Portugal Citizenship Dispute and the “Golden Visa”: What Investors Need to Know

On May 3, the President of Portugal signed an updated citizenship law. For most foreign nationals, the waiting period to apply for citizenship has been extended from 5 to 10 years. For citizens of the EU and the CPLP countries, the timeline has moved from 5 to 7 years. The law takes effect from the day after it is published in the Diário da República.

After more than a year of parliamentary votes, Constitutional Court involvement, and even presidential elections, the situation has finally become clear. Still, for tens of thousands of investors and applicants under the “Golden Visa” program, the key question is practical: how will these changes affect their plans and timelines?

Şafak Nervo, Chief Commercial Officer at Optylon Krea, has advised “Golden Visa” investors in Portugal from Lisbon for more than a decade. Following the signing of the law, she answered the questions her team has been receiving most often.

Has the “Golden Visa” Changed?

No. The “Golden Visa” itself has not been altered. In Nervo’s view, it’s the most common—and most misunderstood—part of the entire discussion. The citizenship law governs citizenship, while the “Golden Visa” program is about residency. These are different legal mechanisms.

The “Golden Visa” program remains a residency-by-investment scheme (RBI). Its core conditions are still in place: an investment of €500,000 into an eligible fund, a residence permit for the investor and family members, travel access across the Schengen Area, and the right to live, work, and study in Portugal. The standard renewal cycle typically involves only around 7 days per year of in-country presence on average.

“Residence, Schengen access, family inclusion, and the ability to live and work in Portugal—none of that has been touched. The program is fully preserved,” Nervo stresses.

What Exactly Changed in the Citizenship Law?

The key change is the waiting period required to obtain citizenship. Previously, holders of the “Golden Visa” could apply for citizenship after five years from the date they submitted their residence application. Under the new rules, most applicants will need ten years. For EU and CPLP citizens, the requirement is seven years.

Just as important is when the clock starts: it now begins from the date the residence permit is issued, not from the date the application is filed.

For investors, this distinction can matter significantly due to processing backlogs and delays at AIMA (the Agency for Integration, Migration and Asylum). In some cases, the gap between application submission and the actual issuance of the permit can be substantial.

“This is no longer speculation. We are working with what the law states and adjusting our guidance for investors based on the rules currently in force,” Nervo says.

If You Already Filed for Citizenship, What Happens?

The law includes provisions intended to protect applicants who have already completed the required five-year period and submitted a citizenship application with a full supporting dossier. As a result, investors who have already applied for citizenship should not be negatively affected by the changes now entering into force.

When signing the law, the President also emphasized that ongoing procedures should not be worsened by legislative changes, and that government delays should not be counted against applicants.

At the same time, it’s important to understand that such wording is not the same as a legally binding rule. However, it may still carry interpretive weight—especially if a case ends up in court in the future.

Can You Get Permanent Residency After Five Years?

“Yes. Nothing has changed there. After five years from receiving the first residence card, you can apply for permanent residency. This status does not expire, does not require additional investment, and does not involve a specific minimum stay requirement in Portugal. The main practical challenge right now is how long it takes to receive the first residence card—the process is taking longer than expected. Still, there are forecasts that timelines will improve,” Nervo explains.

This is the nuance that often gets “lost” in headlines. The five-year milestone still leads to permanent residency—not directly to a passport.

In practice, an investor who reaches this stage may exit the fund, keep permanent residency, and then consider citizenship later with greater flexibility.

What it means for investors: the investment horizon remains five years. Your capital isn’t locked up for a decade. What’s extended is the route to citizenship.

Should Portugal Lower Expectations Now That Citizenship Takes 10 Years?

“In any case, Portugal’s ‘Golden Visa’ remains the only alternative in Europe that can lead to a passport without a requirement to live in the country. That hasn’t changed,” Nervo says.

In most other European residency programs that offer a path to citizenship, applicants are typically expected to relocate physically, spend long periods in-country (often measured in months per year), or meet a combination of both requirements.

Portugal’s “Golden Visa” requires presence of 14 days every two years. If you look at the full ten-year citizenship timeline, total physical presence could amount to less than 70 days.

Other EU countries generally do not offer the same combination of a short in-country requirement, genuine Schengen mobility, family inclusion, and a subsequent route to citizenship. The timeline has increased—but the program’s structural advantage remains.

Does Choosing a Fund Matter More Now?

“Yes—it has always mattered. But the longer investors think about the fact that their capital is inside a fund, the clearer it becomes that the fund must perform and deliver results. The ‘Golden Visa’ is the reason to invest. The fund is the reason your money keeps working while you wait,” Nervo notes.

Ando Europe Fund, which advises Optylon Krea and is managed by Stag Fund Management, focuses on the hospitality sector through the Ando Living brand—Europe’s first lifestyle serviced apartment brand. At least 60% of the fund is invested in Portugal and directed toward hotel infrastructure, including fit-out, furniture and equipment, as well as food and entertainment operations supported by long-term management contracts. The remaining 40% may be allocated to international or other investment categories depending on the fund’s strategy.

The fund structure follows a debt-style model with a target return of 6–8% per year. The instruments are supported by operating companies and lease/management agreements that already generate revenue.

The fund is regulated by CMVM (Comissão do Mercado de Valores Mobiliários), Portugal’s securities regulator. The minimum subscription is €500,000, and the minimum fund maturity period for Ando Europe Fund is five years, aligning with the time logic relevant for eligibility for permanent residency.

What’s the Background?

The Ando Living group—its operating arm—manages more than 2,000 apartments across Portugal, welcomed over 500,000 guests, and processed more than 175,000 bookings. Its yield management system has generated €85 million for property owners. Guest satisfaction exceeds 94%. Gross booking value reached €50 million in 2024, with revenue growth of 94% since 2022.

Optylon Krea structured €200 million of equity across five CMVM-regulated funds and works with more than 800 investors from over 42 countries. The combined track record exceeds €2 billion in gross development value across 38 projects. The group plans to scale to 5,000 units across seven countries by 2028—from Lisbon to Istanbul, Madrid, Paris, London, and Athens.

“We launched our first ‘Golden Visa’ fund in 2018. At the time, the program wasn’t yet mainstream—real estate hadn’t been removed as an option, and most players in the market hadn’t entered the segment yet. We went through every legislative change that affected the program. So when the rules change again, that experience matters,” Nervo adds.

What Should You Do Right Now?

“Get informed. Not from headlines, not from social media, and not from companies still selling the ‘five years’ story. Yes, the law has changed. But the ‘Golden Visa’ itself hasn’t. These are different things, and understanding the distinction is the first step,” Nervo says.

Even while working with investment products, Optylon Krea notes that investors’ main motivations are precisely the “Golden Visa” and the route to citizenship.

Given that responsibility, the company aims to update investors regularly with the most relevant changes and market data. Recently, it prepared a package of answers to the most common questions: materials were shared with four law firms to compare legal positions and provide investors with a clear, consolidated summary.

For investors considering Portugal’s “Golden Visa” in light of the new citizenship law, Optylon Krea offers a confidential, no-obligation consultation to assess eligibility, fund structure, and timelines.

Contact Optylon Krea to learn more.

Expert note on Portugal citizenship law: While investment-based residence programs focus on eligibility timelines, Portugal’s citizenship decisions also rely heavily on administrative interpretation—especially around “effective links” and documentary completeness. In practice, applicants who maintain consistent residency records, keep translations and civil status documents fully aligned with Portuguese requirements, and respond quickly to requests from authorities tend to experience fewer procedural setbacks. This is why many specialists recommend treating the citizenship stage as a compliance process—not just a waiting period—so that the file is ready to move as soon as the legal threshold is reached.

If you’re considering Portugal’s Golden Visa as an investment-based residence permit, changes to the citizenship law mainly affect your timeline and pathway, not the program itself. At Digital Nomad, we help investors understand how the updates may influence residency planning and the next steps— from document preparation to end-to-end guidance. Learn more: https://digital-nomad.gr/en/goldenvisa.

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