Golden Visa Portugal or Greece in 2026: funds vs real estate

Essentials in a Minute: Funds vs. Real Estate

In short, choosing between two programs is a choice between two types of asset. The Portuguese Golden Visa, after the 2023 reform (Mais Habitacao Law), no longer allows money to be used in real estate and capital transfers. There is essentially only one mass route left - an investment of €500,000 or more in a regulated investment fund. This is a financial instrument: you do not receive ownership of a house or apartment, you buy shares of a fund managed by a licensed company.

Greece went the opposite way and retained real estate as the core of the program. Here the investor buys a real object - an apartment, a house, a commercial property - and receives a tangible asset that can be leased for a long time and which grows in price along with the market. Thresholds depend on the zone: from 250,000 € for restoration or conversion, 400,000 € nationally and up to 800,000 € in premium locations.

Hence the whole logic of comparison: Greece is cheaper at entry and provides a tangible asset, Portugal is more expensive and works as a financial portfolio. Next, we will analyze each parameter separately and put everything in a table. We keep the base for the Portuguese program in detailed guide to Portugal Golden Visa.

Portugal: only investment funds from 500,000 euros

Until October 2023, Portugal was a showcase for the “golden visa for real estate”: if you buy an apartment in Lisbon or the Algarve, you receive a residence permit. This door was closed. Today there are several qualifying routes, but the one that really works for a private investor is an investment fund.

• Investment fund from 500,000 € - investment in a regulated venture or private equity fund. The fund must have a maturity of at least 5 years and allocate a significant part of the portfolio (approximately 60%) to companies registered in Portugal.
• Scientific research from 500,000 € - investment in R&D projects.
• Cultural heritage from 250,000 € - support for culture and art; narrow and sparse route.
• Job creation/equity - an option for those who actually open a business and hire staff.

The fundamental point: the fund is a professionally managed instrument; no operational participation is required from the investor. Money works, you watch. But this is also a risk: profitability is not guaranteed, and capital is frozen for the life of the fund. A detailed analysis of the route is in the material about investment funds Golden Visa Portugal.

Greece: real estate and thresholds by zone

The Greek Golden Visa remains “immovable” in nature, but in 2024-2025 the rules were tightened and a zonal threshold system was introduced. Now the entry amount depends not on the whim of the investor, but on where the object is located.

Important 2026 Disclaimers:

• Minimum area 120 sq.m. - for thresholds of 400,000 € and 800,000 €. The object must be unified; It is no longer possible to split the investment into several small apartments.
• Threshold 250,000 € - only restoration of historical objects or conversion of commercial into residential, and the conversion must be completed before submitting the application.

That is, “Greek 250,000 €” is not the purchase of an ordinary apartment for this money, but a special, more complex scenario. The mass threshold in the country is 400,000 €, in top locations - 800,000 €.

Entry threshold: where is it cheaper to start?

On a net entry price basis, Greece is almost always cheaper. Let's compare the starting numbers -to-, without marketing tricks.

The minimum real threshold in Portugal is €500,000 in an investment fund. This is a firm bar, below it there is no mass route for a private investor (cultural heritage for 250,000 € is a rare and narrow option). Greece allows you to enter for 400,000 € throughout the country, and in special scenarios (restoration, conversion) - for 250,000 €.

• Greece, standard threshold - 400,000 € per property outside the premium zones.
• Greece, special threshold - 250,000 € for restoration or conversion.
• Portugal, main route - 500,000 € to the fund.

But “cheaper to enter” does not equal “cheaper in total.” For Greek real estate, a transfer tax (3.09%), notary, lawyer, registration is added - a total of a few more percent on top. The Portuguese fund has its own costs: management fees, subscription fees, government application fees. We keep the full estimate for Portugal in analysis of the cost of the Golden Visa of Portugal. Therefore, with an equal budget, you need to compare not only the entry price, but also all associated costs.

Minimum stay: who is freer?

For an investor who is not planning to move right now, the key question is how many days a year will he have to physically spend in the country. Here both programs are loyal, but Greece is the champion in freedom.

• Portugal - about 7 days per year (formally - on average 7 days per year, or 14 days per two-year period). This is a symbolic presence that is easy to perform even for a busy person.
• Greece - there is actually no minimum stay to maintain status. You don’t have to live in the country at all and can easily renew your residence permit, coming only when necessary.

The difference is small in absolute numbers, but important in logic. If your goal is an “alternate airfield” and EU residency without moving, the Greek zero threshold is more convenient. If you are planning naturalization in the future, the symbolic 7 days of Portugal are still not enough for citizenship: you will need a real connection with the country. More about this in the section about the path to the passport.

Both countries are full members of the EU and the Schengen area, so the holder of a residence permit of any of them moves freely throughout Schengen. This distinguishes them favorably, for example, from Cyprus, which is not yet a member of Schengen.

Path to citizenship: 10 years for Portugal versus 7 years for Greece

There has been a reversal here, which everyone who chooses a program for an EU passport should be aware of. For many years, Portugal was the leader in terms of the speed of naturalization - only 5 years. In 2026 the situation has changed.

In May 2026, a new Portuguese nationality law (Lei Organica 1/2026) came into force: the naturalization requirement was increased from 5 to 10 years for most foreigners and to 7 years for EU and Portuguese-speaking CPLP citizens. Language requirements (level A2), knowledge of history and culture and a declaration of commitment to democratic principles have been added. Applications submitted before May 18, 2026 are considered under the old law - this is “grandfathering” protection for those who were in time.

• Portugal 2026 - 10 years for most, 7 years for EU and CPLP citizens, plus A2 language and integration requirements.
• Greece - about 7 years of legal residence plus proof of integration into Greek society (language, exams).

The conclusion is and unexpected: in terms of time to citizenship, Greece is now not inferior to Portugal, and for the majority of non-European investors it is even ahead of it (7 years versus 10). At the same time, it is important to understand: in both cases, naturalization requires real residence, and not symbolic 7 days. The “golden visa” itself gives a residence permit, and then a choice: remain a resident or switch to a passport. Read more about the Portuguese route in the article about Portuguese citizenship.

Yield: fund return versus rental flow

“What is more profitable” in money is a question not only of the entry price, but also of what the asset brings and how the capital behaves.

Portugal - fund. Regulated funds historically show returns of approximately 6-12% per annum, with individual products claiming even higher returns, up to double digits, depending on strategy and risk. Some funds offer capital protection for the 6th year with buyback. Plus - passivity: you don’t need to look for a tenant, fix pipes, or pay for property management. Minus - the capital is frozen for the life of the fund (from 5 years), profitability is not guaranteed, and in the event of an unsuccessful strategy, losses are possible.

Greece - real estate. Here, income consists of two parts: the rental flow (long-term rental; short-term Airbnb is limited in a number of areas) and the increase in the value of the property against the backdrop of a tourism boom and rising market prices. Plus is a tangible asset that you control and can sell. Minus - illiquidity (selling an object takes time), maintenance and management costs, taxes on rental income.

• Fund - passive income, professional management, but freezing and market risk.
• Real Estate - controlled tangible asset and lease, but hassle and illiquidity.

There is no universal answer: for those who do not want to engage in management, the fund wins; for those who believe in the Greek market and want a tangible object - real estate.

Family and composition of applicants

Both programs are designed for families, and here they are close, but there are nuances.

• Main applicant - an adult investor who has passed verification of the source of funds.
• Spouse) - included in both programs.
• Dependent children - minors, as well as adult children-students on the financial support of their parents (with age and other conditions).
• Parents - can be included if the conditions of dependence are met (in Portugal - the parents of both spouses, in Greece - on the basis of financial dependence).

The fundamental difference is not in the composition of the family, but in the fact that one investment covers the entire family included without additional investments for each member. This makes both programs attractive for family planning. In practice, the composition and conditions for parents and adult children should be calculated individually, because the wording in the laws of both countries changes periodically.

For Russians and CIS citizens, both countries have enhanced compliance: the source of funds, the origin of capital, and the absence of sanctions risks are carefully checked. Everything is done strictly within the law, without any workarounds.

Risks and pitfalls of each program

A fair comparison is impossible without talking about risks. Each program has its own.

Portugal Risks (fund):

• Capital is frozen for the life of the fund (5+ years), early exit is difficult.
• Profitability is not guaranteed; If the strategy is unsuccessful, losses may occur.
• The quality of funds varies greatly - the choice of management company is critical.
• The extension of the citizenship qualification to 10 years reduced the main former advantage of the country.

Risks of Greece (real estate):

• Market overheating in premium areas: prices are rising, and the threshold of 800,000 € does not always correspond to the real value of the property.
• Illiquidity: You won’t be able to sell real estate quickly.
• Restrictions on short-term rentals in some locations are reducing profitability.
• Maintenance costs, rental taxes, managing the property from afar.

The common risk for both programs is regulatory: the rules are changing, as demonstrated by the Portuguese turnaround of 2023-2026 and the Greek tightening of thresholds. Therefore, the decision should be made based on the current state of the law, and not on articles from three years ago.

Who is Portugal suitable for?

The Portuguese Golden Visa is not a choice for everyone, but for a certain investor profile it remains strong.

• For those who do not want to manage an asset. The fund is a passive instrument: you invest and watch. There is no need to look for tenants, make repairs, or pay for property management.
• For those who value portfolio liquidity. It is easier to structure a financial instrument and, if you choose the fund wisely, to exit it upon expiration.
• Citizens of the EU and CPLP countries. For them, the citizenship requirement is 7 years, which makes Portugal still competitive in terms of speed.
• For those who believe in venture and private equity returns. The historical 6-12% per annum with a successful strategy exceeds the rental flow.

Portugal loses out to those who want a tangible asset in their hands or the cheapest possible entry. But it wins over the investor who values ​​passivity, the fund’s profitability potential and a comfortable life in an EU and Schengen country. Those who are considering moving for passive income should also look at the alternative - Portugal D7 visa for rentiers and retirees.

Expert's view: how to choose without illusions

Over the years of practice, we see the same mistake: investors compare programs based on one parameter - most often the entry price - and miss the rest. Let's figure out what to actually look at.

• First the goal, then the program. “Alternate airfield without moving” and “EU passport for children” are different tasks, and different routes are suitable for them.
• Consider the full estimate, not the threshold. Taxes and fees are added to Greek real estate, and management fees to Portuguese funds. A gap of 100,000 € at the entrance can be reduced at the exit.
• Citizenship is a real residence. Neither 7 days in Portugal nor zero stay in Greece automatically gives you a passport: naturalization requires real life in the country.
• Check the law by date. The Portuguese turnaround of 2023-2026 showed how quickly the rules change. An article from three years ago may be misleading.

The main thing is not to chase the “most profitable” program in a vacuum, but to choose the one that exactly fits your situation in terms of budget, mobility and planning horizon.

Bottom line: what is more profitable in 2026

There is no direct answer: “Portugal is more profitable than Greece” or vice versa - everything is decided by your task. Let's reduce the logic of choice to simple guidelines.

• Need a material asset and low entry - Greece. Owned property, threshold from 400,000 € throughout the country, rental flow.
• Need a passive tool without the hassle - Portugal. Fund from €500,000, professional management, potential return 6-12%.
• The goal is an EU passport faster - for non-Europeans now Greece (7 years versus 10 for Portugal); for an EU citizen or CPLP the difference is minimal.
• Maximum freedom of stay - Greece with its almost zero presence.
• Belief in venture returns - Portugal.

Both countries provide a full-fledged residence permit in the EU and Schengen, both lead to citizenship subject to real integration, both require fair compliance. The difference is in the asset format and details, and it is these details that determine which program will be beneficial for you personally. You should always check the current conditions in Portugal on the official portal Portuguese Public Services (gov.pt).

Who is Greece suitable for?

The Greek Golden Visa is a logical choice for a different type of investor.

• For those who need a material asset. Real estate is tangible property that you control, rent, and can sell.
• For those who are looking for a minimum entry threshold. 400,000 € nationally (and 250,000 € in special scenarios) below the Portuguese 500,000 €.
• For those who value maximum freedom of stay. Zero minimum presence - convenient for those who do not plan to move.
• For those who believe in the Greek market. Tourist boom, rising prices and rental potential in popular locations.
• Non-European investors for citizenship. 7 years of qualification against the Portuguese 10 - now this is an advantage for Greece.

Greece loses to those who do not want to get involved in property management and prefer a passive financial instrument. But it wins over the investor who values ​​a tangible asset, low entry and freedom of movement within Schengen.

Summary table: Portugal vs Greece 2026

Let's collect all the key things in one table - this is a framework for making a decision. Figures are as of 2026; Before a transaction, you should always check them with the current version of the laws of both countries.

The table shows: there is no universal winner. Greece is cheaper, freer to stay and now faster to citizenship for non-Europeans; Portugal is more passive in management and potentially more profitable with a successful fund.