Greece is one of only two EU countries in our comparison where buying a home still leads to an investor residence permit. Spain closed its programme in April 2025, Portugal dropped property in 2023, and Hungary has published a draft bill to close its scheme from 2027.
This analysis compares six EU programmes from their laws and official programme documents, as they stand on 11 November 2026: Greece, Portugal, Spain, Malta, Italy and Hungary. It covers the routes, the minimum amounts and what each permit gives.
The numbers
| Country | Status (November 2026) | Property purchase qualifies? | Lowest investment route (€) | Permit |
|---|---|---|---|---|
| Greece | Open (in force) | Yes | 250,000 (conversion to residential or listed building) | 5 years, renewable |
| Malta | Open (in force) | Yes, or rent | 375,000 purchase or 14,000 a year rent, plus fees and a capital requirement | Permanent residence |
| Portugal | Open, no property routes since 7 October 2023 | No | 250,000 (arts or cultural heritage) | Not covered here |
| Italy | Open (in force) | No | 250,000 (innovative start-up) | Investor visa, 2 years |
| Hungary | Open; draft bill to close from 1 January 2027 | No (real-estate fund units only) | 250,000 (real-estate fund units) | Up to 10 years; no extensions under the draft |
| Spain | Closed since 3 April 2025 | No | None | Existing permits valid and renewable under the old rules |
Sources: national laws and programme documents listed below. “Lowest investment route” is the smallest qualifying amount in each country’s rules; the routes are not equivalent.
Greece
Under Article 100 of the Migration Code (Law 5038/2023), the minimum is €800,000 in Attica, the regional units of Thessaloniki, Mykonos and Thira (Santorini), and islands with more than 3,100 residents. It is €400,000 elsewhere. A €250,000 route covers conversions of buildings to residential use and the restoration of listed buildings.
In the €800,000 and €400,000 tiers the investment must be one property with at least 120 m² of main space. Short-term letting is banned; a breach means losing the permit and a €50,000 fine. The permit lasts five years and is renewed for five years each time while the property is kept. Article 100 says time spent outside Greece does not prevent renewal. The permit fee is €2,000, under Article 171.
At the end of September 2026 there were 27,602 active initial investor permits and 8,255 renewed ones, and 6,962 main-investor applications were pending, according to the Ministry of Migration and Asylum.
Portugal
Portugal’s Law 56/2023 revoked three of the investment routes with effect from 7 October 2023, and the law now bars direct or indirect investment in real estate. Existing permits can still be renewed.
The routes still open, under the consolidated text of Law 23/2007, include €500,000 in non-real-estate investment fund units, €500,000 for research, €250,000 for artistic production or cultural heritage, a €500,000 company investment with jobs, and the creation of 10 jobs.
Separately, Organic Law 1/2026, in force since 19 May 2026, set the legal residence needed for naturalisation at 7 years for EU and Portuguese-speaking country nationals and 10 years for everyone else.
Spain
Spain ended its investor visa and investor residence permit with effect from 3 April 2025, under Organic Law 1/2025. Applications filed before then are decided under the old rules. Existing permits stay valid and can be renewed under the rules that applied when they were granted.
Malta
Malta’s Permanent Residence Programme requires buying a property of at least €375,000 or renting one for at least €14,000 a year, kept for five years, according to the Residency Malta brochure. Applicants must also hold capital of €500,000, including €150,000 in financial assets, or €650,000, including €75,000 in financial assets. On top come a €60,000 administration fee and a €37,000 government contribution, set by Legal Notice 146 of 2025, €7,500 for each adult dependant other than the spouse and a €2,000 donation to a local NGO. The status granted is permanent residence.
Malta’s citizenship-by-investment route is a separate matter. The EU Court of Justice ruled on 29 April 2025, in case C-181/23, that it breached EU law, and Malta removed it with Act XXI of 2025.
Italy
Italy’s Investor Visa has four routes: €2 million in government bonds, €500,000 in an Italian company, €250,000 in an innovative start-up or a €1 million philanthropic donation. There is no property route. The official portal describes the visa as lasting two years.
Hungary and Ireland
Hungary’s guest investor scheme, under Act XC of 2023, accepts €250,000 in units of a registered real-estate fund held for five years, or a €1 million donation to a university; buying property directly does not qualify. Its Ministry of Interior published a draft bill on 4 November 2026 that would stop new guest investor visa applications from 1 January 2027 and end permit extensions. It is in consultation until 12 November and is not law. We covered the draft here.
Ireland closed its Immigrant Investor Programme to new applications on 15 February 2023, the Irish government announced.
What it means for buyers
Golden Visa buyers: Among the six programmes compared, Greece and Malta are the only ones where a home purchase still qualifies. The Greek permit has no minimum stay in its law and can be renewed while the property is kept. Greece’s threshold is €800,000 in Attica, Thessaloniki, Mykonos, Santorini and islands with more than 3,100 residents.
Buyers who are tax resident outside the EU and EEA: A Greek bill tabled on 3 November 2026 would raise transfer tax on homes they buy to 15%, for final contracts from 1 July 2027. It is in committee and is not law, as the Hellenic Parliament’s bill page shows; we covered it here.
Buyers should confirm how this applies to them with a Greek lawyer or accountant.
How we got these numbers
We used the legal texts and official programme documents linked in each section, as available on 11 November 2026. We could not verify the permit duration and minimum stay of Portugal’s current routes from the official consolidated text, so the table leaves them out. Cyprus is not included because we could not open its official programme pages. Amounts are the legal minimums; fees, taxes and family costs differ by country.
Sources
- Greece: Migration Code, Law 5038/2023, Article 100
- Greece: Migration Code, Law 5038/2023, Article 171
- Greece: Ministry of Migration and Asylum, legal migration report, September 2026, Annex B (PDF)
- Greece: Hellenic Parliament, tax bill tabled 3 November 2026
- Portugal: Law 56/2023 (PDF)
- Portugal: Law 23/2007, consolidated text
- Portugal: Organic Law 1/2026 (PDF)
- Spain: Organic Law 1/2025, Official State Gazette
- Malta: Legal Notice 146 of 2025 (PDF)
- Malta: Residency Malta, MPRP brochure (PDF)
- EU Court of Justice: judgment in case C-181/23, 29 April 2025
- Malta: Act XXI of 2025 (PDF)
- Italy: Investor Visa for Italy, official portal
- Hungary: Act XC of 2023
- Hungary: public consultation on the draft bill, 4–12 November 2026
- Ireland: closure of the Immigrant Investor Programme





