Three years ago, a couple from South Africa, Frans and Jordaan Viljoen, bought a three-bedroom house in Porto Heli, on the eastern Peloponnese, for €275,000.
They got a Greek golden visa attached to the asset, lived in the house, and rented it on Airbnb for parts of the year, collecting €250 to €300 a night during the long Greek summer. The property has since appreciated to roughly €325,000, the residency permit lets them move freely across the Schengen area, and the rental income covers what is essentially a lifestyle.
Migronis documented their case in detail in 2023, and it became one of the cleanest illustrations of what the Greek program offered at the time: A property in a beautiful country, a residency permit, and a yield-bearing asset, all in one transaction.
That deal cannot be reproduced today. By the time the same investor would walk into an apartment in Pangrati or Glyfada in 2024, the threshold in central Athens had moved twice in eighteen months, from €250,000 to €500,000 and then to €800,000. Short-term rentals on properties bought through the program were prohibited under threat of a €50,000 fine.
The local market itself didn’t crash, the euro didn’t slip, and the tourism economy didn’t weaken. Greek GDP expanded 2.3% in 2024 and 2.1% in 2025, so this is not a story about a weak underlying economy.
A single category of buyer (the residency-linked investor who built his model around real estate yield) found that his model no longer described the world he was buying into. A property consultancy with offices in Greece and the Netherlands, quoted in the Greek press, reports non-EU buyer interest in Greece down 83% year-on-year.
This is not just a Greek story. Spain closed its golden visa program entirely in April of 2025, taking tens of thousands of annual non-EU property transactions out of the Spanish market.
In the same month, the European Court of Justice ruled Malta’s citizenship by investment (CBI) program incompatible with EU law because it commodified EU citizenship, and Malta wound the program down three months later. It was the only passport-by-investment route on the continent, closed not by a parliament but by a court.
Portugal stripped real estate from its golden visa route in October of 2023, and on May 3 of this year, the Portuguese President signed the revised Nationality Law that doubles the standard naturalization timeline from five to ten years (seven for EU and CPLP nationals). The law is awaiting publication in the Diário da República.
Spain, Malta, Portugal, and Greece have all rewritten the rules of residency-linked real estate within twenty-four months, and the people who underwrote those deals against the rules of two years ago have been forced to redo the math.
The implication for everyone still working in this market is, I think, larger than it looks at first. Legislation has stopped being a background variable in investment property and has become the dominant pricing factor.
How to read a program before you read the property
Until recently, residency-linked property could be modeled with the same toolkit as any other real estate purchase: currency exposure, vacancy assumptions, interest rates, the local price cycle. Legislation was always there in the background, and any honest advisor was watching it, but it moved slowly enough to feel like part of the furniture.
After four major EU programs reset themselves in two years, that has stopped being true. Any firm doing serious work in this space now spends as much time analyzing how a program is likely to evolve over a five-year hold as it does analyzing the property itself.
Three things, in our experience, predict the stability of a program. The first is the legislative track record: How often have the rules moved in the past five years?
Greece raised its threshold in prime zones twice in eighteen months. Portugal pivoted off real estate in 2023 and then doubled the naturalization clock in 2026. Turkey moved its real estate threshold once, from $250,000 to $400,000, in June of 2022, and has not touched it since.
The second is whether the program has become a wedge in the country’s domestic politics. Spain and Portugal both saw their programs framed as housing-affordability problems in the run-up to their reforms, and once that frame caught hold, the political constituency for the program collapsed.
The same dynamic now runs through the Greek debates: where a residency program gets covered in the local press as a driver of housing prices, it should be assumed to be politically exposed.
The third is the distance to the next national or parliamentary election. Programs do not change in a vacuum; they change because someone runs against them. A country three or four years out from its next election is, for an investor with a five-year hold, easier to underwrite than one that is six months out.
Where stability still exists
Within the EU itself, the menu has narrowed considerably. Hungary relaunched its Guest Investor Program in July of 2024, and it now stands as the cleanest live option for an EU residence permit through investment: €250,000 into an approved real estate fund regulated by the Hungarian National Bank, a ten-year permit renewable for another ten, no minimum stay requirement, and a path to Hungarian citizenship after eight years.
The fund route is the only one available. A direct €500,000 property purchase option that had been included in the original draft was removed in January of 2025 before it was ever used. Hungary, in effect, did what Greece and Portugal did, but in advance: it built the program around a fund rather than around direct property from day one.
In Malta, a residence-only track at €375,000 in real estate (the Malta Permanent Residence Programme, or MPRP) remains. Like permanent residency programs elsewhere in the EU, it can in principle lead to citizenship, but only through the standard naturalization route, which requires around five years of actual physical residence in Malta and an A2-level Maltese language test.
Outside the EU but still in Europe, the most consistent answer right now is Turkey. The country’s citizenship-by-investment program has held its $400,000 real estate threshold since June of 2022, in spite of recurring market chatter about an increase to $500,000.
The program runs on a three-year holding period, the real estate route is by far the dominant path, and (unlike the Greek model) what the investor receives at the end is not a residence permit but a passport. In our pipeline, we have seen the share of clients evaluating Turkey rather than Greece grow markedly over the past eighteen months.
The pattern is clearest among clients who already hold a strong primary passport and who treat a second one as what flag-theory investors call a Plan B: a backup jurisdiction held in case the primary one becomes uncomfortable, rather than an upgrade.
Like the Turkish program, the Latin American routes do not deliver an EU passport. What they do deliver is something European programs have been moving away from: short, predictable timelines and stable thresholds.
Brazil has held the qualifying levels for its real estate residency route at BRL 1,000,000 (about $190,000) in most of the country and BRL 700,000 (about $133,000) in the North and Northeast. The thresholds have not moved.
More importantly, the Brazilian residential market does not depend on the program for demand: in Florianópolis, where I live, residential prices rose close to 10% year-on-year through mid-2025 according to the FipeZAP index, while the high-end segment recorded a 170% jump in sales value between 2024 and 2025. A foreign buyer here is buying into a market that would still be growing if the residency program disappeared tomorrow.
Costa Rica’s investor visa, held at $150,000 since 2021, is a smaller program, but the stability of its threshold makes the same point.
The bigger change: Real estate and the program have come apart
The single most important shift this decade in residency-by-investment is one I think most underwriting models still miss. For a long time, the decision to buy property and the decision to obtain a residence permit or passport were one decision.
The Greek model, in its old form, the Spanish program, Portugal until 2023: all of them sold a single transaction in which the property generated income, qualified the investor for residency, and would, eventually, support a passport application. That single transaction is mostly gone in Europe.
What this means in practice is that an investor who would once have asked “which European country sells the best property + visa bundle” now needs to ask two separate questions. Where do I want to own real estate as an asset? And, separately, which residency or citizenship program gives me the rights I actually want?
In Portugal, for example, real estate continues to perform on its own fundamentals and remains a serious investment; the path to a Portuguese passport, however, now runs through the fund route to the golden visa, with a longer naturalization clock at the end. In Turkey and Latin America, the bundle exists too, with a faster path to citizenship but without EU rights.
Outside any of this, smaller Caribbean and Pacific CBI programs (Dominica, Saint Kitts, Vanuatu, and others) let an investor add a jurisdiction to a flag-theory portfolio without acquiring property at all.
The investor who is hardest to advise this year is not the one who does not understand the math. It is the one who built a model in 2023 and has not opened it since. Pricing legislative risk explicitly, and treating the property and the program as two separable decisions rather than one bundled deal, is now the baseline for serious work in this space, not the optimization on top of it.
