The €500,000 fund route, and what to ask a fund
Since real estate left the programme, this is the route most investors use. Three conditions decide whether a fund qualifies at all, and two documents decide whether your application survives.
A transfer of at least €500,000 into units of non real estate collective investment undertakings constituted under Portuguese law, with at least five years to maturity at the moment you invest, and at least 60% of investment value placed in commercial companies headquartered in Portugal. There is no low density discount on this route.
- €500,000Minimum subscription, with no reduction anywhere in the country
- 5 yearsMinimum maturity of the fund, measured when you invest
- 60%Of investment value in companies headquartered in Portugal
- ZeroReal estate exposure, direct or indirect
Not because it is cheaper, because it is the one left standing
Law 56/2023 removed property and real estate linked funds. What remains is capital that has to do something productive, and the fund route is the only one that does not ask you to run a business or hire staff.
No payroll, no headcount at renewal.
The ten job route has no capital minimum, which sounds attractive until you notice that AIMA verifies the headcount itself at every renewal. A fund subscription is a single act with a documentary trail, not an operating obligation for five years.
Regulatory Decree 84/2007, Article 65-ESame money, fewer moving parts.
The company route is also €500,000, but it comes bundled with five permanent jobs, or ten jobs of which five are permanent, held for at least three years. The fund route asks for capital and patience instead.
Law 23/2007, Article 3(1)(d)(viii)It is not coming back.
Property acquisition and real estate linked funds were removed in 2023, and the rule now reaches indirect exposure too. A fund that holds real estate through a subsidiary does not qualify, whatever the marketing says.
Law 56/2023The two documents your application stands on
For this route the regulation names exactly what you file. Both come from third parties, which means both are outside your control and worth confirming in writing before you subscribe.
- Ownership certificate
- A certificate proving you hold the units, free of any encumbrance or charge, issued by whichever entity is responsible for keeping the register of unit holders under the law, the management regulation or the contract
- Management company declaration
- A declaration from the fund’s management company attesting the viability of the capitalisation plan, a maturity of at least five years, and application of at least 60% of the investment in commercial companies headquartered in Portugal
- Bank attestation
- A declaration from a credit institution authorised or registered in Portugal with the Banco de Portugal, attesting the effective transfer of at least €500,000
- At renewal
- A fresh ownership certificate, again free of encumbrances, plus a declaration from the management company that the conditions of the investment are maintained
Seven questions to ask before you subscribe
Any fund manager who cannot answer these in writing is asking you to take an immigration risk on their paperwork.
- 1. Is the fund constituted under Portuguese law?
- A Luxembourg or Maltese vehicle does not qualify, however good the strategy
- 2. What is the remaining maturity on the day I subscribe?
- It has to be at least five years at that moment. A fund three years into a seven year term no longer works for a new subscriber
- 3. How do you evidence the 60% test?
- Ask what happens if the portfolio drifts below it, and who tells AIMA
- 4. Is there any real estate exposure, including indirect?
- Get it in writing. Indirect exposure through a holding company is still exposure
- 5. Will you issue the declaration, at subscription and at every renewal?
- The management company’s declaration is not optional, and you will need it repeatedly over five years
- 6. Who keeps the register of unit holders, and can they certify units free of encumbrances?
- If your units are pledged or used as collateral, the certificate fails
- 7. Is the manager supervised by the CMVM?
- Portuguese fund managers are supervised by the CMVM. Ask for the registration, not a claim
The fund term and your five year clock are not the same clock
Your holding period runs five years from the grant of the residence permit, and the permit is granted months after you subscribe. A fund whose term ends exactly five years after subscription can therefore mature before your immigration obligation ends. Match the term to the permit date, not to the wire date, and ask the manager what happens if you need to stay invested longer.
Common questions
The ones we answer on almost every call, and the ones the market most often gets wrong.
Is €500,000 the total cost of the fund route?
No. It is the subscription. On top sit the government fees, which are substantial, plus fund subscription and management fees, legal fees and your own due diligence. The government fees alone run to several thousand euros per person at grant.
Can I split €500,000 across two funds?
The requirement is a transfer of at least €500,000 into qualifying units, and each fund you use has to satisfy the maturity, allocation and non real estate conditions separately. Splitting doubles the documentary burden, including the declarations you need at every renewal.
Does a venture capital fund qualify?
A Portuguese venture fund can qualify, provided it is a non real estate collective investment undertaking constituted under Portuguese law, has five years or more to maturity when you invest, and places at least 60% of investment value in companies headquartered in Portugal.
What if the fund loses money?
The immigration requirement is that you hold the qualifying investment, not that it performs. A fall in net asset value does not by itself break the residency, but a redemption or a transfer of the units does. This is a real investment with real risk, and it should be underwritten as one.
Do I get the 20% low density discount on a fund?
No. The reduction reaches job creation, research and the cultural route only. The fund route is €500,000 everywhere in Portugal.
Talk to us
Ventures.eu is a CMVM regulated venture capital fund manager, so on this route we are one of the answers rather than a neutral guide. We will tell you plainly where we do and do not fit.
Book a call with Fernando
Fifteen or thirty minutes, by Microsoft Teams. Fernando Ferreira, General Partner at Ventures.eu.
