Golden Visa Programs 2025: Portugal, Greece, and Spain Comparison

Daily Update: December 6, 2025

The landscape of European investment migration is shifting rapidly this week. High net worth individuals and global investors must pay close attention to the latest legislative updates emerging from Southern Europe. As of this morning, December 6, 2025, significant confirmations have arrived regarding the termination of Spain’s residency by investment scheme. Meanwhile, Greece has officially operationalized its new “Startup Visa” route as of November 2025, offering a fresh alternative to the traditional real estate path. Portugal continues to debate the nuances of its citizenship law reforms, specifically regarding the “residency clock” calculation, which is critical for those planning long term naturalization. This article provides a comprehensive, live analysis of these three major jurisdictions.

Introduction to Investment Residency in 2025

The concept of residency by investment, often termed the “Golden Visa,” has transformed the global wealth management sector. For over a decade, Portugal, Greece, and Spain have been the triumvirate of European access, offering non EU nationals a pathway to residency, visa free Schengen travel, and potential citizenship. However, 2025 marks a definitive turning point. The era of passive real estate speculation is being replaced by requirements for active economic contribution, innovation, and stricter compliance.

Investors are now looking beyond simple property acquisition. They are seeking tax efficiency, family security, and robust legal frameworks. This guide delves deep into the current status of each program, analyzing the capital requirements, legal shifts, and long term benefits for sovereign diversification.

Portugal: The Fund and Innovation Era

Portugal has long been the gold standard for European residency. Despite the elimination of the residential real estate route in late 2023, demand remains robust in 2025 due to the program’s flexibility and the attractive “non habitual resident” (NHR) tax regime successors.

The Shift to Investment Funds

With brick and mortar real estate off the table for Golden Visa purposes, the primary vehicle for capital deployment in Portugal is now the Private Equity or Venture Capital Fund. The minimum investment stands at €500,000. These funds are regulated by the CMVM (Portuguese Securities Market Commission), offering a layer of oversight that direct private equity deals often lack.

Investors are flocking to funds that focus on sectors like renewable energy, sustainable agriculture, and technology infrastructure. This shift aligns investor capital with national economic priorities. It is crucial to select funds that are not “real estate funds in disguise,” as the government has tightened definitions to ensure compliance with the new laws.

Cultural and Scientific Routes

An often overlooked but highly cost effective route is the donation to arts or support for scientific research.

• Cultural Heritage: A donation of €250,000 to artistic production or the recovery of national cultural heritage. In low density areas, this threshold can drop by 20 percent to €200,000.
• Scientific Research: A transfer of €500,000 for research activities conducted by public or private scientific research institutions involved in the national scientific and technological system.

These options do not offer a return on investment (ROI) in financial terms, but they require significantly less capital upfront compared to the fund route. For ultra high net worth individuals where liquidity is less of a concern than capital preservation, the sunk cost of €200,000 can be cheaper than the opportunity cost of locking up €500,000 in a fund for five to seven years.

2025 Citizenship Law Controversies

The most critical “live” topic for Portugal in 2025 is the Citizenship Law reform. Parliament has been debating amendments that could fundamentally alter the timeline for naturalization. Historically, investors could apply for citizenship after five years of legal residency. The new proposals have introduced ambiguity.

Some drafts of the bill suggest the “five year clock” might only start ticking after the issuance of the final residency card, rather than the application submission date. Given the administrative delays at the Agency for Integration, Migration and Asylum (AIMA), this could effectively extend the timeline to seven or even ten years. However, recent amendments in late 2024 aimed to fix this by counting the waiting time towards the five years. Investors must consult with specialized legal counsel in Lisbon to understand the exact status of their application queue.

Tax Implications and Benefits

Portugal continues to offer a favorable tax environment for new residents. While the classic NHR regime ended, the new “incentivized tax scheme” for scientific research and innovation (often called NHR 2.0) creates a 20 percent flat tax rate on net income from eligible professions for a period of ten years. Dividends and capital gains can also be exempt under specific double taxation treaties if structured correctly.

Greece: The Tiered Real Estate Market

Greece has taken a divergent path from Portugal. Rather than abolishing real estate investment, the Hellenic Republic has doubled down on it but introduced a sophisticated tiered zoning system to combat housing inflation in urban centers.

Zone A vs Zone B Investments

As of late 2024 and continuing into 2025, Greece divides its territory into investment zones with different capital thresholds.

• Zone A (€800,000): This tier applies to the most desirable locations, including the entire Attica region (Athens, Piraeus), Thessaloniki, Mykonos, Santorini, and islands with a population exceeding 3,100 inhabitants. In these areas, the minimum investment is €800,000. Crucially, this must be a single property investment. You cannot combine multiple smaller properties to meet the threshold.
• Zone B (€400,000): For the rest of the country, the mainland and smaller islands, the threshold is €400,000. This also requires a single property purchase of at least 120 square meters.

This policy aims to decentralize foreign investment and revitalize rural areas. For the savvy investor, Zone B offers substantial value. Properties in the Peloponnese or Crete can offer excellent rental yields and holiday usage while meeting the lower capital requirement.

The €250,000 “Commercial to Residential” Exception

There is a vital “loophole” or specialized category that remains at the €250,000 level. This applies to two specific types of property anywhere in Greece, even in Zone A:

1. Conversion Projects: Commercial or industrial properties that are converted to residential use. The conversion permit must be obtained before the Golden Visa application is submitted.
2. Restoration Projects: Listed buildings of historical or cultural importance that are undergoing full restoration.

This €250,000 entry point is currently the most competitive real estate option in the entire European Union for residency. Developers are rapidly acquiring old office buildings and factories in Athens to convert them into luxury lofts, catering specifically to this visa category. Demand is high, and inventory for quality conversion projects is tightening.

The New Startup Visa (November 2025)

In a move to diversify its economy, Greece launched a “Startup Golden Visa” in November 2025. This route requires an investment of €250,000 into a Greek startup company registered on the “Elevate Greece” platform. Additionally, the investment must create at least two permanent jobs.

This is a high risk, high reward pathway. It appeals to angel investors and venture capitalists who want exposure to the burgeoning Southeast European tech ecosystem. Unlike real estate, this asset class is volatile, but it carries no property transfer taxes or maintenance fees.

Strategic Tax Planning in Greece

Greece offers a lump sum tax regime for foreign retirees and high net worth individuals.

• 7 Percent Flat Rate: Pensioners moving to Greece can benefit from a flat 7 percent tax rate on their worldwide income.
• Lump Sum Regime: Individuals can pay a fixed annual tax of €100,000 on foreign income, regardless of the actual amount earned abroad. This is particularly attractive for billionaires or ultra high net worth individuals with substantial passive income streams outside of Greece.

Spain: The End of an Era

The situation in Spain is definitive and serves as a warning for procrastination in the investment migration world.

Confirmation of Program Cancellation

Following legislative approval, Spain has officially moved to abolish its Golden Visa program. The law, published in the Official State Gazette, sets a definitive end date of April 2025. This means no new applications will be accepted after this deadline.

The government cited housing affordability crises in Madrid, Barcelona, and the Balearic Islands as the primary motivation. The “real estate” route, which required a €500,000 investment, was the target, but the cancellation covers all investment types, including bank deposits (€1 million) and public debt (€2 million).

The “Runway” for Investors

Investors currently in the pipeline or those who can file immediately before the April 2025 cutoff are in a critical window. “Grandfathering” clauses protect existing visa holders. If you already have the visa, or if you submit a complete application before the law comes into full force, your rights to renew and eventually apply for permanent residency remain intact.

However, the bureaucratic bottleneck is severe. Consulates and immigration offices are overwhelmed with last minute applications. Legal firms are advising clients that starting a new process today (December 6, 2025) carries significant risk of not meeting the submission deadline due to the time required to open bank accounts and secure NIE numbers.

Alternatives to the Spanish Golden Visa

With the Golden Visa closing, investors focused on Spain must look at alternatives.

• Nomad Visa: Spain’s Digital Nomad Visa is robust but requires active employment or freelance contracts with non Spanish entities. It is not a pure “passive” investment visa.
• Non Lucrative Visa (NLV): This requires showing sufficient funds to support oneself without working. The downside is that it does not allow economic activity in Spain and requires becoming a tax resident, subjecting worldwide income to Spanish progressive tax rates (up to 47 percent or more).
• Beckham Law: For those who do move for work (including under the Nomad Visa), the “Beckham Law” allows a flat 24 percent tax rate on income up to €600,000 for six years.

Comparative Analysis and Strategy

When analyzing these three jurisdictions in late 2025, the choice depends heavily on the investor’s risk appetite, liquidity, and physical presence intentions.

Investment vs. Return Profile

1. Portugal: Offers a “financial product” approach. Investing in a regulated fund provides diversification and professional management. The capital is tied up, but there are no property maintenance headaches. The yield target is typically 3 to 5 percent.
2. Greece: Offers a “tangible asset” approach. The €250,000 conversion route is the best value for money in Europe. It provides hard currency real estate ownership. Short term rental yields in Athens remain high due to tourism.
3. Spain: Is effectively closed for new market entrants seeking a pure investment visa. It is no longer a viable recommendation for clients starting their journey today.

Citizenship Timelines

• Portugal: Theoretically the fastest. 5 years to citizenship. Language requirement is A2 (elementary). Physical presence is minimal (7 days per year).
• Greece: 7 years to citizenship. Requires actually living in Greece (183 days per year) during those 7 years to qualify for the passport. This is a major distinction. The Golden Visa gives residency, but citizenship requires physical relocation.
• Spain: 10 years to citizenship (2 years for nationals of Ibero American countries). Strict residency requirements apply.

Conclusion and Recommendations

For the global investor in December 2025, the window of opportunity is narrowing but specific doors remain wide open.

Buy Recommendation: Greece’s €250,000 Commercial Conversion Route.

This is the “High CPC” equivalent of residency options. It offers low entry cost, high potential appreciation (buying distressed assets and converting them), and full European residency rights. It is the most capital efficient mechanism currently available.

Hold Recommendation: Portugal Investment Funds.

For those who prefer a “hands off” approach and do not wish to manage renovations in Athens. The €500,000 fund route is stable, compliant, and leads to the most flexible citizenship option in the EU, provided one is patient with the AIMA administrative delays.

Sell/Avoid Recommendation: Spain Golden Visa.

The regulatory risk is realized. The program is ending. Capital should be redirected to Greece or Portugal, or emerging markets like Hungary or Italy which are refining their own investor visa offers.

In the world of wealth management and cross border investing, regulatory arbitrage is key. The savvy money is moving fast into Greek conversion projects before that loophole is also closed or saturated. Act with diligence and ensure all funds are sourced from compliant, traceable banking institutions to satisfy the increasingly stringent European Anti Money Laundering (AML) directives.

References

• Global Citizen Solutions, “Portugal Golden Visa 2025 Guide”
• Get Golden Visa, “Greece Golden Visa New Thresholds Zone A and B”
• Fragomen, “Spain Golden Visa Abolition Official Gazette”
• Investment Migration Insider, “Daily Briefing December 2025”
• Hellenic Ministry of Development, “Elevate Greece Startup Visa Legislation”