Portugal's two governing parties have filed a proposal that would rewrite which investments qualify for the Portugal Golden Visa, tightening the rules for the popular investment fund route while opening a cheaper social-care path, according to Investment Migration Insider. The Social Democratic Party (PSD) and CDS-People's Party (CDS-PP) filed the amendment on November 6, the deadline for changes to the 2027 State Budget bill, with 21 deputies signing it under the leadership of PSD's Hugo Soares and CDS-PP's Paulo Núncio.
The proposal now awaits a committee vote. Together, PSD and CDS-PP hold 91 of parliament's 230 seats, short of the 116-seat majority needed to pass the amendment on their own votes, meaning its fate depends on how other parties act when committee votes run from November 18 to 23, ahead of the full budget's final vote on November 24.
What the Proposal Changes
Under the current rule, an investor qualifies for the Portugal Golden Visa by placing €500,000 (approximately $576,000) into a Portuguese non-real-estate fund that invests at least 60% in companies headquartered in Portugal. The amendment lifts that floor to 80% and adds a new condition: the money must arrive "through the reinforcement of the share capital" of those companies, meaning new money exchanged for newly issued shares rather than cash paid to a previous shareholder for existing stock.
The text does not explicitly mention open-ended funds, but as drafted, shares or bonds bought on the open market would no longer appear to count toward the 80% quota, a problem specifically for funds built on listed securities. In their explanatory note, PSD and CDS-PP argue that fund investment should "contribute, in fact, to the capitalization of companies." Jordi Vilanova of Mercan Group, which manages golden visa funds, reads the intent the same way, telling IMI Daily that fund capital "should help strengthen Portuguese companies," and that closed-ended funds "tend to be closer to that model than open-ended funds, which typically need to keep part of their portfolio liquid." He added there is still "room to discuss with the Government how this is best applied."
The amendment also introduces a new €250,000 route for building or restoring social care facilities serving children, young people, the elderly, and people with disabilities, or facilities integrating resident foreigners and beneficiaries of international protection. Investors would channel funds through a closed list of public bodies, public-utility foundations, misericórdias, and similar institutions. The research-donation route would see its minimum investment cut from €500,000 to €250,000. Pending applicants would be grandfathered under existing rules.
Political Arithmetic Behind the Proposal
PSD holds 89 seats and CDS-PP two, leaving the pair well short of a majority. The 2027 State Budget cleared its first vote on October 28 only because the Socialist Party (PS), with 58 seats, abstained while Chega, with 60 seats, voted against. IMI Daily reports that a repeat PS abstention during the amendment vote would allow the change to pass on the governing parties' votes alone.
The source notes that Chega has not been consistently hostile to the golden visa program: in 2022 it voted against abolishing the scheme and proposed widening it instead. Meanwhile, PS has filed its own competing amendment to scrap the Tax Incentive for Scientific Research and Innovation (IFICI) and to commission a formal study of the golden visa's effects.
Madalena Monteiro, founder of Liberty, described the proposal as confirmation of "the rumors" that have circulated in recent months, noting the government had already signaled interest in a social-investment route in its 2024 migration plan, and that Minister of the Presidency António Leitão Amaro said last year the government was studying changes to the program. Monteiro said "it's difficult to tell right now if this is going to pass," but suggested opposition parties have reason to back it because the new wording "aligns with other parties' overall political views and goals" more closely than current law.
WPF Analysis: Eligibility Implications for Fund Investors
World Property Forum analysis suggests the practical effect of the share-capital condition would fall hardest on investors already holding or considering positions in open-ended golden visa funds that rely partly on listed securities for liquidity management. If the 80% Portuguese-company threshold is interpreted strictly to exclude market-purchased shares and bonds, funds structured around secondary-market holdings may need to restructure toward primary share issuances to remain compliant. Werner Gruner of Get Golden Visa cautioned that the proposal "requires further clarification and is likely to undergo amendments before final approval," underscoring that the scope of any exclusion is not yet settled.
WPF analysis also indicates that the grandfathering provision for pending applicants is the single most consequential detail for investors who have already submitted applications under the current 60% rule: it would shield existing positions from retroactive disqualification, though the source does not specify the precise cut-off date or documentation required to qualify as "pending." Investors with applications in process, or close to filing, should treat this distinction as a priority due-diligence item once the budget's final text is published.
Comparing the Transition to Spain's Golden Visa Closure
Portugal's proposed tightening arrives against a backdrop already shaped by Spain's decision to end its own golden visa programme in April 2025, a closure covered in detail in WPF's Portugal vs Spain Golden Visa comparison. Where Spain's programme ended outright, Portugal's current proposal is narrower: it does not eliminate the fund route but narrows its qualifying criteria while simultaneously lowering the entry threshold for two other routes, research donations and now social-care investment. WPF analysis suggests this divergence reinforces Portugal's position as the more actively evolving EU alternative for investors who had been weighing both jurisdictions, a dynamic also explored in the Spain vs Portugal property investment comparison. Investors comparing EU options more broadly may also find the Portugal vs Greece Golden Visa comparison useful for benchmarking thresholds across programmes still accepting new applications.
Practical Due-Diligence Questions
Investors currently evaluating the Portugal Golden Visa fund route should be asking several questions that the source leaves open. First, how will regulators define "reinforcement of share capital" in practice, and will existing fund structures be required to demonstrate compliance retroactively or only for capital deployed after the amendment takes effect? Second, what cut-off date and documentation will determine whether an application counts as "pending" for grandfathering purposes? Third, given Jordi Vilanova's concern that a January 1 effective date alongside the budget would leave "quite a short window" for the market to adjust, what transition period, if any, will the final text include?
For investors drawn to the new €250,000 social-care route, the open question is which specific public bodies, foundations, and misericórdias will appear on the eventual approved list, since the source indicates the list is closed but does not name the institutions. Prospective applicants should also confirm, once the committee text is finalised, whether the research-donation threshold cut to €250,000 takes effect on the same timeline as the fund-route changes.
Limitations and What Comes Next
The proposal is not law. It passed its filing deadline but still requires a committee vote beginning November 18, and PSD and CDS-PP's 91 seats are insufficient without support or abstention from PS or Chega. The source does not confirm how either party will vote on this specific amendment, only that PS abstained on the broader budget's first reading and that PS has filed a competing amendment concerning the IFICI tax incentive and a golden visa impact study. Werner Gruner's comment that the proposal is "likely to undergo amendments before final approval" signals the current text is a starting point, not a final rule.
Investors should treat every figure and condition described here as provisional until the committee process concludes between November 18 and 23, and the full budget receives its final vote on November 24. Those with active or planned golden visa applications should consult immigration counsel before making investment decisions based on the current draft, and should monitor the Golden Visa Programmes Hub and broader WPF Global Property Markets coverage for confirmed outcomes once the budget process concludes.