The Indexed Fund, in terms
A conservative Portuguese private equity fund built around asset-backed securities, bonds, equities and commodities, with the explicit objective of low volatility rather than outperformance. A subscription of €500,000 qualifies for a Portuguese residence permit under the Golden Visa.
| Term | Detail |
|---|---|
| Fund type | Private equity |
| Fund size | €50 million |
| Minimum investment | €50,000 |
| Minimum to qualify for the Golden Visa | €500,000 |
| Investment period | 6 years |
| Fund term | 10 years |
| Set-up fee | 2% over committed capital |
| Management fee | 2% over committed capital |
| Regulator | CMVM, the Portuguese securities market commission |
The strategy is deliberately unexciting: allocate to companies backed by tangible financial instruments, diversify across debt, equity and commodities, and manage cash conservatively so that the position is intact when the residency milestones arrive. For a Golden Visa investor that is often the point. The capital has a job to do in year five, and the job is to still be there.
◇ Note the fee basis. Both the set-up fee and the management fee are charged over committed capital, not over net asset value, which is a different and generally more expensive arrangement than a NAV-based fee. It is worth modelling across the full ten-year term before comparing headline percentages with other funds.
How the €500,000 fund route works
The Golden Visa is a residence permit for investment activity under Article 90-A of Law 23/2007, not citizenship by investment, and since October 2023 not a property programme either.1 What a fund has to satisfy to qualify is specific: CMVM regulation, at least five years of maturity remaining at the moment of investment, a minimum of 60% invested in commercial companies headquartered in Portugal, and no exposure to real estate directly or indirectly.
Where this fund fits
The conservative end of the eligible universe. It is the choice of investors whose priority is capital preservation across a long residency clock rather than return.
The six-year investment period
Deployment happens inside six years, within a fund life of ten. Read that against your own timetable: it is longer than the five-year holding the permit requires, and shorter than the ten-year naturalisation clock.
What it is not
A liquid position. A closed-ended private equity vehicle is committed capital, whatever the underlying assets look like.
The residency timetable, corrected
Lei Orgânica n.º 1/2026 set naturalisation at ten years of legal residence, seven for EU and CPLP nationals, counted from the date the residence title is issued.2 The earlier version of this page said five years, as most fund material still does. It is no longer accurate.
Months 0–6
Tax number, bank account, compliance, then the subscription with proof the capital came from outside Portugal.
Months 6–18
AIMA review, biometrics in Portugal, issuance of the residence title, the point at which the clock starts.
Year 5
Permanent residency, untouched by the reform, and the end of the minimum holding period on the investment.
Year 10
Eligible to apply for naturalisation, with A2 Portuguese, the civics element and the declaration of democratic principles.
Presence did not change: seven days in the first year, fourteen in each subsequent two-year period.
Four things to check before subscribing
1. Fees over committed capital
2% set-up and 2% annual on committed rather than invested capital compounds differently. Over ten years it is the single largest variable in the net outcome.
2. Term against clock
Ten years of fund life against ten years of naturalisation clock is a close fit. If your plan stops at permanent residency in year five, you will be holding the position for another five.
3. "Low volatility" is a target
Asset-backed does not mean guaranteed. Ask what the drawdown looked like in the worst quarter the strategy has lived through.
4. The 60% test, in the portfolio
Ask for the actual allocation to Portuguese-headquartered companies, not the mandate that says it will get there.
The Indexed Golden Visa Fund: frequently asked questions
What is the minimum investment?
What does the fund invest in?
How long is my capital committed?
Does this still lead to citizenship in five years?
What are the fees?
Is it regulated?
Where this comes from
- Lei n.º 23/2007, Article 90-A, the residence permit for investment activity and its qualifying categories after the 2023 reform. dre.pt (English)
- Lei Orgânica n.º 1/2026, naturalisation at ten years, seven for EU and CPLP nationals, counted from issue of the residence title. diariodarepublica.pt
- CMVM, supervision of collective investment undertakings. cmvm.pt
General information, not investment advice. Fund terms are as supplied by the fund manager and may change; the binding version is the fund's own documentation.
Last reviewed 19 August 2026. Programme terms are set by the relevant government and can change; confirm any figure before acting on it.
