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Golden Visa Investment Funds: Understanding the 2021 Regulatory Adjustments
The 2021 Golden Visa reform confirmed investment funds remain viable, requiring CMVM regulation and at least 60% capital investment in Portugal, making funds increasingly attractive to sophisticated investors.
On 12 February 2021, together with the publication of Decree-Law no. 14/2021, the Portuguese government introduced regulatory clarifications affecting investment fund subscriptions used for Golden Visa applications. While the headline reform restricted real estate routes, investment funds remained viable and grew in popularity among sophisticated investors.
The 2021 adjustments confirmed that qualifying funds must be regulated by the Portuguese Securities Market Commission (CMVM) and must invest at least 60% of their capital in Portugal. Funds eligible for Golden Visa purposes typically focus on private equity, venture capital, commercial real estate development or innovation-driven sectors.
For investors from the US, UK, Canada, Israel and Brazil, the fund route became increasingly attractive from 2021 onwards. Compared with real estate, funds offer several advantages: reduced acquisition friction, diversified risk, no property maintenance obligations and potential professional management of the investment.
However, fund selection requires expert due diligence, as risk profiles and liquidity vary significantly. Investors must ensure that subscription documents meet all ARI requirements, and that the fund can provide the necessary compliance declarations.
The 2021 regulatory update strengthened the fund route’s credibility and positioned it as the preferred option for many post-2022 Golden Visa applicants.
Official source: Diário da República, Decree-Law no. 14/2021 and regulatory annexes, 12 February 2021 (https://dre.pt)