Portugal's golden visa for Russians in 2026: funds closed by sanctions, what remains

Can Russians get Portugal's golden visa in 2026

The short answer: under the main option, no. Portugal's golden visa law contains no separate ban on Russian citizens, and most of the advertising is built on that. But the ban is not in Portuguese law. It is in the EU sanctions regulation, which binds every fund, management company and bank in the EU.

In practice it works like this. Portugal's migration agency can accept an application from a Russian citizen. But to file under the fund option you first have to buy fund units, and a Portuguese fund is not allowed to sell them to a Russian citizen. No units means no investment, and no investment means no basis for residence.

• Fund units from €500,000 - closed to Russian citizens and people living in Russia.
• Donations to science and culture - formally available, but the money is not returned.
• The exception - the applicant already holds citizenship or residence of an EU or EEA state or Switzerland.

The general mechanics of the programme are covered in our guide to Portugal's golden visa. Here we cover only what changes for a Russian citizen.

Where the ban sits: Article 5f of EU Regulation 833/2014

Article 5f of Regulation 833/2014 on sanctions against Russia prohibits selling to Russian citizens, people living in Russia and Russian companies securities denominated in the currency of any EU state issued after 12 April 2022. The same ban covers units of collective investment undertakings that provide exposure to such securities.

Funds for Portugal's golden visa are exactly such collective investment undertakings. Their units are issued in euros, and the units an investor buys today were issued after 12 April 2022. So they fall under the description in Article 5f.

This is not a personal sanction but a general measure. It applies to all Russian citizens, not only to people on the sanctions lists. A clean reputation, a transparent source of funds and absence from the lists do not help here: the ban is tied to citizenship and to the type of asset.

The second layer is banks. The same regulation prohibits EU banks from accepting deposits above €100,000 from Russian citizens and people living in Russia. This also covers the account the money passes through on its way to an investment or a donation.

Who the ban does not affect: exceptions and a second passport

The regulation names the exception directly. The ban does not apply to Russian citizens who also hold citizenship of an EU or EEA state or Switzerland, or to those with a temporary or permanent residence permit in one of these countries.

• Citizenship of the EU, EEA or Switzerland. A Russian with, say, a Bulgarian passport can buy units as an EU citizen. But an EU citizen does not need Portugal's golden visa anyway: they already have the right to live in any EU country.
• Residence in the EU, EEA or Switzerland. A Russian with a valid residence permit in, say, Cyprus is not covered by the ban. For them the fund option still works, but the fund and the bank will check that the permit is valid on the date the units are bought.
• A third-country second passport. It does not help. According to the European Commission, restrictions remain for dual nationals holding a Russian passport if the second citizenship is not of an EU or EEA state or Switzerland. A Vanuatu, St Kitts or Turkish passport does not override the Russian one here.

A separate point on residence. The ban also covers people living in Russia, whatever their citizenship. If you hold another country's passport but live in Russia permanently, the fund will refuse on the same grounds.

Which options remain and what is open to a Russian

The 2023 reform removed real estate, bank deposits and government bonds from the programme. The other options remain. For a Russian citizen without residence in the EU they look like this.

If you are offered a golden visa for an apartment in Lisbon, that information is outdated. If you are told that funds can be arranged for Russians, that contradicts the EU regulation. Amounts and costs for each option are in our article on the cost of Portugal's golden visa.

Why a fund will not sell units to a Russian citizen

You often hear that some funds take Russians with a clean source of funds while others refuse under internal policy. Since 2022 this is a matter not of fund policy but of the sanctions regulation. A management company that sells units to a Russian citizen without grounds for an exception breaches EU sanctions.

That is why management companies check the buyer's citizenship and place of residence before accepting money. Trying to enter through a company in a third country, a nominee holder or a relative with another passport is circumvention of sanctions. The regulation prohibits it separately, and it is a criminal risk both for the investor and for whoever offers such a scheme.

If you are told that a particular fund accepts Russians, ask for written confirmation from the fund stating the grounds: which exception from Article 5f applies to you. Without such a document, do not pay a commission. How the funds themselves work is covered in our article on golden visa investment funds.

The same ban closed Hungary's fund-based golden visa to Russians, although intermediaries still sell it. See our analysis on Hungary's golden visa for Russians.

Donations to science and culture: what to know

A donation is not a security, so Article 5f does not apply to it. Formally a Russian citizen can transfer €500,000 to scientific research or €250,000 to cultural heritage projects and apply for the golden visa. But this option has three features worth knowing before you decide.

• The money is not returned. This is not an investment but a non-refundable contribution to a state-approved scientific or cultural organisation. After five years you keep the status, not the capital.
• The bank. The money has to pass through an EU bank, and the limit on deposits above €100,000 from Russian citizens applies. The payment route is worked out in advance.
• The queue. The application joins the same migration agency queue as all the others. According to the minister on 7 October 2026, 46,000 applications are in the queue, about 6,000 have been processed, and the average wait per surveys is 50.4 months.

For most of our clients from Russia, giving away €250,000 or €500,000 and waiting about four years for a decision makes no sense. We consider a donation only for those who need Portugal specifically and knowingly accept these conditions.

Source-of-funds checks and banks

For those to whom the option is open, the check remains strict. The bank, the organisation receiving the donation, the fund and the migration agency all look at the same things.

• Sanctions screening. The applicant and related persons are checked against EU, UN and OFAC lists. A match or a close link to a sanctioned person means refusal.
• Source of funds. Where the money for the specific payment comes from: sale of a business, dividends, salary, inheritance. Documents are needed for every link.
• Source of wealth. How the capital was built up over the years.
• Grounds for the exception. If you rely on EU citizenship or residence, the bank and the fund will check that the status is valid on the date of the transaction.
• PEP status. Politically exposed persons and their close relatives are checked more deeply.

Direct large transfers from Russian banks to EU banks are restricted in practice. If the capital is already in a third country, such as the UAE, the money trail must still be fully transparent and documented. Splitting payments, nominee intermediaries and other people's accounts are not a solution but a breach of the sanctions regime.

The queue, presence and the time to citizenship

The golden visa's presence requirement is light: about 7 days in the first year and 14 days in each following two-year period. Portugal is in the EU and Schengen, so the residence card gives freedom of travel across the Schengen Area.

The time to a passport has changed. A new organic law on nationality was published on 18 May 2026 and took effect on 19 May. For citizens of countries outside the EU and the Community of Portuguese-speaking countries, the period of legal residence before naturalisation rose from 5 to 10 years and is counted from the issue of the first residence card. Years spent waiting in the queue do not count.

If you apply in 2026 and wait about 50 months for a decision, you could receive the card around 2030 and become eligible to apply for citizenship around 2040. More in the article on Portuguese citizenship by naturalisation. A detailed calculation is in our analysis of the queue: 6,000 decisions out of 46,000.

Documents from Russia: apostille and translation

If you go through a donation or through the EU residence exception, Russian documents are prepared under the general rules.

• Apostille. Russia and Portugal are parties to the Hague Convention, so certificates and statements are certified with an apostille rather than consular legalisation.
• Sworn translation. Documents are translated into Portuguese by an authorised translator.
• Criminal record certificate. Needed from Russia and from countries where you lived for a long time. Its validity is limited, so order it closer to filing.
• Financial documents. Statements, contracts and tax returns that confirm the source of funds are translated too.

Documents are best prepared in parallel with the sanctions check and the payment route. Because of the long queue, some certificates will have to be renewed before biometrics.

Common mistakes of Russians

• "Portuguese law has no ban, so it is allowed." The ban is in the EU regulation, and the fund must comply with it.
• "The fund takes Russians with a clean source of funds." A clean source of funds does not lift the ban on selling units. You need grounds for an exception: citizenship or residence of an EU or EEA state or Switzerland.
• "A second passport will solve it." A third-country passport does not help while you hold a Russian one.
• "We will buy the units through a company or a relative." That is circumvention of sanctions with criminal risk.
• "A golden visa for an apartment." Real estate was removed from the programme in October 2023.
• "A passport in 5 years." Since 19 May 2026 it is 10 years, counted from the issue of the residence card.

What works for a Russian citizen instead of Portugal

EU sanctions restrictions are tied to citizenship and to the type of asset, not to the country. So what matters is what exactly the money is invested in.

• Cyprus. Permanent residence from €300,000 in property, including commercial property. This is direct ownership of an asset, not fund units, so Article 5f does not apply. More on the page Cyprus permanent residence.
• Greece via a second citizenship. Filing on a Russian passport is suspended, but filing as a citizen of a second country works. The scheme is described in the article on a Vanuatu passport and Greek residence.
• Portugal after EU residence. If you already hold residence in Cyprus or another EU country, Portugal's fund option becomes possible as long as that permit is valid on the date the units are bought.

Steps for a Russian citizen

• Step 1. Sanctions audit. Lists, related persons, country of residence.
• Step 2. Checking the exception. Whether you hold citizenship or residence of an EU or EEA state or Switzerland. If not, we do not consider Portugal's fund option.
• Step 3. Choosing the basis. A donation, if you need Portugal specifically, or another country.
• Step 4. Source-of-funds dossier. Documents for every link of the capital.
• Step 5. Payment route. Taking into account the €100,000 deposit limit at EU banks.
• Step 6. Documents and filing. Apostille, translation, certificates, filing with the AIMA migration agency and biometrics.

Always check current requirements on the official portal Portugal's government services (gov.pt): the programme rules and the sanctions regime change.

Bottom line: who can use Portugal's golden visa in 2026

For a Russian citizen without EU residence, the main option of Portugal's golden visa is closed in 2026: EU sanctions prohibit selling fund units to them, and neither a clean history nor a third-country second passport changes that. Formally, donations to science from €500,000 and to culture from €250,000 remain, but that means money you do not get back, banking restrictions and the same queue of about four years.

For most of our clients from Russia it makes more sense to look at Cyprus or at Greece via a second citizenship, and to come back to Portugal once they hold EU residence. Where to start in your case we will work out at a consultation, before any expenses.