Portugal versus Greece: Two residence routes, two kinds of asset risk

The decisive difference is the asset, not just the threshold

As at 5 August 2026, Portugal and Greece both retain residence routes for investors from outside the European Union. They are no longer close variations of one generic “golden visa”, however. Portugal has removed direct property purchases from the qualifying activities listed under its Residence Permit for Investment Activity, commonly known as ARI. Greece remains substantially property-led, with capital thresholds divided by location and asset type.

The first question should therefore not be which programme displays the lowest minimum. A better question is what asset an investor is prepared to hold, how much control is required and what exit risk can be accepted while the residence basis is maintained.

Portugal has shifted away from direct property purchases

Portugal’s Agency for Integration, Migration and Asylum lists several current ARI options. They include at least €500,000 in units of a qualifying non-real-estate collective investment vehicle, €500,000 in qualifying research, and €250,000 for specified arts or cultural-heritage support. There are also routes based on forming or capitalising a Portuguese company with job-creation or job-maintenance conditions, as well as creating at least ten jobs.

For the fund route, at least 60% of the vehicle’s investment value must be deployed in companies headquartered in Portugal, and its maturity at the time of investment must be at least five years. That creates a different risk set from owning a home: Manager capability, portfolio valuation, conflicts of interest, capital calls, lock-up periods and the route to selling the fund interest.

AIMA also states a minimum stay of seven days in the first year and fourteen days in subsequent years, access to family reunification, and a two-year term for a temporary ARI permit from issuance. The wording on stay periods and renewal cycles should be confirmed for each application before capital is committed.

Greece retains property but tiers the entry thresholds

Current Enterprise Greece material states an €800,000 property threshold in Attica, the Thessaloniki regional unit, Mykonos, Santorini and islands with populations above 3,100. The standard threshold elsewhere is €400,000. A €250,000 threshold may still apply to specified conversions of industrial buildings to residential use and to qualifying historic-building restoration cases.

Those figures should not be compared by simply selecting the lowest number. Under the standard bands, residential property must have a minimum area of 120 square metres and cannot be used for short-term rentals. In conversion and historic-building cases, a lower threshold comes with planning, permitting, construction and completion-evidence risk.

The Greek Ministry of Migration and Asylum describes the outcome as a permanent investor residence permit. At renewal, the investor must show that ownership of the property, or the qualifying lease, remains in force. Liquidity is consequently more than a question of sale price: A disposal or restructuring of the asset may directly affect the residence basis.

Similar capital can produce very different balance sheets

A €500,000 qualifying Portuguese fund interest and a €400,000 or €800,000 Greek property are not interchangeable investments merely because both may support a residence application. A fund may provide a more diversified portfolio, but the investor has less direct control and depends on the manager’s reporting, governance and exit plan. Property allows diligence on an identifiable asset, but concentrates risk in its location, title, condition, carrying costs, transaction taxes and lawful rental use.

The true cost also includes government charges, legal work, valuation, translation, insurance, tax, asset or fund management and expenses for dependants. These should not be compressed into a single “all-in” number until the same family composition and holding period are used for both countries.

Residence is not citizenship or tax residence

Portugal’s ARI allows a holder to request naturalisation only if the separate Nationality Law is satisfied. The current law generally requires ten years of legal residence for nationals outside the European Union and the Portuguese-speaking-country group; EU and Portuguese-speaking-country nationals face a seven-year period. Applicants must also meet other language, knowledge, security and subsistence conditions.

The Greek official material reviewed for this comparison concerns an investor residence permit, not the purchase of citizenship. Any naturalisation route must be checked separately under nationality law and its actual-presence requirements. Equally, holding a residence permit does not by itself determine tax residence. Day counts, a permanent home, the centre of vital interests and treaty provisions can point to a different result.

A due-diligence list before choosing

Before comparing expected returns, an investor should obtain written answers to six questions:

• Is the asset eligible on the application date
• how long must the capital or ownership be maintained
• what proof is required at renewal
• which dependants fit the same structure
• when does an exit affect residence rights
• and what personal facts support the proposed tax-residence analysis?

Portugal may better fit an investor willing to accept delegated capital-management risk while avoiding concentration in one property. Greece may better fit an investor who wants control of an identifiable asset and is prepared to manage use restrictions, ownership formalities and liquidity. That is a distinction between risk structures, not a conclusion that one programme is universally better.