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Portugal Golden Visa Program Unofficially Suspended

As for Golden Visa Portugal, the news is hardly encouraging. After real estate visas were suspended in Portugal in early 2022, foreign investors may no longer apply for the investment immigration program. Recent investigative reports and articles by highly-reputed industry experts serve as a visible proof thereof. With visas of this type suspended in Portugal, studying the situation and looking for worthy alternatives seems to be a logical workaround.

Suspension of Portugal Golden Visa

Recent developments in the Portugal Golden Visa Program

In Portugal, the Immigration and Borders Service (aka Serviço de Estrangeiros e Fronteiras or SEF) processes residence applications submitted by foreigners through various special-purpose initiatives including ARI, start-up programs, and the residence permit program for financially independent persons. 

SEF official data confirm that within the last 10 years the Autorizações de Residência por Investimento initiative contributed to inviting foreign capital to Portugal en masse. From October 2012 till April 2022, Portuguese officials issued a total of 16,636 residence permits to investors and their relatives. The total investment amount exceeded EUR 6,280,000,000. Most residence permits (around 90%) were issued to real estate investors.

Suspension of residence permit

The above information for year 2022 refers to requests and applications submitted till December 31, 2021, and approved in 2022. With application submission suspended, no more residence permits are issued to real estate investors in Portugal via the ARI program, and the officials keep mum. Industry pros in Portugal, including immigration and real estate agents, ring the alarm bell. What’s up with the golden visa program? Let’s see what Portugal golden visa changes were introduced.

New applications for the Golden Visa Program in Portugal suspended

  • Requests and applications for new ARI cards have been suspended and are processed no longer. New Golden Visa applications are submitted via the ARI online platform. Its operations have been suspended since January 2022. It is safe to say under the circumstances that the Portuguese government has suspended the program. It is no longer possible for real estate investors to submit any new residence permit applications, either directly or indirectly, even though the  platform allows amendments in the earlier applications (submitted before the date they were suspended). Where a real estate investor tries to submit a new application, the ARI platform pops the Impossible to complete your application. This investment type is awaiting regulation error message (Não é possível concluir a candidatura porque o tipo de investment aguarda regulamentação). This error means the program has been suspended. It first appeared in 2022 in the following situations:
    • Foreign investment from the applicant directly purchasing Portuguese real estate
    • Foreign investment originating from local real estate investment funds.
  • No opportunity to renew resident cards received before the program was suspended. According to the Lisbon Regional Council of the Portuguese Bar Association (Conselho Regional de Lisboa da Ordem dos Advogados), after the program was suspended, real estate investors may no longer get new permits. What is worse, they are denied an opportunity to renew the residence permits they once had as real estate investors. The suspension in question has been effective since the beginning of 2022. As provided for under the laws of Portugal, successful foreign investors may renew their residence permits every second year, if they stay in Portugal for 2 weeks during the said 2-year periods and hold their assets. At the expiry of their 5-year residency period, such investors may apply for the citizenship of Portugal if they are naturalized and have passed the language test. If they wish to renew their residence by investment status, program participants need to visit the SEF office in person before their resident card and golden visa expire. In reality, as applications via the ARI platform have been suspended, we have the following situation: if a program participant wishes to enter Portugal to meet the local residence requirement, providing for a 14-day stay in Portugal during the said 2-year period and visit to the local SEF office, they are deprived of this opportunity due to their resident card being void. The Portuguese government actually deceived their significant investors, who pay real estate taxes in Portugal and were promised to have their residence permits renewed in case they meet all the legal requirements. In reality, the government unofficially suspended the initiative. Needless to say, this undermines the country’s reputation abroad.
  • Meetings with SEF officials being canceled or postponed at the very last minute.  Immigration lawyers comment on strange things happening to golden visa applications officially submitted via the ARI platform long before 2022. Shortly before their pre-agreed meetings are to take place, applicants receive notices from SEF on the approval procedure being canceled or suspended, with no explanations from SEF whatsoever. Deadlines are postponed 4 months on average. This causes irritation and major issues on the part of the applicants who arrive for their interview with SEF officials. The interview is about to take place in a week’s time, but the officials cancel it 3 days prior. As we see it, this equals the “last minute cancellation”.
  • Longer naturalization period. Even before the above issues with applications being constantly suspended arose, the minimum period set to process investment applications with naturalization potential made up at least 5 years. With the delays in mind, many investors have to wait for their visas for over 6 years. Very few applicants are ready to have their capital frozen for such a long time, without any rational explanations for such delays being provided.
  • Expired documents. A number of documents necessary to get the residence by investment status in Portugal have short validity periods, with account statements and clean criminal record certificates among them. It takes a long time and costs much money to re-acquire them, especially considering they need to be translated into Portuguese and legalized. It is a heavy burden for program participants to wait for a document review to resume.
  • Lack of family reunification options for potential immigrants. With the program suspended, family reunification may be a way to get your residence permit in Portugal, if you have relatives with golden visas in the country. We are talking about an opportunity to get a residence permit in Portugal through family reunification.  To do it, the investor’s relatives need to call the SEF office and make an appointment. With interviews being constantly postponed or rescheduled, and official procedures suspended, both investors and their dependents find themselves in an environment of uncertainty. No one is sure about the deadlines, and families remain separated.

Why are golden visa applications suspended?

  • In Portugal, golden visa new rules took effect. SEF suspended all visa applications from real estate investors while waiting for new regulations to be adopted. The latter will result from changes in legislation under the ARI initiative, effective since January 1, 2022. The said changes shut the whole system down and put an end to the golden visa (received via real estate investment in Lisbon, Porto, and on the Portuguese coast, including much of the Algarve region real estate) program. Officials adopted legislative amendments to supposedly ease the burden on the overheated residential real estate markets and help ordinary Portuguese people solve their housing issues. Independent experts believe the said amendments are based on wrong assumptions. The foreign investment percentage remains relatively small, and the environment for speculative transactions is unavailable. This is due to the fact that to receive their golden visas, investors need to purchase residential properties in a way that lasts.
  • SEF liquidation. The Immigration and Borders Service is actually a security provider with the Portuguese Ministry of Internal Affairs (Ministério da Administração Interna; MAI). Its operations are suspended, and it will be soon liquidated under the government decision adopted in 2021. The idea is to transfer the body’s powers and responsibilities to other organizations, with the Institute of Registries and Notaries (Instituto dos Registos e Notariado) and the Portuguese Agency for Migration and Asylum, a new government institution in Portugal, among them. The agency’s employees will be distributed between other government institutions. In early 2022, the Portuguese government suspended SEF liquidation. Uncertainty and almost sure prospects of losing their jobs prevent the remaining employees from being productive and promote strikes and labor troubles, resulting in Portugal’s tarnished image. SEF is actually comatose today. Lack of manpower aggravates the situation. Many experienced officers have retired, and no new employees are being trained. Substantial investments in SEF development are also missing.
  • Pandemic. It is not Portugal only that suspended administrative procedures and long waiting lists are characteristic of. Waiting for official decisions to be adopted may take months anywhere in the world. This mostly results from pandemic delays and logistical challenges.
  • Internal and external pressures. Golden visas promote real estate investment and domestic economic growth in Portugal and some other states. However, they have lately become the subject of debate on both national and international level. Several high-powered and affluent government entities insist on either such programs be suspended in Europe or tighter rules thereof be put into effect. This is exactly what happened in Portugal some time ago. The European Union pushes its member countries to apply streamlined regulatory procedures to golden visas if these states have such programs in place. European officials strive to introduce common EU regulations for harmonization of rules and procedures and stepping up the fight against money-laundering, corruption and tax evasion. You may find this information in the official European Parliament press-release disclosed in March 2022. It targets the corresponding programs suspended in the region. The challenging political situation creates additional issues for Portugal golden visa applicants.

SEF’s official stance on the program being suspended

Local mass media contacted the agencies in charge of this issue. Several attempts were made to get in touch with SEF, the Ministry of Internal Administration, the Ministry of Economic Affairs, and the Ministry of Foreign Affairs that actively promoted the golden visa program to raise the country’s investment potential and make the local real estate market more appealing to foreign investors. These attempts failed.

Both SEF and the government keep silence, and this worries industry experts. The latter blame Portuguese officials for the lack of transparency with the program. According to the industry pros, foreign investors may fail to trust the government and its politics as a result. The point of independent experts is that the country’s image is at stake, and the administration’s silence, together with clouded prospects, make the situation even worse.

SEF was contacted several times by email for at least some explanations. Successful requests resulted in run-around replies, though. The officials claim no authorized persons are available at any given time. The ones that are available supposedly don’t have enough knowledge of the situation, as they are not involved with operational decision-making. Some lawyers were filed in on outdated software being the reason why it is impossible to resume the application processing.

Portuguese officials remarkably managed to configure the online platform to help Ukrainian refugees within less than 24 hours. At the same time, they have been improving the ARI software as provided for under the legislative amendments and upgrading it for half a year already. Surprisingly, they haven’t succeeded with it yet.

Considering the above legal developments were announced in spring 2021, the Portuguese experts had enough time to get ready. It is evident that no preparations were made, and this undermined the country’s reputation and resulted in the loss of confidence in Portugal.


  • Raising awareness of the issues SEF faces. Industry experts believe that finding solutions is the responsibility of the government, assisted by the Ministry of Internal Administration. Local lawyers wrote a joint letter to the above ministry to make sure it is aware of the situation. The Portuguese Association of Immigration, Investment and Relocation (or PAIIR) already requested the government to organize corresponding meetings and discuss the above issues.
  • Standardization of consulate procedures. Lawyers also declare it is necessary to standardize immigration and any other consulate procedures, while providing for the scrupulous performance of their official golden visa document processing duties by diplomatic mission employees. Immigration lawyers constantly deal with the fact that certain Portuguese consulates apply their own substandard requirements and procedures. This results in the lack of transparency, officialism, and major issues for foreigners intending to get residence permits in Portugal.
  • Lower requirements for document duration. Ever since it became necessary to actually apply to the SEF office in Portugal, many golden visa applicants appeared to have expired documents. Experts encourage the officials to extend the corresponding document validity periods.
  • Greater transparency with interview scheduling. It is important that all the interviews are scheduled on a transparent basis, following generic standard requirements. Even where extra time is necessary, the officials should demonstrate that all applicants have equal chances to be invited to an interview. As of today, both SEF and other government bodies in Portugal fail to efficiently manage administrative procedures and ensure predictability. Experts believe a central planning service may be an effective solution.

Alternative immigration routes to Europe

The consequences of the ARI program being suspended may already be noticed in the country’s real estate sector, claim industry experts and lots of other sources contacted to gather information for the article. This situation is not appealing to foreign investors who are about to search for their luck elsewhere.

Investment immigration lawyers encourage their customers to focus on worthy alternative programs that function effectively. Portugal happens to be among the states that offer appealing alternative routes for investment immigration.

  • D7 Visa to Portugal for financially independent persons (Visto D7 para Portugal). This immigration route offers an opportunity to receive a Portuguese residence permit with no delays typical of golden visas. Certain requirements have been introduced for program participants. They shall open a personal account with a bank in Portugal and credit it with at least EUR 30,000. Such applicants will additionally submit documents confirming their income from sources outside Portugal (say, salary, royalties, or pensions) above the poverty rate  (EUR 705 per month or EUR 8460 per year). In case of collective applications with the applicant’s relatives included, such applicant will have to document an even higher income (+ 50% to the said poverty rate for a spouse and + 30% for each child). The main thing to do to keep your resident status is to stay in the receiving state for over a half of the calendar year. An applicant, complying with this requirement, will be registered as a tax resident in Portugal, and their tax resident status in the country they lived in previously will be suspended. Hence, to receive your long-term residence status in Portugal, you need to prove you own or lease real estate in the country. A title certificate (for purchased properties) or a lease agreement may be used therefor.
  • Long-term residency status in Serbia for real estate investors. The immigration laws of Serbia provide for an opportunity to obtain a long-term resident status in Serbia for foreign real estate investors. This applies to foreigners intending to live in their newly-purchased properties. You need to actually reside in your apartment or cottage in Serbia to keep your residency card. We recommend you treat it seriously, as officials often check whether investors comply with the demand. Your residency card will be suspended if you disobey.  Legal and tax residence in Serbia via company registration may be used as an alternative way to become a Serbian resident. Minimum investment requirements are not set in Serbia. Still, the applicant shall rent an office to register a legal person therein, plus an apartment or a cottage for themselves to live in.
  • Economic citizenship in Turkey. In case of Serbia and Portugal, applicants and investors will receive their residence permits following a lengthy naturalization procedure. They shall also pass a number of exams to achieve their goal. Economic citizenship is a much easier way to get a second passport. It is more realistic as well. A number of countries allow economic citizenship and offer it. Many experts believe the Turkish Republic has the best value for time and money in this case. An applicant may apply for Turkish citizenship by investment where they invest in real estate, securities, make investment or pension fund contributions, or incorporate companies with at least 50 permanent workplaces. The threshold here makes up USD 400,000, and the procedure itself takes around 3 months. Regardless of the option the investor chooses, they may exit the investment or sell their properties and keep the Turkish passport after the 3-year holding period expires. Everything happens quickly and effectively, and no applications are suspended.

Expert assistance with investment immigration to Europe and more

The global investment immigration market often stirs passionate criticism. Novice market players are in no hurry to launch their own programs, while long-timers leave the market, have their applications suspended, or raise the market on and off. Unless you feel like regretting your lost chances and opportunities afterwards, the International Wealth experts recommend you cut the talk and walk the walk. We will assist you with selecting the program that will work best for you, and support you every step of the way to your residence permit or second passport.

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You are welcome to contact International Wealth and book your individual consultation to learn more. Call us at any of the numbers above or use the contact form on your right

Is the golden visa initiative popular in Portugal?

Official stats confirm that since being launched in October 2012 till April 2022, this investment immigration program contributed over EUR 6,280,000,000 to the host country’s budget. The Portuguese government issued 16,636 residence permits to both investors and their relatives. Real estate investment accounted for around 90% of all investments in Portugal.

Why have residence permit applications from real estate investors been suspended in Portugal?

No official explanation is provided by the Portuguese officials for the fact the residence permit applications have been suspended in this case. The officials practice avoidance or claim the experts able to explain it are unavailable. Many independent professionals reckon that with the Portugal Golden Visa, change is inevitable. SEF employees stopped processing residence permit applications as new golden visa rules kicked in. They also refer to the coming SEF liquidation and staff redeployment. The COVID-19 pandemic and both national and international political tensions may as well be the reasons behind the above applications being suspended.

What alternative programs may I apply for to get my golden visa?

If you feel like putting up with the risk your investment residency or citizenship application may be suspended is not your thing, take a look at the golden visa programs in the UAE, Serbia, and Turkey or economic citizenship of Turkey. Please remember that foreign nationals may take part in them as well, unlike the Portuguese golden visa program. The Portuguese residency program for financially independent persons (Visto D7 para Portugal) deserves high merit.

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