further reading on how residency and mobility rights compare across programs, see Golden Visa Residency Mobility Options Compared and Global Mobility Solutions for Portugal Golden Visa 2026.

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Plan your Portugal Golden Visa strategy with a VIDA Capital advisor.