It wasn’t supposed to be this hard.
At least that’s what Mary Beth Cutshall thought when she began considering and evaluating country residency programs. Around 2019/2020—the COVID days—and living in the Atlanta area, she began to look into pursuing what has come to be known as a “Golden Visa”—a legal residence permit granted to foreign nationals who make a substantial financial investment in a host country.
She was looking for flexibility; the chance to be a citizen not only of the United States but somewhere, too, abroad—a secondary life. And she wanted to land in a Schengen country, which allows eligible travelers to move freely between the 29 nations that compose the area.
It sounded like a golden plan. Just one question: What country?
Cutshall had heard about Portugal and its at-the-time real estate migration product, which made it a rather attractive option: buy a qualifying property and gain residency. If there is one thing Cutshall knows, it’s real estate. She has made a career of it, actively involved in hotel and multi-family real estate transactions totaling nearly $1.5 billion.
“Portugal had a really good reputation,” Cutshall said. She performed her due diligence: How much money would it take? How long? She examined it through the prism of someone who cut her teeth in real estate investment. “What I saw was a lot of momentum building in Portugal and a huge opportunity for investments there,” she said. “I saw property values rising and the trajectory of what it could be. That kind of got my interest in something bigger than just my own Golden Visa.”
She took her first trip to Portugal around 2021 and “fell in love with it,” she said, the people, the culture, the beauty. She also liked the fact that it was fairly easy to get to from the east coast of the U.S. There was one worry: She had heard whispers of the residency program changing and not for the better of the applicant.
Asked whether she would have gone through with the process if she had known what lay ahead when she applied for the program in December, her answer was curt and quick: “No.”
That Was Then, This Is Now
The Portugal Golden Visa program quickly became one of the most straightforward and attractive residency-by-investment (RBI) programs in Europe when it launched in 2012. It was created during the aftermath of the Eurozone debt crisis to attract foreign capital and stimulate economic growth.
Applicants could qualify through several investment routes, but the vast majority chose real estate. The flagship option was easy and uncomplicated: a €500,000 purchase of real estate anywhere in Portugal, with no requirement to live in the property or rent it out. Another option allowed investors to qualify with a €350,000 investment in properties more than 30 years old or located in urban regeneration areas, provided renovations were undertaken. This became particularly popular in Lisbon, the capital, and Porto, with its UNESCO-listed historic center.
Beyond the real estate investments, one of the program’s other inducements was the minimal requirement for physical presence. Investors needed to spend only seven days in the first year and 14 days in each subsequent 2-year period.
The program allowed investors to include a spouse, dependent children, and dependent parents, and to apply for permanent residence after five years and for Portuguese citizenship after five years, subject to language and other legal requirements.
Nothing went swimmingly for Cutshall. After applying for the program in 2021, she was told that within 90 days she’d get an appointment with the government and then, shortly after, would receive her residency visa card with the five-year path toward permanent residency countdown beginning.
“I didn’t get my appointment until two years later,” she said. Cutshall didn’t get her residency card until June of last year.
Along the way, the program became more onerous and more expensive. By 2022, Portugal began limiting residential real-estate purchases in high-demand areas such as Lisbon and Porto, steering investment toward lower-density regions. Then, in 2023, Portugal eliminated the real-estate route entirely for new applicants. Now, applicants are required to invest €500,000 in an investment fund, a regulated financial vehicle that pools foreign capital to qualify for Portuguese residency.
Now, applicants are required to invest €500,000 in an investment fund, a regulated financial vehicle that pools foreign capital to qualify for Portuguese residency.
Portugal has effectively transformed from a “property-based residency program” into a “fund-investment residency program.”
The goal posts continued to move. The monetary commitment was palatable because it offered a rather quick and easy path to citizenship down the line. The rules have become less favorable. Recent nationality law reforms have extended the citizenship timeline for many applicants from five to 10 years.
For applicants like Cutshall, there was no grandfather clause; it didn’t matter where you were in the process; the same rules applied. “That was part of my frustration with the journey,” she said, recounting how she was just days away from the cutoff of the new law taking place. “The thing I worry about now is they keep changing it. The agreement I thought we had doesn’t hold. That has done some damage to investor trust.”
Cutshall thinks the program remains fluid due in part to a housing shortage and affordability problem for Portuguese people. She calls it a legitimate and real issue that needs to be addressed. “The program is one of many things that have driven up the price of real estate,” Cutshall said. She wishes the program redirected funds toward building more affordable housing. “They could have used all this foreign investment to fix the problem.”
Legal Scrutiny of Portugal’s Golden Visa program
Raquel Galinha Roque is a Portugal-based lawyer who has counseled Cutshall throughout her journey. She says that the primary hurdle today boils down to a single factor: time.
Investors, she said, face two major, intertwined timeline challenges. One is the severe administrative backlogs. The transition to a new immigration agency has resulted in profound administrative delays. “A new Golden Visa investor must now expect to wait at least 18 months just to receive their initial residence card,” she said.
Secondly, there is what Roque calls the abrupt nationality law amendment, or Portugal’s revised Nationality Law, which went into effect on May 19, 2026, and significantly extended and altered the criteria for naturalization. “Crucially,” she said, “this 10-year clock only starts ticking from the date the residence card is issued, not the application date. Furthermore, the government implemented this change with absolutely no transition period, creating an immediate shift in the timeline for all current and future applicants.”
Portugal’s citizenship timeline will certainly impact the program’s appeal, noted Adriano Vieira, a migration attorney with AIM Global. “The changes are not positive from a perception standpoint,” he said, arguing that the way they were introduced, without safeguarding the expectations of those who had already committed to the program, created some reputational damage.
Still, the ability to obtain citizenship without strict physical residency is a decisive advantage, he said.
Roque’s legal advice for anyone now navigating this byzantine process is to adopt a structured, long-term strategy and focus on interim milestones rather than just the final passport. “I continually remind clients of the program’s most powerful legal advantage: the minimum stay requirement remains low. Clients can maintain their Golden Visa, and eventually secure their permanent residency and passport, without any obligation to actually reside in Portugal or become Portuguese tax residents,” she said.
Ultimately, and despite its capriciousness, Roque believes the program remains appealing. “I do not foresee a drop in demand; rather, it is purely a matter of aligning client expectations,” she said. “The program has not been weakened; it has simply transitioned from a fast-track passport scheme into a highly secure, long-term premium residency asset.”
Meanwhile, Cutshall waits. What she thought was a five-year journey has now become three times that. “I feel kind of like there was a bait and switch,” she said.
And while the journey has been clunky to put it lightly, Cutshall’s love for Portugal has never wavered, which was the impetus for setting out on the residency path in the first place. “I am still in love with the country and the people,” she said. “I am not in love with the process and the experience.”
