How to Choose a Portugal Golden Visa Fund

A Portugal Golden Visa fund must be authorised by the CMVM, Portugal’s securities regulator, invest at least 60% of its capital in companies with their head office in Portugal, and have at least five years to run when the investor subscribes. Within those rules there are dozens of funds, and the differences that matter are strategy, total fees, maturity and exit terms, the manager’s record, and the fund’s written confirmation that it meets the Golden Visa criteria. The €500,000 is invested, not spent, so choosing the fund is an investment decision as much as an immigration one.

At a glance

• Rules: CMVM-regulated, at least 60% in Portuguese companies, at least five years to maturity at subscription.
• Real estate funds have not qualified since October 2023.
• Typical fees: a subscription fee of 1% to 3% and an annual management fee of 1% to 2%, plus a share of profits in many funds.
• Capital is at risk and returns are not guaranteed.
• The fund manager issues the declaration that AIMA requires.

What makes a fund eligible?

The rules come from the Golden Visa legislation as amended in 2023. The fund must be a collective investment undertaking authorised by the CMVM, must invest at least 60% of its assets in commercial companies with a head office in Portugal, and must have a maturity of at least five years at the time of the investment. Funds that invest directly or indirectly in real estate have been excluded since October 2023. The investor must subscribe with money transferred from abroad and hold the units for the life of the permit.

Question 1: what does the fund invest in?

Eligible funds include private equity funds that buy and grow Portuguese companies, venture capital funds that back start-ups, and sector funds focused on areas such as renewable energy, healthcare, hospitality operations, agriculture and technology. Each carries a different risk. An investor should read the investment policy, understand how concentrated the portfolio will be, and ask how much of the fund is already invested.

Question 2: what does it cost in total?

Headline fees understate the real cost. Investors should add the subscription fee, the annual management fee across the full term, any performance fee or carried interest, and the fund’s own operating costs. Over a six to eight year term, the difference between a lean fund and an expensive one can be tens of thousands of euros on a €500,000 investment.

Question 3: when and how do I get my money back?

Most funds are closed-ended, returning capital when assets are sold at the end of the term, which is often six to ten years. Some offer redemption windows. An investor should know the expected maturity, the conditions for any extension, whether redemptions can be suspended, and how the timing fits the five years needed for permanent residence and the ten needed for citizenship.

Question 4: who manages the fund?

The manager’s track record, the size of its team, the depositary bank, the auditor and how often the fund reports its net asset value all matter. A manager that has raised and returned capital before is a different proposition from one launching its first fund.

Question 5: will AIMA accept it?

The fund manager should provide a declaration confirming that the fund meets the Golden Visa criteria and that the subscription was made with funds from abroad. Investors should ask for it in advance and check that the fund’s documents support it, because AIMA assesses eligibility, not the marketing material.

Question 6: does it fit the investor’s wider plan?

The fund will sit in the investor’s portfolio for years and may have tax consequences in their country of residence. Independent financial and tax advice before subscribing is worth its cost.

Frequently asked questions

Can a Golden Visa fund invest in property?

No. Funds investing directly or indirectly in real estate have not qualified since October 2023.

Is my €500,000 guaranteed?

No. Golden Visa funds are investments and capital is at risk. Returns depend on the fund’s performance.

Can I split the investment across several funds?

Yes, provided the total reaches €500,000 and each fund meets the eligibility rules.

Passport Legacy works with regulated Portuguese fund managers and independent counsel. To compare qualifying funds for a specific family, contact the team.