Hungary Golden Visa vs Portugal vs Greece: 2026 Comparison

September 9, 2026

Last reviewed: 6 September 2026

Hungary, Portugal and Greece all offer residence routes for non-EU investors, but they are built around different assets and long-term goals.

Hungary’s Guest Investor Program (GIP) starts with a EUR 250,000 investment in units of a qualifying Hungarian real-estate fund. Portugal’s Residence Permit for Investment Activity (ARI) no longer accepts real estate as a qualifying investment; the most widely discussed capital route is a EUR 500,000 investment in qualifying non-real-estate collective investment undertakings. Greece remains primarily property-led, with standard thresholds of EUR 400,000 or EUR 800,000 depending on location and a special EUR 250,000 route for defined conversion and listed-building cases.

The best fit therefore depends on the objective. Hungary is strongest for a lower capital threshold, a long permit and minimal presence pressure. Portugal offers diversified non-property routes and a framework for families prepared for its stay and long-term settlement rules. Greece is the clearest of the three for an investor who genuinely wants qualifying property.

None of these programmes guarantees approval, capital return, permanent residence or citizenship.

Best fit by objective

Investor objective	Likely strongest fit	Main reason
Lowest headline qualifying investment	Hungary	EUR 250,000 qualifying real-estate fund route
Long initial permit	Hungary	Permit may be issued for up to ten years
Direct property ownership as the qualifying asset	Greece	Property remains a central legal basis
Diversified non-property investment	Portugal	Qualifying funds, research, culture, job and company-capital routes
Minimal physical-presence pressure	Hungary or Greece	Hungary publishes no minimum-stay rule; Greece’s investor route is generally not maintained through a day-count requirement, subject to current case advice
Long-term settlement and citizenship planning	Case-specific	Each country applies separate residence, presence, language and naturalisation rules

The three countries in context

All three are EU and Schengen members. That supports short-stay Schengen mobility, but a national residence permit does not create an unrestricted right to settle or work in every EU country.

Country	Capital	Population, 2025	Area	Currency	Practical position
Hungary	Budapest	9.54 million	93,012 km²	HUF	Central European base with strong regional land and air connections
Portugal	Lisbon	10.75 million	92,226 km²	EUR	Atlantic-facing EU base with cultural and commercial links to Portuguese-speaking markets
Greece	Athens	10.41 million	131,694 km²	EUR	Southern European location with mainland, coastal and island property markets

Country size does not predict investment performance. The relevant questions are where the family will spend time, which currency it uses, where children will study, how the investor manages business interests and whether the asset remains suitable without the immigration benefit.

Full programme comparison

Issue	Hungary GIP	Portugal ARI	Greece Golden Visa
Main qualifying route	EUR 250,000 units in a qualifying Hungarian real-estate fund	EUR 500,000 qualifying non-real-estate collective investment route	Qualifying Greek real estate
Other routes	EUR 1 million qualifying public-interest donation	Ten jobs; EUR 500,000 research; EUR 250,000 culture; qualifying company capital and employment	Other investor categories exist, but this comparison focuses on property residence
Ordinary residential property	Not a current GIP basis	Not a current ARI basis	Yes, subject to location, size, value and use rules
Standard holding period	Fund units blocked for at least five years	Investment activity generally maintained for at least five years	Qualifying property or investment must be retained for renewal
Permit term	Up to ten years; one extension for up to another ten	Temporary ARI; current cards are generally issued within the statutory temporary-residence framework	Five-year renewable investor permit
Minimum presence	No rule on minimum length of stay for the GIP permit	Seven days in the first year and fourteen days in each subsequent two-year period	No routine minimum-stay condition for maintaining the property-investor permit; verify current practice
Work rights	Work permitted in Hungary	Residence and work permitted in Portugal	Investor permit does not provide access to dependent employment; obtain advice for any intended activity
Family	Family reunification under Hungarian rules	Family reunification available	Qualifying family members may receive linked permits
Main risk	Fund, manager, valuation, leverage and liquidity	Fund or project selection, fees, illiquidity and administrative timing	Title, planning, use, construction, value and resale risk
Citizenship	Separate route; no GIP shortcut	Separate naturalisation route under the May 2026 rules	Separate route requiring genuine residence and integration analysis

Government fees and professional costs change and vary by family. A reliable budget should include application and card charges, legal work, translations, apostilles, banking and custody, fund fees, property taxes, technical due diligence, insurance and renewal expenses. Obtain a dated fee schedule before committing capital.

Hungary: lower capital and long-duration residence

Hungary currently recognises two GIP investments.

The first is at least EUR 250,000 in units issued by a qualifying real-estate fund registered by the Hungarian National Bank. The units must be held in a blocked securities sub-account for at least five years. At least 40% of the fund’s net asset value must be invested in residential real estate in Hungary, and the manager must meet additional statutory conditions.

The second is a EUR 1 million donation to an eligible higher-education institution maintained by a public-interest trust for specified educational, scientific-research or artistic purposes. A donation is not recoverable capital.

Buying a Budapest apartment is not a current qualifying GIP investment. A personal property purchase may be possible as a separate transaction, but it does not replace the qualifying fund subscription or donation.

The permit may be issued for up to ten years and extended once for up to a further ten years. The immigration authority states that there is no rule requiring a minimum length of stay and that it does not apply a 90-in-180-day residence test when considering extension. The permit and related family-reunification status can provide work rights in Hungary.

Hungary’s published 21-day administrative period is not an end-to-end delivery promise. Time used to complete or prove the investment, cure deficiencies or perform additional procedural steps is excluded.

The lower threshold should not obscure investment risk. Before subscribing, review the exact fund’s GIP eligibility, manager, governance, fees, leverage, valuation, conflicts, currency exposure, redemption terms and likely exit after the mandatory block.

Portugal: non-property investment and a changed nationality horizon

Portugal’s ARI remains open, but the 2023 reform removed direct and indirect real-estate investment from the qualifying list.

Current routes include creating at least ten jobs; EUR 500,000 for qualifying research; EUR 250,000 for qualifying arts or cultural heritage; EUR 500,000 in qualifying non-real-estate collective investment undertakings; and a EUR 500,000 company-capital route combined with prescribed job creation or maintenance.

For the collective-investment route, the undertaking must be constituted under Portuguese law, have at least five years’ maturity when the investment is made and allocate at least 60% of its investments to commercial companies based in Portugal. Immigration eligibility is not a quality rating. Fund strategy, valuation, fees, governance, liquidity and exit rights require independent review.

AIMA states that ARI holders may reside and work in Portugal, travel within Schengen and apply for family reunification. It currently requires at least seven days in Portugal during the first year and fourteen days in each subsequent two-year period. Renewal also requires proof that the investment and other conditions remain satisfied.

Portugal’s nationality law changed on 19 May 2026. For naturalisation applications submitted after the reform entered into force, the official minimum legal-residence period is seven years for citizens of Portuguese-speaking countries or EU Member States and ten years for nationals of other states. Additional knowledge, subsistence, criminal-record and other conditions apply, and some provisions require procedural interpretation or supporting regulation. Pending nationality applications continue under the earlier wording according to the Ministry of Justice.

This means older marketing that presents Portugal as an automatic five-year passport route is not reliable for a new applicant.

Greece: property-led residence with location-based thresholds

Greece’s Golden Visa remains the clearest property route in this comparison, but the EUR 250,000 headline is not the general threshold.

The current framework uses:

EUR 800,000 in high-demand areas, including Attica, the Regional Unit of Thessaloniki, Mykonos, Santorini and islands above the statutory population threshold;
EUR 400,000 in other areas; and
EUR 250,000 for specified changes of use to residential property and qualifying listed-building restoration cases.

The EUR 800,000 and EUR 400,000 routes generally require one property, and a minimum 120 m² main-space condition applies to built property. The special EUR 250,000 cases have their own completion and use requirements. Residential property acquired under the programme is subject to restrictions that include short-term rental limitations.

The investor permit is renewable in five-year periods while the qualifying basis remains in place. Linked permits are available for qualifying family members. The route should not be sold as an employment permit or a shortcut to Greek citizenship. Naturalisation requires a separate analysis of actual residence, language, integration and the law in force.

Property due diligence must cover title, encumbrances, planning, land use, building legality, the correct threshold, conversion or restoration obligations, tax, maintenance, rental restrictions and resale liquidity. A seller’s “Golden Visa eligible” label is not legal confirmation.

Capital at risk: fund versus property

Hungary and Portugal both use regulated investment structures, but regulation does not protect an investor from loss. Hungary adds concentration in Hungarian residential real estate and a five-year securities block. Portugal’s eligible fund route has statutory Portuguese-company allocation and maturity conditions, but the underlying portfolio can vary widely.

Greece gives the investor direct ownership of an asset, along with direct responsibility for legal defects, maintenance, taxes, tenant or use constraints and market liquidity. The immigration value can also distort pricing in qualifying segments.

In all three countries, the investment should make sense after removing any assumed return from residence rights. Currency matters too: Portugal and Greece use the euro, while Hungarian assets may introduce HUF exposure even when the subscription threshold is stated in euros.

Family, mobility and tax residence

Family eligibility is not identical. Spouses or partners, children and in some cases dependent relatives may qualify, but age, dependency, custody, study and cohabitation rules differ. Map every family member before the principal investment, especially where a child may age out during processing.

Each permit supports residence in the issuing country and short Schengen visits under applicable rules. It does not permit the family to relocate freely to another member state or automatically work there.

Immigration residence is also separate from tax residence. Day counts, permanent homes, centre of vital interests, business management and tax-treaty rules can create obligations that the immigration card does not answer. Coordinate immigration, tax, succession and corporate advice before changing travel patterns or moving assets.

Four investor scenarios

Low-presence investor: Hungary usually has the clearest fit because it combines the lowest qualifying threshold with no published minimum-stay rule and a permit of up to ten years.

Property-led investor: Greece is the direct comparison. Select the location and property for defensible commercial and family reasons, then verify the precise threshold and legal category before signing.

Fund investor: Hungary requires lower capital but a specific qualifying real-estate-fund structure. Portugal requires more capital for its mainstream fund route and permits a broader non-real-estate portfolio. Compare assets, risk and exit—not only thresholds.

Family seeking long-term settlement: Choose the country where the family can genuinely meet future residence, language and integration requirements. A low-stay Golden Visa may preserve residence but do little to advance citizenship eligibility.

Decision checklist

Before selecting a programme:

Define whether the objective is mobility, relocation, work, education, investment, permanent residence or citizenship.
Confirm eligibility and the complete family structure.
Build a consistent source-of-wealth and source-of-funds file.
Verify the exact asset under current law before transferring money.
Model total cost, taxes, currency, liquidity and downside scenarios.
Confirm the application sequence, realistic timing and renewal evidence.
Obtain independent immigration, tax and investment advice in every relevant jurisdiction.

Conclusion

Hungary is the most compelling of the three for investors prioritising lower capital, a long permit and minimal stay. Portugal suits applicants seeking a non-property investment framework and a long-term Portuguese connection, provided they plan around the post-May-2026 nationality rules. Greece remains the strongest fit for direct qualifying property ownership.

Westbridge Consulting can coordinate an initial strategy and source-of-funds review for Hungary and work with appropriately qualified Portuguese, Greek, tax and investment advisers where needed. Request a confidential consultation.

This article is general information, not legal, tax, financial or investment advice. Rules, administrative practice, fees and eligible investments can change. Approval, renewal, permanent residence, citizenship, investment performance and return of capital are not guaranteed.