One programme asks you to invest first. The other approves you first. Most of what separates them follows from that.
When families narrow a European shortlist to two, it is very often these two. Portugal and Italy share a great deal: a warm climate, a relaxed pace, extraordinary food and residence programmes that do not require you to move. Yet the two work in almost opposite ways, and the difference begins with a single question. Do you commit your capital before or after you know the answer?
This comparison sets the two side by side on the points that genuinely decide it: the order of events, what you invest, the time you spend in each country and the long road to citizenship. We work with both, so this is not a case for either. If Greece and Malta are also on your list, our comparison of all four open programmes covers them too.
| Portugal asks you to invest, then decides. Italy decides, then asks you to invest. Almost every practical difference between the two flows from that order. |
The order of events
In Portugal, you subscribe €500,000 to a qualifying fund first, then file your application with AIMA, the immigration agency, and wait for the decision. The capital is committed before you know the outcome.
Italy reverses that. You apply online for a Nulla Osta, a pre-approval certificate, while your money stays in your own account, and the government committee decides within 30 days of a complete application (Investor Visa for Italy). Only after approval, the visa and your arrival in Italy does the investment fall due, within three months. For many families, knowing the answer before any capital moves is the single most persuasive feature of the Italian programme.
What you invest
Portugal has one main route: €500,000 into an investment fund regulated by the CMVM, Portugal’s securities regulator. Our guide to CMVM regulated funds explains what that oversight means. Property stopped qualifying in October 2023 under Law 56/2023. The fund holds a portfolio of Portuguese businesses, and your subscription is capital you own and later redeem, on the fund’s terms and subject to investment risk.
Italy offers four routes that cannot be combined: €250,000 into an innovative start-up, €500,000 into an established Italian company, €1,000,000 as a philanthropic donation, or €2,000,000 in government bonds. The entry point is lower, but the four are very different things to own, and one of them is a gift you will not see again.
How much time you spend there
Portugal asks for seven days a year on average: seven in the first year, then fourteen across each following two years. Italy asks for none at all to keep the permit.
That sounds like a clear win for Italy, and for keeping the permit it is. But the two rules do different jobs. Portugal’s days keep the permit valid and also count towards citizenship. Italy’s absence of a rule keeps the permit valid but builds nothing towards a passport, because Italian citizenship depends on years genuinely lived in the country.
How long each takes
This is Portugal’s weak point. AIMA has been working through a substantial backlog, and reported timelines from application to first residence card run from around a year to well beyond two, varying considerably between regional offices. Our read on AIMA processing times explains what sits behind the figures.
Italy’s pre-approval, by contrast, arrives within 30 days, with the consular visa following. For a family that needs certainty on dates, the gap between the two is significant.
The road to citizenship
Both countries now ask for ten years, but they count them differently. Since 19 May 2026, under Lei Orgânica n.º 1/2026, Portuguese Golden Visa holders become eligible to apply for citizenship after ten years of legal residence, or seven for nationals of the EU and the CPLP, the community of Portuguese speaking countries, counted from the issuance of the first residence permit. Crucially, those years build while you continue to live elsewhere. Our guide to the citizenship law covers it in detail.
Italy also requires ten years of legal residence, with Italian at B1, one level above Portugal’s A2. The difference is that Italian residence for this purpose means years genuinely lived there. A family that holds its Italian permit from abroad keeps the option open but does not build towards a passport.
In neither country is citizenship automatic. Eligibility to apply means exactly that, and every application is assessed on its own merits under the rules in force at the time.
Side by side
| Portugal Golden Visa | Italy Investor Visa | |
| Order of events | Invest, then apply | Pre-approval within 30 days, then invest |
| What you invest | €500,000 into a CMVM regulated fund | €250,000 to €2,000,000, four routes |
| Time in the country | 7 days a year on average | None |
| Permit | Two year cards, renewed | Two years, then a three year renewal |
| First decision | Around a year to beyond two | Within 30 days |
| Citizenship | After 10 years, while living abroad (7 for EU and CPLP) | After 10 years genuinely lived in Italy |
| Language | Portuguese A2 | Italian B1 |
Which one fits
Neither is better in the abstract. Portugal suits a family that wants its European years to build towards citizenship without moving, and can accept a longer wait at the start. Italy suits a family that wants a decision before any capital moves and values the lower entry point, and is comfortable that a passport would mean actually living there.
Both countries have changed their rules recently and may change them again, so check the date on anything you read before relying on it. Our map of which programmes have closed shows how quickly this area moves.
Where to start
If both countries are still on your list, that is entirely normal. It usually means the deciding facts have not yet been set against your own family’s plans. Our Portugal overview and our Italy guide cover each process in full, and you are welcome to get in touch whenever you would like to talk it through.
Elite Golden Visa provides immigration consultancy services. We do not provide financial or legal advice. All legal services are delivered by independent, qualified immigration lawyers. All investment decisions should be made with independent financial advice.
This content is for informational purposes only and does not constitute financial advice or an offer to invest. Any investment carries risk, including the potential loss of capital. Past performance is not indicative of future results.
