Golden Visa
Portugal Approves New Nationality Law: What It Means for Investors
Portugal has taken a significant step in reshaping its nationality framework. The Assembly of the Republic has approved a revised Nationality Law following a political agreement between the Social Democratic Party (PSD) and Chega, marking a clear shift in the country’s approach to citizenship policy.
While the legislation has passed with the required two-thirds majority, the process is not yet complete and its implications for investors, particularly those considering the Golden Visa program, remain nuanced.
The agreement between PSD and Chega introduced stricter criteria for accessing Portuguese citizenship, including:
Importantly, residency requirements for citizenship remain unchanged:
However, the absence of transitional provisions marks a notable departure from previous legislative approaches, where investor expectations were typically safeguarded through grandfathering mechanisms.
The current President, António José Seguro, is politically aligned with the Socialist Party, which opposed the law and has raised concerns regarding:
As a result, three scenarios are possible:
This means that, despite parliamentary approval, the legislative process remains ongoing.
For investors, several conclusions emerge:
However, the broader context has evolved.
The removal of transitional protections introduces a higher degree of uncertainty regarding future policy stability, particularly for investors planning their pathway to citizenship.
That said, current indications suggest that:
This reflects a broader recalibration rather than an isolated policy change.
The next phase - presidential review and potential constitutional scrutiny - will be critical in determining how the framework is ultimately implemented.
For investors, the key message is clear: The Golden Visa remains a valid and structured pathway, but the broader policy environment is becoming more dynamic.
At 3 Comma Capital, we are closely monitoring these developments and continuously assessing their implications for our investors.
► Considering the Portuguese Golden Visa?
In a changing regulatory environment, timing, structure, and execution matter more than ever.
At 3 Comma Capital, we support international investors through:
Whether you are evaluating your first investment or seeking clarity on the evolving legal framework, our team is available to guide you through every step of the process.
⇒ Get in touch with us at: hello@3commafunds.com
⇒ Or visit our website to schedule a call with our team.
While the legislation has passed with the required two-thirds majority, the process is not yet complete and its implications for investors, particularly those considering the Golden Visa program, remain nuanced.
A Political Shift Toward a More Restrictive Framework
The revised law reflects a broader change in political direction.The agreement between PSD and Chega introduced stricter criteria for accessing Portuguese citizenship, including:
- A reduction in the criminal threshold for blocking citizenship eligibility
- An expanded list of offenses that may lead to loss of nationality
- The removal of transitional protections for current residents
Importantly, residency requirements for citizenship remain unchanged:
- 7 years for EU and CPLP nationals
- 10 years for all other applicants
However, the absence of transitional provisions marks a notable departure from previous legislative approaches, where investor expectations were typically safeguarded through grandfathering mechanisms.
What Happens Next: Presidential Review
Although approved in Parliament, the decree must still be promulgated by the President of the Republic. This introduces a critical layer of uncertainty.The current President, António José Seguro, is politically aligned with the Socialist Party, which opposed the law and has raised concerns regarding:
- Constitutional compatibility
- Lack of consensus
- Protection of legitimate expectations
As a result, three scenarios are possible:
- Promulgation of the law as approved
- Presidential veto, requiring Parliament to reapprove the law
- Referral to the Constitutional Court, suspending the process pending legal review
This means that, despite parliamentary approval, the legislative process remains ongoing.
What This Means for Golden Visa Investors
It is important to distinguish clearly between nationality law and the Golden Visa program.For investors, several conclusions emerge:
- The Golden Visa regime remains unchanged
- Permanent residency eligibility after five years is unaffected
- The citizenship framework is evolving, with increased political and legal complexity
- The investment framework and fund eligibility criteria remain intact
- The legislative process is not yet finalized, leaving room for further developments
However, the broader context has evolved.
The removal of transitional protections introduces a higher degree of uncertainty regarding future policy stability, particularly for investors planning their pathway to citizenship.
That said, current indications suggest that:
- Investors who enter under the current framework are still expected to follow existing rules
- The legal process may introduce delays, but also creates a window for additional clarity
A Broader Trend: Policy Tightening in Developed Markets
Portugal’s move should be viewed within a wider global context. Across Western economies, there has been a gradual shift toward:- More restrictive immigration policies
- Increased scrutiny of citizenship pathways
- Greater political sensitivity around nationality frameworks
This reflects a broader recalibration rather than an isolated policy change.
Final Thoughts
While the approval of the new Nationality Law marks an important milestone, it does not yet represent a final outcome.The next phase - presidential review and potential constitutional scrutiny - will be critical in determining how the framework is ultimately implemented.
For investors, the key message is clear: The Golden Visa remains a valid and structured pathway, but the broader policy environment is becoming more dynamic.
At 3 Comma Capital, we are closely monitoring these developments and continuously assessing their implications for our investors.
► Considering the Portuguese Golden Visa?
In a changing regulatory environment, timing, structure, and execution matter more than ever.
At 3 Comma Capital, we support international investors through:
- Access to regulated, Golden Visa-eligible investment funds
- A fully remote onboarding process
- Open ended daily liquidity structures, providing entry and exit flexibility throughout the investment lifecycle.
- Transparent reporting and daily NAV visibility
Whether you are evaluating your first investment or seeking clarity on the evolving legal framework, our team is available to guide you through every step of the process.
⇒ Get in touch with us at: hello@3commafunds.com
⇒ Or visit our website to schedule a call with our team.
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Duarte Caldas
Investments Principal
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With more than 20 years of experience in financial markets, Duarte specialized in the energy area in the last decade, where he had the opportunity to work with the main European Power and Gas institutions at CIMD Group. Previously, he worked as Market Strategist at IG Markets Iberia.
