Alex Recouso is the Cofounder and CEO of CitizenX.
In recent years, the Portuguese Golden Visa has emerged as one of the most talked-about residency by investment programs.
For high-net-worth individuals seeking mobility and a potential Plan B, this European Golden Visa often appears at the top of recommendation lists. Portugal residency opens opportunities beyond European mobility. Residents gain access to Portugal’s healthcare system, educational institutions and social services.
However, for Americans specifically, this popular program may not deliver despite its reputation.
Investment Options And Requirements
The Portuguese Golden Visa requirements have changed significantly, eliminating real estate investments as a qualifying investment route.
Now, applicants must choose from alternatives including €500,000 capital transfers to investment funds, AIMA-regulated fund investments supporting Portuguese businesses and permanent job creation, €500,000 private equity investments in Portuguese companies or venture capital funds, scientific research activities (€500,000), national cultural heritage or artistic production support (€250,000), among others.
Investment requirements vary by pathway, with program criteria continuously changing as the Portuguese government adjusts regulations. Beyond the minimum investment requirement, potential Golden Visa investors should also be aware of:
• Initial application fees.
• Biometrics and residence card issuance fees.
• Due diligence costs.
• Renewal fees (every 2 years).
No Full-Time Portuguese Residency Requirement
Golden Visa holders’ residency requirement is just 14 days every two years to maintain legal residency status (and 21 days for the subsequent three years). This flexibility attracts HNWIs and families who don’t want to relocate full-time or change their country of residence from a taxation standpoint.
This creates tax benefits for Americans by avoiding double taxation. Since U.S. citizens are subject to global taxation, becoming a tax resident in Portugal (by staying 183-plus days annually) would create additional obligations without necessarily eliminating U.S. tax liability.
Limitations Of The Portuguese Golden Visa
The Portuguese Golden Visa is a residency by investment program, not a direct path to citizenship. This distinction is crucial, as you’re investing in a residence permit for investment activity (ARI)—not a Portuguese passport.
This creates challenges for the main applicant and family members:
1. Long Path To Portuguese Citizenship
While the permanent residency processing time does count toward the five-year residency requirement for naturalization eligibility, the total Golden Visa application process extends much further than the initial 5-year period until naturalization is possible.
I’ve found this often results in a 6-7 year wait for a Portuguese passport—hardly an efficient Plan B for Americans seeking immediate optionality.
2. Unprecedented Delays
The Portugal Golden Visa program is experiencing significant backlogs at the Portuguese Immigration and Borders Service (formerly known as SEF). The average processing time reached 38.3 months in Q4 2024.
3. The Language Barrier And Other Requirements
Obtaining Portuguese citizenship requires passing a language proficiency test at the A2 level. While not insurmountable, this represents an additional hurdle that other citizenship programs don’t impose.
The golden visa application process also requires a tax identification number (NIF), a Portuguese bank account, health insurance, a clean criminal record and a final biometrics appointment.
Why Americans Should Consider Alternatives
Given these limitations, Americans should carefully evaluate whether the Portuguese Golden Visa aligns with their specific objectives:
1. Better Alternatives For Full-Time Relocation To Europe
If your goal is to live in Portugal and enjoy its high quality of life in cities like Lisbon or Porto, other options such as the D7 visa can offer a more cost-effective solution. This visa requires no minimum investment but does have higher presence requirements.
There are other options based on ancestral connections to European countries, such as the Sephardic Jews laws or citizenship by descent programs that provide access to European Union benefits and visa-free travel throughout the Schengen area without the investment requirements.
2. Limited Mobility Enhancement For Americans
Americans already enjoy visa-free travel to the Schengen Area for 90 days within any 180-day period. A Portuguese residency card offers incremental benefits in terms of longer stays but doesn’t substantially enhance mobility.
3. A True Plan B: Citizenship Vs. Residency
Residency without citizenship provides limited protection against political instability. You cannot renounce U.S. citizenship based on Portuguese residency alone, and the residence permit itself could potentially be revoked under extreme circumstances.
Non-EU Alternatives For Americans
Americans looking for genuine diversification might consider more geopolitically neutral options:
1. Caribbean Countries
Countries like St. Kitts and Nevis or St. Lucia offer citizenship through investment programs with processing times measured in months (not years), lower minimum investment amounts and no visit or minimum stay requirements. These are some of the world’s strongest passports, with visa-free access to 140-plus countries, including the European Schengen Area.
2. South Pacific Region
Vanuatu’s citizenship program offers one of the fastest routes to a second passport. While offering fewer visa-free destinations than EU passports, Vanuatu provides geopolitical diversification away from Western alliances.
3. Central And South America
Newer programs like El Salvador’s Freedom Visa require a significant contribution of $1 million in Bitcoin or U.S. dollars but offer efficient processing and significant upside in a rapidly growing economy.
Making The Best Choice For Your Needs
Despite these limitations, the Portuguese Golden Visa may still be appropriate for some Americans, such as those seeking a long-term nomadic lifestyle throughout Europe, where the minimal physical presence requirement is advantageous. This may also be a good choice for investors planning on a multi-decade horizon, where the timeline to become EU citizens is less critical. For example, a client for whom the Portuguese Golden Visa was a great fit was a U.S. citizen who had previously invested in Caribbean citizenship as a plan B and wanted to further diversify with a third passport.
The ideal citizenship strategy should consider both short-term needs and long-term risks. A truly robust passport portfolio involves diversifying investment opportunities across different geopolitical spheres.
Before committing capital to any residency by investment program, Americans should carefully evaluate their objectives and time horizons.
For Americans seeking citizenship elsewhere, the Portuguese Golden Visa’s reputation might exceed its utility. While it does offer a path to European citizenship, the timeline, costs and practical limitations may outweigh the benefits for many U.S. citizens.
The information provided here is not legal advice and does not purport to be a substitute for advice of counsel on any specific matter. For legal advice, you should consult with an attorney concerning your specific situation.
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