Live session: Golden Visa 2026: Portugal vs Italy. Where should your capital go?

• Wednesday 30 September, 18:00 CEST / 17:00 BST / 12:00 EDT
• Dario Montagnese and Michael Maxwell, who have built and raised capital for investment platforms in both countries
• Which profile fits which program, the question this article leaves open
• Where each program is weaker, and what that means in practice

Register here.

For most of the past decade the comparison between Portugal and Italy had a short answer. Portugal offered citizenship after five years, Italy after ten, and for anyone whose goal was a second passport that settled it.

That answer stopped being true in May. Portugal’s revised Nationality Law, Organic Law 1/2026, came into force on 19 May 2026. It moved naturalization from five years to ten for most non-EU nationals. For nationals of EU states and Portuguese-speaking countries, the figure is seven. The gap that decided so many conversations has largely closed, and the two programs now have to be compared on everything else.

What follows is a comparison of the two programs as they now stand.

At a glance

What changed in May, and what did not

Portugal amended its Nationality Law after a long parliamentary process. It was signed on 3 May 2026 and took effect on 19 May. Naturalization now requires ten years of legal residence for most applicants and seven for EU and CPLP nationals. The longer period came with new requirements: Portuguese at A2 level, a civic and history test, and a signed declaration of adherence to democratic principles.

Two points matter for anyone already in the system. Administrative nationality procedures pending on 19 May 2026 continue under the previous wording. And permanent residence in Portugal is unchanged at five years, so the amendment affects the citizenship horizon rather than the residency one.

The route to this law was contested, and one part of it is still open. An earlier version went to the President in November 2025. Fifty members of parliament referred it to the Constitutional Court, which struck down several provisions and sent the text back. The revised version passed on 1 April 2026 by 152 votes to 64 and was promulgated on 3 May. A technical correction was issued the same day it was published, fixing the wording on criminal records.

The residency periods themselves are settled. The transitional arrangements are not. A petition before parliament says the saving provision is too narrow. It protects only formally pending procedures, which leaves out people who had good reason to rely on the old law. Among them are holders of an approved expression of interest who are still waiting for a residence title, and applicants held up by the state’s own delays. The argument rests on the constitutional protection of legitimate expectations. Anyone in the Portuguese pipeline should treat their position as open on this point rather than settled.

A separate measure, creating loss of nationality as an accessory criminal penalty, remains in parliamentary and constitutional process. It amends the Penal Code rather than the residency periods and does not affect the timelines described here.

Italy’s position did not move. Permanent residence remains available after five years of legal residence and citizenship by naturalization after ten, with Italian at A2 for the former and B1 for the latter.

For a non-EU, non-CPLP applicant the two citizenship timelines are now identical. For anyone holding EU or Portuguese-speaking nationality, Portugal is still three years faster.

The qualifying routes

Italy sets four thresholds under the Investor Visa for Italy. €250,000 into a certified innovative start-up registered in the special section of the Companies Register. €500,000 into an established Italian company. €1,000,000 as a philanthropic donation. €2,000,000 in Italian government bonds. One route per application, no splitting across categories, and no borrowed funds.

Portugal operates four non-real-estate routes. €500,000 into a qualifying investment fund. €250,000 as a cultural or heritage contribution, reduced to €200,000 for qualifying projects in low-density areas. €500,000 into research activity. Or the creation of ten or more jobs.

Set side by side, the cheapest way into each country looks similar and behaves very differently. Portugal’s lowest entry is a donation, and a donation does not come back. Italy’s is equity in an early-stage company, which can return capital or lose it. One is a certain cost. The other is an uncertain outcome.

Around the routes themselves, Portugal has the deeper market. Its fund route has had years to build up CMVM-regulated vehicles, administrators and depositaries, and an investor can examine the track record. Italy’s routes are newer in practice and the choice of vehicle is narrower. For many investors that will matter more than the threshold figures.

When the capital moves

Here the two programs differ structurally, and the difference is easy to miss.

Italy approves the application before any money is committed. The file goes to the Investor Visa committee’s Secretariat, which issues the Nulla Osta. That is a certificate confirming there is no obstacle. The visa follows at the consulate, then the residence permit after entry, and the qualifying investment is completed within three months of arriving in Italy. A refused application costs the documentation work rather than the investment.

Portugal requires the investment first. The expression of interest, pre-approval and submission all rest on an investment already made. The capital is committed while the immigration outcome is still open.

Italy’s sequencing removes one kind of risk. Portugal’s forces an investor to be sure of the investment on its own merits, before any immigration decision validates it. There is an argument that this is the better discipline.

Processing, and how to read the numbers

Italian processing is currently predictable. The committee has up to thirty days to review a complete file and current issuance runs at roughly 25 to 35 days, with no backlog reported. End to end, approval typically takes three to six months. Where a file runs long, it is usually because the Secretariat has asked for more documents. That pauses the clock for up to thirty days while the applicant replies.

Portuguese figures disagree with each other.

AIMA reported average end-to-end times of 39.6 months in 2025, with tens of thousands of files still waiting. The backlog goes back to the winding up of SEF, which left AIMA with several hundred thousand pending cases. More recent reporting is considerably better. Firms handling files submitted in mid-2025 report biometric appointments and card issuance inside about nine months. That is a practitioner account rather than a published average. AIMA’s performance through 2026 has improved. The Portuguese government has committed to clearing the backlog.

A single Portuguese processing figure will mislead, whichever one is chosen. The historic average is poor, the recent trend is much better, and the spread between them is wider than anything in Italy. For applicants already in the system when the law was gazetted, the citizenship clock is counted so that official delay does not cost them time. For anyone applying now, the counting rule is less clear. Some sources date it from the first physical residence card rather than from submission. Confirm this with Portuguese counsel rather than assume it.

Residence obligations

Neither program asks for much physical presence. Both have the same catch.

Portugal requires an average of around seven days a year. Italy requires nothing at all. Investor permits also carry an extra feature. For their first five years from issue they are exempt from the continuous residence rule that binds most Italian permits, so the permit can be held while living elsewhere. Renewals must still be filed in person on Italian soil.

Permanent residence and citizenship are measured on actual residence rather than on holding a permit. A family that satisfies the minimum stay and lives principally elsewhere keeps the permit and the travel rights, and does not advance toward naturalization in either country.

Tax

The two countries have moved in opposite directions, and neither regime is a reason to choose a residency program on its own.

Italy’s substitute charge under Article 24-bis is now €300,000 a year on foreign income for anyone moving tax residence from 1 January 2026. Each qualifying family member adds €50,000. It is a flat amount rather than a rate, so its value depends entirely on the size of the foreign income it covers. Italy also runs a separate 7 percent regime for pensioners settling in qualifying southern municipalities.

Portugal replaced the Non-Habitual Resident regime with IFICI, the Tax Incentive for Scientific Research and Innovation, often called NHR 2.0. It applies a flat 20 percent rate to qualifying Portuguese employment and self-employment income against standard rates reaching 48 percent, with exemptions on much foreign-source income, for ten years. Eligibility is narrower than under NHR, and tied to qualifying work in research, innovation and named sectors. Pension income is no longer covered. Holders of the original NHR keep it for the balance of their ten years.

No single number compares them. Italy’s is a fixed annual charge, which suits large foreign income. Portugal’s is a reduced rate tied to qualifying work done in Portugal. Which one wins depends on how a person’s income is made up, and on treaty positions that differ by country of origin.

Where each program is weaker

Italy has the higher language bar for citizenship at B1 against Portugal’s A2. Its flat tax is expensive, and it has risen twice in two years. From €100,000 to €200,000 in 2024, then to €300,000 in 2026. The increases do not apply to those already in the regime, but the pattern is a fact to weigh. Its network of advisers and vehicles is thinner than Portugal’s. The program is suspended for Russian and Belarusian nationals, including dual nationals. Its application volumes are also far below Portugal’s, so there is less accumulated experience to draw on.

Portugal carries the processing history described above, and while the trend has improved, the variance remains wider. The citizenship extension is a material change for anyone who entered on the previous expectation and had not yet filed. Its cheapest route returns no capital. And the tax regime that drew many applicants in the first place has been narrowed considerably, with retirees and passive-income holders largely outside it.

Common questions

Which country gives citizenship faster in 2026?

Neither, for most applicants. Since 19 May 2026 both require ten years of legal residence. Portugal requires seven years for nationals of EU states and Portuguese-speaking countries, which is the one remaining timing advantage either program holds.

Can either program be held without living in the country?

Both permits can. Portugal asks for around seven days a year and Italy asks for nothing. Neither permit advances a holder toward citizenship without actual residence, because naturalization is measured on residence rather than on holding a permit.

Does either still allow property investment?

No. Portugal removed real estate in October 2023 and Italy never included it.

Which has the lower entry cost?

Portugal, at €200,000 to €250,000 for a cultural or heritage contribution, against €250,000 for Italy’s innovative start-up route. The Portuguese figure is a donation and does not return. The Italian figure is an investment that can return capital or lose it.

How long does approval take?

Italy currently runs about three to six months end to end, with the Nulla Osta issued in roughly 25 to 35 days. Portuguese timing varies widely, with a 2025 average of 39.6 months and recent files reported at around nine months.

What this comparison does not settle

Join us for our Portugal vs Italy Webinar.

All of the above describes the programs. None of it describes fit.

Fit turns on things this article cannot know. Nationality matters most, since an EU or CPLP passport changes the citizenship sums entirely. After that comes whether the capital has to be recoverable, and where the income is earned. Then the goal itself: a passport, a European base, or simply the option to move later. Two families of identical means can look at the same facts and reach opposite conclusions.

That is the conversation Dario Montagnese and Michael Maxwell will work through on 30 September at 6:00 PM CEST, 5:00 PM BST, 12:00 PM EDT, in Golden Visa 2026: Portugal vs Italy. Where should your capital go? Register here.

Between them they have built and raised capital for investment platforms in both countries. The session is built around matching circumstances to programs, not around restating what each one requires.

Immigration and tax rules change, and both programs described here were amended during 2026. Current requirements should be confirmed with qualified counsel in the relevant jurisdiction before any application is made. Nothing here constitutes legal, immigration, tax or investment advice.