Fresh figures from the Portuguese Association of Investment Funds, Pensions and Assets (APFIPP) reveal that while redemptions from Golden Visa-eligible funds have accelerated markedly in 2026, new capital is still arriving at almost triple the rate at which it is leaving.

Between January and May 2026, investors pulled €94.7 million ($108 million) out of Golden Visa-eligible funds.

That total has already surpassed double the €45.3 million ($52 million) withdrawn across the whole of 2025.

Monthly outflows rose to roughly €20 million in January and held at broadly that level in the following months.

Even so, the same five-month window brought in €283 million of new subscriptions, according to APFIPP – meaning fresh investment has outpaced withdrawals by nearly three to one.

The rise in redemptions coincides closely with amendments to Portugal's Nationality Law, which took effect on 19 May 2026.

Under the revised rules, the residency period required for naturalisation extends from five to ten years for most non-EU nationals, and to seven years for citizens of the EU and Portuguese-speaking countries.

Across 2025, foreign investors poured a record €732 million ($834 million) into Golden Visa-eligible funds, many presumably wagering that whatever changes lay ahead would honour the timelines and expectations of those who had already committed their money.

Credits: Supplied Image; Author: Portugal Pathways; Despite changes to Portugal's Nationality Law, subscriptions to Golden Visa-eligible funds outrank withdrawals 3-to-1

When the amended law arrived without any transitional protections for existing investors, some of that capital began making for the door.

This backdrop also raises the possibility that a portion of this year's redemptions come from investors who entered later in the cycle specifically to beat the rule change, and who are now closing out those positions – rather than pointing to any broader erosion of confidence among longer-standing Golden Visa investors.

Paul Stannard, chairman and founder of Portugal Pathways, said the surge in redemptions is best read as a natural, short-term adjustment rather than evidence of a structural problem with the fund route itself.

"What we're seeing isn't investors abandoning Portugal, it's the market digesting a change nobody had priced in," he said.

"A meaningful slice of this year's outflows will belong to people who invested in the last 12 to 18 months purely to beat the deadline. Once that cohort has moved on, we'd expect the picture to look considerably calmer."

Stannard was nonetheless candid that the lack of any transitional safeguard for existing investors in the revised Nationality Law represented a missed opportunity.

He explained: "Investors who had already committed capital in good faith, often years before this change was even on the table, deserved some form of continuity.

"That capital has done real work in Portugal, backing companies, sustaining jobs and contributing to the wider economy, and that contribution shouldn't be an afterthought when the rules shift."

Credits: Supplied Image; Author: Portugal Pathways; Portugal's Golden Visa continues to attract international investors

At the same time, Stannard warned against reading too much into the headline redemption numbers without setting them against the subscription figures.

"Three euros coming in for every one going out is not the profile of a programme in decline," he said.

"If anything, it tells us that well-informed investors still see enduring value in Portugal, even with a longer path to citizenship."

For now, the data points to a market in transition rather than retreat: redemptions that are elevated but likely temporary, new investment holding firm, and a client base growing more selective rather than more sceptical.

To find out how you can invest in Portugal’s Golden Visa programme, arrange a free discovery call with Portugal Pathways.