Based on insights gathered from 27 fund managers, legal advisors, and industry participants, the report suggests that the past year was not marked by a decrease in investor interest, but rather by a reshaping of expectations and a maturing market.

Throughout the year, despite periods of uncertainty driven by discussions around the Nationality Law, investor demand did not disappear. On the contrary, investors began approaching the program in a more cautious, informed, and strategic manner.

“What we observed was not a loss of interest, but a shift in expectations,” says Werner Gruner, Portugal Director at Get Golden Visa. “Investors are approaching the programme in a more pragmatic and structured way.”

A shift in how the programme is understood

Debates around potential changes to Portugal’s Nationality Law have directly influenced how investors evaluate the programme.

Rather than focusing on fixed citizenship timelines, investors are increasingly prioritising:

  • Residency rights

  • Legal security

  • Long-term optionality

This shift reflects a broader change in mindset. The Golden Visa is no longer seen purely as a pathway to a passport, but as a flexible framework for international mobility and long-term planning.

Credits: Supplied Image; Author: Client;

Funds move to the centre

With real estate no longer part of the programme, the fund route has become the central pathway.

What was once viewed as an alternative investment structure is now the default option, and investor expectations have evolved accordingly.

Investors are placing greater emphasis on:

  • Governance standards

  • Manager track record

  • Exit strategies

This evolution points to a more structured and regulated investment environment, where decisions are made with greater discipline.

Reliability becomes a deciding factor

Another key theme highlighted in the report is the growing importance of administrative execution.

The transition to AIMA and ongoing efforts to address application backlogs have brought operational performance into sharper focus.

Today, investors are evaluating not only the legal framework, but also how effectively the system functions in practice.

Predictability, consistency, and process discipline have become central to investor confidence.

A programme that is finding balance

Taken together, these developments suggest that the Golden Visa programme is reaching a more balanced and stable phase following a period of transformation.

Rather than being driven by urgency or uncertainty, the programme is increasingly shaped by informed decision-making and more realistic expectations.

As the market continues to evolve, this shift is likely to provide a more sustainable foundation, for both investors and Portugal.

Want to understand which funds, strategies, and structures align with this new phase? Download the full report or get in touch with our advisors for a tailored assessment.