Greece has displaced Portugal at the top of the global residency-by-investment rankings, ending a nine-year streak and reflecting a market that has pivoted sharply away from residential real estate towards fund subscriptions, donations, and job creation.
The European Core: Greece, Portugal, and Hungary
Greece’s golden visa claimed first place in Henley & Partners’ 2025 Global Residence Program Index, scoring 73 out of 100 across 26 evaluated programmes. The programme was overhauled in September 2024 with zone-based pricing: €800,000 for properties in Athens, Thessaloniki, Mykonos, Santorini, and islands with populations exceeding 3,100; €400,000 elsewhere. Short-term rentals via platforms such as Airbnb are now prohibited for golden visa properties, with violations triggering a €50,000 fine and permit revocation.
The Greek Ministry of Migration and Asylum reported that 9,289 applications were submitted in 2024, representing at least €2.32 billion in real estate investment. Greece’s ascent reflects not only its reformed structure but also the deterioration of competing programmes elsewhere in the European Union.
Portugal’s golden visa remains operational but politically contested. Real estate routes closed in October 2023 under the More Housing reform. Investors now choose between €500,000 in qualifying investment funds—the dominant route—€250,000 for cultural or artistic projects, €500,000 for scientific research, or business creation with at least ten jobs. Physical presence requirements remain modest at seven days per year, with permanent residency available at five years and citizenship accessible from March 2026. Yet processing times have reached 39.6 months, and more than 20,000 applicants remain in the queue.
Hungary’s Guest Investor Residence Permit, launched in July 2024, quickly became one of Europe’s most subscribed new options. Two routes are available: €250,000 in a government-accredited real estate fund, or a €1 million donation to a higher education institution. The programme grants a ten-year permit, renewable for a further decade, requires zero physical presence, and confers immediate Schengen travel rights.
Bulgaria and Spain: Diverging Trajectories
Bulgaria offers immediate permanent residency from a single fund investment of €512,000. The programme mandates investment in Alternative Investment Funds or Exchange-Traded Funds licensed by Bulgaria’s Financial Supervision Commission, held for at least five years. The absence of staged residency and the directness of the permanent-residence outcome distinguish Bulgaria’s offer from tiered programmes elsewhere.
Spain’s golden visa entered limbo in April 2024 when Prime Minister Pedro Sánchez announced its termination without specifying a closure date. Applications submitted before any formal end date are generally expected to be honoured, but prospective applicants face material uncertainty.
The UAE and the Gulf Model
The UAE’s Golden Visa is a long-term residence permit enabling foreign nationals to live, work, or study in the Emirates. Industry reporting in April 2026 confirmed that the AED 2 million property investment threshold—approximately €490,000—remains in force. The programme imposes no taxation on personal income, no requirement for Emirati sponsorship after issuance, and renewal terms linked to maintained investment or professional status.
The Gulf model differs structurally from European programmes: residence is functional rather than a staging post to citizenship, and the expectation of eventual naturalisation does not exist. For wealth holders seeking tax-neutral domicile without Western bureaucratic friction, the trade-off is explicit.
Caribbean Citizenship by Investment
The Caribbean programmes grant citizenship rather than staged residency, making ‘golden passport’ the more precise label. According to Passportivity’s 2026 survey, the lowest-cost options are Dominica at USD 200,000, St Kitts and Nevis at USD 250,000, Antigua and Barbuda at USD 230,000, Grenada at USD 235,000, and St Lucia at USD 240,000.
These programmes deliver second passports in months rather than years, though visa-free travel access remains narrower than that available to European or Gulf residence-permit holders. Dominica and St Kitts passports grant access to approximately 140–150 jurisdictions without prior visa arrangements, compared with the 190-plus accessible under Schengen residence combined with a strong first passport.
The United States: EB-5 in Context
The United States operates the EB-5 immigrant investor programme, which requires either a USD 900,000 investment in a targeted employment area or USD 1.8 million in a standard commercial enterprise, with a minimum job-creation requirement of ten full-time positions. A separate route permits investment of USD 100,000 or more into an existing or new business.
Unlike European or Gulf programmes, EB-5 is a pathway to permanent residence (green card) and, eventually, citizenship, but processing times routinely exceed five years, and per-country caps create decade-long backlogs for applicants from China and India. US nationals themselves accounted for 23 per cent of applications processed by Henley & Partners in the most recent reporting year, reflecting both the compliance burden of US tax residency and the desire for optionality.
Market Dynamics and Regulatory Pressure
The golden visa market is consolidating. Over 100 jurisdictions maintain some form of investor residency legislation, but regulatory pressure—particularly within the European Union—has led governments to tighten requirements, limit real estate routes, and prioritise economic contributions that generate employment or fund public goods.
Foreign investment has been blamed for rising residential property prices in Lisbon, Athens, and Barcelona. Political appetite for open-ended real-estate-driven immigration has waned accordingly. Portugal’s real estate closure, Greece’s tiered pricing, and Spain’s prospective termination all reflect this shift.
The Henley Residence Program Index evaluates programmes on reputation, quality of life, visa-free travel, processing efficiency, compliance, and investment attractiveness. Greece’s top ranking signals that regulatory clarity, streamlined processing, and liveable urban centres now matter as much as headline investment thresholds.
Investment Structures and Due Diligence
Common investment routes include real estate purchase, subscription to approved funds, acquisition of government bonds, business creation or expansion, and donations to cultural or scientific projects. Requirements ordinarily include a clean criminal record, passage of due diligence checks conducted by the host jurisdiction or accredited intermediaries, and maintenance of the qualifying investment for a minimum holding period, typically five years.
The shift from real estate to funds reflects both policy intent—governments prefer mobile capital to housing stock withdrawal—and investor preference for liquidity and geographic diversification. Fund-based routes also reduce the operational burden of property management and the exposure to localised real estate cycles.
Sources
- Henley & Partners – Golden Visa guide
- Henley & Partners – 2025 Investment Migration Report
- IMI Daily – Every Golden Visa Still Open in Europe in 2026
- GTP Headlines – Greece Holds World’s Most Attractive Golden Visa Program in 2025
- Harvey Law – Greek Golden Visa New Regulations 2026
- UAE Official Government Platform – Golden Visa
- Adeniyi Associates – UAE Golden Visa Guide 2026
- Passportivity – Cheapest Golden Visa Countries 2026
- World Population Review – Golden Visa Countries 2026
