Golden Visa Portugal vs Spain: The 2026 Decision Guide

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Key Takeaways for 2026 Investors

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• Spain’s Golden Visa ended on April 3, 2025, and no longer accepts any investment-based residency applications.
• Portugal’s Golden Visa remains open in 2026 with a €500,000 minimum fund investment and a 14-day stay every two years.
• Portugal’s new nationality law now points to a 10-year citizenship timeline for most applicants and 7 years for CPLP and EU nationals.
• Spain’s main alternatives, such as the Non-Lucrative Visa, require over 183 days per year in-country and trigger full tax residency.
• VIDA Capital advises Portugal Golden Visa investors through the asset-backed VIDA Fund focused on Portuguese hospitality properties.

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Contact VIDA Capital to explore Portugal Golden Visa options

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Status And Timeline: Portugal Open, Spain Closed

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Spain’s Golden Visa was abolished by Ley Orgánica 1/2025 and the repeal took effect on April 3, 2025. Since that date, no investment in property, funds, bonds, or any other asset grants Spanish residency on its own. Portugal’s Golden Visa remains available through approved investment funds.

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The points below show how the two countries now compare on status, stay requirements, investment routes, and citizenship timelines.

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• Portugal Golden Visa (ARI) — Program Status: Open to new applicants
• Portugal — Minimum Stay: 14 days every two-year renewal period
• Portugal — Investment Route: €500,000 minimum into an eligible investment fund
• Portugal — Citizenship Timeline: Expected 10 years for most applicants and 7 years for CPLP and EU nationals, subject to final legal review

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• Spain (Post-April 3, 2025) — Program Status: Closed to new applicants since April 3, 2025
• Spain — Minimum Stay / Tax Trigger: More than 183 days in a calendar year makes an individual tax-resident in Spain
• Spain — Investment Route: No investment-based residency route for new applicants; the Non-Lucrative Visa and Digital Nomad Visa are the main options.
• Spain — Citizenship Timeline: 10 years of continuous legal residency for most nationalities

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Correction To Common Claims: Many articles and AI summaries still mention a five-year Portuguese citizenship path. Portugal’s October 2025 nationality reform is expected to move naturalization timelines to 10 years for most applicants and 7 years for CPLP and EU citizens once fully implemented. References to a five-year path are now outdated for new applicants under the 2026 law. Those who submitted citizenship applications before the law’s publication should remain under the previous framework, according to AIMA and analysis from CCLex and Sovereign Portugal.

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Talk to an advisor about current Portugal Golden Visa rules

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Key Legal Changes Shaping Today’s Rules

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Three recent legal milestones explain why older Portugal vs Spain comparisons no longer apply.

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• April 3, 2025: Spain’s Golden Visa ended under Ley Orgánica 1/2025, closing all investment-based residency routes.
• October 2025: Portugal’s Parliament approved a new citizenship framework, extending naturalization timelines.
• May 19, 2026: Portugal’s revised Nationality Law entered into force, setting 10 years for most applicants and 7 years for CPLP and EU nationals, subject to ongoing legal review.

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Investors relying on pre-2026 content are often comparing rules that no longer exist. The guidance below reflects the framework currently in force.

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Discuss how the 2026 rules affect your residency plan

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Portugal Golden Visa: Residency And Citizenship Path

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Portugal’s Golden Visa, formally the Autorização de Residência para Investimento (ARI), administered by AIMA, requires a minimum €500,000 investment in an eligible investment fund. The fund must have a maturity of at least five years and at least 60% of its investments in commercial companies headquartered in Portugal. Property-based investments no longer qualify for new applications.

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The minimum physical presence requirement is 14 days in every two-year renewal period. These days can be split across multiple trips. Portugal remains one of the few European countries offering a path to EU citizenship without full relocation.

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When authorities grant the Golden Visa, the investor receives a temporary residency permit valid for two years. That permit is then renewed for two additional two-year periods. Throughout the five-year period, the investor must maintain both the qualifying investment and the minimum stay. After five years, the investor can apply for permanent residency. Because card issuance often takes around a year, many investors complete only one renewal within that five-year window.

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Portugal’s October 2025 nationality reform introduced longer citizenship timelines. Legal analysis from CCLex indicates that the reform extends the residency requirement to 10 years, or 7 years for CPLP nationals and EU citizens, once fully applied. The new rules are expected to govern future applicants, while those who submitted citizenship applications before publication should remain under the previous framework.

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A qualified lawyer is essential throughout the Portugal Golden Visa process. The process usually takes 12 to 18 months from application to receiving the initial residency card. Family members may be included in the same application. This covers a spouse or common-law partner, dependent children who are full-time students and not working, and dependent parents.

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Get guidance on structuring your Portugal Golden Visa application

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Spain After The Golden Visa: Residency Routes That Remain

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Organic Law 1/2025 ended Spain’s Golden Visa on April 3, 2025 and closed every investment-based residency route, including property, bonds, company shares, bank deposits, and funds. New investors can no longer access residency through capital alone.

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For new applicants, the main options are the Non-Lucrative Visa and the Digital Nomad Visa. The Non-Lucrative Visa requires passive income of at least €2,400 per month for a single applicant, prohibits work, and, for renewal under Article 64 of Royal Decree 1155/2024, demands more than 183 days of actual residence in Spain each calendar year. The Digital Nomad Visa requires income from non-Spanish sources and also leads to tax residency once the 183-day threshold is crossed.

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Neither route offers the minimal-stay, investment-based structure of Portugal’s Golden Visa. Spain expects long-term residents to live there and accept Spanish tax residency, which does not suit a “Plan B” strategy that keeps life anchored elsewhere.

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Existing Spanish Golden Visa holders remain under transitional rules. Permits already granted stay valid and renew under the rules in force when they were issued, and applications filed before April 3, 2025 continue under the old framework. Legal representation is strongly recommended, as some offices may misinterpret the abolition when handling renewals.

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Speak with an advisor about shifting from Spain to Portugal

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What Now Replaces Spain’s Golden Visa For Investors?

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For financially independent individuals who once considered Spain’s Golden Visa, the Non-Lucrative Visa and Digital Nomad Visa now carry most of the weight.

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The Non-Lucrative Visa targets retirees and those with passive income. It requires proof of sufficient means and no intention to work. The structure is one year initially, then two-year renewals, with permanent residency after five years and citizenship eligibility after ten. The key constraint is presence. Holders must prove more than 183 days of actual residence per year, and that time counts toward the five years of continuous residence needed for long-term EU permanent residency.

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The Digital Nomad Visa, created under Spain’s Startup Law (Law 28/2022), requires income from non-Spanish sources of around 200% of Spain’s minimum wage. It is designed for remote workers and triggers Spanish tax residency once the 183-day threshold is crossed.

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Neither route recreates Portugal’s core feature: a path to EU citizenship with minimal physical presence. Both Spanish options assume that the holder will live in Spain, pay Spanish tax on worldwide income, and build a life there.

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If you already hold a Spanish Golden Visa, your situation differs from new applicants because the April 2025 abolition closed the door only to new investors.

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If You Already Have A Spanish Golden Visa

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Under the transitional provisions of Organic Law 1/2025, holders of Spanish investor residence permits granted before April 3, 2025 may renew under the rules that applied at the time of the original grant. The route closed to new entrants while remaining available to existing holders.

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Renewals must show that the qualifying investment is still in place. As of 2026, renewed Spanish Golden Visa permits run in successive five-year periods with no fixed cap, as long as the investment conditions remain satisfied under Article 67 of Ley 14/2013. The “roughly one visit a year” practice is administrative rather than statutory. Spending 183 days or more in Spain still triggers tax residency regardless of permit type.

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Applications lodged but undecided before April 3, 2025 sit in a transitional zone. Outcomes can depend on timing and local practice. Legal counsel is crucial for anyone in this position, particularly where offices misapply the abolition to pending or renewing cases.

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Explore moving from a Spanish Golden Visa to a Portugal strategy

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For US Retirees: Tax Residency And The 183-Day Rule

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For US retirees, the most consequential difference between Portugal and Spain is the tax residency trigger. Under Article 9 of Spain’s Income Tax Act, a person becomes tax-resident for a calendar year if they spend more than 183 days in Spain during that year. Once that threshold is crossed, Spain taxes worldwide income for the entire calendar year, including months before arrival.

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Spain’s Non-Lucrative Visa is now the primary route for retirees. To renew it under Article 64 of Royal Decree 1155/2024, holders must prove more than 183 days of actual residence in Spain each year. That time counts toward permanent residency. As a result, every Non-Lucrative Visa holder becomes a Spanish tax resident by design. For US retirees with investment income, pensions, or business proceeds, this creates complex cross-border tax questions that require specialist advice.

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Portugal’s Golden Visa follows a different pattern. The minimum stay is 14 days in every two-year period, roughly one week per year. Portugal generally treats an individual as tax-resident only if they spend more than 183 days in a twelve-month period or maintain a permanent home there. An investor who visits only for the Golden Visa minimum does not automatically become a Portuguese tax resident.

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The Golden Visa grants residency rights in Portugal, not across the entire European Union. During residency, holders can live, study, and work in Portugal and travel visa-free within the Schengen Area for up to 90 days in any 180-day period. After naturalization, a Portuguese passport unlocks full EU rights, including residence, work, study, and access to public healthcare and education across EU member states.

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Speak with an advisor about tax-aware Portugal Golden Visa planning

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How To Choose: Practical Decision Framework

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Your ideal route depends on whether you want an EU passport, a lifestyle move, or a flexible Plan B. Use the scenarios below as a quick guide.

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Best Fit: EU Passport With Minimal Physical Presence

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Portugal’s Golden Visa is the only option in this comparison that offers this outcome. The 14-day stay every two years, combined with a 10-year citizenship path for most applicants and 7 years for CPLP and EU nationals, supports long-term EU citizenship without relocation. VIDA Capital reports a 571% surge in American inquiries since January 2025, reflecting this demand.

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Best Fit: Full-Time Life In Spain With Tax Residency

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Spain’s Non-Lucrative Visa or Digital Nomad Visa suits people who want to live in Spain, accept Spanish tax residency, and do not need an investment-based route. This is a lifestyle relocation choice.

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Best Fit: Plan B Residency And Citizenship Optionality

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Portugal’s Golden Visa fits investors who want capital preservation, minimal disruption, and a credible path to an EU passport for themselves and their families. Since 2024, Americans have been the largest nationality among Portugal’s Golden Visa main applicants, driven largely by this Plan B use case.

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Get help choosing the right residency route for your goals

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Why Investors Choose VIDA Capital And The VIDA Fund

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VIDA Capital connects investors with asset-backed opportunities in Portugal’s hospitality sector through the VIDA Fund. Alex Ohnona of VIDA Capital notes that 2025 brought a clear acceleration in both demand and capital deployment compared to 2024, as investors moved from a wait-and-see stance to decisive action.

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Investor interest has remained strong even after Portugal extended its citizenship timeline, particularly among US investors who value residency-by-investment access to the EU.

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The VIDA Fund acquires and revitalizes undervalued hospitality businesses in Portugal. Through an integrated owner-operator model, the fund aims to turn these properties into premium, higher-margin assets. Because the strategy is asset-backed and tied to physical hospitality businesses, it offers a layer of capital protection that purely financial instruments may not provide. Historical returns are not a guarantee of future returns.

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VIDA Capital’s advisory service includes concierge-style support throughout the Golden Visa process, clear fee disclosure, and direct access to the advisory team. The firm also connects clients with specialized law firms for legal representation. VIDA Capital’s clients invest in the VIDA Fund, not in VIDA Capital itself. VIDA Fund I raised over €20 million from more than 50 investors and supported over 100 Golden Visa applications. VIDA Fund II is now open to investors seeking Golden Visa eligibility through an asset-backed strategy.

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Request details on the VIDA Fund and Portugal Golden Visa eligibility

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Frequently Asked Questions

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Is Spain’s Golden Visa Still Available?

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No. Spain’s Golden Visa ended on April 3, 2025 under Ley Orgánica 1/2025. Every investment-based residency route, including property, bonds, shares, bank deposits, and funds, closed at the same time. Existing permit holders keep their status and may renew under prior rules, but new investors cannot enter the program.

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Can I Still Get Portugal’s Golden Visa?

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Yes. Portugal’s Golden Visa remains open to new applicants in 2026. The main route is a €500,000 minimum investment in an eligible Portuguese investment fund. The fund must have a maturity of at least five years and at least 60% of its investments in commercial companies headquartered in Portugal. Property-based routes no longer qualify.

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How Long Until Citizenship Through Portugal’s Golden Visa?

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Under Portugal’s revised nationality law, the residency requirement for naturalization is expected to be 10 years for most applicants, including US citizens, once fully applied. Nationals of Portuguese-language countries (CPLP) and EU citizens are expected to qualify after 7 years. Applicants who submitted citizenship files before the law’s publication should remain under the previous framework. The law remains under legal review, so investors should consult a qualified lawyer about their specific case.

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Do I Need To Live In Portugal To Keep The Golden Visa?

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No. The Portugal Golden Visa requires 14 days of physical presence in every two-year renewal period, and days do not need to be consecutive. This low stay requirement makes the program suitable as a Plan B for investors who do not plan to relocate. Spending more than 183 days per year in Portugal would trigger Portuguese tax residency, but the Golden Visa minimum remains well below that threshold.

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What Happens To My Existing Spanish Golden Visa?

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Existing Spanish Golden Visa permits remain valid for their original term. Renewals follow the rules that applied when the authorization was first granted. The abolition closed the program to new entrants. Some local offices may misapply the new law to renewals, so legal representation is strongly recommended for anyone renewing under transitional provisions.

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Talk with VIDA Capital about transitioning from Spain to Portugal

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Conclusion: Portugal Remains The Viable EU Residency Path

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The Portugal vs Spain comparison for residency by investment now has a clear outcome. Spain ended its Golden Visa in April 2025, and its remaining options require relocation and full tax residency. Portugal’s Golden Visa remains open, built around a €500,000 fund investment, a 14-day stay every two years, and a defined path to EU citizenship without mandatory relocation.

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The citizenship timeline has lengthened, and the five-year path in older articles no longer applies to new applicants. Under the May 2026 nationality law, most investors face a 10-year timeline, with 7 years for CPLP and EU nationals. The horizon is longer, yet it remains a clear, legally grounded route to an EU passport that many investors can pursue while keeping their primary life in the United States.

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VIDA Capital guides investors through the Portugal Golden Visa process via the VIDA Fund, an asset-backed vehicle focused on acquiring and transforming undervalued hospitality businesses in Portugal. For investors seeking capital preservation, minimal disruption, and a structured path to EU residency and eventual citizenship, the VIDA Fund offers a transparent framework. Historical returns are not a guarantee of future returns.

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Read VIDA Capital’s full Portugal vs Spain Golden Visa comparison for more detail, or contact the team to discuss your situation directly.

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Schedule a consultation about your Portugal Golden Visa strategy