Compare Portugal’s non-property investment routes with Greece’s property-based Golden Visa: qualifying investments, rental restrictions, citizenship conditions and liquidity risks.
Key Takeaways
- Portugal does not accept new real-estate investments, including commercial property, for ARI eligibility.
- Portugal’s non-real-estate fund route requires €500,000 and statutory investment conditions; cultural and research routes have different thresholds.
- Greece’s standard property thresholds are €800,000 or €400,000; €250,000 applies only to qualifying conversion or listed-building routes.
- Greek standard property purchases require one property and at least 120 m² of main-use space; sharing-economy short-term letting and subletting are prohibited.
- Portugal’s current general nationality residence condition is seven years for EU and Portuguese-language-country nationals, ten years for other nationals; citizenship is not automatic.
Portugal and Greece serve different investment goals. Portugal’s ARI programme no longer qualifies new property purchases, including commercial property. Greece retains a property route, but the advertised €250,000 entry point is a special exception, not the standard price throughout cheaper regions. This comparison was checked against official legislation on 21 October 2026.
Portugal vs Greece at a glance
| Decision | Portugal | Greece |
|---|---|---|
| Property eligibility | No new real-estate route | Qualifying property route |
| Core investment | €500,000 qualifying non-real-estate fund; other statutory routes available | €800,000 or €400,000 standard purchase; €250,000 qualifying exceptions |
| Investment constraints | Fund maturity, domestic-company allocation and indirect real-estate prohibition | One property; 120 m² standard-route main-use minimum; route-specific use conditions |
| Citizenship | Current general residence condition: seven or ten years by nationality, plus other conditions | Separate nationality process; holding a permit alone is not a passport entitlement |
| Processing | No guaranteed completion deadline in sources reviewed | No guaranteed completion deadline in sources reviewed |
Portugal: what still qualifies?
Article 3 of Lei 23/2007 lists job creation, scientific research, cultural support, qualifying collective investment and company capitalisation with employment conditions. The €500,000 fund route must use Portuguese-law non-real-estate collective investment undertakings, have at least five years of maturity remaining at investment, and allocate at least 60% to commercial companies headquartered in Portugal. Remaining ARI activities cannot be directed into real estate, directly or indirectly.
Research ordinarily requires €500,000 and cultural support €250,000. Qualifying low-density activities can receive a 20% reduction for the job, research and cultural routes only. This can mean €400,000 for research or €200,000 cultural support, but is not a discount on the fund route. A qualifying company-capital route requires €500,000 alongside specified job-creation or maintenance conditions. Check the actual transaction documents before paying.
Greece: which properties qualify?
Law 5100/2024, Article 64 sets the standard €800,000 threshold for the whole Attica Region, Thessaloniki Regional Unit, Mykonos and Thira Regional Units, and islands with more than 3,100 inhabitants. The standard threshold elsewhere is €400,000. Piraeus is in Attica; it is not a separate €400,000 tier.
Standard purchases must concern one property. Developed property or property with a building permit needs at least 120 m² of main-use space. Combining multiple smaller apartments does not meet this standard purchase rule.
The €250,000 conversion exception requires qualifying main spaces to change to residential use. The official change-of-use registry requires completion after 5 April 2024 and before application, subject to its permit qualifications. One property is required; the standard 120 m² minimum does not apply. Industrial premises have additional evidence requirements.
The listed-building route also has a €250,000 acquisition minimum, restoration or reconstruction duties for first renewal, and restrictions on transfer before completion. A low asking price does not establish either exception’s eligibility.
Rental income: do not assume tourist letting is allowed
The Greek statute prohibits sharing-economy short-term letting and subletting of covered properties. Conversion properties may not be used as a business registered office or branch. Breaches carry residence-permit revocation and a €50,000 administrative fine. We have not verified a binding primary-source interpretation of reported 2026 tourist-use changes, so do not treat them as permission for an Airbnb strategy.
Citizenship is a separate decision
Lei Orgânica 1/2026, effective 19 May 2026, sets Portugal’s general nationality residence condition at seven years for EU and Portuguese-official-language-country nationals, and ten years for other nationals. Additional language, civic, criminal, security and self-support conditions apply. These are eligibility conditions, not guaranteed passport delivery times.
The law expressly preserves prior rules for administrative proceedings pending at commencement. It does not expressly guarantee that every earlier ARI investment, application or permit protects a future nationality application under the old five-year rule. Obtain advice for the particular case. Greece likewise has a separate naturalisation process: maintaining an investor permit without actual integration must not be marketed as automatic citizenship.
Tax: NHR is not an automatic investor benefit
Portugal’s tax authority says NHR was repealed from 1 January 2024, with existing and qualifying transitional beneficiaries protected. Its replacement IFICI is conditional: qualifying activities and employment or self-employment income can receive a 20% special rate for ten consecutive years, but an ARI permit alone does not qualify a taxpayer. Consult the tax authority’s IFICI leaflet before assuming a tax saving. Neither programme by itself determines Australian tax residency.
Liquidity, total cost and programme choice
A Portuguese fund is not equivalent to buying a Greek home. Review fund redemption dates, charges, underlying assets and eligibility obligations. A Greek property can carry resale risk, renovation costs, ongoing maintenance and permit-linked ownership conditions. Investment thresholds exclude professional, administrative and transaction costs. Model returns without unsupported yield figures and without prohibited short-term rental income.
Choose Greece if qualifying property ownership is the central objective and the specific property meets all legal and use conditions. Consider Portugal for a qualifying non-property investment rather than a house purchase. For either country, independently check ownership, compliance and exit terms; do not rely on a promised processing or citizenship deadline.
Continue your research
Read the Portugal Golden Visa guide and Greece Golden Visa guide, then compare the Portugal and Greece country profiles. Broader context is available at Learn and our sister publication Australian Property Forum.
Official sources and scope
Sources: Portugal Foreigners Law Article 3; Lei Orgânica 1/2026 Articles 6–8; Portugal tax authority IFICI guidance; Greece Law 5100/2024 Article 64 and the National Registry’s conversion and listed-property procedures. Checked 21 October 2026. This guide is general information, not individual immigration, legal or tax advice.
Frequently Asked Questions
Can Portuguese commercial property qualify for a new Golden Visa?
No. Portugal’s remaining ARI investment activities cannot be directed, directly or indirectly, into real estate. Commercial property is not an exception. See Article 3 of Lei 23/2007.
What is Portugal’s qualifying fund investment?
At least €500,000 in Portuguese-law non-real-estate collective investment undertakings, with at least five years of maturity remaining when invested and at least 60% invested in Portuguese-headquartered commercial companies. A fund’s marketing label alone does not establish eligibility.
Where does Greece require €800,000?
The whole Attica Region, Thessaloniki Regional Unit, Mykonos and Thira Regional Units, and islands with more than 3,100 inhabitants. The standard threshold elsewhere is €400,000. These standard routes require one property and at least 120 m² of main-use space.
Can I buy any Greek property for €250,000?
No. €250,000 is a special route for qualifying change-of-use properties or listed-building restoration, not a general regional price tier. Conversion must be completed before application and satisfy the official registry conditions.
Does Portugal still promise citizenship after five years?
No general five-year promise is accurate under the current law. Article 6 now states seven years of legal residence for EU and Portuguese-language-country nationals, ten years for other nationals, alongside additional requirements. The express transition covers administrative proceedings pending when the amendment entered into force; it should not be assumed to protect every earlier ARI investor’s future nationality application.
Can Golden Visa property be used for Airbnb?
The Greek statute prohibits sharing-economy short-term letting and subletting of covered properties. Violations can lead to permit revocation and a €50,000 fine. Do not base an investment return forecast on prohibited rental use.
Which programme is faster?
No universal processing deadline is established by the official sources reviewed here. Confirm current application and appointment availability with the relevant authority and adviser rather than relying on old two-to-four-month or twelve-to-eighteen-month estimates.