How long must you hold a Portugal Golden Visa fund investment?

The Portugal Golden Visa fund holding period is the minimum time an investor must keep the EUR 500,000 qualifying fund investment in order to keep the residence permit: five years, counted from the date the residence permit is granted, not from the date the money is invested (Article 65-B of Regulatory Decree 84/2007, checked 2 November 2026).

In short: A Portugal Golden Visa fund investment must be held for at least five years from the date AIMA grants the residence permit. Because the grant typically comes 12 to 18 months after filing, an investor should plan to hold the fund for roughly six to six and a half years from subscription, and longer if processing slows.

Figures verified 2 November 2026.

Key facts at a glance

Table 1: Portugal Golden Visa fund route, holding and maturity rules. Figures checked 2 November 2026 against Law 23/2007 (consolidated to Law 62/2026 of 10 September 2026), Regulatory Decree 84/2007 and AIMA’s Migration and Asylum Report 2024.

Does the five-year holding period start when you invest or when the permit is granted?

The Portugal Golden Visa five-year holding period starts on the date the residence permit is granted. Article 65-B of Regulatory Decree 84/2007 states that the minimum five-year requirement for maintaining the investment activity is counted from the date the residence permit is granted. The parent law, Law 23/2007, article 3(1)(d), defines a qualifying investment activity as one maintained in Portugal for a minimum period of five years, and leaves the start date to the regulation.

This is commonly reported as “hold the investment for five years”. The actual position is five years from grant, because Article 65-B fixes the start of the clock at the grant of the permit, not at subscription and not at filing. The difference is the time AIMA takes to decide the application, which in recent years has been the largest single variable in the programme.

The rule is not new. It first appeared in article 4 of Despacho 11820-A/2012, which governed the programme when it opened on 8 October 2012, and moved into the regulatory decree when Regulatory Decree 15-A/2015 added articles 65-A to 65-J. What changed is the queue. When decisions took weeks, the gap between “five years” and “five years from grant” hardly mattered. It now does.

How long will you actually hold a Golden Visa fund?

A Portugal Golden Visa investor should plan to hold the qualifying fund for about six to six and a half years from subscription, and up to eight years if processing is slow. That is a Citizenship360 calculation, and the working is short.

• You subscribe before you apply. The quantitative requirements must be met when the application is filed, and the file must include a certificate showing you own the units (Regulatory Decree 84/2007, arts. 65-A(12) and 65-D(9)).
• AIMA then decides. Our processing times guide plans on 12 to 18 months from submission to residence card for a well-prepared file; some applicants who filed in more congested periods waited considerably longer. We use the card date as a conservative proxy for the grant date.
• The five-year clock then runs from grant.

Table 2: when the five-year holding is met, by time from subscription to grant, and how far short a fund of a given term would fall. Citizenship360 calculation, 2 November 2026, assuming filing shortly after subscription.

In our client conversations, the question that comes up most often just before subscription is when the capital comes back. The honest answer is five years after a date that nobody, including AIMA, can fix in advance.

Why does the fund’s maturity date matter?

A Portugal Golden Visa fund must have a maturity of at least five years at the moment you invest (Law 23/2007, art. 3(1)(d)(vii)). That eligibility test and the holding test are different, and a fund can pass the first while failing you on the second. A fund with exactly five years left to run on the day you subscribe will reach the end of its term before your five years from grant are complete, unless your permit is granted the same day.

Most qualifying funds are closed-ended, with terms of six to ten years, as our guide to the qualifying funds sets out, and many allow the term to be extended. Before subscribing, check three things in the fund’s management regulation:

• the final maturity date, measured against your realistic grant date rather than your subscription date;
• whether the term can be extended, by how long, and who decides;
• whether the manager can return capital early through distributions or compulsory redemptions, which could take your holding below EUR 500,000 before the five years are up.

We are not aware of published AIMA guidance on reinvesting the proceeds of a fund that winds up mid-period into a new qualifying fund. Treat that as a risk to avoid, not a plan to rely on.

Can you pledge, transfer or partly redeem the units during the five years?

At grant and at each renewal of a Portugal Golden Visa, the investor must produce a certificate showing ownership of the fund units free of charges and encumbrances, issued by the entity that keeps the register of unitholders; at grant, a declaration from the management company is also required (Regulatory Decree 84/2007, arts. 65-D(9) and 65-E(10)). Three practical consequences follow.

• Pledging the units as security for a loan creates exactly the encumbrance the certificate must exclude.
• Partial redemption that takes the qualifying holding below EUR 500,000 before the five years end leaves you unable to evidence the investment at renewal.
• The holder must be you, or your own company. The regulation contemplates units held personally or through a single-member company (sociedade unipessoal por quotas) of which you are the sole shareholder, with its seat in Portugal or another EU state and a permanent establishment in Portugal (Regulatory Decree 84/2007, art. 65-A(11)). Nominee, wrapper or custody structures that do not put your name, or your company’s, on the unitholder register can fail this test.

Our fund due diligence guide covers the rest of the checklist.

What happens when the five years are up?

Once five years from grant have passed, the minimum holding requirement in article 3(1)(d) of Law 23/2007 has been met. That does not by itself settle what residence status you hold next. Under Lei Orgânica 1/2026, in force since 19 May 2026, Portuguese naturalisation requires ten years of legal residence for most nationalities, or seven for EU and CPLP nationals (Law 37/81, art. 6(1)(b), as amended). An investor aiming for citizenship therefore needs a valid residence title for roughly twice as long as the investment must be held.

Whether to keep renewing the investment permit with the investment still in place, or to move to permanent residence, which has its own conditions, is a decision to take with your lawyer before you redeem, not after. Our analysis of the 2026 nationality law explains the citizenship clock in detail.

How should the holding period shape fund selection?

Our position is that the holding period should be the first filter in Portugal Golden Visa fund selection, ahead of target returns. A fund’s term, not its strategy, decides whether it can carry you to the end of your five years from grant without a forced exit or an awkward reinvestment. In practice that means preferring funds whose remaining term at subscription comfortably exceeds six and a half years, or whose extension mechanism is clear and not solely at the manager’s discretion, and reading the liquidity terms for year five after grant rather than year five after subscription.

The trade-off is real. A longer-dated fund locks capital up for longer and may hold you beyond the point at which you would choose to exit; a shorter one risks ending before your obligation does. Neither is wrong in itself, but the choice should be made knowingly. Our complete guide to the Portugal Golden Visa places this decision in the context of the whole programme.

Frequently asked questions

Is the Portugal Golden Visa holding period five years?

Yes. The Portugal Golden Visa investment must be maintained for at least five years, counted from the date the residence permit is granted (Regulatory Decree 84/2007, art. 65-B).

Does the time spent waiting for AIMA count towards the five years?

No. The five-year clock for a Portugal Golden Visa investment starts at grant, so the time between filing and AIMA’s decision is additional holding time.

Does a Golden Visa fund need five years left to run when I invest?

Yes. A qualifying Portugal Golden Visa fund must have a maturity of at least five years at the moment of investment (Law 23/2007, art. 3(1)(d)(vii)). That is a minimum for eligibility, not an assurance that the fund will outlast your holding period.

Can I sell my Golden Visa fund units after five years?

The Portugal Golden Visa holding requirement is met five years after grant. Whether redeeming then is sensible depends on the fund’s liquidity terms and on the residence status you will rely on next, particularly if you are working towards citizenship after ten years of legal residence.

Can I hold Golden Visa fund units through a company?

Only through a single-member company (sociedade unipessoal por quotas) of which you are the sole shareholder, with its seat in Portugal or another EU state and a permanent establishment in Portugal (Regulatory Decree 84/2007, art. 65-A(11)).

This article is general information, not legal, tax or investment advice. Investment migration rules and tax rules change frequently and depend on your personal circumstances. Figures are correct as at the date shown and should be confirmed before you act. Speak to a qualified adviser, and contact Citizenship360 for guidance specific to your situation.

Sources

• Law 23/2007 of 4 July, article 3(1)(d), consolidated text including Law 62/2026 of 10 September 2026, Procuradoria-Geral Distrital de Lisboa: pgdlisboa.pt. Checked 2 November 2026.
• Regulatory Decree 15-A/2015, adding articles 65-A to 65-J to Regulatory Decree 84/2007 (articles 65-A(11), 65-A(12), 65-B, 65-C, 65-D(9), 65-E(10)): text as published. Checked 2 November 2026.
• Despacho 11820-A/2012, Diário da República, 2nd series, no. 171, 4 September 2012, article 4. Checked 2 November 2026.
• Lei Orgânica 1/2026 of 18 May, amending Law 37/81 (Nationality Law), Diário da República no. 95, 1st series: published text. Checked 2 November 2026.
• AIMA, Relatório de Migrações e Asilo 2024 (October 2025), page 14: aima.gov.pt. Checked 2 November 2026.