Investors pulled €94.7 million (approximately $108 million) out of Portugal’s Golden Visa-eligible investment funds between January and May 2026, according to figures from the Portuguese Association of Investment Funds, Pensions and Assets (APFIPP). That is more than double the €45.3 million (approximately $52 million) redeemed across the whole of 2025.
Redemptions jumped to roughly €20 million in January and held near that level for months, breaking a pattern in which monthly outflows from this niche segment rarely topped €5 million.
On the other hand, APFIPP put new fund subscriptions at €283 million through May.
The accelerated redemption rate follows changes to the Portuguese Nationality Law, which entered into force on May 19, 2026, extending the residency period required for naturalization from five years to ten years for most third-country nationals, and to seven years for citizens of the European Union and Portuguese-speaking countries.
A rush in, then a reversal
Throughout 2025, foreign investors hurried a record €732 million (approximately $834 million) into the funds, likely assuming that any future legislation would protect the rights and timelines of those already holding active investments.
When the new law arrived without that safeguard, the funds met a wave of redemption orders.
As such, some of the 2026 redemptions may simply reflect investors who entered late to beat the rule change now unwinding those positions, rather than long-term holders losing faith.
Fund managers downplay redemption fears
Alexandre Cunha Elias, whose firm 3 Comma Capital (3CC) runs a Golden Visa-eligible fund, said redemptions among his own clients have been minimal.
“Since the law changed, we have had fewer than half a dozen redemptions across our investor base,” he said, describing the effect as “largely immaterial and nowhere near the levels that might suggest a loss of confidence in the Fund route.”
Yet Cunha is unambiguous that the nationality timeline changes were “very disappointing” in lacking any protection for golden visa investors, whose capital, he said, “has been highly beneficial for Portugal, supporting businesses, employment, and economic growth.”
Pedro Oliveira, whose firm Optimize Investment Partners also runs a Golden Visa-eligible fund, said that fund redemptions remain outweighed by steady inflows.
“Although a small percentage of our investors have redeemed their positions, we continue to see strong demand, with new subscriptions significantly exceeding redemptions,” he said, adding that for his firm, “new investments this year have been over five times higher than redemptions.”
Like Cunha, Oliveira lamented the nationality law but reserved his sharper criticism for the market reaction to it, which he said has been “driven by misconceptions about the law’s practical impact.” That impact, in his view, is minimal, with the “program’s core benefits intact” and only the timeline now longer.
Recovery ahead?
Oliveira expects the episode to sort the field. Investors have grown more selective, he said, weighing track record, liquidity, governance, and long-term performance more heavily, a shift he believes “has separated stronger funds from weaker ones” and concentrated demand among better-established ones.
Cunha expects the redemption trend to ease within the year. “Our view is that the redemption trend will gradually slow, with investment activity picking up again from September onwards,” he said.
He reads the broader European direction as favorable to Portugal, arguing that after EU Court of Justice ruled against Malta’s citizenship program last year, “all investment migration programs are under increasing pressure to make access to citizenship more and more restrictive.”
Against tightening competitors, Cunha expects Portugal to “re-emerge as the strongest European option, primarily because its residency requirement remains exceptionally attractive, just 7 days per year.”
