Portugal's golden visa requires a €500,000 investment in a qualifying fund and seven days a year of presence, and since May 2026 it leads to citizenship after ten years rather than five. Greece's requires a property purchase from €250,000 to €800,000 depending on location and type, has no minimum stay, and leads to citizenship after seven years of residence with language and integration tests. For the first time since the two programs were created, Greece offers the shorter path to an EU passport. Which is right depends on whether the applicant wants a light touch base or a home, and on how much the passport itself matters against the residence.
At a glance
- Portugal: €500,000 in a CMVM-regulated fund (the property route closed in October 2023); seven days a year of presence; citizenship after ten years, or seven for nationals of Portuguese-speaking countries, under Lei Orgânica 1/2026 in force from 19 May 2026.
- Greece: property purchase of €800,000 in Athens, Thessaloniki, Mykonos, Santorini and larger islands, €400,000 elsewhere, or €250,000 for conversions of commercial property and listed-building restorations; no minimum stay; citizenship after seven years of residence with tests.
- Greek permits are five-year and renewable; Portuguese permits run two years then three, with renewals tied to the presence requirement.
- Greece's Ministry Circular 1/2026 of April 2026 clarified the 120 square metre minimum (main areas only), the single-property rule, and the ban on short-term letting, which carries a €50,000 fine.
- Neither program requires the applicant to work or to speak the language to obtain or renew the residence permit; both require language for citizenship.
What changed in Portugal in 2026?
Portugal's naturalisation period was five years, which made its golden visa the fastest investment route to an EU passport in Europe: five years of a permit that needed only a week's presence each year. Lei Orgânica 1/2026, in force from 19 May 2026, extended the period to ten years for most nationalities and seven for nationals of Portuguese-speaking countries, and revoked the route for descendants of Sephardic Jews. Applicants who had already reached five years and applied before the law took effect are assessed under the old rule; everyone else is on the new one.
The residence permit itself did not change. The fund route, the presence requirement and the family inclusion rules are as they were, and for an investor whose objective is an EU residence base rather than a passport, Portugal is exactly as attractive as it was in April. What changed is the answer to the question "how soon can I be an EU citizen", and that answer is now Greece.
What does each program cost, all in?
Portugal's entry ticket is €500,000 into a qualifying fund, which is invested rather than spent and is returned, with whatever gain or loss the fund produces, at maturity, typically after six to eight years. Government fees for the permit and its renewals, legal fees and fund subscription costs add roughly €25,000 to €40,000 over the first five years for a family; Passport Legacy's separate guide to the Portuguese fund route itemises them.
Greece's entry ticket is a property. In the highest-demand areas it is €800,000, elsewhere €400,000, and for the conversion of commercial premises into residential use or the restoration of a listed building it is €250,000, provided the conversion is complete before the permit application. Property transfer tax, legal and notary fees and the permit fees add roughly 10% to 12% to the purchase price. The property is an asset the family owns and can live in; it cannot be let on short-term platforms, and since 2026 it must be a single property of at least 120 square metres of main living area on the €400,000 and €800,000 tiers.
How much time must be spent in each country?
Portugal asks for seven days in the first year and fourteen in each subsequent two-year period. Greece asks for nothing: the permit can be held by someone who never sets foot in the country after the purchase. On the residence permit alone, Greece is the lighter obligation.
Citizenship reverses the picture. Both countries naturalise residents, not permit holders, and both require the applicant to have actually lived in the country for the qualifying period, to speak the language to a tested standard, and to show integration. A Greek golden visa holder who never lives in Greece will not become Greek after seven years; a Portuguese one who spends a week a year in Portugal will not become Portuguese after ten. The shorter Greek path is available only to a family that moves.
How do the two compare on tax?
Neither permit makes the holder tax resident by itself; residence for tax follows presence and centre of life. Portugal's former non-habitual resident regime closed to new applicants in 2024 and was replaced by a narrower incentive for research and innovation professionals. Greece offers a flat annual tax of €100,000 on foreign-source income for new tax residents who invest €500,000 in the country, which for a wealthy family that intends to move can be decisive. A family that does not intend to move is not affected by either regime and should choose on residence and property grounds alone.
Which should a given applicant choose?
Choose Portugal if the objective is an EU residence base with the lightest possible obligations, no property to manage, capital that is invested rather than spent, and a passport that is welcome if it comes but is not the point. Choose Greece if the objective is a home in Europe, a passport within a decade, and a willingness to live in Greece for most of the qualifying period; the property is cheaper to enter at the lower tiers, the timeline to citizenship is three years shorter, and the tax regime rewards those who relocate. Families who want both a European home and a fast second passport often pair a Greek golden visa with a Caribbean citizenship, and Passport Legacy structures that combination regularly.
Frequently asked questions
Can I still get Portuguese citizenship in five years?
Only if the five-year period was completed and the application filed before Lei Orgânica 1/2026 took effect on 19 May 2026. New applicants are subject to the ten-year rule, or seven years for nationals of Portuguese-speaking countries.
Does the Greek golden visa require me to live in Greece?
No, not to obtain or renew the permit. Citizenship after seven years does require actual residence, language and integration.
Can I rent out a Greek golden visa property?
Long-term letting is permitted. Short-term letting through platforms is prohibited, with a fine of €50,000 and the risk of losing the permit.
Passport Legacy advises on both programs and on their combination with citizenship options elsewhere. To compare them for a specific family, contact the team.
.webp)
.webp)
.webp)
.webp)
.webp)
.webp)
