You’re obviously right, but I look at the GV program differently than a country changing its immigration requirements. With the GV program, Portugal is asking foreigners to invest in its country - in exchange for a benefit.
Thus I feel it’s not unreasonable for investors to expect Portugal to adhere to terms when the investment was made. Just like when I buy a govt bond and I fully expect the govt that issued the bond to pay out the interest and return the capital invested per the terms agreed.
I was struck by your comment
“I applied for GV with the expectation I could lose it all.”
That’s a pretty steep risk.
I’ll be honest, I definitely didn’t apply with the " I can lose it all mindset" I did think it could potentially cost 10-15% more. But now it looks like it could be 50% more if not greater.
Very simply 500K @3% for 5 years is ~80K throw in another 20K in fees, trips etc a round 100K. If that becomes 10 years from card, and the card is delayed 4 years. Suddenly that starts to look more like 250-300K.
The opportunity cost is higher since you can easily beat 3% almost anywhere.
It is, and I’m not trying to be hyperbolic. I feel like this PSA needs to be made, especially now. People need to be honest about their tolerance for maximum loss before committing to the GV program. Citizenship or PR with low residency requirements comes at a cost.
If you can barely get the funds together to meet the minimum investment, or if that minimum is a very large share of your overall wealth, you’re taking on a lot of risk. On top of that, the immigration outcome is not guaranteed. As we have now seen in multiple countries, programs can be changed or shut down. You can lose the money and still not end up with the status you wanted.
Just on the money side, GV investments are normal high risk investments in property, funds, or businesses. Property can be destroyed or tied up or seized by courts, businesses can go under or defraud you, and funds can go bust. There is no extra protection or guarantee just because a fund qualifies for the GV. You are treated like any other investor if the project underperforms or collapses.
When I first looked at this program, there was an option to just transfer 1.5 million euro into a bank account like a term deposit. Lower risk, lower reward, higher liquidity, but much higher investment. By contrast, the cultural donation amount is lower because there is no financial return, so the risk is only that you will not get the immigration outcome. Investments always involve trade offs between risk, return, and liquidity.
The glaring issue now is that the Portuguese fund minimum of 500k euro sits at the bottom threshold for an individual to qualify as a professional investor. That means the legal framework permits people with relatively modest overall wealth to commit almost everything to one fund. Putting everything you have into a GV fund means concentrating your entire financial life in a single alternative investment that regulators and the funds themselves describe as risky, illiquid, and with a maximum possible loss of 100% of capital. Again, I’m not being hyperbolic. If you read the fine print in most fund documents, they have explicit risk warnings that mention a maximum possible loss of 100%. Even open ended funds can have limited liquidity (notice periods, gates, suspensions), so you are not protected from these risks just because the fund is open ended.
None of this means people shouldn’t do it, but they should go in on the basis that you really can lose everything and have nothing to show for it. And if that’s unacceptable, they should accept the limitations of their situation and look at other types of residency programs.
Your point is well taken.
I also think most investors probably lie somewhere on the spectrum of ..entire financial life in a single investment (very bad idea) and can afford to lose everything (it’s no big deal).
Likely not clustered at one end or the other, like any other normal distribution (just my guess)
The immigration outcome was certainly not guaranteed, although eligibility was assured under the SEF documents at that time. As we know now, is at the crux of matters.
Yeah I think that’s probably right about the distribution. And I don’t excuse how the Portuguese government has screwed people over, nor am I suggesting people have no legal grounds to challenge the changes.
My point was more about honest risk assessment leading to better expectation setting and better choices. I invest for a living so have learned a lot of hard lessons and practice what I’m preaching. Before we invested back in 2020, my family had a conversation about whether we would be ok if the fund went bust and Portugal changed the rules so we ended up with nothing (even though we could take the financial hit with no problem). I said at the time that the program looked too good to be true, especially given the political headwinds around immigration around the world. I think that was realistic, it meant we were not overexcited by the government spin, and with hindsight it set our expectations at the appropriate level, which is especially important when your loved ones are involved and want to make life plans. I’ve seen families break up over bad investments so I tread very cautiously.
Does Bulgaria offer citizenship with no residency requirement? There are many EU countries offering a Golden Visa with minimal stay requirements, but won’t allow one to apply for citizenship until several years of actual residency is established. If Bulgaria is an exception, it will be nice to know. I thought, whether it’s given in 5 or 10 years, obtaining an EU citizenship through Portugal without necessarily living there, is what made its proposal unique within the EU.
Keep talking about it, and we’ll see how long it lasts 
Remember there have always been cases where people spent the “required” 7 days per year in the country, but were turned down for “insufficient ties” when they applied for citizenship. So it was never a bright line.
People close to retirement should first consider where they want to live (considering lifestyle and taxes) within Europe, if they are set on Europe. If you’ve already worked out your tax situation in [Portugal with NHR 1.x] / France / Italy / Ireland / wherever, and have a good time living there, the passport comes as a bonus after a number of years. In this case, get a retiree visa instead of GV, and eliminate the risk of feeling scammed down the road.
Younger folks who are getting GVs for the passports (as opposed to an actual CBI program) need to be able to accept the risks of the naturalisation criteria changing during those 10 years to explicitly require physical residency. In other words, people should throw in good money for a Portugal GV only for option value.
As per various immigration attorneys, “citizenship applications also do not require physical residency.” See, for instance: Bulgaria Golden Visa - Markony Immigration Services LLP
I don’t personally know anyone who has ever done it, but then I also don’t know anyone in Portugal who has accomplished it (with 7 days/year in country).
One key difference between Portugal and Bulgaria (from my arguably limited knowledge of the latter) is to which degree you’re guaranteed citizenship if you meet the naturalization eligibility requirements.
In Portugal the law says (paraphrasing) that the government “grants” citizenship to someone who meets requirements X, Y, Z. The state has very limited possibilities to reject an application that meets the requirements, and any such rejection can be argued against in court.
In Bulgaria the equivalent term in the law is “may acquire” citizenship. It’s always discretionary, with the President always retaining the right to refuse to sign the relevant decree to grant citizenship.
I’m not sure how that actually works in practice in Bulgaria. But at least in other countries that retains discretion in granting naturalization it’s often not sufficient to meet the requirements outlined in the law. Take Malta for example, for their regular naturalization track the law states that you may qualify after 5 years of residency. In practice you actually need closer to 20 years.
That’s an interesting nuance, thanks. I would have to factor into the equation time duration. Even if Portugal has a slightly stronger commitment to grant citizenship to GV holders, I feel that commitment is more likely to soften - even if it requires a change of law - over 15 years for Portugal than over 6 years for Bulgaria. (I’m roughly estimating the time until citizenship granted.)
However, Bulgaria certainly carries risks.
Another key point is that Bulgaria only allows dual citizenship via naturalization if the applicant is either of Bulgarian origin or already an EU, EEA, or Swiss citizen, so the vast majority of those applying through their Golden Visa would need to renounce their existing citizenship to become Bulgarian.
Bulgarian nationality law - Wikipedia
Romania, which is soon launching a residence by investment program reported to contain an expedited path to citizenship, doesn’t appear to have any restriction on dual citizenship, so could become a more compelling alternative.
Def a risk on Bulgaria. Some Bulgarian immigration attorneys say you only have to agree that you will renounce your previous citizenship within 3 years and that no one checks later. But you’re right to point that out.
With the demise of Portugal, Romania really has a chance to become the best GV plan in Europe, drawing a huge amount of investment into its economy and attracting some of the best immigrants you can imagine. Let’s see what happens.
Romanian nationality law requires minimum six months physical residence per year to naturalize.
But it does have a flat 10% tax which is comparable to NHR
Supposedly an exception for golden visas is under discussion now. Let’s see…
No one checks until later, someone checks.
I doubt the EU will allow it
The EU won’t allow Romania to do what Portugal is already doing? Doesn’t seem fair…
Portugal doesn’t have an explicit citizenship exception for Golden Visas. It just lacks the wording that Romania has requiring six months from everyone.
And I’m sure the EU is working on pressuring Portugal to close their loophole too, which we now know they can do retroactively
Let’s see what the TC says about that…
Keeping a close eye on Romania. I have been working toward citizenship by descent, which now requires B1 language certificate. This was just a theory when I started the official document search last year. I will be surprised if they don’t require at least A2 and a minimum stay for GV, despite the current claims. It’s tempting though, and maybe easier than learning B1 Romanian! If you think Portuguese is hard… 