‘Golden Visas’ Cost Real Money. Why the Rules Keep Changing.

Greece retained the option to invest in real estate when it overhauled its golden visa in 2024, but investment minimums vary by location. (Aris Messinis / AFP / Getty Images)

Wealthy individuals and families worldwide increasingly are seeking a second residency in another country by investing in job-creating funds, real estate, and other ventures.

But what governments from Portugal to the U.A.E. require to secure residency—or citizenship—in their country not only varies, it constantly changes amid shifting economic and domestic priorities.

Over the past two decades, “investment migration,” as this practice is called, has gone from a “niche offering” in a few countries, “to a central instrument of national policy,” according to Armand Arton, who runs a global firm advising those who are seeking residency or citizenship in another country.

“Countries are increasingly relying on these programs to attract capital, talent, and innovation,” Arton said in an email.

That’s evident in the U.S., where the Trump administration has introduced a “gold card,” that offers permanent residency in exchange for a $1 million “contribution” to the government. The contribution is required per person, meaning, a family of four would pay $4 million. The gold card currently remains an addition to the EB-5 program, a lengthier process for receiving permanent residency that requires an investment of at least $800,000 in a project that spurs economic development.

Arton’s Montreal-based firm, Arton Capital, recently collaborated with King’s College London to analyze and compare current programs outside the U.S., going deep on a handful to explain the history of why they developed in each country, to quantify the costs and benefits, and to examine how governments that offer golden visas manage the domestic tensions that can result.

A goal of this effort—resulting in a report written by Andreza Aruska de Souza Santos, an associate professor and director of the Brazil Institute at King’s College London—aims to dispel the “assumptions and emotions” that often drive public debate around golden visa initiatives.

Portugal, for example, began offering golden visas in 2012 to attract foreign direct investment to boost its economy in the wake of the euro zone debt crisis. Since then, the program has generated more than €7.3 billion ($8.6 billion).

The country’s golden visa became popular, originally among Chinese and Brazilian citizens, and later, citizens from North America, for providing access to a Portuguese passport—and therefore to all of Europe—without having to stay in the country more than seven days a year, on average.

An applicant could get a Portuguese golden visa by making various types of investments but real estate was the most popular, attracting more than 79% of all investment dollars, the report said. Those investments changed the complexion of Lisbon and Porto, as land values rose and the cities’ housing markets were reshaped, according to the report, which quantifies these changes. The repercussions of the shifting landscape in these cities worsened for the local population during the Covid-19 pandemic, “highlighting the housing precarity faced by vulnerable social groups,” the report said.

In 2023, the country scrapped the real estate investment option. Now, applicants must invest a minimum 500,000 euros ($587,000) in funds that create or maintain jobs or finance public or private scientific research institutions. Applicants can also contribute at least €250,000 toward a project that preserves Portugal’s cultural heritage, the report said. The idea was to create attractive investment options that have “greater public relevance,” the report said.

Greece—another European destination—retained the option to invest in real estate when it overhauled its golden visa in 2024, but raised the minimum threshold from €250,000 to €800,000 in the “high-demand” urban areas preferred by investors and €400,000 everywhere else. Applicants can still invest only €250,000 if they rehabilitate historic buildings or industrial zones to residences. Greece also scrapped the ability to use properties for short-term rentals.

The U.A.E.—a popular destination for citizens from India, China, North America, Saudi Arabia, and Russia—began offering an automatically renewable long-term residence visa in 2019 to bring in investors, professionals, entrepreneurs, and “specialized talents,” without a local sponsor. Visa holders have the right to live, work, and study in the U.A.E., and they can sponsor family members of any age. Unlike other programs, however, the U.A.E.’s doesn’t offer a path to citizenship, which means even these long-term visa holders are rarely fully integrated into local society, the report said.

Since its inception, the U.A.E.’s golden visa has continually evolved, adding new categories of individuals who can apply—including students, artists, and scientists, and adding a minimum 2 million dirhams ($544,514) for investment in real estate in 2021. This year, the government broadened the definition of qualified professionals to anyone earning at least the equivalent of about $8,200 a month, and specifically expanded its scope to include teachers and nurses.

This shift toward a merit-based model—similar to policy shifts in other countries—reflects “a global recalibration,” Arton said.

“Investment migration must operate like a public-private partnership if it’s to thrive,” he said. “This means raising standards, embracing robust due diligence measures, creating clear links between revenue and social outcomes, and designing programs that contribute to national development.”

The ever-shifting landscape of golden visas isn’t dissuading people from securing one, however.

“Demand doesn’t disappear—it redirects,” Arton said. “If one route closes, our clients interest tends to move into alternative funds or jurisdictions. What matters to them is the stability of the program and the country they are investing in.”

Write to Abby Schultz at abby.schultz@barrons.com