What is the purpose of the Portugal Golden Visa fund route?

To capitalize Portuguese companies and support productive economic activity. Funds that mainly finance tourism operations, trade luxury goods, hold crypto, or cycle capital internally are misaligned with this purpose even if technically eligible.

Does CMVM supervision guarantee investment quality?

No. CMVM supervision and statutory audits confirm legal and reporting compliance, but do not assess investment quality, governance strength, incentive alignment, or the strategy’s commercial merits. Investors must evaluate these factors themselves.

How easy is it to set up a fund manager (SCR) in Portugal?

It is relatively simple. An Alternative Fund Manager (SCR) can be created with about €75,000 in share capital, allowing recently formed entities with limited track records to manage funds.

What risks arise when a third-party manager is hired?

When promoters are not licensed and hire a third-party manager, real investment decisions may remain with the promoter while the licensed manager provides a regulatory shell. This can weaken governance and accountability.

Are hospitality, crypto, cars, or collectibles suitable themes for Golden Visa funds?

They may be technically eligible, but they do not align with the program’s purpose of capitalizing Portuguese companies and building productive activity. In practice, these themes often operate as workarounds of the law and carry higher risk.

What is the concern with SIFIDE-driven capital in VC funds?

In SIFIDE-certified VC funds, many investors participate for tax relief rather than financial performance, which can reduce pressure on managers to select strong companies and may lead to weaker portfolios.

Should I avoid funds offering guaranteed returns or buy-back arrangements?

Yes. Your capital may be at risk. Guarantees and buy-backs are red flags that often mask structural or credit risks elsewhere in the fund, besides not being allowed.

Are subsidy-dependent strategies a red flag?

They can be. Agriculture and renewables often rely on incentives. If subsidy rules change, the revenue model can collapse. Prefer strategies that do not depend on government incentives.

What manager attributes should I verify?

Look for a verifiable track record managing illiquid assets through full cycles, with real exits and disciplined governance. Avoid newly formed managers without relevant experience.

How should I think about market risk if investing in listed equities or mutual funds?

Assess your tolerance for downturns. Global valuations are stretched; a U.S. shock often hits Portugal harder due to higher volatility in peripheral markets.

A person marking items on a digital checklist beside a laptop, illustrating the due diligence process for selecting Portugal Golden Visa investment funds.

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Cristóvão Matos

Managing Director

Nomera Capital

Published: Nov 11, 2025Updated: Nov 11, 2025