Golden Visa in Portugal

The ARI is provided for in Article 90-A of Law 23/2007, of July 4 (Foreigners Act (Lei de Estrangeiros)). The types of investment allowed are defined in Article 3(1)(d) of the same law (Article 3). The implementing rules are in Articles 65-A to 65-K of Regulatory Decree 84/2007 (Decreto Regulamentar), as worded by Regulatory Decree 1/2024.

To be granted the permit, the investor must meet the following requirements simultaneously (Art. 90-A(1)):

• meet the general requirements of Article 77, with the residence visa waived;
• have entered with a valid Schengen visa and regularize their stay within 90 days of first entering Portugal;
• carry out one of the investment activities in Article 3(1)(d) and maintain it for at least five years. This period runs from the date the permit is granted (Art. 65-B of the Regulatory Decree).

What changed in the most recent laws

• Law 56/2023 (Mais Habitação), in force since October 7, 2023: repealed the options of a €1 million capital transfer, real estate purchase and urban regeneration (sub-paragraphs (i), (iii) and (iv)). It amended the fund (vii) and commercial company (viii) options and prohibited the remaining options from being directed, directly or indirectly, to real estate investment. It also made it possible to refuse or cancel the permit for persons subject to European Union restrictive measures.
• Law 61/2025, of October 22: did not change the investment options. It changed the general family reunification regime: it requires accommodation and means of subsistence without recourse to social support, sets a minimum age of 18 for spouses and provides for integration measures. It kept the rule that family members of ARI holders do not need to wait for the two-year residence period required in other cases (Art. 98(3)(c)).
• Law 62/2026, of September 10, in force since September 11, 2026: deals mainly with asylum and the implementation of the European Pact on Migration. It did not touch Article 90-A or the investment options. Among the procedural changes, it establishes that applications for grant and renewal may be filed by the applicant or by their legal representative (Arts. 81 and 81-A) and that the cancellation of a permit must be notified together with its grounds (Art. 85(5)).

The options that currently allow an application for a new ARI are the following (Law 23/2007, Art. 3(1)(d)):

1. Creation of at least 10 jobs (sub-paragraph ii).
2. Transfer of at least €500,000 for scientific research activities carried out by public or private institutions that are part of the national scientific and technological system (sub-paragraph v).
3. Transfer of at least €250,000 for artistic production or for the recovery or maintenance of the national cultural heritage, made through the public or equivalent entities provided for by law (sub-paragraph vi).
4. Transfer of at least €500,000 for the acquisition of units in non-real estate collective investment undertakings set up under Portuguese law. At the time of the investment, the fund must have a maturity of at least five years, and at least 60% of the amount invested must be applied in commercial companies with their registered office in Portugal (sub-paragraph vii).
5. Transfer of at least €500,000 to set up a commercial company with its registered office in Portugal and create five permanent jobs. A capital increase in an existing company is also allowed, provided that at least five permanent jobs are created, or at least ten jobs, of which at least five are permanent, are maintained for at least three years (sub-paragraph viii).

In low-density territories (Ministerial Order 208/2017 (Portaria)), the amounts for options ii), v) and vi) may be 20% lower: 8 jobs, €400,000 and €200,000, respectively. This reduction does not apply to funds or to the commercial company.

The investment may be made personally or through a single-member private limited company (sociedade unipessoal por quotas) of which the applicant is a member. It must have been made at the time of the application and be proven by a statement from a credit institution authorized by the Banco de Portugal attesting to the actual transfer of the amount (Regulatory Decree 84/2007, Arts. 65-A and 65-D).

What is no longer possible

Since October 7, 2023, the law does not accept new applications based on real estate purchase, urban regeneration or a simple €1 million capital transfer. A fund or company used as an indirect vehicle for real estate investment is not allowed either (Art. 3(5)).

Article 42 of Law 56/2023 safeguarded the position of those who already held an ARI:

• ARIs granted under the previous regime, including real estate ones, may continue to be renewed;
• the same rule applies to the grant and renewal of permits for reunified family members;
• holders and their family members who meet the requirements of Article 80 may apply for a permanent ARI;
• applications already pending on October 7, 2023 remained valid (Art. 43).

The law adds that, in these cases, renewal converts the permit into a residence permit for immigrant entrepreneurs (Art. 89(4) of Law 23/2007), keeping the minimum stay of 7 days in the first year and 14 days in each two-year period.

According to AIMA, renewals of ARIs with cards that expired between February 22, 2020 and December 31, 2026 must be requested on the Renewals Portal (AIMA ARI FAQ). Anyone holding an older ARI should have their case analyzed before selling the property or changing the investment, because doing so may jeopardize the renewal.

• Minimum stay: 7 days, consecutive or not, in the first year, and 14 days, consecutive or not, in each subsequent two-year period (Regulatory Decree 84/2007, Art. 65-C).
• Validity: the initial permit is valid for two years from the issue of the card (Art. 75(1) and AIMA information).
• Renewals: these are made for periods of two years, provided the holder proves that they continue to meet the investment requirements (Art. 90-A(2)). The general three-year renewal rule in Article 75 does not apply to the ARI, because Article 90-A has its own rule.
• Requirements for renewal: maintaining the investment, meeting the minimum stay, having means of subsistence and accommodation, having a regular tax and social security position and having no relevant convictions (Arts. 78 and 90-A). The application must be filed at least 30 days before the end of the validity period.

With a valid ARI, the holder may travel within the Schengen area under the general conditions. Ordinary temporary residence permits may be canceled for absences of six consecutive months or eight non-consecutive months (Art. 85(2)). For the ARI, what counts is its own minimum-stay rule.

The family reunification application may be filed together with the investor's application, but depends on the latter being granted. Family members of ARI holders do not need to wait for the two years of residence required in other cases (Law 23/2007, Art. 98(3)(c), as worded by Law 61/2025). According to AIMA, the following may be included, in particular:

• the spouse or partner in a stable union recognized by Portuguese law, both at least 18 years old;
• minor children, or children lacking legal capacity, dependent on the couple or on one of the spouses;
• adult children up to 25 years of age, single, who are studying and dependent on the couple or on one of the spouses;
• 1st-degree ascendants of the investor or of the spouse, provided they are dependent.

AIMA indicates that proof of accommodation and means of subsistence may be requested. Law 61/2025 also provides for integration measures for reunified family members, such as training in the Portuguese language and in constitutional values, on terms to be defined by regulatory decree (AIMA — ARI).

Permanent residence permit

After five years of temporary residence, the holder may apply for permanent residence, provided they meet the requirements of Article 80 of Law 23/2007: no relevant convictions, means of subsistence and accommodation and proof of basic knowledge of Portuguese. An ARI holder receives a permanent ARI, which cannot be canceled under the general rules on absence from the country that apply to permanent residence (Regulatory Decree 84/2007, Art. 65-K).

Citizenship by naturalization

Since May 19, 2026, with Organic Law 1/2026 (Lei Orgânica), naturalization requires seven years of legal residence for nationals of Portuguese-speaking countries, such as Brazil, and for EU citizens. For other foreign nationals, the period is ten years. The following are also required:

• sufficient knowledge of the Portuguese language and culture, history and national symbols;
• knowledge of fundamental rights and duties and of the political organization of the State;
• a declaration of adherence to the principles of the democratic rule of law;
• the ability to support oneself;
• absence of the criminal and security impediments provided for by law.

Periods of legal residence are added together, whether consecutive or not, provided they fall within a maximum window of 9 years for CPLP and EU nationals (Nationality Act (Lei da Nacionalidade), Art. 15). The ARI is a residence permit provided for in the Foreigners Act, so the time during which the investor holds an ARI counts as legal residence. The previous rule, which counted the period from the residence permit application (former Art. 15(4)), has been repealed. Citizenship applications already pending on May 19, 2026 follow the previous law.

According to the fee table published by AIMA, prepared on the basis of Ministerial Order 307/2023, the current amounts for the ARI are as follows. The first amount is the one set in the Ministerial Order; the second, in parentheses, already includes the 25% reduction for applications filed digitally:

• receipt and review of the application for grant or renewal (per applicant, including family members): €842.80 (€632.10);
• grant of the ARI: €8,418.90 (€6,314.20);
• renewal of the ARI: €4,210.30 (€3,157.80);
• grant of a permit to a reunified family member: €8,418.90 (€6,314.20);
• renewal of a reunified family member's permit: €4,210.30 (€3,157.80).

The fees are paid through a Single Collection Document (DUC), issued on the portal or paid at the in-person appointment by bank card. The amounts may be updated, so we check the table in force on the date of each application. The firm's fees are charged separately.

Holding an ARI does not make anyone a tax resident in Portugal. Tax residence depends on the criteria in Article 16 of the IRS Code: a stay of more than 183 days in any 12-month period, or a dwelling that suggests the intention to keep it as a habitual residence. With the ARI minimum stay, the investor may remain a tax resident of Brazil. This requires planning in both countries, including in light of the Brazil–Portugal convention for the avoidance of double taxation.

The investor needs a Portuguese NIF. Those living outside the EU and the EEA may have to appoint a tax representative in Portugal when they have tax obligations in the country (Portal das Finanças).

The former Non-Habitual Resident (NHR) regime was replaced by IFICI (Art. 58-A of the Tax Benefits Statute). This regime applies only to those who become tax residents in Portugal, have not been resident in the previous five years and carry out certain qualified activities. It does not derive from the ARI and does not, in itself, cover passive investment income. We assess whether it may apply on a case-by-case basis, without anticipating outcomes.

1. Analysis of the option: we study the investor's profile, the source of funds, the family's composition and the objectives (residence, mobility, future citizenship) and identify the legally compatible options.
2. Legal due diligence on the investment: we check the documentation of the fund, the company or the beneficiary entity against the legal requirements. In the case of funds, this includes the non-real estate nature, the maturity, the investment of 60% in companies with their registered office in Portugal and the statements required from the management company. We do not recommend specific funds or products, nor do we give opinions on returns.
3. Preparation: obtaining the NIF, tax representation where necessary, support in opening a bank account in Portugal, and gathering, translating and apostilling Brazilian documents.
4. Application at AIMA: pre-registration on the ARI Portal, submission of documents, issue of payment slips, follow-up on the scheduling and the in-person appointment, and responses to notices.
5. Family reunification: family members' applications filed in parallel with the investor's.
6. Renewals and maintenance: monitoring of deadlines, days of stay and maintenance of the investment, followed by the permanent residence application and the citizenship process.
7. Succession planning: coordinating ownership of the investment with international succession planning between Brazil and Portugal.

If AIMA fails to decide within the time limit or rejects the application, we also assess the appropriate administrative and judicial remedies.