The Portugal Golden Visa program has undergone a fundamental transformation, emerging stronger and more strategically focused in 2025. For investment migration professionals and high-net-worth individuals seeking European Union (EU) residency, fund investments have decisively become the primary and most strategically aligned route.
Following pivotal reforms in October 2023, the program shifted away from real estate options, successfully channeling foreign capital into productive Portuguese enterprises.
The 2025 fund landscape is defined by a standard minimum investment of €500,000 in non-real estate collective investment entities, which are rigorously regulated by the Portuguese Securities Market Commission (CMVM) to ensure high transparency and investor protection.
Available fund categories span high-growth sectors such as renewable energy, technology, hospitality, and sustainable agriculture, directly reflecting Portugal’s national development priorities. The country’s positive economic outlook for 2025 — including resilient GDP growth, declining inflation, and supportive interest rates — further reinforces this shift.
There is a notable surge in interest from global investors, particularly from the United States and United Kingdom, who increasingly view the Golden Visa as a strategic option for financial stability and enhanced global mobility.
The Portuguese government’s decision to restructure rather than terminate the program underscores its strong political commitment to maintaining this pathway as a dependable, long-term tool for attracting foreign capital.
This report offers a factual, data-driven analysis of the 2025 fund market, providing essential insights on regulatory compliance, fund selection, and broader economic context. It serves as an authoritative guide for investment migration professionals and high-net-worth individuals navigating this evolving landscape.
The Evolving Landscape of Portugal’s Golden Visa Program in 2025
As of 2025, Portugal’s Golden Visa program remains fully active and continues to attract global investors seeking EU residency. The most significant transformation came with the legislative reforms finalized in October 2023, which eliminated both direct and indirect real estate investments as well as large capital transfers as qualifying options.
This shift, introduced under the government’s "Mais Habitação" (More Housing) initiative, was designed to address housing affordability while channeling foreign capital into productive sectors that support long-term national growth.
This strategic reorientation underscores Portugal’s commitment to using investment migration as a tool for economic development and social impact. By emphasizing "productive investments," particularly those that strengthen Portuguese businesses and create jobs, and introducing solidarity-based options aimed at social projects such as affordable housing, the program now closely aligns with national economic and social priorities.
Fund investment has emerged as the most popular and streamlined pathway. Investors must commit a minimum of €500,000 to non-real estate collective investment entities regulated under Portuguese law. These funds must:
- Have a minimum maturity of five years
- Invest at least 60% of their capital in commercial companies headquartered in Portugal
This structure ensures that investments generate direct and tangible benefits for the domestic economy.
The shift from property to funds has elevated the level of financial sophistication required from applicants. Rather than simply purchasing real estate, investors must now evaluate fund performance and risk profiles, understand management strategies, and review fee structures and liquidity considerations.
This new reality emphasizes the importance of engaging specialized legal and financial advisors to navigate the selection process and ensure compliance.
The Golden Visa grants holders and their families the right to live, work, and study in Portugal, along with visa-free travel across the Schengen Area. A significant advantage remains the minimal stay requirement — just seven days per year on average over five years.
After this period, Golden Visa holders become eligible to apply for permanent residency or citizenship, with a recent change often allowing the five-year count to start from the initial application date.
General requirements include being a non-EU/EEA/Swiss citizen, over 18 years old, and having a clean criminal record. For Portuguese citizenship, applicants must also demonstrate A2-level Portuguese language proficiency.
Regulatory Framework and Eligibility Criteria for Golden Visa Funds in 2025
The Portuguese Securities Market Commission (CMVM) maintains rigorous oversight of all Golden Visa investment funds, ensuring compliance with Portugal’s securities law and providing essential investor protections.
While no official “CMVM approved” fund list exists, eligibility is established through legal registration documents that must explicitly reflect Golden Visa criteria in their management regulations.
CMVM regulation guarantees transparency through mandatory reporting requirements, professional fund management standards, and comprehensive investor protection mechanisms.
CMVM regulation also requires funds to report net asset valuations semi-annually and undergo annual audits by accredited independent firms such as PwC, KPMG, or EY. These measures further strengthen transparency and financial accountability.
Investors must always verify CMVM registration diligently, as investments through unauthorized entities are not protected by compensation systems and carry severe financial risks.
The mandatory requirements for Golden Visa fund eligibility include specific criteria that align investment objectives with program goals:
Portugal Golden Visa investors may diversify their minimum investment requirement across multiple qualifying funds, enabling sophisticated portfolio allocation strategies while maintaining program compliance. This flexibility allows risk mitigation through sector diversification and varying investment horizons.
The application process has been streamlined for 2025, migrating entirely to online submission through the ARI portal. Required documentation includes personal identification, investment proof, fund compliance verification, and Portuguese bank account details.
General applicant requirements include being a non-EU/EEA/Swiss citizen, over 18, and holding a clean criminal record from both the country of origin and Portugal. Certain documents must be legalized (apostilled) and officially translated into Portuguese.
The typical processing timeline spans 10–14 months from application submission to residence permit approval, with recent efficiency improvements projecting future timelines of four to six months.
Biometric appointments are now automated following document upload, and AIMA (Portuguese Immigration Agency) has implemented significant backlog reduction efforts. These operational improvements reflect the program’s commitment to processing efficiency while maintaining thorough due diligence standards.
The table below summarizes the key requirements for Golden Visa fund investments in 2025.
Overview of Eligible Golden Visa Fund Categories
Portuguese Golden Visa funds encompass distinct categories, each aligned with different investor risk profiles and Portugal’s strategic development priorities.
Understanding these categories enables informed fund selection that matches investment goals with risk tolerance and return expectations.
To illustrate these options clearly, here’s an overview of the primary fund types and their key features:
Additionally, many Golden Visa funds target strategic sectors crucial to Portugal’s economic future:
- Hospitality: Major contributor to GDP (forecast €62.7 billion in 2025), strong job creation, premium asset repositioning.
- Agriculture & Farmland: Focus on regenerative practices, stable yields, capital preservation, potential annual dividends.
- Technology & Startups: Rapidly expanding, supported by government incentives and Lisbon’s tech ecosystem.
- Corporate Credit & Bonds: Income-focused, high-yield Portuguese bonds.
- Niche Sectors: Specialty projects like self-storage, hospitality renovations, or specialty industries.
While these funds offer broad sectoral diversification, including select niche opportunities such as digital assets, investors should note that at least 60% of investment value must remain in commercial companies based in Portugal.
This creates a strong geographic concentration, meaning diversification is primarily sector-based rather than international.
The advantages of fund investments over direct property ownership include professional management by experienced fund managers, comprehensive CMVM regulatory oversight, and the ability to diversify across different sectors and projects.
Investors benefit from potential international capital appreciation, lower administrative burden, and flexible multi-fund strategies.
Portugal also offers attractive tax advantages:
- 0% withholding tax on capital gains for non-tax residents.
- 10% reduced tax rate for Portuguese tax residents.
- No wealth or inheritance taxes.
Spotlight on Key Golden Visa Funds
Understanding the fee structure is crucial for assessing the true cost and potential net returns of a fund investment.
Generally, Golden Visa funds levy three primary types of fees:
- Subscription Fees: These are one-time fees paid at the commencement of the investment. They typically range from 1% to 3% of the total capital invested. For a €500,000 investment, this could amount to between €5,000 and €15,000. These fees often cover administrative costs, investor onboarding, anti-money laundering checks, and other legal and compliance procedures.
- Management Fees: These are recurring annual fees paid to the fund manager. They commonly range from 1% to 2% of the committed capital annually. This fee covers the fund's operational overheads, administrative expenses, and salaries for the management team, and is typically paid regardless of the fund's performance.
- Performance Fees: These are additional fees charged by some funds, calculated as a percentage of the fund's overall return that exceeds an agreed-upon hurdle rate. For example, a 20% performance fee with an 8% hurdle rate means the fund manager takes 20% of any returns generated above 8%. These fees are designed to align the interests of investors and fund managers by incentivizing strong performance.
A selection of Portuguese investment funds for 2025, based on available data, is detailed below:
1️⃣ New Frontiers Energy Fund
- Sector: Solar / Renewable Energy.
- Minimum Investment (Fund): €50,000.
- Duration: 8 years.
- Strategy: This fund focuses on early-stage, pre-construction solar projects in Southern Portugal. The fund assists with development to the "Ready-To-Build" (RTB) stage and then exits its position by selling shares for profit. It is fully CMVM regulated and explicitly compliant with new Golden Visa rules, as it does not invest in real estate.
- Deadline: December 2025.
- Performance: The fund targets a return of 10% per annum. Specific past performance data for the fund is not provided in the available information.
2️⃣ Pela Terra II: Regenerate Fund
- Sector: Farmland / Agriculture.
- Minimum Investment (Fund): €200,000.
- Duration: 8 years.
- Strategy: This fund invests in crop-yielding assets with water rights across Portugal and the wider Iberian Peninsula. It employs a strategy of purchasing, holding, and cultivating large orchards, with a strong emphasis on regenerative agricultural practices that prioritize soil health, biodiversity, and carbon sequestration. The fund aims for solid capital preservation and an annual yield.
- Deadline: December 2025. The subscription end date is specifically noted as November 30, 2025.
- Performance: While specific fund performance is not detailed , historical data for farmland investments generally indicates average annual returns between 7-12% (combining income and appreciation), positive correlation with inflation, and negative correlation with stock market volatility.
3️⃣ VIDA Fund
- Sector: Hospitality.
- Minimum Investment (Fund): €200,000.
- Duration: 7 years.
- Strategy: The fund acquires undervalued Portuguese hospitality businesses and undertakes their transformation into premium, high-margin operating assets. The fund emphasizes capital preservation through disciplined hospitality investments.
- Deadline: October 2025.
- Performance: VIDA Fund I successfully raised over $21 million, achieved 130% operational performance versus budgeted targets, and reported a 113% current Net Asset Value (NAV). The fund is fully regulated by CMVM and audited bi-annually by Deloitte.
4️⃣ ActiveCap Corporate Bond Fund
- Sector: Corporate Credit.
- Minimum Investment (Fund): €100,000.
- Duration: Open-ended. This characteristic implies greater liquidity compared to fixed-term funds.
- Strategy: This fund invests in investment-grade and high-yield Portuguese corporate bonds, designed as an income-focused, liquid fund.
- Deadline: Open.
- Performance: Specific past performance data for this fund is not available in the provided information.
5️⃣ Terra Nova Fund
- Sector: Agriculture / Farmland.
- Minimum Investment (Fund): While the Golden Visa minimum is €500,000 , general fund minimums mentioned for similar funds are €100,000.
- Duration: 8 years.
- Strategy: The fund invests in and develops irrigated farmland operations in Portugal, aiming to provide secure, long-term returns from both crop yields and land appreciation. The fund emphasizes low-risk investment with recurring cash flows, strong exit returns, and adherence to high ESG (Environmental, Social, and Governance) and Positive Impact standards.
- Deadline: Not explicitly specified in the available information.
- Performance: Historical agricultural land value appreciation is noted at approximately 6% per annum, generating total returns above 10%. No specific past performance data for this fund is available in the provided information.
6️⃣ C2 X Legacy Buy Out Fund
- Sector: Companies / Sector-agnostic.
- Minimum Investment (Fund): €150,000.
- Duration: 8 years.
- Strategy: This fund targets late-stage companies with proven business models and steady cash flows across multiple sectors that have not yet unlocked their full potential. Its investment strategy involves acquiring majority positions (less than 100%) with a view to preserving management teams and institutional knowledge. Target companies often include private businesses where founders are nearing retirement and ownership succession planning is not in place.
- Deadline: December 2025.
- Performance: The fund targets a yield of 15% IRR per annum.
Strategic Investment Considerations for Golden Visa Applicants
The Portugal Golden Visa fund route in 2025 demands strategic planning that extends well beyond basic compliance. With over 30 qualifying investment funds open to foreign investors and an economic context characterized by stable GDP growth and strong capital inflows, careful evaluation is critical to align financial objectives with residency goals.
Notably, targeted sectors include renewable energy (with Portugal aiming for 81.2% renewable generation by 2025), hospitality (projected to contribute €62.7 billion to GDP, 21.5% of the national economy), technology, and agriculture. These priorities reflect Portugal’s broader strategy to channel foreign investment into productive, future-oriented sectors.
Key considerations for prospective Golden Visa fund options include:
- Fund Manager Credentials: Evaluate professional track records, regulatory compliance history, and fiduciary responsibilities to ensure robust governance and investor protection.
- Portfolio Quality & Historical Performance: Review underlying portfolio companies, diversification strategies, and past performance data to gauge realistic return expectations and operational resilience.
- Risk Tolerance & Strategy Alignment: Match fund selection to individual risk profiles; venture capital funds typically carry higher risk and potential upside, while private equity or growth funds target more stable, moderate returns.
- Exit Strategy Planning: Coordinate fund redemption timelines with the program’s mandatory five-year investment holding period and subsequent permanent residency or citizenship application plans.
- Tax Structuring & Efficiency: Leverage Portugal’s favorable tax regime and extensive tax benefits, including 0% withholding tax on capital gains for non-tax residents, a reduced 10% tax rate for residents, and no wealth or inheritance taxes, to optimize after-tax returns and global tax obligations.
Integrating these strategic elements enables applicants to achieve strong alignment between Portuguese residency ambitions and investment performance, while supporting
Portugal’s national development priorities. A structured, data-driven approach enhances both regulatory compliance and long-term financial outcomes.
Conclusion
The 2025 Portugal Golden Visa Fund Index highlights the program’s evolution into a sophisticated and economically focused residency pathway. The shift away from real estate toward fund-based investments channels foreign capital directly into priority sectors like renewable energy, technology, hospitality, and agriculture — aligning investor interests with Portugal’s national development goals.
This transition demands higher financial literacy and careful due diligence, as applicants must now assess fund strategies, manager track records, and sector exposures. While diversification exists across funds and industries, the requirement to invest at least 60% in Portuguese companies creates a focused economic impact that supports local growth.
CMVM oversight ensures transparency and investor protection, bolstering confidence in fund selection. Combined with Portugal’s positive economic outlook, minimal stay requirements, and tax advantages, the program remains one of the most attractive options for global investors seeking EU residency and enhanced mobility.
To succeed, investors should pair strategic fund choices with expert legal and financial guidance, ensuring alignment between long-term residency goals and strong financial outcomes.
Sources
- Did The Portugal Golden Visa Program Close? - https://www.goldenvisas.com/did-portugals-golden-visa-program-close
- Portugal: Macroeconomic and financial outlook - CaixaBank Research - https://www.caixabankresearch.com/sites/default/files/content/file/2025/01/14/34411/2025_01_portugal-macro-and-financial-outlook_cbvf_0.pdf
- CMVM - Portal do Investidor - https://investidor.cmvm.pt/PInvestidor/Content?Input=0D0C6D5E24C4866D50F52A463049AD89CE9A81EA5E809F2743E2E5D0CCDA920F
- Portugal Real Estate Market Outlook 2025 - https://www.cbre.pt/en-gb/insights/reports/portugal-real-estate-market-outlook-2025
- Portugal: EIB provides €400 million loan to Santander to boost financing for SMEs and mid-caps and the agricultural sector - https://www.eib.org/en/press/all/2025-199-santander-recebe-400-milhoes-de-euros-do-bei-para-reforcar-financiamento-a-pme-e-midcaps-em-portugal-incluindo-no-setor-agricola
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- Portugal Golden Visa Program: Updated in 25 - AICEP - https://www.portugalglobal.pt/en/news/2025/may/portugal-golden-visa-program-updated-in-2025/
- Portugal Stock Market Trends for 2025 - ACE Money Transfer - https://acemoneytransfer.com/blog/portugal-stock-market-trends-for-2025
- ESG Investing: Why Pela Terra II Scores High – Carbon Offset Analysis - https://www.pelaterra.com/resources/esg-investing-why-pela-terra-ii-scores-high-carbon-offset-analysis
- PPAs are transforming the renewable energy sector in Portugal - https://strategicenergy.eu/ppa-renewable-energy-portugal/
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