Portugal vs Greece Golden Visa: Cost, Stay Rules and Citizenship

Portugal and Greece run two of the best-known residence-by-investment programmes still open in the EU, and they can look interchangeable: a few hundred thousand euros, a Schengen residence permit, family included. They are different products. As of September 2026, Portugal’s route runs through funds, research, culture or job creation rather than property, asks for about a week a year there, and leads to permanent residence after five years and, for most nationalities, citizenship after ten. Greece’s route is mostly property priced by location, asks for no time there at all, and leads to citizenship only for people who move there.

What qualifies, and what the money actually buys

• Portugal, funds: €500,000 in Portuguese non-property funds with at least five years to run and at least 60% invested in Portuguese companies.
• Portugal, other routes: €500,000 for scientific research, €250,000 for the arts or cultural heritage, creating ten jobs, or €500,000 of company capital plus five permanent jobs. Since October 2023 no route may go into property, directly or indirectly.
• Greece, property: €800,000 in Attica, the Thessaloniki area, Mykonos, Santorini and islands of over 3,100 people, and €400,000 elsewhere — in both cases a single property of at least 120 square metres.
• Greece, €250,000: converting a commercial building to residential use, or restoring a listed building.
• Greece, other routes: from €350,000 in qualifying Greek-focused funds, €500,000 in Greek bank deposits or government bonds, and a €250,000 start-up route with job-creation conditions.

The Portuguese fund route buys units in a supervised fund you do not control, locked up for years and charging fees; the research and cultural routes are generally contributions rather than capital you get back. Greek property is a home you can use or let on a long lease, but not on holiday-rental platforms: short-term letting of golden visa property is banned, and a breach can cost the permit plus a fine that Greek lawyers put at €50,000 or more. The Greek permit does not allow its holder to take a job in Greece, whereas a Portuguese investment permit allows work.

Time in the country, permanent residence and a passport

Portugal requires seven days in the first year and fourteen in each following two-year period. After five years of holding the permit, a holder with basic Portuguese, adequate means and housing can apply for permanent residence, which does not depend on keeping the investment. Greece requires no days at all; its five-year permit renews while the investment is kept but, held from abroad, leads nowhere further. Greek naturalisation needs seven continuous years of lawful residence — the investor permit is among the titles that count — plus evidence of economic and social integration, such as Greek tax and social-security records, and a pass in an exam testing Greek at roughly B1 level alongside history and institutions. For someone who moves, that is shorter than the ten years Portugal asks of most nationalities; for someone who stays away, it is out of reach.

Portugal’s parliament passed a tighter nationality law in October 2025; on 15 December the Constitutional Court, at the request of Socialist deputies, struck down four provisions — including a transitional rule affecting applications already pending — but did not strike down the longer residence periods or the new counting rule. A revised text, re-approved on 1 April 2026, took effect on 19 May as Organic Law 1/2026. It sets ten years of legal residence, seven for EU and Portuguese-speaking (CPLP) nationals, repeals the 2024 rule that started the clock on the date of the permit application, and adds a test of Portuguese culture, history and national symbols. Applications filed earlier follow the old law. A group of investors still waiting for AIMA, the immigration agency, to issue their permits has complained to the Ombudsman and threatened litigation; as of September 2026, no court has ruled.

Take a hypothetical non-EU investor who files in October 2026, and assume her Portuguese card arrives 18 months later or her Greek one after nine. In Portugal, meeting the minimum stay, she could apply for permanent residence around April 2033 and for citizenship around April 2038, if she passes the tests (the old rules pointed to late 2031). In Greece, if she never moves, the permit is simply renewed every five years. If she moves and genuinely lives there, a naturalisation application could open around 2034 — roughly four years sooner than in Portugal — but only with B1 Greek and, in practice, years as a Greek tax resident.

Family, processing, tax and risk

Portugal’s permit extends to a spouse or partner, minor children, dependent adult children in education and dependent parents, and investment-permit holders are exempt from the two-year wait for family reunification introduced in October 2025. Greece covers a spouse or partner, children generally up to 21 and both spouses’ parents. Processing currently favours Greece. In Portugal, filing to card has commonly taken one to three years or more in AIMA’s backlog. Greece’s backlog, counting family members, peaked above 52,000 files in early 2025 and had fallen to about 29,000 by the end of July 2026, according to ministry data reported by trade press, with complete recent files often decided within months.

Neither permit makes anyone tax resident; that generally turns on spending over 183 days a year in the country or making it your main home. For those who move, Greece offers special regimes as of September 2026, including a flat €100,000 a year on foreign income for people investing €500,000 or more and 7% on foreign pensions; Portugal closed its non-habitual resident regime to newcomers in 2024 and replaced it with a narrower incentive for research and innovation roles. On risk the two are alike: the investment can lose value whatever happens to the permit, funds are locked up, property is slow and costly to sell, and both governments have changed the rules at short notice — Portugal in 2023 and 2026, Greece in 2023 and 2024.

Who each tends to suit

Portugal tends to suit someone who does not plan to move soon, wants permanent residence at five years for about a week a year, may want citizenship later without relocating, and is comfortable holding a fund rather than property. It suits less well anyone who needs a passport within a decade. Greece tends to suit someone who wants to own and use a home there, wants no presence obligation, or genuinely intends to relocate and learn Greek — for them the path to citizenship can be shorter. It suits less well anyone counting on holiday-let income or a passport without moving. This is general education as of September 2026, not financial, tax, legal or immigration advice; check official sources and a licensed immigration lawyer before committing money.

This article is educational and general in nature. It isn’t personalized investment, tax, or legal advice — always weigh your own circumstances, or talk to a licensed professional, before making financial decisions.

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