The Bitcoin Golden Visa Fund, in terms
A CMVM-regulated Portuguese fund with passive exposure to Bitcoin, structured so that a subscription of €500,000 qualifies for a Portuguese residence permit under the Golden Visa. The exposure is taken through BlackRock's spot Bitcoin ETF (IBIT) rather than by the fund holding coins directly.
| Term | Detail |
|---|---|
| Fund size | €100 million |
| Minimum investment | €100,000 |
| Minimum to qualify for the Golden Visa | €500,000 |
| Fund type | Digital assets, invested through BlackRock's ETF (IBIT) |
| Projected yield | Based on passive exposure to BTC |
| Fund term | 8 years |
| Management fee | 1.5% per annum |
| Performance fee | 10% |
| Regulator | CMVM, the Portuguese securities market commission |
Two things follow from the structure and both matter more than the headline. Because the vehicle is a Portuguese collective investment undertaking supervised by the CMVM, it sits inside the regime the Golden Visa recognises: an independent depositary holds the assets, the net asset value is struck and published on a defined cycle, and the fund is audited. And because the exposure is taken through a listed spot ETF rather than by self-custody, there is no private key in the structure, which is precisely the point of the wrapper for an investor whose objective is residency rather than operating a wallet.
◇ This page describes the fund and the residence route attached to it. It is not investment advice, and nothing here is an offer: subscription is made on the fund's own documentation, which is where the binding terms live.
How the €500,000 fund route actually works
The Golden Visa is a residence permit for investment activity, granted under Article 90-A of Law 23/2007. It has never been citizenship by investment, and since October 2023 it has not been a property programme either: the Mais Habitação reform removed real estate, and the routes that survived are collective investment funds, capitalisation of Portuguese companies, job creation, and cultural or scientific contributions.1
What qualifies here
A subscription of €500,000 or more in a qualifying Portuguese collective investment undertaking, regulated by the CMVM, with capital transferred into Portugal from outside and documented as such.
What the fund route buys
A residence permit for the investor and immediate family, renewable, with one of the lightest presence requirements in Europe. Permanent residency becomes available at year five.
What it does not buy
A passport in five years. That was true until 2026 and is the single most out-of-date claim in this sector, including on the earlier version of this page.
The real timetable, after the new Nationality Law
Lei Orgânica n.º 1/2026 doubled the residence requirement for naturalisation from five years to ten for most nationalities, seven for EU and CPLP nationals, and, the quieter change, it counts that period from the date the residence title is issued, not from the date you applied.2
Months 0–3 · Groundwork
Portuguese tax number, Portuguese bank account, source-of-funds compliance. Rarely faster than a quarter, whatever anyone promises.
Months 3–6 · The subscription
Capital transferred from outside Portugal into the fund, with documentary confirmation of the transfer. The subscription is what the application is built on.
Months 6–18 · AIMA and the card
Application, biometrics in Portugal, then issuance. Golden Visa files have historically been the slowest in the system and this stage carries the variance.
The clock starts here
Not at subscription, not at application: at issuance of the residence title. Every month of administrative delay is a month added to the end.
Year 5 · Permanent residency
Available on the Golden Visa as on any other permit, and untouched by the 2026 reform. For many investors this, not the passport, is the realistic destination.
Year 10 · Eligible to naturalise
Seven years for EU and CPLP nationals. Then the application itself, plus A2 Portuguese, the new civics element and a declaration of adherence to democratic principles.
The fund's own term is eight years and the naturalisation clock is now ten. Those two numbers do not have to match, and reading them as a conflict is the most common misunderstanding we field on this structure. What the residence permit requires is that the qualifying investment stays in place while the permit is renewed on it, a minimum of five years. Permanent residency at year five is what releases you from that; naturalisation is a separate, longer clock that runs on residence, not on the investment.
Bitcoin inside a regulated fund, against holding it yourself
The investment case for the two is the same asset. Everything else about them is different, and the differences are what decide whether this wrapper is right for a given investor.
| Through the fund | Held personally | |
|---|---|---|
| Custody | Independent depositary; exposure through a listed spot ETF | Your keys, your exchange, your operational risk |
| Golden Visa eligible | Yes, at €500,000 | No. Cryptocurrency held personally has never qualified |
| Costs | 1.5% management, 10% performance | Exchange spreads and withdrawal fees |
| Liquidity | Governed by the fund's terms and its eight-year horizon | Immediate, at any hour |
| Reporting | Fund reporting, audited accounts, published NAV | Your own records, transaction by transaction |
The tax point people get wrong
Portugal's well-known crypto exemption is written for personal holdings: dispose of a cryptoasset you have held for 365 days or more and the gain is excluded from Portuguese personal income tax; dispose of it sooner and the gain is a Category G capital gain at a flat 28%.3 That rule is about cryptoassets. Units in a collective investment undertaking are a different asset with their own treatment, and the exemption does not transfer to them by analogy. If the tax position is part of why you are considering this structure, model it with a Portuguese accountant against your own residence position before you subscribe, and note that the exemption only ever mattered to people who are actually tax resident in Portugal, which a Golden Visa holder spending seven days a year is not.
What you have to keep doing
Hold the investment
The qualifying subscription stays in place for as long as the permit is renewed on it, five years minimum, to the point of permanent residency or naturalisation.
Show up, barely
Seven days in the first year and fourteen days in each subsequent two-year period. It is the lightest presence requirement of any European residence programme, and it is enforced at renewal.
A2 Portuguese, eventually
Required for naturalisation, not for the permit. It is the lowest language bar attached to any comparable European citizenship, and the certificate is the item most often left too late.
Clean record, every renewal
Criminal record certificates from Portugal and from each country of residence, refreshed at each stage.
Five things to weigh before subscribing
1. Volatility is the product
Passive exposure to Bitcoin means the residency is stable and the capital is not. A drawdown does not affect a permit already granted, but it does affect what the €500,000 is worth when you exit.
2. The horizon is not five years any more
Anyone budgeting on a 2019-era five-year passport timeline is out by half a decade. Permanent residency at year five is the milestone that still holds.
3. AIMA delay is now expensive
Under the old counting rule, administrative delay was frustrating but neutral. Now it postpones the start of the clock, so time spent waiting for the card is time added at the far end.
4. Fund liquidity is not exchange liquidity
Bitcoin trades around the clock; your position in a closed-ended vehicle with an eight-year term does not. Read the redemption terms as carefully as the exposure.
5. The tax assumption
The 365-day exemption is for personal cryptoasset holdings and for people tax resident in Portugal. Neither is automatically true of a fund investor who visits for a week a year.
The Bitcoin Golden Visa Fund: frequently asked questions
Can you get a Portugal Golden Visa with Bitcoin?
What is the minimum investment?
Does the Golden Visa still lead to citizenship in five years?
How much time do I have to spend in Portugal?
Is the fund regulated?
Is real estate still an option for the Portugal Golden Visa?
What happens to my residence permit if Bitcoin falls?
Can my family be included?
Where this comes from
The timetable on this page changed in 2026, and a great deal of what is still published about the Golden Visa predates that. Everything time-sensitive here is sourced to the statute or the regulator.
- Lei n.º 23/2007, Article 90-A, the residence permit for investment activity, and the qualifying investment categories as amended by the 2023 Mais Habitação reform that removed real estate. dre.pt (English)
- Lei Orgânica n.º 1/2026, the 2026 Nationality Law: naturalisation at ten years, seven for EU and CPLP nationals, counted from issue of the residence title. diariodarepublica.pt
- Código do IRS, the treatment of cryptoassets: exemption on disposals after 365 days of holding, 28% on shorter holdings, and the separate categories for yield and business activity. portaldasfinancas.gov.pt
- CMVM, the Portuguese securities market commission: supervision of collective investment undertakings, depositary requirements and reporting. cmvm.pt
- AIMA, appointments, biometrics, permit issuance and renewals. aima.gov.pt
This guide is general information about a residence route and a fund structure, not investment, immigration or tax advice. Thresholds and timelines move, and the nationality rules changed materially in 2026. Confirm your own position with AIMA, the fund's documentation and a Portuguese accountant before acting.
Last reviewed 19 August 2026. Programme terms are set by the relevant government and can change; confirm any figure before acting on it.
