Q1 Figures Show Portugal on Track to Approve All-Time Record Number of Golden Visas in 2023

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Portuguese golden visa approvals reached 163 in March, the highest monthly approval figure in nearly three years, capping a strong Q1 that saw the program issue a total of 386 golden visas based on investments amounting to EUR 177.2 million. If Portugal’s SEF (or APMA, the new agency that will take over the job of processing golden visas) approves as many applications in the remaining three quarters of the year, the program is on track to issue an all-time record number of golden visas in 2023.

On the one hand, record approval volume in 2023 is a realistic prospect considering the momentous backlog of applications built up during the first half of 2022, as well as the rush of applications that have come in following the government's February 16th announcement of its intention to close the program. On the other, the government's final legislative proposal includes provisions that would make those post-February 16th applications null and void. This particular provision, however, has been roundly criticized as unconstitutional because of its retroactive effects, which reduces the likelihood of the law's approval as currently formulated.

Once again this March, Americans were the top nationality among those approved, accounting for 28 approvals. Chinese nationals recorded 23 approvals, British 16, Brazilians and South Africans 11 each, and Turks 7. In a clear manifestation of post-Brexit interest in the golden visa, March was the fifth month in the last seven in which UK investors appeared on the top-5 monthly approvals list, a feat they had only managed twice before in the program's almost 11-year history.

As in 2022, Americans and Chinese remain neck-and-neck in the race to be the program's top investor group.

As of the end of the first quarter of this year, 18.1% of approved applicants were Americans, the highest US proportion on record.

Chinese investors' share of the program, meanwhile, has reached a nadir of 14.8% so far in 2023.

While the 163 approvals in March represented the highest such figure observed since the pandemic boom month of May 2020, total investment for the month was a more modest EUR 78.5 million, which is actually lower than the total for December last year, a month during which only 151 applicants received approvals.

That apparent paradox is attributable to the falling per-applicant average investment: While it reached EUR 562,000 in December, the average in March was EUR 482,000. Average per-applicant investment has fallen by about a third since early 2020, when it reached EUR 661,000.

In 2023, approvals under the residential real estate investment option no longer account for a majority (or even plurality) of golden visas. The biggest investment category for the program is now Subparagraph 4 (renovation properties), which account for 4 out of 10 approved golden visas this year. The fund investment option, once a niche-product, now accounts for a quarter of approvals.

Measured in euros rather than approvals, however, the bigger-ticket Subparagraph 3 investment category remains the biggest qualifying route.

The fund investment category remains the fastest-growing option in relative terms. Having doubled between 2020 and 2021, and tripled between 2021 and 2022, Q1 2023 figures indicate this category could double (in absolute terms) also this year.

Overall, total investment in the program inches ever-closer to EUR 7 billion, a milestone it is likely to reach this month, and certainly by May.

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