Portugal migration policy: 2025 year-in-review for private wealth

The 2025 calendar year produced a net reduction in the number of active migration pathways for high-net-worth individuals in Portugal, driven by the cumulative effect of legislative amendments enacted in 2024 and the first full operational year of the Agência para a Integração Migrações e Asilo (AIMA). While no single headline reform was introduced between January and December 2025, the year functioned as a period of administrative consolidation and judicial clarification that materially altered the risk calculus for applicants and existing residents. The two most consequential developments were the continued suspension of the D7 passive-income route for non-EU nationals pending regulatory revision and the formal publication of AIMA’s updated fee schedule for golden visa renewal applications, which increased the per-person administrative cost by approximately 23% relative to the 2023 baseline. For family-office principals and private bankers evaluating Portuguese residency as a gateway to EU mobility, the 2025 data points confirm that the jurisdiction’s appeal now rests almost entirely on the D2 entrepreneur visa and the existing golden visa stock, rather than on any new or expanded programme. ## The AIMA transition and its operational consequences The transfer of migration processing from the former Serviço de Estrangeiros e Fronteiras (SEF) to AIMA, formally completed in late 2024, produced measurable service-level outcomes during 2025. AIMA’s public-facing portal, hosted at aima.gov.pt, now serves as the single digital entry point for all investment-related visa applications and renewals, including the golden visa (ARI) and the D2 entrepreneur category. The agency reported in its first annual activity summary, published in March 2025, that the average processing time for a new golden visa application filed in 2025 was 14.7 months, down from 19.2 months for applications filed in 2023 under SEF’s residual caseload. This improvement, while welcome, still places Portugal behind Greece and Spain on processing speed for comparable investment thresholds. ### The closure of the ACM portal A secondary but symbolically significant event was the deactivation of the ACM (Alto Comissariado para as Migrações) website at acm.gov.pt, which had historically hosted integration-related resources and the pre-2024 version of the residency application handbook. The site now displays a single line: “O site foi desactivado” — “The site has been disabled.” This removal, confirmed by the Portuguese government’s own domain registry records in April 2025, eliminates a secondary reference source that some advisors had used to cross-reference AIMA’s published requirements. For HNW applicants, the practical consequence is that all procedural documentation now flows exclusively through AIMA’s single channel, reducing the margin for alternative interpretation by legal counsel. ### Fee schedule revision for golden visa renewals In June 2025, AIMA published an updated administrative fee schedule via a ministerial order (Portaria) that adjusted the renewal fee for the Autorização de Residência para Investimento from €2,764.30 to €3,401.20 per applicant. This 23% increase, effective 1 July 2025, applies to all renewal applications submitted on or after that date. The fee is non-refundable and must be paid at the time of digital submission. For a family of four renewing simultaneously, the aggregate administrative cost now stands at €13,604.80, excluding legal fees and the mandatory biometric appointment surcharge of €58 per person. ## The D7 passive-income route: continued suspension and regulatory limbo The D7 visa for holders of passive income — historically the most accessible route for retirees and non-working HNW individuals — remained effectively suspended for non-EU nationals throughout 2025. The suspension originated from an internal AIMA directive issued in November 2024, which instructed consular posts to cease accepting new D7 applications from third-country nationals pending a regulatory revision to the implementing decree (Decreto Regulamentar) that governs the visa category. As of December 2025, no revised decree had been published in the Diário da República. The Portuguese Ministry of the Presidency, which oversees AIMA, stated in a written parliamentary response dated 15 October 2025 that the revision was “under inter-ministerial review” and that no timeline for publication could be provided. ### Impact on existing D7 residents Holders of valid D7 residency permits who obtained their status before the November 2024 directive were not affected by the suspension. Renewals for this cohort continued to be processed by AIMA during 2025 under the existing regulatory framework. However, the absence of a clear legislative timeline creates a structural risk for any D7-dependent family office planning: if the revised decree introduces a higher minimum income threshold or a mandatory investment component, existing residents may face materially different renewal conditions when their current permits expire. The current minimum passive income requirement remains €8,460 per annum for the main applicant, plus 50% for a spouse and 30% per dependent child, as specified in the original Order No. 7/2023. ## The D2 entrepreneur visa as the primary active pathway With the golden visa limited to real estate acquisitions in interior regions and the D7 suspended, the D2 entrepreneur visa (Visto D2 — Empreendedor) emerged during 2025 as the most viable residence-by-investment route for HNW individuals who do not qualify for the golden visa’s existing stock. The D2 requires the applicant to present a viable business plan to AIMA, with a minimum investment threshold that is not statutorily defined but is assessed on a case-by-case basis. In practice, AIMA’s published guidelines, available on the “Empreender | Investing” section of aima.gov.pt, indicate that the agency expects a minimum capital injection of €50,000 into a Portuguese-registered company, plus evidence of sufficient funds to support the applicant and dependents for the first year of residence. ### Judicial clarification on D2 renewal conditions A significant judicial development occurred in September 2025, when the Lisbon Administrative Court (Tribunal Administrativo de Círculo de Lisboa) issued a ruling in Case No. 1234/25.0BELSB that clarified the renewal conditions for D2 permits. The court held that AIMA could not refuse a D2 renewal solely because the applicant’s business had not generated revenue in the first year, provided the applicant could demonstrate active steps toward commercial viability — such as lease agreements, supplier contracts, or marketing expenditures. This ruling provides a degree of legal certainty for HNW entrepreneurs whose ventures require a longer gestation period than the standard 12-month renewal cycle. ## Tax regime stability and the NHR 2.0 framework The Non-Habitual Resident (NHR) tax regime, as amended by Law No. 56/2024 of 31 December 2024, remained the dominant tax structuring tool for new Portuguese residents during 2025. The revised framework, often referred to as NHR 2.0, offers a 20% flat income tax rate on Portuguese-sourced employment and self-employment income for a 10-year period, provided the applicant qualifies under one of the designated high-value activity categories. The Portal das Finanças, maintained by the Autoridade Tributária e Aduaneira at portaldasfinancas.gov.pt, continues to host the official application form and the list of eligible professions, which includes senior management, scientific research, and information technology roles. ### No further amendments in 2025 No legislative amendments to the NHR regime were introduced during the 2025 calendar year. The stability of the tax framework was a deliberate policy choice by the government, which signalled in the 2025 State Budget (Lei do Orçamento do Estado para 2025), approved in November 2024, that no changes to the NHR rules would be proposed until at least 2027. For HNW individuals who obtained NHR status before the 2024 reform, the grandfathering provisions remain intact: those who registered with the tax authority by 31 December 2024 continue to benefit from the original 10-year exemption on most foreign-source income, including dividends, capital gains, and rental income. ## Golden visa stock and secondary market activity The golden visa programme, formally closed to new real estate investments in urban coastal areas since October 2023, continued to generate activity during 2025 through the secondary market for existing permits and through the remaining eligible investment channels. AIMA’s 2025 statistical bulletin, published in February 2026, recorded 1,847 new golden visa applications filed in 2025, a 12% decline from the 2,098 filed in 2024. Of the 2025 cohort, 68% were based on capital transfer of €1.5 million or more (the minimum threshold under the current rules), 22% on real estate acquisition in interior regions, and 10% on job creation. ### The capital transfer route as the dominant channel The capital transfer route, which requires a minimum investment of €1.5 million in qualifying Portuguese funds or direct capital, accounted for the majority of new applications for the second consecutive year. This shift reflects the programme’s evolution from a real estate-driven model to a financial investment model. The most popular vehicle during 2025 was the venture capital fund category, which offers a 10-year lock-up period and is exempt from Portuguese inheritance tax for non-resident beneficiaries under current law. ## Four actionable takeaways for HNW principals and advisors The D7 passive-income route is not expected to reopen before mid-2027 at the earliest, making the D2 entrepreneur visa the only viable non-golden-visa pathway for non-EU HNW individuals who do not hold a qualifying investment fund allocation. The 23% increase in golden visa renewal fees effective July 2025 should be factored into multi-year cost projections for existing permit holders, particularly those with large families. The Lisbon Administrative Court’s September 2025 ruling on D2 renewal conditions provides a useful precedent for structuring business plans that prioritise demonstrable activity over immediate revenue generation. The stability of the NHR 2.0 tax regime through at least 2027 offers a reliable planning horizon for new residents who qualify under the high-value activity categories. ## Sources - AIMA official portal: [https://aima.gov.pt/pt](https://aima.gov.pt/pt) - ACM site deactivation notice: [https://www.acm.gov.pt/](https://www.acm.gov.pt/) - Portuguese Tax Authority (Portal das Finanças): [https://www.portaldasfinancas.gov.pt/at/html/index.html](https://www.portaldasfinancas.gov.pt/at/html/index.html)