Investor risk from the Golden Visa now matters more than property risk: what changed across Europe

Exactly three years ago, a couple from South Africa, Frances and Jordan Wilhoyn, bought a three-bedroom home in Porto-Heli (eastern Peloponnese) for €275,000. The deal included a Greek “golden visa” tied to the property: the couple lived in the home, and at other times rented it out on Airbnb. During the peak months of the Greek summer, they earned €250–€300 per night. Since then, the property has risen to roughly €325,000, and the residence permit provided freedom to travel across the Schengen Area. In effect, the investment functioned like an income-producing asset and a lifestyle support tool.

In 2023, Migronis described this case in detail and presented it as one of the “cleanest” early examples of how the program worked: buying real estate in a desirable location, obtaining a residence permit, and generating income—all in one operation.

Today, you can’t replicate that setup. If, in 2024, an investor entered a similar property in Athens (for example, in areas like Pangrati or Glyfada), the threshold for central zones had already changed twice within 18 months: from €250,000 to €500,000, and then up to €800,000. At the same time, restrictions were introduced on short-term rentals of properties purchased under the program; violations could lead to a €50,000 fine.

Importantly, Greece’s economy didn’t collapse. The euro didn’t crash, and tourism didn’t weaken. The country’s GDP grew by 2.3% in 2024 and by 2.1% in 2025. So this wasn’t a story about weak fundamentals.

The problem was elsewhere: one specific buyer category—an investor who built a model around real-estate yield—ran into the fact that “the world” they were buying changed. According to a consulting firm with offices in Greece and the Netherlands, quoted in the Greek press, demand from non-EU buyers fell by 83% year over year.

This isn’t only a Greek story. In April 2025, Spain fully shut down its Golden Visa program, removing tens of thousands of annual property deals from the Spanish market that were driven by third-country citizens.

In the same month, the European Court of Justice (ECJ) ruled that Malta’s citizenship by investment (CBI) program is incompatible with EU law—because it “commodified” citizenship. Three months later, Malta wound down the program. It was the only “passport for investment” route in Europe that closed not by parliamentary decision, but via a court ruling.

Portugal had already removed real estate from its Golden Visa route in October 2023. And on May 3, the President of Portugal signed an updated citizenship law: the standard naturalization period was doubled—from 5 to 10 years (for EU and CPLP citizens—7 years). The law is expected to be published in the Diário da República.

Spain, Malta, Portugal, and Greece rewrote the rules for residence permits tied to property purchases within the last 24 months. Investors who “priced” deals based on rules from two years ago now have to recalculate the economics from scratch.

For anyone continuing to work with this market, the takeaway looks bigger than it may seem at first glance: regulatory changes stopped being a “background variable” and became a pricing-defining factor.

How to read the program before choosing a property

Previously, buying real estate that grants a residence permit (or citizenship) could be assessed using the same tools as a standard investment: currency risk, vacancy assumptions, loan interest rates, and the local price cycle. The law always existed “in the background,” and a diligent advisor tracked it—but the pace of change was so fast that it started to feel like part of the “interior” rather than something external.

After major EU programs were reshaped dramatically over the past two years, the approach changed. Now serious market players spend as much time analyzing how the program might evolve over a 5-year horizon as they do analyzing the property itself.

In practice, program stability can be assessed using three indicators.

First—legislative track record. How often have the rules changed over the last five years?

For example, in Greece, the threshold for “prime zones” increased twice within 18 months. In Portugal, in 2023 there was a shift away from real estate; then in 2026, the naturalization period is planned to double. Turkey changed its property threshold once—from $250,000 to $400,000 in June 2022—and has not returned to adjustments since.

Second—political vulnerability. If a route becomes publicly discussed as a driver of housing price growth, it can easily become a political target. Spain and Portugal experienced a similar scenario: during reforms, the program was framed as a housing affordability problem, and once that narrative took hold, political support for the route weakened sharply.

In Greece, the same mechanism is now visible: if the residence-permit program is regularly covered by local media as a driver of housing prices, it should be treated as politically sensitive.

Third—distance to the next national or parliamentary elections. Programs rarely change “in a vacuum.” They get adjusted when someone moves against them. For an investor with a 5-year holding horizon, it’s easier to “bet on” the rules of a country that is 3–4 years away from elections than on a jurisdiction where only 6 months remain.

Where stability still exists

Within the EU, options have narrowed overall. Hungary restarted its Guest Investor Program in July 2024. Today, it is one of the most “transparent” ways to obtain a residence permit via investment: €250,000 into an approved real-estate fund regulated by the National Bank of Hungary; a 10-year permit with the possibility of extension for another 10; no minimum residence requirement; and a path to citizenship possible after 8 years.

What matters is that the fund-based route is effectively the only one. A direct real-estate option worth €500,000 that had been included in the initial draft was removed in January 2025 before it could be used. Hungary did what Greece and Portugal did later—but earlier: it “packaged” the program around a fund, not around a direct property purchase.

In Malta, there is still a track for residency only: the Malta Permanent Residence Programme (MPRP) requires €375,000 in real estate. Like other EU permanent residence programs, it can theoretically lead to citizenship, but only through standard naturalization: roughly 5 years of actual residence in Malta plus a Maltese language test at A2 level.

Looking beyond the EU but still within Europe, the most consistent option right now is Turkey. The real-estate-based citizenship by investment threshold has stayed at $400,000 since June 2022, despite periodic market talk about raising it to $500,000.

The program is designed for a 3-year holding period. Property is the main and dominant route. Unlike the Greek model, however, the investor receives a passport, not a residence permit. In advisors’ funnels, it’s clear that the share of clients considering Turkey instead of Greece has increased noticeably over the last 18 months.

This is especially visible among clients who already have a strong primary passport and view a second citizenship as a Plan B (a backup jurisdiction if the main option becomes inconvenient), rather than as an “upgrade.”

Like the Turkish route, Latin American CBI programs do not offer an EU passport. But they provide what European routes are moving away from more and more: short and predictable timelines and stable thresholds.

Brazil keeps residency criteria via real estate at BRL 1,000,000 (about $190,000) for most regions and BRL 700,000 (about $133,000) for the North and North-East regions. The threshold hasn’t changed.

The key advantage is that Brazil’s real-estate demand isn’t propped up only by the program. For example, in Florianópolis (where the author lives), prices have been rising by nearly 10% year over year according to FipeZAP data through mid-2025. And in the high-end segment, the value of sales increased by 170% by transaction volume between 2024 and 2025. Here, the foreign buyer is essentially buying into a market that would keep growing even if the residence-permit program disappeared tomorrow.

Costa Rica’s investor visa is smaller in scale: $150,000 since 2021. But threshold stability reinforces the same point.

The biggest change of the decade: property and the program have effectively “decoupled”

The most important change in recent years — according to the author — is something that valuation models still often fail to account for. Previously, the decision to buy property and the decision to obtain a residence permit or passport were, in practice, one and the same action.

The Greek model in its previous form, the Spanish program, and Portugal before 2023 all sold a single package: the property generated income, simultaneously supported eligibility for residency, and in the future helped the passport application. Now, that logic is largely disappearing across Europe.

In practice, investors have to ask two separate sets of questions. First: where do I want to own real estate as an asset? Second: which specific residence-permit or citizenship route gives me the rights I truly want?

For instance, in Portugal, real estate still works on its own market terms and remains a serious investment. But the path to a Portuguese passport is now tied to the fund-based Golden Visa route, and the naturalization timeline has lengthened. In Turkey and in Latin America, the “package” also exists—though there it’s often a faster route to citizenship, with no EU rights.

Separately, there are smaller CBI programs in Caribbean and Pacific countries (Dominica, Saint Kitts and Nevis, Vanuatu, etc.) that allow you to add a jurisdiction to a “flags portfolio” without buying real estate.

The most difficult client to advise this year isn’t the one who doesn’t understand the math. The hardest is the one who built a model in 2023 and didn’t update it. The baseline standard now is to price legislative risk directly into the deal and to treat property and the program as two separate decisions rather than one “bundled” product.

Considering a Golden Visa and want to understand how investor risks—thresholds, regulations, and rental limits—have shifted across Europe? Digital Nomad supports you with a clear assessment of entry scenarios, potential returns, and legal constraints so your investment stays predictable. Book a consultation to build a strategy aligned with today’s rules.

Our Telegram channel about various types of Greek residence permits, digital nomad programs, and the Greek Golden Visa: @digitalnomadgr