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Six jurisdictions, side by side. Thresholds, stay requirements, citizenship timelines, and what each program actually delivers — set out plainly, including where Portugal is not the strongest answer.
We advise on Portugal. On the other jurisdictions here we report publicly available program parameters so you can frame the decision before taking specialist advice in the relevant country.
Figures are program minimums before taxes, government fees, legal costs, and due diligence charges. Real all-in cost is materially higher in every case, and family composition changes the arithmetic substantially.
| Portugal | Greece | Italy | Malta | Cyprus | UAE | Spain | |
|---|---|---|---|---|---|---|---|
| Status | Open | Open | Open | Open | Open | Open | Closed to new applicants since 3 April 2025 |
| Minimum investment | €250,000 cultural donation (€200,000 in designated low-density areas); €500,000 regulated fund | €250,000 conversion or listed-building restoration; €400,000 most regions; €800,000 prime areas | €250,000 innovative startup; €500,000 Italian company; €1m philanthropic; €2m government bonds | €375,000 property (€300,000 south Malta / Gozo) or €14,000 p.a. rent, plus fixed government charges | €300,000 plus VAT, in property, company shares, or Cypriot fund units | AED 2m in property (approx. USD 545,000) | Formerly €500,000 property |
| Real estate qualifies | No — removed October 2023 | Yes — the principal route | No | Property is one required component, not the whole investment | Yes — new-build from a developer, or other property types | Yes — the principal route | — |
| Additional mandatory costs | Government and processing fees per applicant; legal and fund subscription costs | Roughly 7–10% for transfer taxes, notary, registration, and immigration fees | Consular and permit fees; investment held for the permit’s duration | €37,000 government contribution, €60,000 administrative fee, €2,000 NGO donation, €7,500 per adult dependant | VAT on new property; legal and registration costs | Transfer and registration fees; visa issuance costs | — |
| Income or asset test | None beyond proof of lawful source of funds | None beyond lawful source of funds | Proof of sufficient means and traceable source of funds | Assets of €500,000 (of which €150,000 financial), or €650,000 (of which €75,000 financial) | €50,000 secured annual income from outside Cyprus, plus €15,000 spouse and €10,000 per minor child | None for the property route | — |
| Physical presence | Approx. 7 days per year on average (14 days per two-year period) | None required for renewal | Some presence required; no fixed minimum-day rule for renewal | None required | Enter at least once every two years | None required | — |
| Permit granted | Temporary residence, renewable; permanent residence after 5 years | 5-year renewable residence permit | 2-year permit, renewable in 3-year increments | Permanent residence from grant; card renewed every 5 years | Permanent residence, indefinite; card renewed periodically | 10-year renewable residence | — |
| Schengen access | Yes | Yes | Yes | Yes | No — Cyprus is not a Schengen member | No — non-EU | — |
| Citizenship timeline | 10 years of legal residence (7 for EU and CPLP nationals) under Lei Orgânica n.º 1/2026, counted from the first residence permit | Approx. 7 years of actual residence under standard naturalization | 10 years of residence, with B1 Italian | Not a citizenship route. Malta’s former investor-citizenship model no longer exists | Standard naturalization only, around 7–8 years with Greek language requirements. No accelerated investor route | No standard path. Emirati citizenship is separate and highly selective | — |
| Family inclusion | Spouse or partner, dependent children, dependent parents, under one application | Spouse, children under 21, and parents of both spouses, with no increase to the threshold | Spouse, dependent children, and dependent parents in defined circumstances | Up to four generations, including grandparents, under a single application | Spouse and minor children; unmarried dependent children aged 18–25 may qualify. Parents not included on a single investment | Spouse, children of any age, and parents | — |
| Realistic processing | Historically extended under AIMA backlogs (12–24 months). Capacity has been expanded and waiting times are reducing | Several months, subject to municipal and consular workload | Among the faster EU routes, commonly 3–6 months | 6–14 months end to end, with a temporary permit available at submission | Among the fastest EU routes, commonly 2–6 months | Weeks rather than months once the title deed is certified | — |
| Capital recoverable | Fund route: yes, subject to performance and redemption terms. Cultural donation: no, non-refundable | Yes, through sale — but disposal below threshold ends the permit | Startup and company routes: yes, subject to performance. Philanthropic donation: no | Government contribution and admin fee non-refundable. Property recoverable after the 5-year hold | Yes, through sale — subject to maintaining the qualifying holding | Yes, through sale — subject to maintaining the qualifying holding | — |
Since real estate was removed in October 2023, Portugal is a capital-deployment program rather than a property program — arguably a strength: the regulated fund route keeps the qualifying capital as the client’s own asset rather than a fee or a donation.
The stay requirement is the lightest of any program granting Schengen rights, permanent residence remains available at five years, and the client keeps full freedom to buy Portuguese property on its own merits.
Greece kept real estate and priced it by geography. Prime markets now sit at €800,000; most of the country at €400,000, with a 120 m² minimum and a single-property rule. The €250,000 tier is narrow, applying to commercial-to-residential conversions and listed-building restorations.
Qualifying property cannot be used for short-term letting, which removes the yield assumption many buyers arrive with.
No real estate route, but a low startup threshold and the quickest processing among the EU options here. The 2026 Budget Law’s extension of the flat-tax regime for new residents has made Italy materially more interesting to families who will actually move their tax residence.
The permit structure is shorter-cycle than its peers — two years initially, then three-year renewals.
Malta grants permanent residence from the outset rather than a temporary permit that matures. That is a genuine structural difference. The cost sits in fixed government charges that are unrecoverable regardless of route.
Its distinguishing feature is family breadth: up to four generations under one application, which no other program here matches.
The lowest EU threshold on this page, and among the fastest to process. The constraints are meaningful: Cyprus is outside Schengen, the €50,000 external income test is annual and ongoing, and parents cannot be added on a single investment.
Failure to evidence the income requirement each year can put the permit at risk for the whole family.
The fastest and most permissive route here. The February 2026 removal of the equity-payment requirement means mortgaged and off-plan property now qualify on certified value, and multiple holdings can be combined to the AED 2m threshold.
It is not comparable to the EU programs. There is no Schengen access and no realistic path to citizenship — the proposition is a durable, low-friction base with no personal income tax.
Portugal is the program we advise on and, for most international families, the one we would recommend. That recommendation is only worth something if it could have gone the other way — so here are the specific cases where a client is better served elsewhere, and what they give up in exchange.
Portugal no longer offers a property route. If the residency itself must be secured by real estate, Greece and the UAE are the live options. In practice this rarely decides the matter: clients acquire Portuguese property alongside a qualifying fund position, holding the asset and the residency independently — which leaves the property free of the disposal restrictions Greece imposes.
Portugal’s five-year naturalization advantage is gone. Greece’s ordinary route is shorter on paper, but requires genuine, continuous residence rather than a week a year — a far heavier commitment than the headline suggests. Against Italy’s ten years, Portugal is level; against Malta, Cyprus, and the UAE, which offer no investor route to a passport at all, Portugal remains ahead.
Malta’s four-generation inclusion is unmatched, and for families intending to bring grandparents it deserves a look. The offset is that Malta’s core cost — roughly €99,000 in government contribution and fees — is unrecoverable in full, where Portugal’s fund subscription remains the client’s capital.
Cyprus at €300,000 undercuts Portugal’s fund route on headline threshold. It also carries an ongoing €50,000 annual income test, excludes parents, and sits outside Schengen. Where the objective is European mobility rather than the lowest entry number, the saving buys materially less.
On the balance of the criteria that matter to most families, Portugal remains the strongest program in Europe. No other jurisdiction combines full Schengen rights, a stay requirement of roughly a week a year, an EU legal system and property market, permanent residence at five years unaffected by the nationality reform, and a route where the qualifying capital stays the client’s own. The reforms narrowed Portugal’s lead. They did not displace it.
We will tell you plainly whether Portugal is the right program for your objective, and where another jurisdiction would serve you better. The Portuguese side is handled with our immigration, real estate, tax, and corporate law partners.
Scope of this page. Luznur Capital advises on Portuguese real estate and investment matters. In relation to Greece, Italy, Malta, Cyprus, the United Arab Emirates, and Spain, the information above is a summary of publicly available program parameters compiled for comparison purposes only. It is not advice on the law of those jurisdictions, and we do not hold ourselves out as qualified to give it.
No legal, tax, or immigration advice. Nothing here constitutes legal, tax, immigration, or investment advice, and no advisory relationship arises from reading it. Residency and nationality rules change frequently and are applied on the facts of each case. Figures are program minimums and exclude taxes, government charges, professional fees, and due diligence costs. Before acting, obtain advice from licensed counsel in the relevant jurisdiction. Portuguese matters are handled with our immigration, real estate, tax, and corporate law partners.
Currency and verification. Parameters verified 18 July 2026 and reviewed quarterly. Where sources conflict — including on Cypriot naturalization timelines and on the transitional treatment of residency accrued before Portugal’s 2026 nationality reform — we have stated the position conservatively and flagged the uncertainty rather than resolving it in our own favor.
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