Portugal: inflows into Golden Visa funds triple the redemption volume, despite changes to the citizenship law

Between January and May 2026, investors pulled €94.7 million (about $108 million) from Portuguese investment funds that qualify under the Golden Visa program. According to the Portuguese association for investment funds, pension funds and assets, APFIPP, this is more than twice the amount redeemed over the entire 2025 year, when €45.3 million (about $52 million) was bought back.

At the same time, redemptions picked up noticeably at the start of the year: in January, the figure was roughly €20 million, and then remained at a similar level for several months. Previously, outflows in this segment typically did not exceed €5 million per month.

Meanwhile, APFIPP also reports strong interest in new products: fund subscriptions from January to May totaled €283 million.

First the rush, then the turnaround

Throughout 2025, foreign investors directed a record €732 million (about $834 million) into the funds. Demand was likely supported by expectations that future legislative changes would not affect the rights and timelines of investors who had already put money in.

However, after the new rules took effect, investors accelerated applications for early redemption. The revised Portugal citizenship law began applying on 19 May 2026. For most third-country nationals, the residence period required for naturalization was extended from 5 to 10 years. For EU citizens and people from Portuguese-speaking countries, the requirement rises to 7 years.

One possible explanation for the spike in redemptions in 2026 is not necessarily declining confidence in the model itself. Some buybacks may involve investors who entered late to meet the old rules, and then started winding down positions once the implications of the reform became clearer.

Fund managers don’t see panic

Alexandre Cunha Elias, head of 3 Comma Capital (3CC), the firm that manages a fund meeting Golden Visa criteria, said that redemptions among his clients are limited.

“After the law changed, we saw fewer than half a dozen redemptions within our investor base,” he said. In his view, the impact on the portfolio is “to a large extent immaterial” and “nowhere near the level that would suggest a loss of confidence in the route via the fund.”

At the same time, Cunha called the changes to naturalization timelines “very disappointing,” arguing that the law did not include protective measures for those who had already invested under the Golden Visa. He also emphasized that these funds have been “substantially helping Portugal,” supporting business, employment and economic growth.

A similar stance was shared by Pedro Oliveira from Optimize Investment Partners, another manager of a Golden Visa fund. He noted that redemptions remain lower than the inflow of new investors.

“A small share of our investors has indeed taken up redemption, but we continue to see strong demand: new subscriptions are clearly higher than redemptions,” he said. In his assessment, “this year new investments are more than five times higher than redemptions.”

Like Cunha, Oliveira criticizes the legal changes, but is more cautious about how the market is responding. He believes the reaction is “to a large extent driven by misconceptions about the law’s practical impact.” In his view, the actual effect is limited: “the key benefits of the program are preserved,” with the main change being the timing—the waiting period before citizenship.

Potential recovery: demand may shift back toward stronger funds

Oliveira believes the situation will gradually “sort itself out.” He says investors have become more selective and are assessing not only whether the program is involved, but also the fund’s track record, liquidity, corporate governance and long-term returns. In his view, this approach “separated stronger funds from weaker ones” and redirected demand toward managers that have already proven themselves.

Cunha expects redemption rates to begin easing over the course of the year. “Our position is that the redemption trend will gradually slow down, and investment activity will start to revive from September,” he said.

He also links the outlook to broader trends across Europe. Following an EU Court ruling last year that affected Malta’s citizenship scheme, he believes competing programs will be forced to tighten access to citizenship even further. Against this backdrop, Cunha thinks Portugal may “return to being the strongest option in Europe”—primarily because the residence threshold remains highly attractive: just 7 days per year.

It looks like, after the updated naturalization rules, investors in Portugal are moving faster: Golden Visa demand and related investment products remain strong, while early redemptions can create noticeable shifts in fund inflows. If you’re considering an investment residence permit and want to assess legal-change risks and timelines in advance, the team at Digital Nomad will help you choose the right strategy for your situation—from investment structuring to full document support.

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