Greece vs Portugal Golden Visa Comparison 2026: After the Removal of the Real Estate Option

Golden Visa Greece vs Portugal is the most frequently discussed comparison in the EU residency investment community in 2026, especially after Portugal formally removed the real estate investment option under the Mais Habitação Law 56/2023 in October 2023, while Greece continues to keep real estate as its main option but has raised the thresholds under Law 5100/2024. The two programmes now follow two clearly distinct paths: Greece focuses on zoned real estate, while Portugal focuses on venture capital funds.

This article analyses the comparison in detail across the five criteria most important to Vietnamese investors: the current investment structure, capital thresholds and actual costs, real residency requirements, the path to citizenship, and family policy. The content is based on the official legal framework as of 05/2026, including the significant reform currently before the Portuguese Parliament to extend the time required to apply for citizenship.

Current investment structure

Greece — zoned real estate and specific alternative options

Greece keeps real estate as the main pillar of its Greece Golden Visa following the reform under Law 5100/2024, with a three-tier structure based on geographic zone. The €800,000 EURO level applies to Zone A, covering the Attica Region, the Thessaloniki Regional Unit, Mykonos, Santorini and 32 islands with a population above 3,100. The €400,000 EURO level applies to Zone B, covering the rest of Greece. The €250,000 EURO level remains for two specific options: converting commercial property into residential use, and restoring a heritage building.

Alongside the three real estate levels, Greece also offers non-real-estate options, including: transferring €500,000 EURO into a Greek bank with a 5-year lock-in, purchasing Greek government bonds worth at least €500,000 EURO, investing €800,000 EURO in shares of listed Greek companies, or investing €350,000-€800,000 EURO in a Greek AIF/UCITS fund. In practice, however, over 95% of investors choose the real estate option for its transparency and tangible asset.

Portugal — venture capital funds and cultural contributions

Portugal has a completely different structure following the Mais Habitação Law 56/2023 reform enacted in October 2023. The real estate option (both direct purchase and real-estate-linked funds) has been removed entirely, along with the removal of the €1,500,000 EURO bank transfer option. The five remaining options all fall under non-real-estate investment or contributions.

The most popular option today is investing €500,000 EURO in a Private Equity or Venture Capital fund licensed by CMVM (the Portuguese Securities Market Commission) . The fund must invest a minimum of 60% of its capital in businesses headquartered in Portugal and must have no direct or indirect connection to real estate.

The four remaining options in the Golden Visa Greece vs Portugal structure are: creating 10 full-time jobs (with no fixed capital threshold), investing €500,000 EURO in a Portuguese business while creating 5 jobs, contributing €500,000 EURO to scientific research activities, or contributing €250,000 EURO to a cultural heritage or arts project.

Comparing capital thresholds and actual costs

Criteria	Greece Golden Visa	Portugal Golden Visa
Lowest threshold	€250,000 (conversion/heritage)	€250,000 (cultural contribution)
Most common threshold	€400,000 (Zone B property)	€500,000 (investment fund)
Highest threshold	€800,000 (Zone A property)	€500,000 (most options)
Asset type	Tangible (property)	Financial (fund, contribution)
Legal fees	3-5% of the property price	1-2% of the fund value
Processing fee	~€2.000 EURO	~€5.500 EURO
Property transfer tax	3% of the contract price	N/A
Ability to recover capital	Sale of the property (60-80% of value)	Fund redemption after 5-8 years

With a budget under €500,000 EURO, there are really only two options: Greece’s Zone B €400,000 EURO property, or Greece’s €250,000 EURO conversion/heritage option. Portugal has no option below €500,000 EURO except the €250,000 EURO cultural contribution (a complete loss of capital, with no possibility of recovery).

With a budget above €500,000 EURO, the difference lies in investment philosophy. Greece offers a tangible asset that can be resold after leaving the programme, with recovery of 60-80% of the purchase price depending on the market and the timing of sale. Portugal offers a financial investment through a professional fund, with a target yield of 2-20% per year depending on strategy, in exchange for the capital being locked up for a minimum of 5-8 years.

Golden Visa Greece vs Portugal on actual residency requirements

This is a major difference between the two programmes. Portugal requires a minimum stay of 7 days in the first year and 14 days in each subsequent 2-year period, one of the lowest requirements in Europe. This is easy to meet with a short business trip or holiday, and does not pressure an investor to change their main life in Vietnam.

Greece has no minimum residency requirement across the entire 5-year life of the Golden Visa card. Investors only need to visit Greece once, to provide biometric data (fingerprints and a facial photo) when receiving the card. This is a fundamental difference: Portugal requires a small amount of physical presence, while Greece requires almost none.

However, this difference has an important tax consequence. Both countries determine tax residency based on staying more than 183 days in the country during the year. With a low 7-14 day residency requirement, a Portuguese investor will almost never become a tax resident, keeping their tax status unchanged in Vietnam. With Greece requiring no residency at all, the tax outcome is similar, but the investor retains the option of taking up actual residence at any time if they wish (for example, so a child can study in the EU).

Golden Visa Greece vs Portugal on the path to citizenship

Portugal — moving from 5 years to 10 years

Portugal was previously well known for the shortest path to citizenship in the EU (5 years). However, under the new Nationality Law proposals submitted by the Portuguese Council of Ministers to Parliament in 2025 and currently under review, the residency period required to qualify for citizenship is expected to rise from 5 years to 10 years for most applicants.

Citizens of CPLP countries (the Community of Portuguese Language Countries) remain at 7 years. As of 05/2026, these provisions have not yet been formally signed into law by the President, but they are expected to take effect during 2026-2027. This is an important variable to consider when weighing Golden Visa Greece vs Portugal for citizenship purposes.

Naturalisation requirements include sufficient lawful residence, no serious criminal record, and passing an A2-level Portuguese language test (a basic communication level, mostly multiple-choice questions). Investors should note that, even though applying for citizenship requires a 5-10 year wait, applicants can still apply for permanent residence (PR) after 5 years, which grants the right to live and work in Portugal and across the EU without needing to maintain the investment any longer.

Greece — a stable 7 years

Greece maintains a 7-year path to citizenship under Nationality Law 3284/2004, which has remained stable for decades with no sign of change. Naturalisation requirements include 7 years of lawful residence, passing a B1-level Greek language test (one level above Portugal’s A2), and a test on Greek culture and history.

Both countries grant Greek citizenship citizenship of Greece or Portugal together with an EU passport, allowing free movement to live, work and study across 27 EU countries. Portugal and Greece rank similarly on the Henley Passport Index, both in the world’s top 10, with visa-free or visa-on-arrival access to over 180 countries.

Practical comparison: if Portugal’s new Nationality Law proposals are passed, Greece becomes the faster route to citizenship (7 years vs 10 years). Conversely, if Portugal keeps the 5-year period, Greece is 2 years slower. This is an important factor for investors for whom citizenship is the main goal.

Golden Visa Greece vs Portugal on family policy

The two programmes share a great deal in common regarding the scope of family members who can be sponsored, but differ in important details. Both allow sponsorship of a spouse, a legally cohabiting partner, and dependent children. Both allow sponsorship of the investor’s own parents and the spouse’s parents.

The difference lies in the age limit for sponsored children. Greece limits this to under 21, after which children must move to other categories such as student or worker status. Portugal extends this to under 26, provided the child is unmarried and in full-time education. This 5-year difference matters greatly for families with children of university age, especially since studying in Europe often extends to age 24-25.

Comparison table of family policy:

Criteria	Greece	Portugal
Legal spouse	Yes	Yes
Common-law partner	Yes	Yes
Children under 18	Yes	Yes
Children aged 18-21	Yes (no conditions)	Yes (while studying)
Children aged 21-26	No	Yes (while studying, unmarried)
Investor’s parents	Yes (no conditions)	Yes (financial dependency required)
Spouse’s parents	Yes (no conditions)	Yes (financial dependency required)
Maximum number of children	Unlimited	Unlimited

For families with children studying at undergraduate or postgraduate level in Europe (aged 18-25), Portugal has the advantage. For families spanning three generations (grandparents – parents – children), Greece has the advantage because it does not require proof of the parents’ financial dependency.

Processing time

Both countries face a backlog of Golden Visa applications, though to differing degrees. Greece’s statutory processing time is 2 months, but in practice it takes 4-12 months depending on the region and the complexity of the file, owing to a backlog of around 50,000 applications awaiting review.

Portugal has a considerably longer processing time. After the AIMA (the Agency for Integration, Migration and Asylum) agency replaced the former SEF in October 2023, Golden Visa processing has usually taken 12-18 months, and in some cases up to 24 months. However, Portugal made an important decision in 2025: the residency period counted for citizenship purposes now begins from the date of application, not from the date the residence card is issued, easing the pressure of administrative processing time.

Both countries are digitising their processes. Greece launched an online application platform in 2025. Portugal is in the process of rolling out AIMA digital tools to speed up processing. However, for actual applications in 2026, Greece still processes files faster.

Tax advantages

Greece offers three special tax regimes: a 7% pension tax for 15 years for retirees who transfer their tax residence to Greece, a 50% income tax exemption for 7 years for digital nomads and highly skilled professionals, and the Non-Dom 5A regime with a flat €100,000 tax per year on worldwide income (requiring a €500,000 investment in Greece). Details are set out in the article taxes in Greece.

Portugal’s well-known NHR (Non-Habitual Resident) regime ended in 2024. The government replaced it with the new NHR 2.0 regime (Tax Incentive for Scientific Research and Innovation – IFICI), aimed at workers in science, research, technology and innovation. This regime is not as broadly available as the old NHR and requires investors to meet specific sector criteria.

Overall, Greece now has a broader and more flexible tax incentive system than Portugal after 2024. However, because neither Golden Visa programme requires enough residence to become a tax resident, the practical impact of this tax difference is only relevant to investors who intend to actually move to and live in the EU.

Who each programme suits

The Greece Golden Visa suits three groups better. The first is investors with a budget under €500,000, particularly €250,000-€400,000, because Portugal has almost no option in this range (other than a non-recoverable cultural donation). The second is investors who prefer a tangible property asset that can be passed on to the next generation, with no interest in financial assets. The third is families with elderly parents who want to sponsor them without having to prove financial dependency.

The Portugal Golden Visa suits three other groups better. The first is investors with a budget above €500,000 who prefer professional financial investment with a target yield of 2-20% per year over owning property. The second is families with children aged 21-26 studying at undergraduate or postgraduate level in the EU, who need a longer sponsorship extension. The third is investors betting on a shorter route to citizenship (if the new Nationality Law keeps the term at 5 years rather than 10).

For Vietnamese investors with a budget of VND 8-15 billion (equivalent to €300,000-€600,000), Greece has a clear advantage thanks to the Zone B €400,000 property option and the €250,000 conversion-heritage option. See also our in-depth articles on Greek Golden Visa Zone B €400,000 for details on the route that suits a mid-range budget.

Summary

The Greece vs Portugal Golden Visa comparison in 2026 is no longer a like-for-like match of investment structures as it was before 2023. After Portugal removed the real estate option, the two programmes now serve two different investor segments: Greece for those who prefer a tangible asset from €250,000 upwards with flexible geographic zoning, and Portugal for those who prefer financial investment from €500,000 upwards with the lowest actual residence requirement in the EU.

The final decision depends on three personal factors: actual budget (under €500,000 favours Greece), investment philosophy (tangible assets favour Greece, financial investment favours Portugal), and the EU pathway goal (long-term residence favours Greece with its broader tax incentive system, while a paper-only route favours Portugal with its 7-14 day residence requirement). See our in-depth articles on each option to build a pathway suited to your family’s asset structure and specific goals.