The Concept
A golden visa is residency in exchange for a passive investment: buy an asset of a set size — receive the right to live in the country (more often, the right not to live there while keeping the status). It differs from citizenship by investment fundamentally: you get residence, not a passport; and from ordinary residence permits — in requiring no job, no business activity and no permanent presence.
The class emerged in 2012: Portugal and other peripheral EU economies, emerging from the debt crisis, sought capital inflows and offered residency for property purchases. Within a decade the scheme spread to some fifty countries — from the Caribbean to the Gulf — peaking in the late 2010s. Then the pendulum swung back, under pressure from Brussels, money-laundering scrutiny and the housing question boiling over in the capitals.
The class in parameters:
| Thresholds | €250–800k in the EU, AED 2m in the UAE, S$10m in Singapore |
|---|---|
| Formats | Real estate, funds, business, government bonds, deposit, contribution |
| Citizenship | Not part of the status: Portugal — 10 years (7 for EU/CPLP); Saudi Arabia — none |
| Tax | Never automatic: the 183-day rule and the centre of life decide |
| Legal frame | A member-state competence; citizenship for money closed by C-181/23 |
The Active Programs
Europe
European programmes compare on the entry threshold and the investment format.
| Programme | Threshold | Format and condition |
|---|---|---|
| Greece | €400–800k | Real estate (€800k in Athens, Thessaloniki and islands like Mykonos and Santorini); no residence requirement |
| Italy | €250k – €2m | Investor visa: startup €250k, company €500k, government bonds €2m |
| Hungary | €250k | Guest investor: a fund, 10 years with no presence requirement |
| Portugal | €500k | CMVM-regulated investment fund, residential real estate excluded since 2023; citizenship in 10 years (7 for EU/CPLP) |
| Andorra | from €600k | Passive residency; in practice closer to €1m with the AFA deposit |
The €250k entry in Greece survives only for commercial-to-residential conversions, heritage restorations and startup investments. It is Europe's most in-demand program: a record 8,879 approvals in 2025, +61% applications in Q1 2026; the Italian investor visa +43% in the same quarter.
The Portuguese fund must hold at least 60% in Portuguese companies and carry no direct or indirect real-estate exposure; since 19 May 2026 the citizenship clock runs from card issuance (Lei Orgânica 1/2026). Malta's GRP and Gibraltar's Category 2 sit alongside on a different basis: what is bought is not an entry threshold but a tax ceiling — a flat 15% on remitted income and a cap on tax for HNWIs.
The Middle East and Asia
Outside Europe the threshold is set in local currency and the format runs from property to portfolio assets.
| Programme | Threshold | Format and status |
|---|---|---|
| UAE Golden Visa | AED 2m | Property; 10 years, no minimum presence, zero personal income tax |
| Saudi Premium Residency | SAR 800,000 once or SAR 100,000 a year | Status sold outright: residence with no time limit or the annual track, no presence requirement, no personal income tax |
| Singapore GIP | S$10m | Business or funds; permanent residence for operating entrepreneurs |
| Malaysia MM2H | — | Long-term residency via deposit, tiered after the reform |
| Hong Kong CIES | HK$30m | Portfolio assets |
The UAE threshold is measured by the property's full value rather than the amount paid (Article 8, section Second, of the Annex to Cabinet Resolution No. 65 of 2022, in force 3 October 2022), so mortgaged and off-plan purchases qualify; the old AED 1m minimum down payment was an administrative requirement dropped in January 2024, not February 2026.
Saudi Arabia is the only programme in the region that sells an open-ended status outright (Royal Decree No. M/106 of 10/09/1440H, 15 May 2019). Five qualifying categories were added in January 2024:
- an investor from SAR 7m creating ten jobs;
- a residential property owner from SAR 4m;
- an entrepreneur from SAR 400,000;
- a special talent on a salary threshold;
- a gifted applicant on a recommendation from the relevant ministry.
The programme carries no route to citizenship.
The Americas and the Islands
The Cayman Islands and the Bahamas — residency through property in zero-tax jurisdictions; Bermuda follows the same logic. Paraguay and Costa Rica (inversionista) — low thresholds and territorial tax systems.
How to Choose
The task first, the program second. If the goal is a backup base without relocating, pick programs with no presence requirement (Greece, the UAE, the Caribbean). If the goal is citizenship, count the naturalisation clock and the actual-residence requirements. If the goal is taxes, a golden visa by itself solves nothing: look at the special tax regimes and the 183-day rule — a residence permit does not make you a tax resident automatically, and conversely, excess days in the country will make you one even without a visa.
This map answers the question of which programmes exist. The decisive layer is a different one: which legal structure is actually being bought and what is consumed for good in each — contribution, fund, property, business or deposit: the five models of investment migration. The overall order — from model to region and on to a specific programme — is set out in the investor cluster map.
Regulation and the Cancellation Risk
Brussels presses along two lines. Citizenship for money was held incompatible with the nature of Union citizenship by the EU Court in April 2025 (Commission v Malta, C-181/23) — closing the EU's last CBI program. Residency was untouched by the ruling: golden visas remain a member-state competence. The political pressure is real nonetheless: Spain closed its program from April 2025; Portugal and Greece raised thresholds and narrowed property as the entry route.
The second line is transparency. Source of funds is vetted under AML rules, and new-resident status falls within automatic exchange: CRS sees the account regardless of where the residence permit was issued. Residency is therefore planned together with tax residency and the exchange regime, not as their replacement; a genuine relocation adds the exit tax of the country of departure.
Where It Is All Heading
The trend runs from residential property to investments in the economy: funds, business, government bonds. New entrances appear too: in December 2025 the US opened intake for the "Gold Card" — the route created by Executive Order 14351 of 19 September 2025 (published 24 September 2025, 90 FR 46031). There are two cards, and their terms differ.
| Card | Contribution | What it gives |
|---|---|---|
| Gold Card | $1m by an individual or $2m under a corporate scheme, plus a $15,000 fee (announced as $5m) | Lawful permanent resident status as an EB-1 or EB-2 holder; the holder is a U.S. person taxed on worldwide income |
| Platinum Card | $5m | Promised: up to 270 days a year without tax on non-U.S. income; not created by the executive order, not open for applications |
The Gold Card carries no tax break: the official programme site states that holders will be subject to U.S. tax, including on non-U.S. income. The Commerce Secretary has said that implementing the Platinum Card requires action by Congress. Demand is modest so far: by spring 2026 only a handful of approvals.
In parallel, the Gulf's fast zero-tax hubs and the Caribbean hold their ground, and the perpetual-traveler scenario is back in fashion among those who need the status without the move.
Q/A
How does a golden visa differ from citizenship by investment?
A residence permit gives the right to live and (in the EU) move around Schengen, but not a passport. Citizenship by investment is a separate class of programs (the Caribbean, Türkiye) with different thresholds and risks: see the "Second citizenship" hub.
Can you hold a golden visa without becoming a tax resident?
Yes — that is the standard configuration: the status is maintained with minimal presence (in Greece, zero), while tax residency stays in another country. It breaks when the actual centre of life moves: formal day counts stop helping, and the treaty tie-breaker decides.
Can the state cancel the program after I buy?
Programs are cancelled regularly, but existing statuses are usually preserved (grandfathering): Spanish visas issued before April 2025 keep renewing. The risk is not losing the status, but the impossibility of upgrading terms — and the politics of the next government.