Portugal vs Spain
Portugal vs Spain Golden Visa 2026: Why Spain Is Gone and What Replaces It
Spain abolished its golden visa in April 2025. We compare Portugal's surviving EUR 500k fund route against Spain's non-investment visas for 2026.
If you came here to choose between the Portuguese and Spanish golden visas, the choice has already been made for you. Spain abolished its golden visa on 3 April 2025. There is no investment route into Spanish residency anymore, at any price. Portugal’s golden visa survives, the EUR 500,000 fund route is open, and for most readers it is now the only investment-migration path into the EU that both programs once offered. So the honest framing is not “which golden visa wins.” It is “Spain is gone, is Portugal the replacement, and if you specifically wanted Spain, what non-investment routes are left.”
The head-to-head, stated plainly
There is no live Spanish golden visa to compare. Spain’s Congress voted to scrap the scheme, and the repeal entered force on 3 April 2025. Since that date no new application can be filed. The government’s stated reason was housing: Prime Minister Pedro Sanchez argued the visa turned homes into a speculative asset in Madrid, Barcelona and the islands. Existing holders keep their permits and can renew under the original conditions, and applications filed before the cutoff are still being processed. But for anyone deciding today, Spain by investment does not exist.
Portugal kept its program and, just as importantly, restructured the rules around the property-driven abuse that sank Spain. Since the 2023 reform, Portugal’s golden visa no longer accepts residential real estate. The headline route is now a EUR 500,000 investment in a qualifying Portuguese venture capital or private equity fund, held for a minimum of five years. So the two countries actually converged on the same diagnosis. Spain killed the program; Portugal killed the property and kept the program.
What Portugal now costs and how long it takes
The fund route is EUR 500,000 in capital, plus government and processing fees, legal fees, and fund management and subscription costs that typically add tens of thousands of euros over the holding period. Budget realistically for total outlay well above the headline number once fund fees compound across five-plus years.
The bigger 2026 change is the citizenship timeline. Portugal passed a revised Nationality Law: Parliament approved it on 1 April 2026, the President signed it on 3 May 2026, and it was published as Lei Organica n.o 1/2026, entering force on 19 May 2026. The required residence period for naturalisation rose from five years to ten years for most nationalities, and seven years for nationals of the EU and the Portuguese-speaking CPLP countries. That is a structural shift. The five-year passport that made Portugal famous is gone for new applicants.
Two cushions matter. First, permanent residency is still available after five years, which gives an independent long-term right to live and work in Portugal and move within the Schengen Area, without keeping the investment going. Second, the residency clock for new applicants now counts from the date AIMA, the immigration agency, physically issues the first residence card. Given AIMA’s well-documented processing backlog, the gap between paying and the clock starting is a real planning risk. Coordinate timing with immigration counsel before wiring funds.
Physical presence stays light: an average of roughly seven days per year in Portugal, among the lowest in Europe, which is the feature that makes the program work for people who do not intend to relocate full time.
The Spanish alternatives, honestly assessed
If you wanted Spain specifically, two non-investment residence permits do most of the work the golden visa used to, with one crucial difference: they require you to actually live there.
The Digital Nomad Visa (DNV), created under the 2023 Startup Act, is for remote workers and freelancers employed by or contracting with non-Spanish companies. The 2026 income threshold is 200 percent of Spain’s minimum wage (SMI). With the 2026 SMI set at EUR 1,221 per month by Royal Decree 126/2026, that is about EUR 2,849 per month, with surcharges for dependents. Its standout feature is tax: DNV holders can elect the Beckham regime, a flat 24 percent on Spanish-source employment income up to EUR 600,000, with most foreign income left outside the Spanish net, for up to six years. Note the rigidity flagged by Spain’s processing unit in 2026: you cannot switch into DNV status from inside Spain on a tourist or non-lucrative footing. You leave and apply at a consulate.
The Non-Lucrative Visa (NLV) is the retiree and passive-income route. It bans all work, Spanish or remote, and requires you to show passive income or savings of roughly EUR 2,400 per month (about EUR 28,800 per year), tied to the IPREM indicator, with more for dependents.
Both routes lead somewhere. Time on either counts one-to-one toward permanent residency after five years and citizenship after ten by naturalisation. And here is Spain’s genuinely unmatched advantage: nationals of Latin American countries, the Philippines, Equatorial Guinea, Andorra, Portugal, and Sephardic Jews of Spanish origin can naturalise after just two years of legal residence. For that population, Spain’s ten-year rule barely applies.
The comparison table
| Factor | Portugal Golden Visa (2026) | Spain Golden Visa | Spain DNV | Spain NLV |
|---|---|---|---|---|
| Status | Open | Abolished 3 Apr 2025 | Open | Open |
| Entry route | EUR 500k fund (5-yr hold) | None (closed) | Remote-work income | Passive income |
| Minimum financial bar | EUR 500,000 invested | n/a | ~EUR 2,849/mo income | ~EUR 2,400/mo income |
| Can you work? | No work required | n/a | Yes, foreign employer | No work allowed |
| Physical presence | ~7 days/year average | n/a | Substantial, tax-resident | Substantial (183+ days) |
| Permanent residency | After 5 years | n/a | After 5 years | After 5 years |
| Citizenship | 10 yrs (7 EU/CPLP) | n/a | 10 yrs (2 for Ibero-American) | 10 yrs (2 for Ibero-American) |
| Tax hook | Coordinate; NHR replaced by IFICI | n/a | Beckham 24% flat, up to 6 yrs | Spanish tax resident |
| Best for | Passive EU optionality, no relocation | No longer available | Remote workers relocating | Retirees, passive income |
Tax, stated carefully
Tax is where these decisions go wrong, so treat the table as a prompt, not advice. Portugal’s old Non-Habitual Resident regime closed to new entrants; a narrower successor, the IFICI incentive, targets specific qualified professions and is not a blanket flat rate. Spain’s Beckham regime is genuinely attractive for high earners but only if you pass the no-prior-Spanish-residence test and apply within six months. Both interact with your home-country tax system and, for Americans, with worldwide US filing. Model your actual numbers with a cross-border tax adviser before committing.
Who each option actually suits
Choose Portugal’s golden visa if you want EU residency and an eventual passport without uprooting your life, you can deploy EUR 500,000 into a fund and leave it for five-plus years, and you accept that citizenship is now a ten-year horizon. The light presence requirement is the whole point. You are buying optionality and a Schengen base, not a place to live tomorrow.
Choose Spain’s DNV if you genuinely want to live in Spain, earn remote income from outside it, and would benefit from the Beckham flat tax. You are trading capital for relocation and a real tax residency.
Choose Spain’s NLV if you are retired or live on passive income, want Spain as a home, and do not need to work.
And if you hold a Latin American, Filipino, or related nationality, Spain quietly becomes the strongest citizenship play on this page, because two years of residence beats Portugal’s seven or ten by a wide margin. That single fact reorders the entire comparison for millions of people.
The blunt summary: Spain by investment is over. Portugal by investment is the surviving route, slower to a passport than it was but still the cleanest low-presence path to EU residency. The Spanish dream is still reachable, just on foot rather than by wire transfer, and for the Ibero-American world it is reachable faster than anywhere else in Europe.
Questions
Is the Spanish golden visa still available in 2026? +
No. Spain abolished its golden visa on 3 April 2025. No new applications can be filed at any investment level. Existing holders keep their permits and may renew under the original conditions, and applications filed before the cutoff are still being processed.
Did Portugal end its golden visa too? +
No. Portugal's golden visa remains open. It removed residential real estate as an option in 2023, so the main route is now a EUR 500,000 investment in a qualifying Portuguese venture capital or private equity fund, held for at least five years.
How long does Portuguese citizenship take now? +
Under the Nationality Law that entered force on 19 May 2026, naturalisation requires ten years of residence for most nationalities and seven years for EU and CPLP nationals. The previous five-year rule no longer applies to new applicants.
Can I still get permanent residency in Portugal after five years? +
Yes. Permanent residency remains available after five years of legal residence. It gives a long-term right to live and work in Portugal and move within the Schengen Area, even after you exit the investment, separate from the longer citizenship timeline.
What is the cheapest way to move to Spain now that the golden visa is gone? +
The two main non-investment routes are the Digital Nomad Visa, requiring about EUR 2,849 per month in remote-work income, and the Non-Lucrative Visa, requiring about EUR 2,400 per month in passive income. Both require you to actually live in Spain rather than just invest.
What income do I need for Spain's Digital Nomad Visa in 2026? +
The threshold is 200 percent of Spain's minimum wage. With the 2026 SMI at EUR 1,221 per month, that is roughly EUR 2,849 per month for a single applicant, with surcharges for dependents.
How fast can Latin Americans get Spanish citizenship? +
Nationals of Latin American countries, the Philippines, Equatorial Guinea, Andorra, Portugal, and Sephardic Jews of Spanish origin can naturalise after just two years of legal residence in Spain, far faster than Portugal's seven or ten years.
Does the Beckham Law apply to digital nomads in Spain? +
Yes, eligible Digital Nomad Visa holders working for a non-Spanish employer can elect the Beckham regime, a flat 24 percent tax on Spanish-source employment income up to EUR 600,000 for up to six years, provided they were not Spanish tax resident in the prior five years and apply within six months. Confirm eligibility with a tax adviser.
Is Portugal a good replacement for the Spanish golden visa? +
For passive investors who want EU residency and an eventual passport without relocating, yes. Portugal is now the surviving low-presence investment route, requiring only about seven days per year in country. The trade-off is a longer ten-year citizenship timeline.
When does the Portuguese citizenship clock start counting? +
For new applicants, the residency clock counts from the date AIMA physically issues your first residence card, not from your application date. Given AIMA's processing backlog, the delay can be significant, so coordinate timing with immigration counsel.
Sources
- 1 Spain: Golden Visa Program to be Eliminated (Fragomen)
- 2 Spain's Golden Visa Is Dead. Three Ways You Can Still Move There (IMI Daily)
- 3 Portugal Extends Citizenship Timeline (Fragomen)
- 4 Portugal President Signs Revised Nationality Law, Extending Citizenship Timeline to 10 Years (Outbound Investment Group)
- 5 Spain: Publication of the minimum wage (SMI) for 2026 (Garrigues)
- 6 Spain Digital Nomad Visa 2026: Requirements, Income, & How to Apply (Global Citizen Solutions)
- 7 Portugal Golden Visa: June 2026 Updated Guide (Get Golden Visa)
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