Six Jurisdictions.One Comparison.
All data verified July 2026. Programme terms shift frequently — this comparison reflects the current legislative and operational status of each programme.
Six Active Programmes.
Bespoke dynamic frameworks mapped directly across regulatory parameters for structured asset alignment.
Hungary
Temporary Residence
Portugal
Temporary Residence
Malta
Permanent Residence
Cyprus
Permanent Residence
Bulgaria
Permanent Residence
Greece
Temporary Residence
Side-by-side Programme Matrix.
Row groups cover programme basics, investment structure, residency and travel, family inclusion, tax treatment, process, and active risk disclosures. Scroll right on smaller screens.
| Program Classification |
🇭🇺 Hungary | 🇵🇹 Portugal | 🇲🇹 Malta | 🇨🇾 Cyprus | 🇧🇬 Bulgaria | 🇬🇷 Greece |
|---|---|---|---|---|---|---|
| PROGRAM BASICS | ||||||
| Status | Open | Open | Open | Open | Open | Open |
| Permit Type | Temporary residence | Temporary residence | Permanent residence | Permanent residence | Permanent residence | Temporary residence |
| Permit Duration | 10 years, renewable | 2 years, renewable | Lifetime | Indefinite | Immediate permanent | 5 years, renewable |
| Path to PR | 3 years | 5 years | Immediate at entry | Immediate at entry | Immediate at entry | 5 years |
| Path to Citizenship | 8 years (naturalization) | 5 years — Legislative risk Parliament voted to extend to 10 yrs; presidential signature pending | 5 years physical residence — MIEN closed Fast-track terminated Apr 2025 by ECJ | 7 years; no fast-track (golden passport scheme terminated 2020) | 5 years naturalization; possible fast-track at doubled investment | 7 years with genuine integration: language test, 183 days/yr, civics exam |
| INVESTMENT | ||||||
| Minimum Investment | €250,000 | €250,000 (cultural) / €500,000 (fund) | €375,000 (property) or €14k/yr rent + €97k fees | €300,000 + €50k/yr secured foreign income | €512,000 | €250,000 (special category) / €400,000 (Zone B) / €800,000 (Zone A) |
| Eligible Asset Types | Government-approved real estate fund (min 40% Hungarian residential) or €1M donation to public trust | VC / investment fund (most common), scientific research, cultural heritage, company creation | Property purchase (€375k) or property rental (€14k/yr) — no direct ownership required on rental route | New residential property (from developer + VAT), commercial real estate, company shares, or investment funds | Government-approved AIF, ETF, or Bulgarian Stock Exchange-listed shares | Real estate (4-zone structure) or capital contribution to Greek companies / REITs |
| RESIDENCY & TRAVEL | ||||||
| Physical Presence Required | None | 7 days/year | None | Once every 2 years | None | None |
| Schengen Access | ✓ Yes | ✓ Yes | ✓ Yes | ✗ No — Cyprus not yet a Schengen member. Accession targeted 2026, unconfirmed. | ✓ Yes (full member since January 2025) | ✓ Yes |
| Work Rights | ✓ Unrestricted (work + business) | ✓ Yes | ✓ Yes (in Malta) | ✓ Yes (subject to Cypriot employment market) | ✓ Unrestricted | ✓ Yes |
| Can Serve as Company Executive | ✓ Yes | ✓ Yes | ✓ Yes | ✓ Yes | ✓ Yes | ✓ Yes |
| Russian / Belarusian Nationals | Conditional — must apply on a second passport (sanctions apply) | No formal exclusion | No formal exclusion | No formal exclusion | No formal exclusion | No formal exclusion |
| FAMILY INCLUSION | ||||||
| Qualifying Dependants | Spouse + children to age 25 + parents | Spouse + children (any age if dependent or enrolled) + parents | Spouse + children (any age if unmarried/dependent) + parents + grandparents (4 generations) | Spouse + children under 25 (students) | Spouse + children under 18 (parents possible for temporary residency — verify current rules) | Spouse + children to age 24 (enrolled) + parents of both spouses |
| Additional Investment for Family | ✓ No | ✓ No | ✓ No | ✓ No | ✓ No | ✓ No |
| TAX | ||||||
| Tax Regime Available | 15% flat PIT | IFICI / NHR 2.0: 20% flat on qualifying professional income; most foreign income exempt for 10 years | GRP companion regime: 15% on foreign income remitted to Malta; min €15,000/yr | Non-Dom: 0% on dividends and interest for 17 years (extendable); 60-day residency rule | 10% flat PIT + 10% flat CIT — EU’s lowest rates | Non-Dom: €100,000 lump sum/year covers all foreign income of any amount; up to 15 fiscal years |
| Key Tax Benefit | Low flat rate; no dedicated non-dom regime | Foreign income exempt for 10 years under NHR 2.0 | Remittance basis; foreign income taxed only when brought to Malta | Zero tax on dividends and interest income for 17+ years | EU’s lowest flat corporate and personal income tax | Single annual lump sum covers unlimited foreign income |
| PROCESS | ||||||
| Typical Processing Time | ~5 months | 6–18 months (AIMA backlog improving) | 4–6 months | 4–6 months (fast-track Category F only—Category F has 5–7 yr backlog, avoid) | 4–6 months | 12 to 16 months typical in high-volume regions (backlog improving through 2026) |
| ACTIVE RISK FLAGS | ||||||
| Disclosed Risks | No active programme-level flags. | Citizenship Timeline The 2026 nationality law is in force since 19 May 2026: 7 years for CPLP and EU nationals, 10 years for other nationalities. Applications filed on or before 18 May 2026 keep the earlier 5 year rule. | MEIN Terminated Fast-track citizenship-by-investment closed April 2025 by ECJ ruling. Naturalization (5 yrs physical residency) is the only remaining route. | No Schengen Cyprus is not a Schengen member. Accession targeted 2026 but not confirmed. Permit does not provide free movement within Schengen area. | FATF Update Bulgaria received a positive exit decision at the June 2026 FATF plenary; formal delisting is pending final verification. Banking and KYC friction is easing. | Processing Backlog ~42,000 pending applications as of November 2025. Improving but delays remain material. STR Ban Short-term rental (Airbnb) use of Golden Visa properties is prohibited. |
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Where each programme leads.
No single programme dominates every dimension. These rankings identify where each jurisdiction holds a clear, data-supported advantage over its peers.
Hungary
Leads to a 10-year renewable investment residence permit status framework. Permanent tracking paths require sustained regional physical footprint validation elements verified inside regulatory renewal windows.
Cyprus
Secures direct absolute Permanent Residency status permissions immediately. Pathing configurations unlock naturalization windows following aggregate physical tracking thresholds matching standard timeline mandates.
Malta
Grants lifetime permanent residency certificates subject to initial 5-year compliance monitoring routines. Naturalization tracks follow specialized high-tier sovereign vetting metrics explicitly outside baseline paths.
Portugal / Greece / Bulgaria
Initial rolling residency permits conversion pipelines. Fully unlocking passport applications occurs on year 5 or year 6 marks following mandatory language proficiency examinations or asset lock-in verifications.