Comparing the Italy vs Portugal Golden Visa in 2026 means looking at two programmes that have moved in opposite directions. Italy has kept its structure unchanged since 2018. Portugal has gone through three rule changes since 2022, a collapsed tax regime, and an approval backlog now documented at up to 40 months.
Italy vs Portugal Golden Visa: Key Numbers at a Glance
| Italy | Portugal | |
|---|---|---|
| Minimum investment | €250,000 (startup) / €500,000 (corporate) | €500,000 (fund route) |
| Approval sequence | Approval before capital deployment | Capital first, approval after |
| Processing time | 4 to 6 months | Up to 40 months |
| Programme stability | Unchanged since 2018 | 3 rule changes since 2022 |
| Current status | Active. No disputes. | Class action underway |
| Citizenship path | 10 years residency | 5 years residency |
| Flat tax regime | €200,000/year on foreign income (15 years) | NHR abolished January 2024 |
| Physical presence requirement | No minimum stay required | 7 days/year (year 1), 14 days/year thereafter |
Why Portugal Lost Ground
Portugal’s Golden Visa programme has gone through three rule changes since 2022. The most significant was the removal of the real estate route, which pushed applicants toward fund investments with less liquidity and longer lock-up periods.
The approval backlog is now documented at up to 40 months. Capital is deployed before residency is granted, which means investors are exposed during the entire waiting period.
In 2024, Portugal abolished the Non-Habitual Resident (NHR) tax regime, which had been one of the main fiscal draws for international investors. A replacement scheme exists, but it covers a narrower set of beneficiaries and carries less certainty.
A class action filed by investors caught in the backlog is currently underway.
Why Portugal Lost Ground
Portugal’s Golden Visa programme has gone through three rule changes since 2022. The most significant was the removal of the real estate route, which pushed applicants toward fund investments with less liquidity and longer lock-up periods.
The approval backlog is now documented at up to 40 months. Capital is deployed before residency is granted, which means investors are exposed during the entire waiting period.
In 2024, Portugal abolished the Non-Habitual Resident (NHR) tax regime, which had been one of the main fiscal draws for international investors. A replacement scheme exists, but it covers a narrower set of beneficiaries and carries less certainty.
A class action filed by investors caught in the backlog is currently underway.
Italy’s Structural Advantages in 2026
The Italian Investor Visa programme has processed applications since 2018 with no structural rule changes. The approval sequence protects the investor: the Nulla Osta is issued before any capital is committed. No approval, no deployment.
Processing time runs between 4 and 6 months from application. The programme recorded 7 applications in 2018 and 209 in 2025, a CAGR of 62.6%. Projections for 2026 reach up to 1,000 applications, making it one of the fastest-growing programmes in Europe.
The flat tax regime for new residents sets a fixed €200,000 annual payment on all foreign-source income for 15 years, regardless of the actual amount. For investors with complex income structures across multiple jurisdictions, this is one of the most predictable fiscal frameworks available in the EU.
There is no minimum physical presence requirement after approval. Investors can maintain their primary residence elsewhere and activate the Italian residency on their own timeline.
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Italy vs Greece Golden Visa: A Shorter Comparison
The Italian Investor Visa programme has processed applications since 2018 with no structural rule changes. The approval sequence protects the investor: the Nulla Osta is issued before any capital is committed. No approval, no deployment.
Which Programme is Right for You
The right programme depends on three variables: your current tax situation, how much capital you want to commit, and your timeline.
Italy is the stronger option if fiscal planning is a priority, if you want approval before capital deployment, or if you are moving from a programme that stalled (see the Portugal Switch Programme for investors with blocked Portuguese applications).
Portugal may still be relevant if EU citizenship within 5 years is the primary objective and you can absorb the current backlog and fiscal uncertainty.
Greece is worth evaluating if you want real estate exposure and a lower entry point outside the major urban zones.
The comparison on paper only tells part of the story. The legal structure, the banking setup, and the advisory team around the application make a material difference to outcomes.
