Russia's Golden Visa vs EU Programs (Portugal, Greece, Spain): 2026 Comparison

Last updated: May 2026

By Dmitry Zapolskiy, Licensed Immigration Attorney | Cross-Border Advisory

Between October 2023 and April 2025, three of Europe's most established golden visa programs either closed entirely or raised investment thresholds beyond recognition. Portugal shuttered its Autorisation de Residence pour Investissement. Spain followed. Greece tripled its minimum in prime areas. For investors who had treated EU residency-by-investment as a reliable planning tool, the landscape shifted beneath them in under eighteen months.

Russia's Golden Visa, launched in 2024 under amendments to Federal Law No. 115-FZ, entered this vacuum with a starting investment of approximately $61,000 — a fraction of what EU programs demanded at their peak. But comparing Russia to the EU programs it notionally replaces requires precision. The proposition is structurally different: permanent residence without Schengen access, zero physical presence without Western banking infrastructure, the lowest entry cost on the market without the regulatory ecosystem investors associated with the European Union.

This analysis examines each program on its documented merits, identifies the decision factors that separate one investor profile from another, and addresses the dual-jurisdiction strategies that have emerged since the EU closures. The comparison draws on practitioner experience at NovosCivis processing golden visa applications across multiple jurisdictions.

This content is for informational purposes only and does not constitute legal advice. Immigration regulations are subject to change, and individual circumstances vary. Consult a qualified immigration attorney for advice specific to your situation.

---

Quick Comparison Table

Before examining each jurisdiction in detail, the following table consolidates the parameters that drive most investment migration decisions. Current status reflects program availability as of May 2026.

The table reveals two distinct value propositions. EU programs offered Schengen mobility and Western financial integration at a premium price. Russia offers permanent residence and zero physical presence at a fraction of the cost — without Schengen or EU banking access.

---

What Happened to EU Golden Visas?

The contraction of European golden visa programs between 2023 and 2025 was not a coincidence. It reflected a convergence of domestic housing crises, EU-level regulatory pressure, and shifting political sentiment toward investment migration. Understanding what closed — and why — contextualizes the options that remain.

Portugal: The End of Europe's Most Popular Program

Portugal's Autorisation de Residence pour Investissement (ARI) program closed to new applications in October 2023 following amendments to Law 23/2007 enacted by the Socialist government under Prime Minister Antonio Costa. The program had operated since 2012 and attracted over 12,000 main applicants, generating approximately EUR 7.3 billion in investment (Portuguese Immigration and Borders Service, SEF data through 2023).

The closure was driven by three factors. Housing affordability had deteriorated sharply in Lisbon and Porto, with property prices rising 83% between 2015 and 2023 according to Eurostat residential property indices. Political opposition framed the golden visa as a contributor to this crisis. Simultaneously, the European Commission's 2022 recommendation urged member states to phase out investor residence schemes, adding supranational pressure.

At its final pricing, the ARI required EUR 500,000 in real estate (EUR 280,000 in designated low-density areas). Existing holders retain their permits and renewal rights. No new applications are accepted. Portugal's Non-Habitual Resident (NHR) tax regime — which offered a 20% flat rate on Portuguese-source income — also ended for new registrations in 2024, removing a second pillar of the country's appeal to foreign investors.

Greece: Still Open, Dramatically More Expensive

Greece remains the most accessible EU golden visa. But "accessible" now carries a different price tag. In September 2024, the Greek government raised the minimum real estate investment from EUR 250,000 to EUR 800,000 in prime areas — Athens, Thessaloniki, Mykonos, Santorini, and municipalities with populations exceeding 3,100. Non-prime areas retained a EUR 400,000 threshold, itself a 60% increase from the original minimum.

The tripling in prime areas altered the program's positioning fundamentally. At EUR 250,000, Greece competed with Portugal and attracted cost-sensitive investors. At EUR 800,000, it competes with Malta and Cyprus — jurisdictions that offer citizenship, not merely residence.

Processing times have extended as well. According to industry reports from Henley & Partners (2025), Greek golden visa applications now take 6 to 12 months, compared with 2 to 3 months before the 2024 changes. The Greek program still grants a five-year renewable residence permit with Schengen access, and eligibility for citizenship after seven years of residence. For investors who prioritize EU mobility above all else, Greece remains the primary option. The question is whether it justifies a 3x to 14x premium over alternatives outside the EU.

Spain: Abolished in 2025

Spain's golden visa program ended on April 3, 2025, when amendments to Law 14/2013 took effect following passage through the Cortes Generales. The program, which had required EUR 500,000 in real estate, attracted approximately 14,000 investors over its eleven-year history according to Spanish Ministry of Inclusion data.

The abolition was driven by housing market pressure comparable to Portugal's. Spanish property prices rose 48% in major cities between 2015 and 2024 (INE data), and the ruling coalition framed the golden visa as a factor in the affordability crisis. Spain joins Portugal in complete closure. Existing permit holders are grandfathered and may renew, but no new applications are processed.

---

Russia's Golden Visa: The 2024 Entrant

Russia's investor permanent residence program launched under 2024 amendments to Federal Law No. 115-FZ, implemented through Government Decree No. 2573. Unlike the EU programs it is compared against, Russia's Golden Visa grants permanent residence — vid na zhitelstvo (VNZh) — from the outset. There is no temporary stage, no probationary period, no upgrade pathway required.

Five investment routes qualify. The charity donation pathway, at 5 million rubles (approximately $61,000 at current exchange rates), represents the lowest entry point. Government bonds (OFZ) require 10 million rubles but offer 15-17% annual yields with capital recovery. Real estate routes range from 20 million rubles in regions to 50 million rubles in Moscow and St. Petersburg. A full breakdown of each pathway is available in our complete guide to Russia's Golden Visa.

The structural differences from EU programs are worth stating directly:

• Permanent from day one. No renewal cycle. No requalification risk. EU golden visas typically grant temporary residence that requires periodic renewal and can be denied.
• Zero physical presence. The permit is maintained indefinitely without visiting Russia. This is not a relaxed requirement — it is absent entirely.
• No Schengen access. Russian residence does not confer travel rights in the EU, the United Kingdom, or the United States. This is the single largest functional difference from any EU golden visa.
• Family coverage. Spouse and minor children are included. The application process for dependents is detailed in our family dependents FAQ.
• Path to citizenship. Eligible after five years of permanent residence, subject to Russian language proficiency and other standard requirements. Our step-by-step application guide covers the full process.

For investors whose primary objective is Schengen access, Russia's program is not a substitute. For those whose priorities center on cost, legal protection, jurisdictional diversification, or zero-presence permanent status, the comparison warrants closer examination.

---

Head-to-Head: Key Decision Factors

Raw comparison tables identify differences. They do not resolve which differences matter for a given investor. The following analysis addresses each decision factor that, in practice, determines where clients allocate their investment migration capital.

Investment Threshold

The cost differential is not marginal. It is structural.

Russia's entry point is 7x cheaper than Greece's non-prime threshold. It is 14x cheaper than a prime-area Greek golden visa. For an investor allocating $880,000 to a Greek property in Athens, the same capital covers Russia's charity pathway fourteen times over — or funds the Russian program and leaves $819,000 for other jurisdictional strategies.

The cost gap is not simply a matter of affordability. It reflects a fundamentally different economic model. EU programs leveraged Schengen access to command premium pricing. Russia, without that leverage, competes on accessibility and structural features. Details on Russia's investment tiers are covered in our investment requirements guide.

What You Actually Get

Residency permits are not fungible. What matters is what the permit enables.

Russia grants permanent, indefinite residence. The holder may live, work, and operate a business in Russia without time restrictions. There is no renewal process. The permit does not expire. Critically, Russia maintains no extradition treaties with the United States, the United Kingdom, or EU member states — a factor that is relevant to investors in jurisdictions with aggressive cross-border enforcement regimes. We examine this legal framework in detail in our analysis of Russia's non-extradition framework.

Greece grants a five-year temporary residence permit, renewable upon proof that the qualifying investment is maintained. The permit includes full Schengen zone travel — free movement across 27 EU member states and four EFTA states. Citizenship eligibility begins after seven years.

Portugal and Spain (historical) granted temporary permits with Schengen access on similar terms. Portugal's path to citizenship was five years; Spain's was ten.

The divergence is clear. EU programs sold mobility. Russia sells permanence and legal positioning. These are not interchangeable.

Tax Implications

Tax treatment varies not merely by rate but by structural design. The differences affect how investors position residency within their broader wealth architecture.

Russia applies a progressive income tax between 13% and 22% for tax residents (those present 183+ days). However — and this is the operative detail — Golden Visa holders who maintain zero physical presence are not Russian tax residents and owe nothing on worldwide income. No inheritance tax exists (abolished 2006). Russia maintains 80+ double taxation agreements. This combination allows Russia to function as a residence jurisdiction without a tax footprint, a structure explored in our tax benefits analysis.

Greece offers a 7% flat tax on foreign-source income for qualifying transferees under its non-domicile regime (Article 5A of the Income Tax Code, introduced 2020). The regime requires an annual investment of EUR 500,000 and a flat fee of EUR 100,000 per year. Standard Greek tax rates reach 44% for higher brackets.

Portugal no longer offers its NHR regime to new applicants. Standard rates reach 48%.

Spain applies standard rates up to 47%, with no special investor tax regime currently active.

Physical Presence Requirements

For HNWI managing commitments across multiple jurisdictions, physical presence obligations represent operational friction — and, critically, they interact with tax residency thresholds.

Russia requires nothing. Zero days. The Golden Visa remains valid regardless of whether the holder ever enters Russia. This is not a relaxed standard; it is an absent one. Portugal's ARI required 7 days per year — minimal, but still a scheduling obligation that, if missed, could jeopardize renewal. Greece requires periodic visits tied to the five-year renewal cycle. Spain required 7 days annually.

The practical significance extends beyond convenience. For investors holding residence in two or three jurisdictions simultaneously, each country's presence requirement creates a compliance calendar. Eliminating Russia from that calendar — while maintaining permanent resident status there — simplifies multi-jurisdictional life materially. It also eliminates the risk of inadvertently triggering Russian tax residency through overstay, since there is no minimum stay to exceed in the first place.

Banking and Financial Access

This is where Russia's proposition encounters its most significant structural limitation — and where the comparison demands honesty rather than advocacy.

Greek golden visa holders access the full EU banking ecosystem: SWIFT transfers, Visa and Mastercard networks, euro-denominated accounts, correspondent banking relationships with every major financial center.

Russian residence provides access to Russian domestic banking, which operates under extensive Western sanctions imposed since 2022. Major Russian banks were disconnected from SWIFT. International card networks Visa and Mastercard suspended operations. Cross-border transactions now route through alternative systems — China's CIPS, Russia's SPFS, and bilateral arrangements with partner countries.

For investors whose operations depend on Western financial connectivity — dollar-denominated trade, EU supplier payments, US or UK banking relationships — Russia's banking environment presents genuine operational challenges. For those operating within Russia-adjacent economic corridors (MENA, CIS, Turkey, parts of Southeast Asia), the sanctions-related limitations are substantially less impactful. The Russia-UAE double taxation agreement, signed in February 2025 and effective January 2026, has further strengthened financial corridors between these two jurisdictions.

We address the practical mechanics of Russian banking access in our guide to opening bank accounts in Russia as a foreigner.

Why Some Investors Choose Russia Despite No Schengen

In practice, a specific investor profile selects Russia's Golden Visa not despite the absence of Schengen access, but because Schengen access is not their primary criterion. Three patterns recur in our advisory work:

Legal protection. Russia's absence of extradition treaties with Western jurisdictions provides a layer of legal insulation that no EU golden visa can replicate. For individuals facing or anticipating cross-border legal proceedings, this is the decisive factor.

Cost-driven diversification. At $61,000, Russia's program allows investors to add a jurisdiction without a significant capital commitment. The capital efficiency enables multi-jurisdiction strategies that would be prohibitively expensive if every jurisdiction demanded EUR 500,000 or more.

Privacy considerations. Russia's data-sharing agreements with Western tax authorities are limited compared to EU member states, which participate in the OECD Common Reporting Standard (CRS) and EU Directive 2014/107/EU on automatic exchange of financial account information. Our article on jurisdictional diversification for HNWI examines this dimension in detail.

---

The Dual Strategy: Russia + EU Residency

A pattern has emerged since the EU program closures that merits direct examination. Rather than choosing between Russia and the EU, some HNWI are pursuing both — holding Greek residence for Schengen access alongside Russian permanent residence for legal diversification and cost-efficient jurisdictional coverage.

This is not a contradiction. It is portfolio logic applied to personal jurisdiction. Greece provides EU mobility, euro-zone banking, and a familiar regulatory environment. Russia provides permanent status, zero-presence maintenance, and a legal framework outside Western enforcement structures. Neither jurisdiction prohibits holding residency in the other. The combined capital requirement — approximately $500,000 to $940,000 depending on the Greek investment zone — delivers both Schengen access and non-Western permanent residence.

Asset allocation across jurisdictions follows the same reasoning as geographic diversification in an investment portfolio. Real estate in Greece satisfies the golden visa investment minimum while holding value in a euro-denominated market. The Russian investment — whether bonds yielding 15-17%, charity donation, or regional property — sits in a ruble-denominated asset class with different risk characteristics and correlation patterns. The two positions hedge against each other's geopolitical risks.

Tax management across the two jurisdictions requires careful planning. Spending fewer than 183 days in either country avoids triggering tax residency in that jurisdiction. Russia's zero-presence requirement makes this straightforward on the Russian side. The challenge lies in managing the Greek presence threshold while maintaining golden visa renewal eligibility.

NovosCivis advises clients on multi-jurisdictional structuring that accounts for tax treaty interactions, reporting obligations, and the practical mechanics of maintaining residence in jurisdictions with different administrative expectations. The starting point is always an individual assessment of which combination of jurisdictions aligns with the investor's operational reality, not a generic recommendation. For a comprehensive comparison of Russia against other non-EU jurisdictions, see our Russia vs UAE vs Kazakhstan residency analysis.

---

Frequently Asked Questions

Can I still get a golden visa in Europe in 2026?

Greece remains the only major EU golden visa program accepting new applications, with a minimum investment of EUR 400,000 in non-prime areas and EUR 800,000 in prime locations (Athens, Thessaloniki, major islands). Portugal and Spain have closed their programs to new applicants. Malta offers citizenship-by-investment but at a substantially higher threshold (EUR 600,000+ donation). Latvia and Hungary maintain residency-by-investment routes, but with limited Schengen benefits and higher regulatory scrutiny. The practical reality is that EU golden visa access has contracted dramatically, and the remaining options carry significantly higher price tags than the programs that closed.

Is Russia's Golden Visa a replacement for Portugal's?

No. The two programs serve fundamentally different purposes. Portugal's ARI provided Schengen zone access, EU banking integration, and a path to Portuguese (and therefore EU) citizenship. Russia's Golden Visa provides permanent residence in a non-EU jurisdiction with no Schengen access and limited Western banking connectivity. Russia is not a substitute for what Portugal offered. It is an alternative that appeals to a different investor profile — one that prioritizes cost efficiency, zero physical presence, legal protection through non-extradition, or jurisdictional diversification outside Western regulatory frameworks. Investors who specifically needed Schengen access should evaluate Greece's program or other residency options.

Does Russian residence give me any EU travel benefits?

Russian permanent residence does not confer any travel rights within the European Union or the Schengen zone. Russian residents who are citizens of countries requiring Schengen visas must apply for visas through standard consular channels. Russian residence may, however, facilitate visa applications to certain non-EU jurisdictions that maintain favorable relations with Russia, and it provides visa-free or simplified access to many CIS countries and select MENA nations. The travel profile of Russian residence is oriented toward Eurasia rather than Europe.

Can I hold both Russian and Greek residency simultaneously?

Yes. Neither Russia nor Greece prohibits dual residency in another jurisdiction. Holding both is legally permissible and has become a recognized strategy among HNWI advisors. The practical considerations are tax-related: spending more than 183 days in either country triggers tax residency in that jurisdiction, with implications for worldwide income reporting. Careful planning around physical presence thresholds is essential. Russia's zero-presence requirement simplifies this — you maintain Russian permanent residence without triggering Russian tax residency while managing your Greek presence to optimize your overall tax position.

What is the cheapest golden visa still available in 2026?

Russia's Golden Visa at approximately $61,000 (charity pathway) is the lowest-cost program that grants permanent residence among established investment migration jurisdictions. Our forthcoming comparison of the cheapest golden visa programs globally will provide a comprehensive ranking. Among programs granting EU residence, Greece's non-prime pathway at EUR 400,000 remains the most accessible. The Caribbean citizenship-by-investment programs (St. Kitts, Dominica, Grenada) start around $100,000 but grant citizenship rather than residence, in non-EU jurisdictions with limited global mobility compared to Schengen access.

---

Conclusion

The EU golden visa era — as investors knew it through 2023 — is functionally over. Portugal and Spain have closed their doors. Greece has repriced its program at levels that exclude the cost-sensitive segment that drove much of European investment migration's growth.

Russia's Golden Visa did not emerge to replace these programs. It emerged alongside their contraction, offering a structurally different proposition: permanent residence from day one, zero physical presence, and an entry cost that is an order of magnitude lower than what remains available in the EU. What it does not offer — Schengen access, Western banking integration, EU regulatory familiarity — is equally clear.

The investor's decision is not which program is objectively better. That framing misunderstands the comparison. The decision is which program aligns with a specific set of priorities: mobility versus permanence, cost versus access, Western integration versus jurisdictional independence.

For a confidential assessment of which jurisdiction — or combination of jurisdictions — fits your investment profile and operational requirements, contact the NovosCivis advisory team.

---

This content is for informational purposes only and does not constitute legal advice. Consult a qualified immigration attorney for your specific situation.

---