Europe’s investment migration market is changing quickly. For years, Portugal was the obvious leader. Its Golden Visa programme attracted thousands of investors, billions of euros of capital and enormous international attention. But by 2023, Portugal was beginning to question the future of the model itself, particularly as the country confronted mounting political pressure over housing affordability.

That creates an obvious question for international investors: where does the capital go next?

Greece may be one of the most compelling answers.

The Greek Golden Visa programme was introduced in 2013 and offers non-EU nationals a renewable residence permit in return for qualifying investment. The most visible route has been real estate, with a minimum investment of €250,000 in most parts of the country. In certain high-demand areas, however, Greece has already legislated for a €500,000 threshold, signalling that the government is beginning to manage the programme differently from the way Portugal managed its own property-based model.

For an international investor, the proposition remains remarkably straightforward. Acquire a qualifying asset and obtain a European residence option while retaining ownership of the underlying investment. Greece combines that proposition with EU membership, access to the Schengen area for travel, a substantial property market and a Mediterranean lifestyle.

It is easy to see why demand has increased.

Portugal Changed the Market

The timing is important.

Portugal spent years establishing itself as the leading European Golden Visa destination. The programme became one of the most successful examples of investment migration anywhere in Europe, particularly because it combined a relatively accessible investment threshold with a strong lifestyle proposition and the possibility of obtaining residence without relocating permanently.

Then the political environment changed.

In February 2023, the Portuguese Government announced its Mais Habitação package, explicitly linking the proposed end of new Golden Visa concessions to its response to the country’s housing problems. The Government described the measures as part of a broader effort to combat speculation and increase housing supply.

By March, the Government had formally advanced proposals that included ending the granting of new Golden Visas. The measure was therefore no longer merely a political discussion; it had become part of a concrete legislative process.

That created an obvious question for investors and advisers: where does the capital go next?

Greece was one of the most obvious answers.

It offered many of the characteristics that had originally made Portugal attractive: EU membership, Schengen access, a Mediterranean lifestyle, a substantial property market, relatively low investment thresholds and, importantly, a Golden Visa programme that still allowed the investor to own real estate.

But Greece also had something Portugal no longer had in quite the same form: room to develop the programme further.

€250,000 Is a Powerful Number

The €250,000 threshold is important.

For a wealthy investor, €250,000 may not be a particularly large allocation. But the Golden Visa is not necessarily competing for the €250,000 investor. It is competing for the investor who might spend €500,000, €1 million or considerably more.

The lower threshold simply reduces the cost of entry and gives an investor an option. They can buy one property, acquire several properties where permitted, invest more than the minimum or retain substantial capital elsewhere while establishing a European foothold.

That optionality is one of the reasons Greece has become so interesting.

There is, however, an important qualification. Greece had already decided that €250,000 was no longer appropriate in some of the country’s most popular markets. Under legislation adopted in late 2022, the minimum investment for specified areas of Athens, Thessaloniki, Mykonos and Santorini was to rise to €500,000. The new regime was scheduled to take effect after a transitional period, while the broader €250,000 threshold remained available elsewhere.

The subsequent Immigration Code extended the transitional arrangements, giving investors additional time to secure qualifying transactions under the existing €250,000 regime in the affected areas.

This was already telling us something about Greek policy.

Greece was not simply opening the door to unlimited foreign property capital. It was beginning to differentiate between markets.

Two Countries, Two Different Opportunities

Greece should not simply attempt to become the next Portugal.

The two countries have different property markets and quite different economic structures. They have different investor profiles, different political circumstances and different experiences with foreign capital.

Greece is still dealing with the legacy of its sovereign debt crisis, but the country has also undergone a significant economic transformation. Tourism has expanded, foreign investment has recovered and the country’s property market has become considerably more attractive to international investors.

Enterprise Greece reported in March 2023 that the Greek economy had expanded by 5.9% in 2022 and that Greece had attracted a record €6.2 billion in foreign direct investment during the previous year, with roughly one-third of that investment connected to property.

That is significant because the Golden Visa is not operating in isolation.

It is operating within a much broader investment story.

Athens has become increasingly visible to international capital. Tourism investment has expanded. The Athens Riviera is undergoing major redevelopment, while logistics, hospitality, energy and technology are becoming increasingly important parts of the country’s investment narrative.

The Golden Visa is therefore not merely an immigration product. It sits within a country that is actively trying to reposition itself as an investment destination.

Real Estate Is the Product

The attraction of the Greek programme is partly that the investment itself is tangible.

An investor is not simply making a donation. They are acquiring an asset.

That asset may generate rental income or appreciate in value. It can potentially be sold. It can be used by the investor or family. It can form part of a broader investment portfolio. And, importantly, it creates an economic connection with Greece.

This matters.

Investment migration works best when the immigration benefit is attached to an investment that the investor would be comfortable owning even without the immigration benefit.

That is a much stronger proposition than an investment whose only purpose is to obtain an immigration benefit.

Greece has benefited from precisely this simplicity. The investor understands what they are buying, the underlying asset is familiar and the immigration benefit is relatively easy to explain.

But simplicity can also become a weakness if too much capital flows into the same asset class.

Property Creates a Risk

There is a warning here.

Portugal’s experience demonstrates what can happen when an investment migration programme becomes heavily concentrated in residential property. The very success of the programme can eventually create political opposition.

The programme begins as a mechanism for attracting foreign capital.

Then the narrative changes.

Foreign capital becomes foreign property ownership. Foreign property ownership becomes rising prices. Rising prices become a housing problem. And the investment migration programme eventually becomes part of the political debate over affordability.

Greece needs to watch this carefully.

If foreign investors begin to dominate particular residential markets, local buyers may increasingly perceive the Golden Visa as contributing to affordability problems. The political narrative can change very quickly.

Today the investor is described as foreign capital.

Tomorrow the same investor may be described as a foreign buyer pushing prices beyond the reach of local residents.

That is the political risk of a property-based programme.

Greece has already recognised the concentration problem. The decision to increase the minimum investment requirement to €500,000 in selected markets was, in part, a response to the growing pressure in those areas. The affected locations included the northern, central and southern sectors of Athens, the municipality of Vari-Voula-Vouliagmeni, the municipality of Thessaloniki, and the islands of Mykonos and Santorini.

This is an interesting policy response.

It does not eliminate the Golden Visa. It does not eliminate property investment. Instead, it changes the price of entry in the markets where demand is greatest.

That may prove to be a more sustainable approach.

Two Greek Property Markets

The result could effectively create two Golden Visa markets.

In the most popular areas, the investment threshold will rise to €500,000. In much of the rest of Greece, the €250,000 threshold remains available.

That gives investors a choice.

Pay more for the most established locations, or search for value elsewhere.

From an investment perspective, this is potentially more interesting than it first appears.

Greece is a large country. It has islands, coastal markets, regional cities, tourism infrastructure and areas where international capital remains relatively limited. The investor who is willing to look beyond Athens, Mykonos and Santorini may find a very different risk-and-return proposition.

That could ultimately be one of the strengths of the Greek model.

If the programme successfully redirects some capital away from the most overheated markets, it could produce a more geographically distributed investment effect. That would be considerably more valuable to the Greek economy than simply increasing property prices in central Athens.

The policy challenge is therefore not necessarily to stop foreign investment. It is to direct it more intelligently.

The Investor Is Also Changing

There is another important development.

The international Golden Visa investor is becoming more sophisticated.

The investor is no longer necessarily looking for a holiday apartment. They may be looking for a European base. They may be considering education for their children, diversifying geopolitical exposure, establishing a business or gaining access to European markets. They may want a second residence without immediately becoming tax resident.

They may simply want optionality.

That makes the Golden Visa part of a much larger wealth-management decision.

The same shift was already visible in the broader investment migration market. As I argued in Investment Migration Is No Longer Just About a Passport, the sophisticated investor increasingly views residence as one component of a wider strategy involving family, capital, taxation, business and jurisdictional risk.

Greece therefore does not need to sell itself merely as a place to buy property.

It can sell itself as a place where international capital, family mobility and investment opportunity can coexist.

Residence Is Not Tax Residence

This distinction is critical.

A Golden Visa gives an investor a residence right. It does not automatically make the investor a Greek tax resident.

Greek tax residence is determined under separate rules, including considerations such as permanent or principal residence, habitual abode and centre of vital interests, as well as the 183-day rule.

The distinction is important for internationally mobile investors.

An investor can therefore analyse the immigration opportunity separately from the question of where they will actually live and where they will become tax resident, although the two decisions obviously need to be considered together when designing a wider wealth and mobility strategy.

The residence permit is an option.

The investor decides how that option fits into the wider personal and financial structure.

Greece Has a Window

Greece therefore has a significant opportunity.

Portugal’s political problems have created demand. International families are increasingly concerned with geopolitical and jurisdictional optionality. Greece has a product that remains relatively simple, while its wider economy is attracting increasing attention from international investors.

But this window will not remain open indefinitely.

The more successful the programme becomes, the greater the political scrutiny will become.

That is almost inevitable.

This is the paradox of investment migration. A programme needs investors, but too many investors concentrated into the same asset class can create the very political conditions that threaten the programme.

The Government then faces a difficult choice.

It can close the programme. It can raise the threshold. It can restrict particular areas. Or it can change the qualifying investment.

Greece has already chosen one of those options.

The €500,000 threshold in selected markets is effectively a form of market segmentation. It allows the Government to continue attracting capital while attempting to reduce pressure in the most popular areas.

That is a more sophisticated response than simply closing the door.

Greece Should Think Beyond Property

The long-term opportunity, however, is bigger than residential real estate.

Greece needs capital, businesses and infrastructure. It needs renewable energy, tourism and development capital. It needs technology and innovation. It needs investment capable of creating employment and generating economic activity beyond the purchase of an existing apartment.

Enterprise Greece was already highlighting the country’s opportunities in tourism and hospitality, noting the scale of investment in hotels, resorts, cruise infrastructure and other tourism-related assets.

It is therefore possible to imagine an investment migration model in which the Golden Visa becomes connected to a much broader range of productive investments.

Instead of asking:

“How many houses did foreign investors buy?”

the Government could ask:

“How much productive capital did the programme attract?”

That is a much stronger question.

The Fund Model Could Become Important

This is where the evolution of European investment migration becomes particularly interesting.

Portugal’s experience is pushing the market away from pure property investment. Greece could potentially benefit by developing alternative investment routes alongside property.

Investment funds can aggregate capital. Professional managers can allocate it. Investors can obtain diversification. Governments can potentially direct capital toward sectors that need investment.

That creates a different alignment.

The investor receives a qualifying investment opportunity. The economy receives capital that can potentially be deployed into businesses, infrastructure, renewable energy, technology, hospitality or development.

That alignment is difficult to achieve through thousands of individual property purchases.

It also moves investment migration closer to the world of professional capital management.

The investor is no longer simply buying an apartment because an immigration programme requires it. The investor is allocating capital to an investment strategy that happens to provide a residence benefit.

That is a potentially much more sustainable model.

Greece Can Learn From Portugal

This is where Portugal becomes particularly instructive.

Portugal demonstrated how powerful the Golden Visa model could become. But it also demonstrated the political vulnerability of a programme that becomes too closely associated with residential property and housing affordability.

Greece now has the benefit of seeing that experience unfold.

The lesson should not be that property is inherently problematic.

It is not.

The lesson is that concentration creates political risk.

A diversified investment migration programme is potentially more resilient than one overwhelmingly dependent on a single asset class. If Greece can attract capital into property while also encouraging investment into productive businesses, infrastructure, tourism, technology and other sectors, the economic case for the programme becomes considerably stronger.

This would also give investors more choice.

And choice is increasingly important in the investment migration market.

But Investors Should Not Assume Permanence

There is a lesson here for investors as well.

The fact that a programme exists today does not mean it will exist in the same form tomorrow.

Investment migration is ultimately government policy. Governments respond to housing market pressures, political priorities, economic conditions and public opinion. Investment programmes change with them.

An investor therefore needs to distinguish between the investment decision and the policy decision.

The property needs to make sense independently. The residence benefit needs to make sense. And the investor needs to understand the possibility that the rules may change.

This is one of the reasons I have argued in Portugal’s Golden Visa: When Success Becomes a Problem that the greatest risk in investment migration is often not the investment itself, but the assumption that government policy will remain static.

The New European Leader?

Is Greece the new European Golden Visa leader?

Perhaps.

But I would frame the question differently.

Greece currently has an opportunity to become the new benchmark for European residence by investment.

Portugal demonstrated how powerful the Golden Visa model can be, but it also demonstrated its weaknesses. Greece now has the opportunity to learn from both.

It can continue attracting foreign capital while protecting its housing markets. It can encourage investment outside the most expensive locations. It can broaden the programme beyond residential property. And it can increasingly connect immigration policy with the country’s wider economic strategy.

That would make the programme more sustainable.

The first generation of European Golden Visas was largely about property.

The next generation may be about capital.

That means funds, private equity, infrastructure, businesses, development, innovation and strategic investment.

Greece has an opportunity to be part of that transition.

The €250,000 property investment may remain the headline attraction in much of the country, while €500,000 becomes the threshold in selected high-demand markets. But the property route should not necessarily be the entire product.

The strongest investment migration programme is one where the interests of the investor and the country remain aligned.

Portugal may have discovered the limits of a property-heavy model.

Greece now has the opportunity to build something better.

The question is not whether Greece can replace Portugal.

The question is whether Greece can learn from Portugal before it repeats its mistakes.