Portugal's Golden Visa Latest Regulation Changes

According to the latest discussion, Portugal governement as decided to make changes to current GV regulations - to end the property investment channel for Golden Visa in big cities like Lisbon & Porto.

New regulation will be effective by July 1st, 2021. There will be approximately 2 years of transition period in 2021 and 2022, where the investment threshold for these cities will gradually increase.

According to the budget, the government will end property investment in coastal area and metropolitan cities. For those initially approved visa, renewal of visa is permitted.

According to Mariana Vieira da Silva, 'GV investment are linked prominently to property investment. We hope to channel this investment to inner continent area, to create more developments and jobs to those areas.

Details will be announced in the decree law. We will keep posted on all new announcements, and post recommendations on investment strategy due to the new regulations, and other investment channels for Golden Visa.

Will try to update here regularly. Or you can subscribe to our newsletter to keep posted.

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So that leaves (effectively) six months…
Is that enough time to buy a property & secure a Golden Visa?
How long does it typically take?
Are there any ways of speeding up the process?

Barely, especially during the Pandemic. Only buy a property where the Final Deed can be done instantly, where the licenses are in place, and if you are confident that you have all the documents and attestations required to put in the initial SEF application (it took SEF over 2 months to process my SEF application whcih was uploaded in August, 2020. )

Hi David,

Thanks for your message. The short answer is yes, you still have time. The deadline of end June is for the online submission of GV application, so you still have time. We have experience to having everything concluded from the day of property purchase to GV online submission within 1- 2 months. But you need to hurry up, it is best to conclude the property by the end of first quarter to be safe because the process also depends on the time needed for property purchase procedures (and the type of property you buy). We will advise clients on the property if they want to catch the timeline.

And you need to start opening bank account, apply NIF, etc in the first quarter. I am not sure where you are from, but currently tourist travel from US to Portugal is not allowed, and we don’t know how long it would last. Applying in person is quick and easy, but maybe doing so remotely would be an option for you to make sure you have all things ready for the application in time (we can help you on that).

And you also need to get all documents ready, (the critical one is the criminal record), and get them apostilled, then translated and certified by Portugal lawyer (we can do that for you). Timing is crucial, as you don’t want to get it too soon (some documents have a validity of 3 months), but you need to have it in time.

We are confident to be able to conclude the application, if you can finish the property purchase by end March. We will help you and guide you throughout the whole process.

If you have any further questions, please let me know.

“And you also need to get all documents ready, (the critical one is the criminal record), and get them apostilled, then translated and certified by Portugal lawyer (we can do that for you). Timing is crucial, as you don’t want to get it too soon (some documents have a validity of 3 months), but you need to have it in time.”

Just to reinforce this recommendation… for those GV applicants from the US, the FBI Fingerprint (Criminal Background) Check can only be apostilled at the US State Department in Washington DC. Their walk-up counters are closed due to Covid, and all requests must be submitted by mail. As a result, the third party apostille companies are unable to guarantee expedited service. All requests apparently must be completed by mail, and the stated turnaround time is 2-3 months per the Office’s website.

The FBI Check is one of the documents that only has a 3 month validity, so the process to obtain the apostille, and then get it submitted with the online application before it expires (under the SEF guidelines) can be a challenge.

Yes, the US DoS apostille of the FBI report is definitely a time problem for the process. However, we (and at least one other participant in this forum) have had a good recent experience of a 3-week turnaround time on apostille from US DoS by using apostille-legalization.com. For more info, refer to the topic Apostille and document preparation for US GV investors

This may be able to save you some time.

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I just received an apostilled FBI report using another service (monumentvisa.com) this morning and had a similar experience. You email the FBI docs to them, then they print them out and hand-walk them over to DoS. I also used their FedEx option to get them back. 26 days start to finish for the apostille process once we had the FBI docs (and that included occurring over the Thanksgiving and Christmas holidays). I second Jake-n-Ann’s recommendation to read the topic Apostille and document preparation for US GV investors.

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With the changes, we are advising different routes clients can take before and after the new changes come into effect. We have outlined the 4 main strategies here.

  1. Invest in target cities/ regions before the effective date of July 1st, 2021

Pros
-Able to make the investment that you have initially targeted

Cons
-Need to take actions immediately to catch the timeline for the property purchase, documents gathering and so on

Remarks
The whole process of property purchase to GV online submission can be done within 1 - 2 months. However, It is crucial to have documents on hand and have a team ready to support you on every stage (eg. lawyer, real estate agents, translators, etc).

We are writing on the steps and processes you need to take to catch the timeline, will post here as well.

  1. Invest in venture capital funds (lowest entry 350K)

Pros
-Not affected by the regulatory changes
-Can go ahead with your own timeline
-There are funds focusing on the real estate market
-Less transactional cost
-Not subject to tax if you are non tax resident

Cons
-Funds and real estate investment are two different type of asset class. Some investors may not feel comfortable with investing in financial assets or may want to focus on real estate asset for asset allocation purposes

Remarks
Investment through funds has always been the alternative for GV, with less hassles and less cost. There are fund options focusing on different industries. Expected returns ranges from 5% - 15% per year on average.

  1. Invest in low density areas (lowest entry 280K)

Pros
-Not affected by the regulatory changes
-Can go ahead with your own timeline
-Lower entry threshold of 280K

Cons
-Not as many options at the moment for total rehabilitation projects, but it is anticipated that there will be more projects coming out with the new regulatory changes
-May not be easy to find tenants or property management company for rental if the property is too remote

Remarks
It would be a good choice if you would like to live in the country side as your main or second resident.

If for investment purpose, we suggest to choose refurbish developments, preferably with rental options and/ or guarantee rent for easier management of your property.

  1. Invest in target cities/ regions with the new changes and before the end of 2022

Pros
-Have more time to choose the property and prepare for the whole application process

Cons
-Still not clear what the new investment threshold will be after July 1st
-More cash lay out

Remarks
This may be a good strategy if you have the cash and wish to buy a larger property, a property in a more luxury area or several properties. There are plenty of options. For example, properties of 3 bedrooms+ in luxury areas such as Cascais, Estoril and in certain areas of Lisbon, Porto and Algarve. These type of properties are very popular with or without GV purpose to local and expat market.

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we have written something about the timeline. Sorry, can’t post the excel table here. The main issue is the the deadline is for online application submission, not approval. This is specifically for property in Lisbon, Porto, and coastal areas.

How to Catch the Timeline to Submit Your Golden Visa Application Before July 1st, 2021

  1. Is there still enough time if I am starting from ground zero?
    The short answer is yes, there is still enough time.
    The deadline of June 30th, 2021 is the time for submitting your Golden Visa application online, not getting your approval from the SEF (immigration office).

  2. What are the steps and procedures to get the golden visa?

We can separate the process into 3 different areas

Step 1 - Initial set up
This includes opening a bank account, getting your NIF (tax payer ID) and a tax representative. This basic set up is essential for all types of visas in Portugal. Getting a NIF doesn’t mean you are liable for paying tax in Portugal. You can get your NIF months, even years, before you actually submit your visa application. It is recommended to get this as soon as possible.

If you travel in person to Portugal, the setting up of bank account, applying for NIF/ tax representation can be done within 1-2 day.

If you choose to do so remotely, you would need professional help.

Step 2 - Buying your property
Ideally you would have already been looking into the real estates market; narrowed down your search to certain areas and criteria; seen some eligible properties and short list some of them.

If you travel in person to Portugal, viewing of your short-listed properties and choosing the property can typically be done in 2-3 days. You would need to get a lawyer for the purchase of the property. With a power of attorney, all other process can be handled by the lawyer, so you do not need to be physically in Portugal during the purchase process.

It is crucial to shortlist your properties and pre-arrange with viewing date and time with your agent ahead of time before your trip to Portugal.

You can also choose to view properties remotely. If it is an off-plan development, you can get all the necessary information to make the decisions. Or you can arrange a virtual property viewing.

Step 1 & 2 can be combined into a single trip to Portugal. And 3-4 days is all it needs for you to be in Portugal. You do not need to be back until the appointment with SEF is set up to take your biometrics (after initial approval).

Step 3 - Getting your application documents ready
You need to gather your documents for the online application to the SEF website. The critical one is the criminal record. Countries differ in how they issue the criminal record for their citizen. Some countries even require a request letter from the Portugal Consulate to in order to process the issuance of the criminal record, so a trip to the nearest Portugal Consulate to where you live is an extra steps.

Do also take into consideration the time to get the documents. It is not the sooner the better, as a lot of the documents have only a 3-month validity period (from the issuance date to the online submission date). In between this 3 months, you would also need to get those documents apostilled in your home country, and then translated in Portuguese and certified. We recommend you to research on the time needed to get the documents, and for them to be apostilled in your home country. The translation in Portuguese and getting it certified is not difficult, and usually take less than 1 week.

Refer to the below table to the validity period of the documents and requirements for apostilled.

Note: This is not the full list of documents, as other documents may be needed for your dependents

Other than documents from your original country, you would also need to get documents in Portugal. With a power of attorney, your lawyer should be able to prepare the documents for you here. The validity of the documents is usually 2 months.

Applicant’s permission for the authorities to access his/her Portuguese criminal record.
Certificate of no debts from the Portuguese tax and national insurance offices.
Signed statement by the applicant that he/she will fulfil the investment requirements.
Evidence that the minimum investment has been made (this consists of a certificate issued by the appropriate registry office and, where applicable, a letter from a local bank confirming the transfer of the required funds)

  1. How long does a typical property purchase takes?

There are 2 steps to the purchase of a property - the promissory contract and final deed. Usually we need to wait around 15 days between both, to allow the City Council to exercise the rights of purchases preference (just as a standard procedures) and if the property has a current mortgage, it takes around 10-15 days for the bank to prepare the mortgage distract. So the quickest timeline would be 15 days.

  1. How long does the whole process takes?
    Let’s take a look of at the timeline of the whole process. This is an example for someone who would be coming to Portugal to do the initial set up and the property viewing. If you wish to do the whole process remotely, it is advisable to do the initial set up as soon as possible.

The whole process, from start to finish, can be done in 3 around months as with the below timeline.

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New regulation will be effective by July 1st, 2021

susanayang do you have a supporting link to an official government source? Given that you’re in the business of selling assistance to GV seekers, I’m surprised you didn’t post such a link.

The only mentions of ‘1 de Julho’ in the 2021 budget have nothing to do with the GV. I searched the law using the Portuguese words and phrases used in the 2020 law. None were found. I’ve yet to see any posts on the facebook expat forums claiming the GV investment requirements have changed.

The law: https://dre.pt/web/guest/home/-/dre/152639825/details/maximized

Hi Susana

You appear to very knowledgeable about the GV - thanks for your contribution to the group.

One quick question if I may … the requirement for medical insurance. Can this be travel insurance with a repatriation clause, instead of medical insurance ? I guess it needs to apply from the date of the application but how long should it last ?… especially when I believe that you can go onto Portuguese Medicare when your GV becomes approved…

Thanks

Eugen

It was announced, However it’s not yet published in the official gazette.

No I didn’t include a link because it’s all over the news. I am surprise you didn’t find any. I am even more surprised that none of the other sources you follow mentioned about it? If you want some reference to the news i can send it to you but a search would easily find it.

Susana from iPhone

Hi,

Thanks for your message. We would recommend buying proper medical insurance instead of a travel insurance. Travel insurance is not a medical insurance and many just cover emergency items or accidents, so it is not replaceable to a medical insurance. The insurance should apply from / before the date of the application. The coverage period is preferably 1 year, or at least 6 months. As the application process takes a few months, and with Covid, it may be longer. There are some medical insurance where you can buy annually, but pay monthly and can cancel anytime during the year. Always ask the company if you are able to do this when you do the search. That way, after you get your resident card and register to the health benefits here, then you can cancel the medical insurance.

I hope this helps.

Yes, it’s all over the news. None of the news sources link to an official government source. All the articles I saw seem as if they were copied, then slightly modified, from the same unknown source. There won’t be changes until the law is published. Without a link to an official government source, the proposed changes reported by the news media could be 100% true. They also could be anything from a rumor to a fabrication.

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