Golden passport: what a golden visa actually leads to, and how long it really takes

There is no such thing as a golden passport. No statute in any of the four jurisdictions this site covers uses the phrase, none of them sells citizenship, and the one that came closest was stopped by the Court of Justice of the European Union in April 2025.

What these states do sell is a residence permit and, with it, a clock. The clock is the part worth reading carefully, because there are three of them and almost every comparison table published on the subject merges at least two. They run for different lengths, they count different things, and only one of them ends in a passport.

Is there such a thing as a golden passport?

As a legal status, no. As a market term, it means one of two very different things, and conflating them is where most of the confusion starts.

The first is citizenship by investment: money in, passport out, with no requirement to live anywhere. In Europe that product existed in Malta and nowhere else in this group, and on 29 April 2025 the Court of Justice of the European Union held in Case C-181/23, *Commission v Malta*, that the scheme was contrary to EU law. It ended there. Anyone still marketing it in 2026 is selling something a court has held unlawful.

The second is residence by investment, which is what all four of these jurisdictions actually operate. It gets you a permit. The permit gets you a place in a queue for a status that, years later and on conditions the permit itself does not impose, might become citizenship. That gap — between the permit's own rules and the naturalisation rules — is the whole subject of this page.

Greece citizenship by investment: the route that does not exist

The phrase returns thousands of searches a month and describes nothing. Greek law has no citizenship-by-investment provision. What it has is the investor residence permit under article 100 of Law 5038/2023, and ordinary naturalisation under the Citizenship Code, Law 3284/2004 as amended — two separate instruments with no bridge between them beyond time.

There is no accelerated naturalisation for investors, no reduced period, and no price. An investor stands in the same queue as anyone else who has lived in Greece long enough, and the permit's own terms make standing in that queue harder rather than easier, for a reason set out below.

Greece golden visa citizenship: seven years, and what the seven years count

Seven years of lawful residence is the naturalisation period, and it is the least interesting number on this page. The interesting part is what the seven years have to be made of.

The application costs €550. Before it, an applicant must hold the certificate of knowledge adequacy for naturalisation, the ΠΕΓΠ, which the Ministry of Interior administers under Law 4735/2020 amending article 7 of the Citizenship Code. The examination costs €150 and tests Greek at roughly B1 together with history, geography and culture, at a pass mark of 70%. The fee has to be paid at least two days before the application is submitted, and the applicant's name and date of birth have to match the tax authority's records — a mismatch has to be corrected first.

Now the part that decides whether any of it is reachable. Article 100 §4 of Law 5038/2023 provides that periods of absence from the country are no obstacle to renewing the investor permit. Read on its own, that is a convenience. Read against the naturalisation requirement, it is a trap: the permit renews indefinitely while you live elsewhere, and the residence it certifies is not residence you spent. The clock a holder believes is running is not running at all.

The commercial pages ranking for this query mostly do state a presence requirement, and the number they state is 183 days a year. That figure is the tax-residency threshold, not a naturalisation condition, and it appears nowhere in the Citizenship Code. What the Code requires is seven years of lawful residence; precisely what counts as residence for that purpose is not something we have established from the statute, and we are not going to invent a number for it. What can be said with confidence is the direction: a permit held from abroad builds nothing.

Malta: the only one that ever sold a passport

Malta is the exception that proves the shape of the market, and its history is worked through in full in our Malta guide. The sequence is short and each step has a number.

29 April 2025 — the Court of Justice, Grand Chamber, in Case C-181/23, Commission v Malta, held that by operating the investor citizenship scheme Malta failed to fulfil its obligations under article 20 TFEU and article 4(3) TEU. The judgment's own words for what was wrong: a scheme under which nationality is "essentially granted in exchange for predetermined payments or investments" is the "commercialisation of the granting of the status of national of a Member State".

24 July 2025 — Act XXI of 2025 substituted article 10(9) of the Citizenship Act, Cap. 188, with a power to naturalise "by merit", for exceptional services or an exceptional contribution to Malta or to humanity, and deleted the definition of "individual investor programme" from article 2. No amount appears in the Act.

29 July 2025 — Legal Notice 159 of 2025 amended rather than repealed the subsidiary legislation, S.L. 188.06, which is now titled the *Granting of Citizenship by Naturalisation on the Basis of Merit Regulations*. It deleted Part IV, headed "Special provisions applicable to naturalisation for exceptional services by direct investment", together with the Second and Third Schedules. The words "direct investment" no longer appear in it, and neither does any euro figure — only "applicable non-refundable administrative fees", unquantified.

So no price is published in the law. But this is where the honest version of the sentence has to be longer than the market's, because the Maltese state has not finished tidying up: the agency's own services page still carries, live, the direct-investment route with its figures spelled out — €600,000 and €750,000 of "exceptional direct investment", €700,000 of property or €16,000 of annual rent, a €10,000 donation — under update stamps as recent as February 2026 and with no notice of closure, beside a separate agency document for the merit route that publishes no figure at all and says the decision is discretionary, case by case, and final.

Those figures have had no legal basis since Part IV was deleted. They are still on the government's website. A page that tells you Malta charges €600,000 for a passport is quoting the state accurately and the law not at all — and if you are being sold that route today, the instrument behind it does not exist.

Ordinary naturalisation is what remains, and it is not the "about five years" that comparison tables print — this site's own included, until we read the statute. Articles 10(1) and 11 of Cap. 188 require an applicant to have

> "resided in Malta throughout the twelve (12) months immediately preceding the date of application"

and

> "resided in Malta for an aggregate period of a minimum of four (4) years, during the six (6) years preceding the above period"

plus adequate knowledge of Maltese or English. Five years is the floor. The shape is twelve continuous months, then four years inside the six before them, which can be spread across as much as seven.

And the Maltese trap is the Greek one exactly. Naturalisation counts residence; the programme that sells Maltese residence publishes no minimum presence at all. Nothing excludes a permanent-residence holder from applying, but the years have to be years actually spent on the island.

Portugal: ten years, seven for some, counted from a date most pages get wrong

Portugal was the fast route to a European passport and stopped being one on 19 May 2026, when Lei Orgânica 1/2026 came into force. Naturalisation now takes ten years for most applicants and seven for citizens of EU states and of Portuguese-speaking countries, with a culture and history examination added on top of the language requirement. Neither statute names a CEFR level for the language.

Two details decide whether the arithmetic works for a given person, and both are routinely misreported.

The first is the start date, and it changed on the same day as the period, in a different article of the same law. Between March 2024 and 19 May 2026, article 15(4) of Lei 37/81 counted the time from the day the residence permit was applied for, provided it was later granted — a paragraph written for an immigration queue that runs one to three years between filing and a card. Article 5 of Lei Orgânica 1/2026 repeals it. What remains is article 15(1): lawful residence means being in Portugal with regularised status under any title, visa or authorisation of the immigration or asylum regime. That is broader than the plastic card — a national residence visa is a title — but it does not reach back over a queue. Against one to three years of waiting, that is not a rounding error; it is a third of the clock. And article 7(2) preserves the old counting for any file already pending on 19 May 2026, so two people who applied a month apart are now on two different rules.

The second is the same one as Greece and Malta. What accumulates towards naturalisation is time actually lived in Portugal. A permit renewed from abroad preserves the status and builds nothing towards a passport. What follows a Portuguese permit — the renewals, the card, and permanent residence at five years, which is a different status on a different clock again — is set out in its own guide.

The UAE: the only law here that names investors, and the only one you cannot apply under

This is the inversion worth understanding, because it is the opposite of what the market implies.

Of these four jurisdictions, the Emirates is the only one whose nationality rules expressly name investors as a category eligible for citizenship, alongside doctors, specialists, inventors, scientists, intellectuals, artists and people of creative talent, together with their spouses and children. The 2021 amendments to the executive regulation of the citizenship and passports law introduced them, and the naturalised citizen may keep their original nationality.

And it is the only one of the four where no one can apply. The government's own platform puts it without qualification:

> "You can acquire the UAE's citizenship only through the Rulers' and Crown Princes' Courts, Offices of the Executive Councils and the Cabinet based on the nominations of federal entities."

Not a form, not a queue, not a period of residence that ripens into a right. A nomination, made by a federal entity, decided by a court of a ruler or by the Cabinet. A golden residence does not start that process and does not improve the odds of it in any published way. Any page presenting Emirati citizenship as the far end of the golden visa is describing a discretion, not a route.

The three clocks people confuse

Almost every comparison table on this subject collapses at least two of the following three, and they are not the same object.

The permit's own clock governs whether you still hold the permit. It is set by the programme, it is the one the seller talks about, and in Greece it expressly tolerates absence. Satisfying it keeps your card valid and does nothing else.

The long-term residence clock governs a different status — EU long-term resident, or a national permanent residence — and it is the first one that tests presence rather than paperwork. In Greece it is article 144 §1, requiring lawful and uninterrupted residence with capped absences, which is why the investor permit's tolerance of absence and this status point in opposite directions.

The naturalisation clock governs a passport. It is the longest, it tests presence, and it adds requirements the other two never mention: a language examination, in Greece and Portugal a history and culture examination as well, and in every case a clean record.

A person can satisfy the first indefinitely, never begin the second, and never approach the third. That is not an edge case. For an investor who bought a permit in order to keep living somewhere else, it is the normal outcome, and it is the single thing that no page selling the permit will put in writing.

Frequently asked questions

Where this sits in the rest of the site

The Greek permit itself — thresholds, zones, the FIP alternative, permanent residence and the 7% pensioner rate — is in the Greece guide. The Maltese programme, the judgment that ended the passport, and the naturalisation arithmetic in full are in the Malta guide. Portugal's routes and its naturalisation change are in the Portugal guide, and what happens after a Portuguese permit is granted is in its own guide. The Emirati instruments are in the UAE guide. Who may file an application in the first place, and what stops one, is in the application guide. And what a golden visa is, in the words each state's own law uses, is a page of its own.

If the passport is the actual goal

We do not sell property and we do not give legal advice. What we do is put a person who knows what they are asking in front of a licensed firm in the right jurisdiction.

If citizenship is the objective rather than a permit, the question that decides everything is how much of each year you are genuinely willing to spend in the country — and that question has a different answer in each of these four. It is worth putting to a regulated adviser before any money moves, not after. Send it through the enquiry form. We take no part in the fee.

Sources: where each figure comes from

• Malta — Case C-181/23, *Commission v Malta*, judgment of 29 April 2025; the Maltese Citizenship Act, Cap. 188, as amended by Act XXI of 2025, and S.L. 188.06 as amended by L.N. 159 of 2025; the naturalisation conditions quoted from articles 10(1) and 11 of Cap. 188: our verification file for Malta, 1 September 2026.
• Greece — the seven-year naturalisation period under Law 3284/2004 as amended, the €550 application fee, the €150 examination fee, and the ΠΕΓΠ at B1 plus history, geography and culture with a 70% pass mark: our verification file for Greece, 28 August 2026. The examination's administering authority, its legal basis in Law 4735/2020 amending article 7 of the Citizenship Code, and the payment and identity-matching conditions: the National Registry of Administrative Public Services record for the examination, read 5 September 2026.
• Greece — absence being no obstacle to renewing the investor permit: article 100 §4 of Law 5038/2023, read in full in the same verification file. The presence requirement for long-term residence: article 144 §1.
• Portugal — ten years, seven for citizens of EU and Portuguese-speaking countries, with a culture and history examination and no CEFR level named, and with article 15(4) repealed so that time waiting for the permit no longer counts: Lei Orgânica 1/2026, in force 19 May 2026, as recorded in our verification file for Portugal, 28 August 2026 and re-read 7 September 2026.
• UAE — the categories eligible for naturalisation, the retention of the original nationality, and the quoted sentence on nomination: the UAE government's official platform page on Emirati nationality, read 5 September 2026.
• Not established, and therefore not published: exactly what counts as residence for the purposes of the seven-year Greek period, which the Citizenship Code's own text would have to settle; and whether that Code contains a discretionary honorary-naturalisation route and on what terms, which was not read in this round. The "183 days a year" that consultancy pages attach to Greek naturalisation is the tax-residency threshold and is not a condition of the Citizenship Code.