What Is a Golden Visa? How It Works, Country Comparison and Caveats Explained by an Administrative Scrivener [2026]

A golden visa is the common name for schemes that grant a country's residence permit to foreign nationals who make an investment of at least a set amount (in real estate, investment funds, government bonds, donations, etc.). It is not a legal term; each country uses its own name, such as "investor residence permit" or "residence permit for investment activity". What you obtain is a residence permit, not permanent residence or citizenship as such. Many schemes have light stay requirements, so you can secure "a country you can move to at any time" while continuing to live where you are now; this is the biggest difference from ordinary immigration visas. This article explains how golden visas work, how they differ from citizenship by investment and investor permanent residence, compares the minimum investment of the main schemes open as of September 2026, looks at schemes that have closed and at the EU's stance, and sets out the points Japanese nationals and other investors should watch regarding nationality law, tax and investment risk.

*Amounts and rules are as of September 14, 2026. This article is an English version of our Japanese guide, adapted for foreign residents of Japan and international investors.

*This article is a general explanation based on information published as of September 14, 2026 by national governments, EU institutions and local media. Each country's rules, amounts and fees change frequently. Please check with a professional before applying regarding your individual eligibility and tax position.

What is a golden visa: a scheme that grants a "residence permit" in return for investment

"Golden visa" is the common name for investor residence permit schemes, also called "Residence by Investment" in English. The schemes share three features.

• Investment is the condition: you put at least a set amount into something the country designates, such as buying real estate, subscribing to an investment fund, buying government bonds, investing in a business, or donating to the government or a university
• What you get is a residence permit: a temporary residence permit (roughly 1–10 years, renewable) or a permanent residence permit. Citizenship is not included
• Light stay requirements: many schemes let you keep the permit with only a few days, or zero days, of stay per year, so you can keep the right without actually moving

Despite the word "visa", it is not an entry visa but a status for staying after entry (a residence permit). The official names are "residence permit for investment activity (ARI)" in Portugal, "investor permanent residence permit" in Greece and "investor visa" in Italy; the word "golden" appears nowhere in the law.

The schemes trace back to Caribbean citizenship-by-investment programs in the 1980s and the US EB-5 (investor green card) launched in 1990, but the name "golden visa" spread after the euro crisis, when Portugal, Spain and Greece introduced residence permits in exchange for real estate investment one after another in 2012–2013. Since then it has become the generic term among investors for "schemes that let you buy the right to live in the EU through investment".

How it works: what you invest in and what you get

The eligible investments differ by country but fall into five broad types. It is important to separate investments where you may get your money back from those where you will not.

The rights you obtain come in stages. First you receive a temporary residence permit (2 years in Portugal, 5 years in Greece, etc.), which can be renewed as long as you maintain the investment. After a certain number of years of lawful residence you become eligible to apply for permanent residence, and if you meet further years-of-residence and language requirements, you can apply for citizenship (naturalization). However, many countries require that you actually lived in the country to apply for permanent residence or citizenship, so simply holding a golden visa with light stay requirements normally does not satisfy those requirements. Portugal is the exception: its scheme is designed so that 7–14 days of stay per year lead to eligibility for permanent residence and citizenship.

Golden visas vs. citizenship by investment, investor permanent residence and long-stay visas

Besides golden visas, there are three other types of "rights abroad obtained through investment". Because the names are similar they are easily confused, but the rights you get and their treatment under Japanese law are completely different.

For Japanese nationals, the decisive difference is with citizenship by investment (CBI). Article 11(1) of Japan's Nationality Act provides that a Japanese national who acquires a foreign nationality by their own choice loses Japanese nationality, so Japanese nationality is lost automatically the moment you acquire a foreign nationality through investment. A golden visa is only a residence permit, so this problem does not arise. If you see a claim that "you can get citizenship with a golden visa", you need to work out whether it refers to applying for naturalization after a period of residence, or to citizenship by investment. Status of residence in Japan after losing Japanese nationality is explained in Status of residence after losing Japanese nationality.

Country comparison: minimum investment for the main golden visas open in 2026

The main schemes that Japanese nationals can apply for as of September 2026 are listed below, ordered not by minimum investment but by how commonly they are used by applicants from Japan. "Typical path to permanent residence / citizenship" refers to each country's general residence requirements; these are not obtained automatically just by holding a golden visa.

Bulgaria (fund, €512,000) also has a scheme, but there have been few applications from Japan. Latvia's real estate route (from €250,000) was abolished by the new immigration law in force from September 15, 2026, and is due to be replaced by a €150,000 investment in a state fund, but the fund that is to receive the investments has not yet been set up.

Among applicants from Japan, interest is highest in Portugal, Greece and the UAE, and we cover each of them in separate articles. Their purposes differ: Portugal is the only scheme in the table where "the path continues to citizenship with almost no stay requirement", Greece is the scheme "held through a physical asset, real estate", and the UAE is the scheme "with no income tax or inheritance tax and fast procedures". For details, see Portugal golden visa: requirements and costs, Greece golden visa: requirements and costs (for other visas and permanent residence requirements, see Greek visa types and permanent residence requirements), and Dubai golden visa: requirements and costs.

Closed and scaled-back schemes and the EU's stance: golden visas are on the way out

Golden visas have shrunk rapidly over the past five years. Major countries have closed their schemes one after another, citing money laundering and security concerns and criticism over soaring housing prices.

At the EU level, the European Parliament adopted a resolution in March 2022 calling for citizenship by investment to be abolished entirely and for legislation regulating residence by investment, and in the same month the European Commission recommended that member states end citizenship-by-investment schemes immediately and tighten oversight of residence permit schemes. The April 2025 ruling of the Court of Justice of the EU confirmed that granting citizenship in exchange for investment violates EU law, and schemes to "buy citizenship" within the EU have effectively disappeared. Residence-type golden visas remain, but countries are narrowing the entrance by raising investment amounts (Greece raised it to €800,000 for major cities in 2024), abolishing real estate routes (Portugal, Latvia) and lengthening the time to citizenship (Portugal, from 5 to 10 years).

Caribbean citizenship by investment is not unaffected either. In 2024 the five main countries raised the minimum donation to US$200,000, and on January 1, 2026 the United States partly restricted visa issuance to nationals of Antigua and Barbuda and Dominica. You need to factor in the stability of the scheme itself, on the assumption that "there is no guarantee that a scheme available today will still exist on the same terms in a few years".

Four criteria for choosing a golden visa

Which country's scheme suits you depends less on the size of the investment than on "what you want it for". If you sort out the following four points first, the candidates narrow down naturally.

Choosing on the basis of "the cheapest country" often leads to mistakes. For example, Greece's €250,000 route is limited to converting commercial property to residential use or restoring historic buildings, and requires you to secure a property and manage the works. Of the roughly €470,000 total for Malta's permanent residence permit (purchase route), about €100,000 is non-refundable contributions and fees, so it is closer to "the cost of buying permanent residence" than an investment. Compare not just the headline investment figure but the amounts you get back and those you do not.

Caveats: nationality law, tax, investment risk and rule changes

There are four things to check before applying for a golden visa.

(1) For Japanese nationals: nationality law: citizenship by investment means losing Japanese nationality

As noted above, a Japanese national who acquires foreign citizenship through investment loses Japanese nationality (Nationality Act, Article 11(1)). A golden visa itself is a residence permit and has no effect, but the same problem arises if you later naturalize in that country. If your goal is "an EU passport", you will be deciding on the premise of giving up Japanese nationality.

(2) Tax: getting a golden visa does not automatically change your tax residence

Obtaining a residence permit does not by itself change your status as a tax resident of Japan. Japanese taxation is determined by "where the center of your life is", not by the number of days of stay alone. Conversely, if you stay in the investment country for a long time, you may become a tax resident there and be taxed on your worldwide income. People holding securities of JPY 100 million or more are also subject to the exit tax (taxation on departure from Japan) when they become non-residents of Japan. Any tax savings from a golden visa arise only when you actually move your place of residence, not merely from holding the right. For details, see Leaving Japan: tax and resident registration procedures and The exit tax and the JPY 600 million and JPY 3 billion thresholds.

(3) Investment risk: illiquid real estate, rental restrictions, fund losses

On real estate routes, you cannot sell as long as you want to keep the residence permit, so you cannot let go even if prices fall. In Greece, short-term rentals (such as holiday rentals) of golden visa properties have been banned since 2024; violations can lead to a €50,000 fine and revocation of the residence permit. On fund routes, you cannot redeem during the lock-up period of five years or more, and the principal may lose value. When choosing an investment, check not only "will it get me a residence permit" but also "is it a sound investment" with a separate professional.

(4) Rule changes: no guarantee that the conditions at the time of application will be maintained

Spain abolished its scheme in 2025, and in 2026 Portugal doubled the number of years to citizenship. In many countries, people who have already applied remain under the old conditions, but there are cases, such as Portugal's Nationality Act amendment, where the way residence years are counted changed and affected people awaiting a decision. Rather than rushing in before a scheme closes, the sound way to use one is to hold it for a purpose that will not be undermined if the scheme closes.

Costs beyond the investment: government fees, lawyers and document certification

The cost of a golden visa is not just the investment. Government fees in each country, fees for local lawyers and agents, the cost of preparing documents in Japan and renewal costs are added, and some items are charged per family member.

Concrete cost examples by family size are worked out in Portugal golden visa: requirements and costs. For documents from Japan, the standard for EU golden visas is to attach an apostille from Japan's Ministry of Foreign Affairs to documents such as family register certificates and criminal record certificates, together with a translation into the designated language. Our office handles obtaining apostilles, translations and certifications on your behalf (in Japanese) and obtaining family register certificates from abroad (in Japanese).

FAQ

Can I get citizenship (a passport) with a golden visa?

What a golden visa gives you directly is a residence permit. Citizenship is obtained only by applying for naturalization after meeting requirements such as a set number of years of residence and language ability. Portugal (10 years) is about the only country where light stay requirements still lead to eligibility for naturalization; other countries assume you actually live there. Note that a Japanese national who acquires foreign citizenship through naturalization loses Japanese nationality.

Can I keep a golden visa while continuing to live in Japan?

Greece, Malta and the UAE have no stay requirement, and Portugal can be maintained with 7 days of stay in the first year and 14 days every two years thereafter. Italy also has no stay requirement for renewal. However, in most countries, applying for permanent residence or citizenship requires actual residence.

Which is the cheapest golden visa?

Among EU schemes as of September 2026, the minimum is €250,000: Greece (conversion of commercial property to residential, restoration of historic buildings, startup investment), Italy (innovative startup), Hungary (real estate fund) and Portugal (cultural and artistic support). However, Portugal's cultural support is a non-refundable donation, and Greece's €250,000 route is limited to certain property types, so the "cheaper" the scheme, the stricter the conditions.

Can my family obtain it with me?

The main applicant's spouse and minor children can apply at the same time under almost every scheme. Some countries also allow adult children (students or dependants) and parents (Portugal, Greece, Malta, etc.). Government fees and documents are needed for each person; the additional cost for family members does not exceed the investment, but it does increase by several hundred thousand yen or more.

For Japanese nationals: Japan does not allow dual nationality. Is a golden visa a problem?

No. A golden visa is a residence permit, not citizenship, so it does not affect Japanese nationality. Japanese nationality is affected if you acquire foreign citizenship through citizenship by investment (CBI), or if you naturalize after holding a golden visa. Each country's approach and Japan's Nationality Act are explained in Countries that allow dual citizenship and Japan's Nationality Act.

Summary: a golden visa is a residence permit obtained through investment; think about citizenship separately

"Golden visa" is the common name for schemes that grant a residence permit in exchange for a set investment; it is not permanent residence or citizenship as such. As of September 2026, the realistic options for applicants from Japan include Portugal (fund, €500,000), Greece (real estate, €400,000–€800,000), Italy (from €250,000), Malta (permanent residence permit), Hungary (fund, €250,000), Cyprus (€300,000) and the UAE (real estate, AED 2,000,000), while the real estate routes in Spain and Latvia have already closed. When choosing, compare not by "investment amount" but on four points: purpose, stay requirement, path to citizenship and recoverability of the investment, and keep in mind the difference from citizenship by investment (whether Japanese nationals lose their nationality) and the fact that your tax residence does not change automatically.

Related articles

Minimum costs by country are listed in Costs of permanent residence and citizenship by country. If you want to start from the differences between permanent residence, citizenship, visas and tax residence, read Permanent residence, citizenship, visas and tax residence: the differences; for the United States, the leading example of investor permanent residence, see How much a US green card costs; and for deposit-based long-stay visas, see Malaysia MM2H: requirements and costs. A comparison of how easy it is to obtain permanent residence, including routes other than investment, is in Countries where Japanese nationals can most easily obtain permanent residence.

References (primary sources)

• Royal Partners Administrative Scrivener Office: Portugal golden visa requirements and costs (investment routes, AIMA fees, 2026 Nationality Act amendment)
• IMI Daily, March 13, 2026: European golden visas available in 2026 (open and closed)
• Global Citizen Solutions, September 7, 2026: New Greek golden visa rules (Law 5275/2026, short-term rental ban)
• Arletti & Partners: Italian investor visa requirements for 2026
• Golden Visa Map: Malta permanent residence (MPRP) requirements for 2026 (Legal Notice 146/2025)
• Golden Harbors: CJEU ruling (C-181/23, April 29, 2025) and the abolition of Malta's citizenship by investment (July 24, 2025)
• National Law Review, July 24, 2024: Hungary guest investor residence permit requirements (real estate route ended at the end of 2024)
• WhereNext: Cyprus permanent residence (€300,000 investment) requirements for 2026
• Global Investments: UAE golden visa (AED 2 million real estate) requirements for 2026
• KPMG, January 9, 2025: Abolition of Spain's investor visa (Organic Law 1/2025, in force April 3, 2025)
• Immigration Lex & Finance, September 3, 2026: Abolition of the real estate route under Latvia's new immigration law (in force September 15, 2026)
• European Parliament: Legislative developments on citizenship and residence by investment schemes (March 2022 resolution, European Commission recommendation)
• Global Citizen Solutions, August 6, 2026: Comparison of the five Caribbean citizenship-by-investment programs (donation amounts, US visa restrictions)
• Organisation of Eastern Caribbean States (OECS): Memorandum of agreement on citizenship by investment (US$200,000 minimum, 2024)
• US Congressional Research Service (CRS): Expansion of travel restrictions effective January 1, 2026
• e-Gov Law Search: Nationality Act (Article 11(1))

The rules and amounts in this article are as of September 14, 2026.