Greece vs Portugal Golden Visa 2026 — Real Estate Route Verdict
Portugal closed property Golden Visa · Greece's €250k commercial-to-residential channel remains open
Verdict
Portugal closed the real-estate investment route for its Golden Visa, while Greece retains qualifying property routes with €250k, €400k and €800k thresholds depending on property type and location. Family eligibility, renewal, presence, biometrics and travel rules must be checked under the current official framework.
1. Program Background & Legal Basis
The Portuguese Golden Visa (ARI) was once the benchmark European real-estate investment migration program. However, the Mais Habitação Act passed in October 2023 closed the real-estate investment route, retaining only fund, scientific research, and artistic donation channels. Concurrently, Portugal's NHR tax preferential regime ended in 2024. The Greek Golden Visa continued to maintain a real-estate route after the 2024 reform (Law 5038/2023), including the commercial-to-residential €250k exemption. This article provides a point-by-point comparison based on the official legal frameworks of both countries to support an international applicant's decision.
2. Side-by-Side Comparison
Based on official legal/policy documents of both countries, comparing 10 key dimensions.
Minimum Investment
Real Estate Investment Supported
Residency Requirement
Processing Time
Family Coverage
Schengen Access
Citizenship Path
Permanent Residence Validity
Tax Preferences
Legal Basis
| Dimension | 🇬🇷 Greece | 🇵🇹 Portugal |
|---|---|---|
| 01Minimum Investment | €250,000 (commercial-to-residential / protected heritage restoration) | €500,000 (fund) / €250,000 (artistic donation) / real estate route closed |
| 02Real Estate Investment Supported | ✅ Supported (primary route) | ❌ Closed since October 2023 |
| 03Residency Requirement | 0 days/year (no minimum stay) | 14 days first 2 years + 14 days every 2 years thereafter |
| 04Processing Time | Case-specific: transaction, documents, appointments and authority workload | Check the current official process and backlog |
| 05Family Coverage | Principal + spouse + unmarried children under 21 + parents of both spouses (three generations) | Principal + spouse + children (parent conditions strict) |
| 06Schengen Access | ✅ 29 countries | ✅ 29 countries |
| 07Citizenship Path | 7 years (subject to tax residency conditions) | 5 years (language exam + residency requirement) |
| 08Permanent Residence Validity | 5-year renewable indefinitely; convertible to EU LTR after 5 years | 2 years initial + 2-year renewals |
| 09Tax Preferences | Non-Dom application available (€100,000 annual flat tax) | NHR ended 2024 |
| 10Legal Basis | Law 5038/2023 | Law 23/2007 (frozen by 2023 amendments) |
Gold-highlighted rows show dimensions where Greece is significantly advantaged. Data based on public legal texts as of May 2026; OULANG INTERNATIONAL does not assume responsibility for data currency. Confirm with current regulations before formal application.
🇬🇷 Greek Advantages
- ✓Real-estate investment route still open (Portugal closed)
- ✓€250k commercial-to-residential threshold — lowest active Golden Visa in Europe
- ✓Different residence-maintenance, presence and biometric rules that must be verified under current law
- ✓Three-generation coverage — Portugal's parent eligibility is stricter
- ✓A property route remains available in Greece, while Portugal closed its property route; current processing must be checked case by case
- ✓Non-Dom tax preferences (€100k/year flat tax) still active — NHR ended
🇵🇹 Portugal Limitations / Restrictions
- ✗Real-estate investment Golden Visa route completely closed since October 2023
- ✗NHR tax preferences ended 2024 — significantly reduced appeal for wealthy clients
- ✗Fund route threshold ≥€500k + 5-year lockup, poor liquidity
- ✗Severe processing backlog: new applications 8–14+ months
- ✗Residency requirement low but still requires annual entry
3. Which Audience Fits Which Program
International families seeking a real-estate-based residence route, value for money, three-generation coverage and long-term European education planning
High-net-worth individuals with existing Portuguese business / research / cultural connections willing to pursue fund or donation routes
4. Real Client Scenario (OULANG 2024–2026 Records)
Illustrative decision scenario: a family comparing Portugal and Greece should verify which investment routes remain open, whether a specific property qualifies, which relatives can be included and what residence or travel conditions apply. This is a planning example, not a client result or approval promise.
5. Frequently Asked Questions
Can the Portuguese Golden Visa still be obtained after closure?+
Yes, but only via fund (≥€500k), artistic donation (≥€250k), scientific donation (≥€500k), or business investment (creating 10 jobs) routes. The real-estate investment route closed completely in October 2023. For international applicants targeting a property-based residence route, Greece's €250k commercial-to-residential option is generally more direct.
Greek Golden Visa vs Portuguese Golden Visa — which is better for international applicants?+
The answer depends on the investment goal. Greece is generally more suitable for applicants prioritizing tangible real estate, a lower commercial-to-residential threshold, zero minimum stay and three-generation coverage. Portugal may remain relevant for applicants preferring fund, research, donation or business routes and willing to meet its residence conditions.
Is the Portuguese fund Golden Visa still worthwhile?+
Suitable for specific groups: investors with existing Portuguese business networks, those preferring fund-based diversified investment, or those whose ultimate goal is Portuguese citizenship after 5 years (subject to language exam requirements). However, for "real estate + permanent residence + three generations" goals, Greece is more direct.
Will Greece's real-estate Golden Visa also close in the future?+
The Greek government has explicitly maintained the real-estate route through Law 5038/2023 in 2024, raising thresholds rather than closing. Policy trajectory shows Greece prefers "price adjustment" over "closure," though the €250k commercial-to-residential channel may tighten in the future. We recommend applying within the 2026–2027 window.
- •Portugal closed the real-estate route for its Golden Visa, while Greece still keeps property investment routes under the current three-tier framework.
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