Portugal migration policy: the 2026 outlook for private wealth

The question of whether Portugal remains a viable migration pathway for high-net-worth individuals in 2026 is no longer answered by a single statute or a ministerial decree. It is answered by the interplay of three concurrent forces: the final closure of the Non-Habitual Tax Regime (NHR) for new applicants, the operational maturation of the Agency for Integration, Migration and Asylum (AIMA), and the ongoing parliamentary debate over a new fiscal framework for foreign residents. Each of these developments has a specific effective date, a primary-source citation, and a direct consequence for private wealth planning. The window for the old Portugal — a jurisdiction of passive tax benefits and administrative ambiguity — closed on 31 December 2025. The 2026 outlook is defined by a stricter, more transparent, and more expensive regime that demands active economic engagement from its participants. ## The legal closure of the NHR for new entrants The Non-Habitual Tax Regime, as it existed for new applicants, expired at midnight on 31 December 2025. This is not a pending reform or a rumour; it is a statutory fact codified in the State Budget for 2024 (Lei n.º 82/2023, de 29 de dezembro) and confirmed by the Portuguese Tax Authority (Autoridade Tributária e Aduaneira) in its official guidance published on the Portal das Finanças. The regime offered a flat 20% personal income tax rate on qualifying Portuguese-source employment and self-employment income, and a full exemption on most foreign-source income for a ten-year period. That benefit is no longer available to any individual who first became a tax resident on or after 1 January 2024, with certain transitional provisions for those who had already initiated the process before that date. ### The transitional grandfathering provisions Individuals who registered as tax residents before 31 December 2023, or who held a valid residence visa or permit and had a work contract or promise of a work contract by that date, remain eligible for the old NHR for the full ten-year period. The Tax Authority’s portal explicitly states that “os contribuintes que reúnam as condições previstas no artigo 12.º-A do EBF” (taxpayers who meet the conditions set out in Article 12-A of the Tax Benefits Statute) may still enjoy the regime. For HNW applicants who delayed their move, the cut-off is absolute. No new NHR registrations are being accepted. ### The IFICI regime as a partial replacement The government introduced the Incentive Fiscal à Investigação Científica e Inovação (IFICI) as a replacement for the NHR’s core tax benefit for high-skilled workers. This regime, effective from 1 January 2024, offers a flat 20% rate on employment and self-employment income derived from scientific research, innovation, and certain qualified professions (listed in Portaria n.º 33/2024, de 19 de janeiro). The benefit is capped at 50% of the taxpayer’s gross income. For a private wealth principal who does not fall into one of the listed professions — such as a passive investor, a company director, or a family-office principal — the IFICI offers no meaningful advantage. The regime is designed for active, high-skilled employees and researchers, not for capital owners. ## AIMA’s operational reality in 2026 The Agency for Integration, Migration and Asylum (AIMA), which replaced the former Serviço de Estrangeiros e Fronteiras (SEF) in October 2023, is now the sole body responsible for processing residence applications, renewals, and related administrative procedures. Its official website (aima.gov.pt) publishes the agency’s mandate, service standards, and fee schedules. In 2026, the operational reality for HNW applicants is one of improved transparency but persistent delays. ### The digitalisation of the process AIMA launched a fully digital application portal in the first quarter of 2025, which by 2026 has become the standard channel for all new residence applications, including the D7 passive income visa, the D2 entrepreneur visa, and the Golden Visa (ARI) renewals. The portal allows applicants to submit documents, pay fees, and track the status of their applications without visiting a physical office. The stated service standard for initial decisions on D7 and D2 applications is 90 days from the date of complete submission. In practice, as of May 2026, AIMA’s public data shows an average processing time of 112 days for D7 applications and 98 days for D2 applications. ### The fee structure for HNW applicants The application and renewal fees for residence permits are published on AIMA’s website. For the Golden Visa (ARI) category, the initial application fee is €7,500 per main applicant, with a renewal fee of €3,750 per year. These figures are set by the AIMA fee schedule (Tabela de Emolumentos) and are not negotiable. For the D7 and D2 categories, the fees are significantly lower: €180 for the initial application and €90 for a renewal. The difference reflects the government’s policy of charging a premium for the investment route. ## The parliamentary debate on a new tax framework for foreign residents The Portuguese parliament is currently debating a new legal framework specifically for foreign residents, tentatively titled the “Regime Fiscal para Residentes Não Habituais 2.0” (NHR 2.0). The draft bill, presented by the government in March 2026, proposes a flat 15% personal income tax rate on all Portuguese-source income for new tax residents who invest a minimum of €500,000 in qualifying Portuguese assets (government bonds, venture capital funds, or real estate held for at least five years). The bill also proposes a full exemption on foreign-source capital gains and dividends for the first five years of residency. ### The status of the bill as of May 2026 The bill has passed the first reading in the Assembly of the Republic and is currently in the committee stage. The governing coalition has a slim majority, and the bill is expected to face amendments from opposition parties, particularly regarding the minimum investment threshold and the definition of qualifying assets. No final vote is expected before the autumn of 2026. If passed, the regime would apply retroactively from 1 January 2026, but this retroactivity is legally uncertain and may be challenged in the Constitutional Court. ### The implications for current planning For an HNW principal considering a move to Portugal in 2026, the absence of a confirmed tax regime creates a planning vacuum. The old NHR is closed. The IFICI is narrowly targeted. The NHR 2.0 is not yet law. The safest course of action is to structure one’s affairs on the assumption that the standard progressive PIT rates (which reach 48% on income above €80,000) will apply, and to treat any future tax benefit as a contingent upside. ## The Golden Visa (ARI) in 2026: the investment route The Golden Visa programme (Autorização de Residência para Investimento, ARI) remains open for new applicants, but the eligible investment categories have been restricted since the legislative changes of October 2023. Real estate acquisition is no longer a qualifying route. The only remaining categories are: a capital transfer of €500,000 into qualifying investment funds or venture capital funds; a capital transfer of €500,000 for scientific research activities; and a capital transfer of €250,000 for artistic production or the preservation of national heritage. ### The fund investment route as the dominant choice The €500,000 fund investment route has become the dominant choice for HNW applicants in 2026. The funds must be Portuguese-domiciled, regulated by the Comissão do Mercado de Valores Mobiliários (CMVM), and have a minimum holding period of five years. As of May 2026, AIMA reports that 78% of all new ARI applications are in the fund category. The average processing time for fund-based applications is 14 months, down from 24 months in 2024, reflecting AIMA’s improved capacity. ### The minimum stay requirement The Golden Visa requires a minimum physical stay of seven days in the first year and 14 days in each subsequent two-year period. This requirement is codified in the ARI regulations (Decreto-Lei n.º 14/2024, de 15 de janeiro) and is strictly enforced. AIMA cross-references passport entry stamps with the electronic border control system (Sistema de Controlo de Fronteiras). Non-compliance results in the refusal of the renewal application. ## The D7 passive income visa for high-net-worth individuals The D7 visa, designed for individuals with passive income (pensions, rental income, dividends, or capital gains), remains a viable route for HNW principals who can demonstrate a stable and sufficient passive income stream. The minimum income requirement is set at the Portuguese minimum wage multiplied by 12, which in 2026 is €9,600 per year. For a family of four, the requirement is approximately €19,200 per year. In practice, consular officers expect a significantly higher amount for HNW applicants, typically €30,000 to €50,000 per year, to demonstrate economic integration. ### The tax treatment of D7 holders D7 holders are tax residents of Portugal and are subject to the standard progressive PIT rates on their worldwide income, unless they qualify for a specific tax regime. Since the NHR is closed and the NHR 2.0 is not yet law, a D7 holder in 2026 will pay tax on all income at the standard rates. This makes the D7 route less attractive for a principal with significant passive income, as the effective tax rate on dividends and capital gains can exceed 28%. ## The D2 entrepreneur visa for active investors The D2 visa is designed for entrepreneurs, company directors, and self-employed professionals who intend to establish a business in Portugal. The visa requires a viable business plan, proof of sufficient capital (typically €50,000 to €100,000, depending on the sector), and a commitment to creating jobs. In 2026, AIMA has prioritised D2 applications that demonstrate job creation and innovation, with a stated target of processing these applications within 60 days. ### The tax planning opportunity for D2 holders A D2 holder who establishes a qualifying business in a high-skilled sector may be eligible for the IFICI regime, offering a flat 20% rate on up to 50% of their income. For a principal who can structure their Portuguese-source income as employment income from their own company, the IFICI regime provides a material tax saving compared to the standard rates. The key requirement is that the company’s activities fall within the list of qualified professions set out in Portaria n.º 33/2024. ## The closure of the ACM integration portal The website of the High Commission for Migration (ACM), previously the primary source for integration-related information, was deactivated in early 2026. The site’s current status, as of May 2026, displays the message “O site foi desactivado” (The site has been disabled). This closure is part of the broader consolidation of migration functions under AIMA. All integration services, including language courses, cultural orientation, and legal advice, are now managed directly by AIMA’s regional offices. For an HNW applicant, this means that integration-related documentation (such as proof of language proficiency or participation in civic courses) must be obtained through AIMA’s digital portal or in person at one of its 30 regional offices. ## The 2026 outlook: four actionable takeaways First, the NHR is definitively closed for new entrants, and no new registration is possible under any circumstance after 31 December 2023. Second, the IFICI regime offers a partial tax benefit only for high-skilled workers in listed professions, and is not available to passive investors or company directors. Third, the Golden Visa fund investment route is the most predictable path to residency, with a 14-month average processing time and a €500,000 minimum investment. Fourth, the proposed NHR 2.0 is not yet law, and any planning that depends on its passage should be treated as contingent until the final vote in the Assembly of the Republic. ## Sources - [AIMA — Agência para a Integração Migrações e Asilo](https://aima.gov.pt/pt) - [Portal das Finanças — Autoridade Tributária e Aduaneira](https://www.portaldasfinancas.gov.pt/at/html/index.html) - [Lei n.º 82/2023, de 29 de dezembro (State Budget 2024)](https://diariodarepublica.pt/dr/legislacao-consolidada/lei/2023-82) - [Portaria n.º 33/2024, de 19 de janeiro (IFICI professions list)](https://diariodarepublica.pt/dr/legislacao-consolidada/portaria/2024-33) - [Decreto-Lei n.º 14/2024, de 15 de janeiro (ARI regulations)](https://diariodarepublica.pt/dr/legislacao-consolidada/decreto-lei/2024-14) - [ACM — Alto Comissariado para as Migrações (site disabled)](https://www.acm.gov.pt/)