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Golden Visa Portugal vs Malta vs Cyprus 2026: Complete Guide

Bruna BarretoBy CEO — Bruna Barreto 29 Jul 2026

The European residency-by-investment landscape in 2026

The European market for residency and citizenship by investment programs changed radically in 2025 and 2026. Malta closed its citizenship-by-investment program in July 2025 following a landmark ruling by the EU Court of Justice. Spain abolished its Golden Visa in April 2025. Cyprus closed its direct citizenship-by-investment route as far back as 2020 and definitively removed any remaining ministerial discretion in December 2025. Portugal, meanwhile, maintained its Golden Visa program — reformed since 2023, without real estate, but active and functional.

For those comparing European options, the 2026 landscape is simpler than it appears: there is less choice, and the Portuguese Golden Visa has emerged as one of the few European residency-by-investment programs still available with the characteristics that international investors most seek.

Malta: the citizenship-by-investment program closed in 2025

For years, Malta was the only EU country to offer direct citizenship by investment — making its program especially attractive for those seeking a European passport in the shortest possible timeframe. In April 2025, the EU Court of Justice ruled, in Case C-181/23, that the Maltese program was incompatible with European law for treating citizenship as a commercial transaction without requiring a genuine connection to the country. In July 2025, Malta formalised the closure with the adoption of Act XXI of 2025.

What remains: Malta now has a Citizenship by Merit route, based on exceptional contributions to the country in areas such as science, innovation, arts, or entrepreneurship. It is not an investment program — it is a discretionary distinction for exceptional cases. Malta also maintains a Permanent Residency by Investment program (MPRP), with a minimum investment of €150,000, which grants residency but not direct citizenship.

Important: Maltese citizenships issued before the program closed were not revoked by the CJEU ruling — existing holders retain their rights. The closure applies only to new applications.

Cyprus: citizenship by investment closed since 2020 — with no return

Cyprus closed its citizenship-by-investment program in November 2020 following a corruption scandal that resulted in the irregular issuance of passports. In December 2025, the Cypriot parliament removed the ministerial discretionary power to grant citizenship by exception — definitively eliminating any possibility of an informal citizenship-by-investment route.

What exists in Cyprus in 2026: the Cypriot Golden Visa program, which grants permanent residency (not citizenship) with a minimum investment of €300,000. The process takes between 6 and 9 months. Permanent residency does not require effective stay in the country — a visit every two years is sufficient to maintain the status. Cypriot citizenship is available, but only after 8 years of effective residency, with language and civic requirements. Cyprus is not yet part of the Schengen area in 2026, although it is in the accession process.

Portugal: the program that remains — and what changed

The Portuguese Golden Visa has existed since 2012 and, unlike the programs of Malta and Spain, survived European pressure — by adapting. The 2023 reform eliminated real estate as an eligible route (which also reduced political pressure on the program) and concentrated investments in CMVM funds, cultural donations, and job creation.

In 2026, the Portuguese Golden Visa offers:

  • Residency permit with only 7 days of stay in the 1st year, 14 days in each subsequent 2-year period
  • Free movement across the Schengen area (27 countries)
  • Family inclusion — spouse, children, and parents
  • Path to Portuguese citizenship (7 years for CPLP, 10 years for other nationalities)
  • Minimum investment of €500,000 (CMVM funds)

Direct comparison: Portugal vs Cyprus in 2026

Malta is no longer directly comparable — the citizenship program has closed. The relevant comparison today is between Portugal and Cyprus, the two European residency-by-investment programs with the greatest demand in 2026.

  • Minimum investment: Portugal €500,000 (CMVM funds) or €200,000 (cultural donation in low-density areas); Cyprus €300,000 (real estate or funds)
  • Type of residency: Portugal — renewable residence permit; Cyprus — immediate permanent residency
  • Mandatory stay: Portugal — 7 days in the 1st year, 14 days in each subsequent 2-year period; Cyprus — visit every 2 years
  • Schengen: Portugal — yes; Cyprus — no (accession in progress)
  • Path to citizenship: Portugal — 7 or 10 years of residency; Cyprus — 8 years of effective residency
  • Family included: both allow spouse and children; Portugal is more flexible for parents
  • Real estate eligible: Portugal — no; Cyprus — yes

Portugal advantage: immediate access to the Schengen area is a very significant practical difference for those who value European mobility. Cyprus, not being a Schengen member, does not offer this benefit with permanent residency.

Spain: closed in April 2025

Spain abolished its Golden Visa on 3 April 2025, by decision of the Congress of Deputies. The program, which required a minimum real estate investment of €500,000, was closed due to pressure on the housing market, particularly in Barcelona and Madrid. Holders of visas issued before the closure retain their renewal rights. New applications are not accepted.

Greece: the alternative that gained relevance

With the closure of Malta's and Spain's programs, Greece gained relevance as a European alternative. The Greek Golden Visa maintains real estate as the main route, with differentiated investment thresholds by zone: €800,000 in Athens, Thessaloniki, Mykonos, Santorini, and islands with more than 3,100 inhabitants; €400,000 in other regions; and €250,000 for renovation properties or startups. 5-year renewable residency, with no stay obligation. Schengen: not fully (Greece is a Schengen member, but Golden Visa residents have limited Schengen access — 90 days in 180 in other Schengen countries). Citizenship after 7 years of effective residency.

Which is the best option in 2026?

There is no universal answer — the best option depends on each person's profile and objectives. For those who value immediate Schengen access, the Portuguese Golden Visa is the clearest available option. For those who prefer real estate investment with a lower threshold and immediate permanent residency, Cyprus may be an alternative — but without Schengen. For those who want real estate in Europe with conditional Schengen access, Greece remains an option. In none of these cases does a European program exist in 2026 that offers direct citizenship by investment.

Frequently Asked Questions

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