Golden Visa: Every Residency-by-Investment Program Compared

“Golden visa” is a marketing label, not a legal term. Each country gives its program a statutory name: Portugal's autorização de residência para atividade de investimento (ARI), Greece's residence permit for investors, Hungary's guest investor residence permit, the US EB-5 immigrant investor category, Panama's Qualified Investor visa, and so on. What they share is a simple trade: you place a defined sum in an approved asset (property, a fund, a company, government bonds, a bank deposit or a non-refundable contribution) and in return the state issues a residence permit for you and, usually, your family.

What a residence permit lets you do

A residence permit lets you live in the country lawfully, open bank accounts, enrol children in school and, in most programs, work or run a business. In EU states that belong to Schengen (Portugal, Greece, Italy, Malta, Hungary, Latvia and others) the permit also lets you travel within the Schengen Area for up to 90 days in any 180 days. It does not give you a new nationality, a new passport, the right to vote or the right to live in other EU states.

Temporary, permanent, or a long-stay visa

The label hides three very different products. Most European programs issue a renewable temporary permit: Greece issues five-year cards renewable while you keep the investment, Hungary up to ten years renewable once, and Italy an initial two-year visa and permit^[4][6][12]. A smaller group grants permanent residence from day one: Malta's MPRP, Cyprus's fast-track Regulation 6(2) permit, Panama's Qualified Investor route and the US EB-5 green card (two-year conditional at first)^{[5][13][10][8]}. A third group is really a long-stay visa with no route to permanent status, such as the Thailand Privilege card^[16].

Residency versus a second passport

Residency by investment is often confused with buying citizenship. They are separate products with separate laws. A golden visa gives you a home base and, after years of genuine residence and a language test, possibly the right to apply to naturalise. Citizenship programs, offered mainly by five Caribbean states and a handful of others, grant a passport within months but no right to live in Europe or North America. Our guide to the difference between a golden visa and a second passport sets out the trade-offs, and the overview of citizenship programs lists every passport route that still exists. Since the EU Court of Justice ruling of April 2025, no EU state sells citizenship; see what happened to Malta's passport program.

Headline minimums are the least useful number on most comparison sites. Two programs with the same €250,000 threshold can differ by €100,000 once taxes, fees, holding costs and exit value are counted, and by a decade in how long it takes to reach a secure status. Answer these six questions first.

1. What is your real budget, and must the money come back?

Separate recoverable investments (property, funds, bonds, deposits, company shares you can sell after the holding period) from sunk costs (donations, government contributions, fees, transfer tax, VAT, legal fees). Malta's MPRP, for example, needs about €99,000 of non-refundable government contributions and fees on top of buying a €375,000 home or leasing one for €14,000 a year, while Hungary's €250,000 fund must be held for five years and returned at whatever the fund is worth^[5][6]. A deposit or bond route preserves capital but ties it up at low yield; a property route adds 5–15% in purchase costs and market risk. Our ranking of the lowest-cost residency programs compares total cost, not just the threshold.

2. Do you need Schengen access?

A permit from a Schengen state gives visa-free travel across 29 European countries for short stays. That matters most to holders of passports that need Schengen visas. Cyprus is in the EU but not in Schengen; the UAE, Panama, the US, Thailand, New Zealand and Singapore offer no European travel benefit at all. If Schengen is the goal, start with our comparison of European residency programs.

3. How much time can you actually spend there?

Stay rules range from none at all (Greece, the UAE, Malta, Hungary for the permit itself) through token presence (Portugal: 7 days in the first year, then 14 days in each two-year period) to genuine residence (the US green card, which assumes the US is your home)^[4][7][1][8]. New Zealand's Active Investor Plus asks only 21 days over three years on the Growth category but 105 days over five years on Balanced^[18]. Note that the minimum stay to keep a permit is not the stay needed to naturalise.

4. Do you want permanent residency or citizenship later?

If a passport is the long-term aim, compare naturalisation rules, not permit rules. Portugal's naturalisation period rose from five to ten years of legal residence for most applicants under Organic Law 1/2026, in force since 19 May 2026^[2]. Greece requires seven years of actual residence, Hungary eight years plus a language exam, and the US five years as a green card holder. Panama allows naturalisation after five years of residence, and New Zealand grants permanent residence after the three-year Growth investment period^[18]. The guide to the fastest routes from residency to a passport ranks these timelines.

5. Where will you be tax resident?

A golden visa does not make you tax resident by itself. Tax residence normally follows physical presence (often 183 days) or a home or centre of interests. If you do move, regimes differ widely: Italy's optional flat tax on foreign income for new residents rose to €300,000 a year from 2026, with €50,000 per family member^[27]; the UAE has no personal income tax; US green card holders are taxed on worldwide income from day one. Program choice and tax planning should be done together with a tax adviser in both countries.

6. Who in your family must be covered?

Most programs cover a spouse and minor children. Differences appear at the edges: Greece includes children up to 21 and the parents of both spouses; Malta covers four generations, with each adult dependant paying €7,500; the UAE lets golden visa holders sponsor children regardless of age; the US EB-5 covers only a spouse and unmarried children under 21^[4][5][7][8]. If you have adult children or elderly parents, this alone can decide the program.

Latvia now looks cheap, but the €50,000 company route requires a real business paying at least €40,000 a year in taxes, permits run for two years at a time, and a €150,000 fund route written into the new Immigration Law exists only on paper: the state fund manager has not been set up, and on 3 September 2026 five Progressive MPs proposed deleting it^[14][15]. Thailand is a prepaid membership with concierge benefits, not an investment, and leads to no permanent status^[16]. The state operator's membership page still lists Bronze at THB 650,000 for five years, and agents report that the Bronze window, earlier due to end on 30 September 2026, has been extended to 31 December 2026; after that Gold at THB 900,000 would become the entry tier^[16][17][31]. The operator has not said what happens to Bronze in 2027.

Malta is cheap in cash out of pocket only if you rent; buyers commit nearly half a million euros, and you must still show €500,000 of assets (€150,000 of them financial) or €650,000 (€75,000 financial)^[5]. Panama clarified its thresholds by decree in September 2026: $300,000 for a first-sale property, $500,000 for resale property, securities or a state-bank deposit, and $750,000 for a private-bank deposit. Despite widely repeated reports, no published decree sets a further increase for 15 October 2026^[10]. Cyprus grants permanent residence immediately but requires secured foreign income of €50,000 a year, plus €15,000 for a spouse and €10,000 per child^[13].

The automatically generated region tables below list every program we track. This overview explains how each region differs in what it offers.

Europe: Schengen access and the slow road to an EU passport

European programs are bought mainly for Schengen mobility, schooling and a safe-haven address. The established options are the Greek property residence permit, Portugal's fund and donation routes (with its island option covered under residency in the Azores), Hungary's guest investor permit, Malta's permanent residence program and Italy's investor visa. Smaller or narrower options include Cyprus fast-track permanent residence, Latvia's company-investment permit, Bulgaria's investor residence and, outside the EU, Montenegro's property-based residence. Italy's investor visa is suspended for Russian and Belarusian citizens, and Latvia bars them from its investment routes^[12][14].

Middle East and Caucasus: speed, no income tax, no stay rules

The Gulf states compete on speed and tax. The UAE's ten-year golden residence needs AED 2 million in property, a deposit or a company, has no minimum stay, and covers children of any age^[7]. Saudi Arabia's premium residency and Oman's investor residence follow similar models. Further north, Turkey's property residence permit and Georgia's investor residence are low-cost entry points, though neither gives Schengen access.

Americas: green cards and permanent residence from day one

The EB-5 immigrant investor green card remains the main investment route into the US, alongside the newer and still contested Trump Gold Card and the non-immigrant E-2 treaty investor visa^[8][9]. In Latin America, Panama's Qualified Investor visa grants permanent residence from day one, typically about three to six months after you start, while Costa Rica's investor residence and Paraguay's Investor Pass offer lower entry points. Canada's federal investor routes are closed; see what remains for investors in Canada.

Asia-Pacific: high thresholds or lifestyle visas

Asia-Pacific splits into very expensive permanent residence and cheap long-stay visas. Singapore's Global Investor Programme starts at S$10 million in a business and targets established founders and family offices, and New Zealand's Active Investor Plus visa starts at NZ$5 million^[19][18]. At the other end, the Thailand Privilege long-stay visa, Malaysia's MM2H and Indonesia's second-home and golden visas suit retirees and part-year residents. Australia closed its investor visas in 2024; see Australia's National Innovation visa for the talent-based successor^[24].

Since 2022 Europe and the Anglosphere have closed or cut back almost every investor route. Three pressures drove this: EU institutions' concerns about security, money laundering and tax evasion; housing affordability, especially where property routes pushed up prices in city centres; and, after Russia's invasion of Ukraine, sanctions-evasion risk. The pattern matters for buyers: closures almost always protect existing holders and pending applications, but they can arrive with weeks' notice.

• United Kingdom, 17 February 2022: the Tier 1 Investor visa closed to all new applicants with immediate effect over security concerns; existing holders could extend and settle^[25]. See the UK's current investor and founder routes.
• Ireland, 15 February 2023: the Immigrant Investor Programme closed to new applications; applications on hand continued to be processed^[20]. See what replaced Ireland's investor programme.
• Portugal, 7 October 2023: Law 56/2023 removed real estate purchases, renovation and plain capital transfers; fund, donation, research and job-creation routes remain^[1].
• Netherlands, 17 April 2024: the €1.25 million foreign investor scheme, which fewer than ten people had used in recent years, was abolished. It had been widely expected to close on 1 January 2024, but the formal abolition took effect in April^[21][22].
• Australia, 31 July 2024: the Business Innovation and Investment Program, including the Significant Investor stream, closed permanently to new applications^[24].
• Spain, 3 April 2025: Organic Law 1/2025 ended all investor residence routes, including the €500,000 property route; see Spain's closed program and its alternatives^[11].
• Canada, 31 December 2025: IRCC stopped accepting new Start-up Visa applications, except from holders of a 2025 designated-organisation commitment, and paused the program entirely on 30 June 2026; applications accepted before then are still processed, and a new entrepreneur pilot has been announced but not launched^[23][30].
• Latvia, 15 September 2026: the new Immigration Law abolished residence through real estate purchases and subordinated bank deposits; existing permits can be renewed^[14].

For the full timeline, what happened to existing holders and which programs look exposed next, see our tracker of ended and closing residency programs.