For over a decade, the Portugal Golden Visa has been one of Europe’s most attractive residency-by-investment programs. It promised an easy entry into Portugal — and eventually the European Union — with minimal stay requirements and a five-year route to citizenship. The idea was simple: make a qualifying investment, visit the country occasionally, and walk away in half a decade with a Portuguese passport.
That was the promise. The reality in 2025 looks very different.
Between frequent law changes, political uncertainty, and massive delays in processing, the Golden Visa has turned into a slow, frustrating, and unpredictable process. For many investors — especially those who applied from 2022 onwards — it now feels like a scam.
Let’s break down why.
1. Uncertainties and Moving Goalposts
The biggest frustration for Portugal Golden Visa investors today is the sheer unpredictability of the program. Over the last three years, Portugal has rewritten its immigration laws multiple times and attempted to rewrite nationality law.
Key recent changes include:
- October 2023: The real estate route — the most popular option — was shut down under the Mais Habitação housing bill. New applicants had to choose from less common paths like investment funds, cultural donations, or research projects.
- June 2025: Lawmakers proposed to double the residency requirement for Portugal citizenship from 5 to 10 years for most foreigners (7 years for Portuguese-speaking nationals). They also proposed stricter language requirements, cultural knowledge tests, and proof of “civic integration.”
- August 2025: Portugal’s Constitutional Court struck down parts of a controversial immigration law that would have forced most immigrants to wait two years before applying for family reunification. While Golden Visa holders were already exempt from this clause, the ruling does not address the citizenship timeline changes — leaving that battle for another day.
For investors, each of these changes feels like the rules are rewritten mid-game. You make your investment based on one set of expectations, only to find those expectations evaporating a year later.
2. Process Frustration: A Bureaucratic Waiting Game
Nowhere is this more visible than in the Portugal Golden Visa delays.
For years, investors could expect to receive their first residence card within months of applying. But after the 2022–2023 political shifts and the messy dissolution of SEF, timelines collapsed.
Here’s what’s happening:
- Investors who applied in the first half of 2021 are generally in better shape. Most have received their first residence cards, even if renewals are taking longer than before.
- Those who applied in 2022 are in a nightmare. Only a small percentage have received residence cards as of mid-2025. A significant proportion are still waiting for their first approval or biometric appointment.
- Applications from late 2022 onwards are effectively frozen in some cases, with no clear timeframe for resolution.
This isn’t just a slow queue — it’s a structural backlog. The newly formed AIMA inherited over 400,000 pending immigration files from SEF. Despite promises to clear all pending applications by June 2025 — and even requiring applicants to effectively reapply and submit fresh documentation in January 2025 — investors remain in limbo with no legal certainty. While Portugal continues to enjoy the economic benefits of their capital, the investors themselves are left waiting, unsure of when, or if, their cases will be resolved.
For investors who put down €280,000 or more, this is a bitter pill to swallow. You’ve tied up your money, you’re paying fund or maintenance fees, and yet you can’t even set foot in the Schengen Zone with the promised residency card because it hasn’t been issued.
3. The Legal Shield That’s Only Part of the Story
Portugal’s law generally prevents retroactive application of immigration rule changes. This means that, in theory, if you applied under one set of rules, those should continue to apply to you.
However, changes to legislation can still influence how administrative processes operate in practice. Historically, major policy shifts — such as proposals to tighten requirements or extend timelines — have coincided with slower case handling, stricter documentation reviews, and additional procedural steps. Whether this is due to resource constraints, process adjustments, or shifting priorities, the effect on applicants can be similar to that of a formal rule change.
4. Legitimate Expectations Under EU Principles
This is where the situation moves from frustrating to arguably unfair.
Under EU law, there’s a principle known as “legitimate expectations”. It protects individuals from sudden changes to rules that would unfairly disadvantage them after they’ve already acted based on previous legislation.
When an investor commits hundreds of thousands of euros to a Portugal Golden Visa — often in illiquid assets or long-term funds — they’re making a decision based on the rules in place at that time. Doubling the citizenship timeline after the investment is made not only undermines that decision but also erodes trust in Portugal as a predictable legal environment.
While Portugal’s non-retroactivity rules offer some protection, the reality is that prolonged Portugal citizenship timeline extensions, even if applied only to future applicants, can still harm current investors indirectly — by delaying processing, creating uncertainty, and eroding the program’s political backing.
5. The Constitutional Court Ruling — A Mixed Signal
In August 2025, the Constitutional Court made headlines by striking down parts of the new immigration law. Specifically, it rejected the two-year waiting period for family reunification in most visa categories, citing constitutional violations.
At first glance, this looked like a win for investors — and in some ways, it was. The Court confirmed that Portugal can offer preferential treatment to certain visa categories, such as the Golden Visa, when it serves the national interest.
However, the ruling does not address the proposed changes to the nationality law, which still await formal approval in Parliament. This leaves one of the most critical aspects for investors — the timeline to citizenship — entirely unresolved. The pressing question is whether the ruling party will take the Constitutional Court’s reasoning as a signal to proceed cautiously, respecting the spirit of fairness and legal stability, or whether they will push ahead with measures that, while technically legal, undermine the legitimate expectations of investors who committed substantial capital under a very different set of promises. For many, the answer to this question will determine whether Portugal can still be seen as a trustworthy jurisdiction for long-term immigration investment.
6. The Real Timeline: From 5 Years to 8–15 Years
Officially, Portugal still advertises the Golden Visa as a five-year path to citizenship. In reality, the combination of:
- Long processing times for the initial residence permit,
- Backlogs in renewals and biometrics,
- Potentially doubled citizenship timelines,
- And unpredictable political shifts,
…means that many investors will be looking at 8–15 years before they can realistically obtain a Portuguese passport.
That’s triple the promised timeline — and for some, it will make the program’s original value proposition completely unrecognizable.
Conclusion: Not Fraud, But Only for the Patient and Wealthy
The Portugal Golden Visa is still a legal and valid route to residency, and potentially citizenship. The recent Constitutional Court ruling confirms that the state can — and sometimes will — protect investor interest.
But the combination of political risk, administrative backlog, and slow-moving bureaucracy means the program is not what it used to be.
If you’re considering it:
- Make sure the investment represents only a small fraction of your net worth.
- Be prepared to wait far longer than five years — possibly over a decade.
- See it primarily as a lifestyle or long-term residency option, not a quick passport route.
For investors seeking certainty, speed, and clear rules, Portugal may no longer be the best choice. For those who can play the long game, it might still be worth the gamble.
