Comparing investor residence schemes in Bahrain, Greece, Cyprus, Malta, and Portugal
Among wealthy families and business owners around the world, the idea of maintaining a “Second Residence” has become increasingly common.
The reason behind this is not simply an aspiration to move overseas.
International diversification of assets, children’s education, business expansion, preparation for political and geopolitical risks, and future lifestyle planning all play a role. As the environment surrounding a family becomes more complex, “where to live” has become a theme that cannot be separated from asset administration or business succession.
One option that many countries have developed is a system that grants medium- to long-term residence status to foreign nationals who satisfy certain investment or asset requirements. These systems are often generally referred to as “Golden Visas.”
However, it is important to note that there is no strict, universally shared legal definition of the term “Golden Visa.”
Does the applicant receive permanent residence status, or a Residence Permit for a fixed period? Is real estate investment required, or is fund investment also acceptable? Is there a minimum stay requirement?
The design of each scheme differs significantly from country to country.
This article compares the schemes of five countries based on publicly available information as of September 2026.
Bahrain — Golden Residency with Real Estate Ownership of BHD 130,000 (Approx. USD 345,000) or More
Bahrain is one of the Gulf countries worth watching.
Bahrain offers a Golden Residency programme for eligible applicants, including property owners, professionals, retirees, and individuals with exceptional talent.
For property owners, the current threshold is BHD 130,000 (approximately USD 345,000). Applicants must own property in Bahrain with a total ownership interest of at least BHD 130,000 at the time of purchase. This requirement may be met through a single property or through the combined value of multiple properties.
The threshold was previously BHD 200,000 (approximately USD 530,000), but was reduced by 35% to BHD 130,000 in November 2025. The Bahraini government has positioned this change as part of its efforts to promote real estate investment and strengthen Bahrain’s competitiveness as a destination for long-term residence, business, and investment.
Another notable feature is the flexibility of the programme.
Golden Residency provides permanent residency status, and there is no minimum stay requirement to maintain its validity. Holding residency status in another country does not affect eligibility for Bahrain’s Golden Residency.
The programme is not limited to property owners. It also provides routes for eligible professionals, retirees, and individuals with exceptional talent or achievements.
Golden Residency holders may also sponsor their spouse, parents, and children. Other benefits include freedom to enter and exit Bahrain and access to opportunities to establish and operate a business in the country.
In other words, the main features of Bahrain’s Golden Residency can be summarised as:
A relatively clear real estate ownership threshold
＋ Permanent Residency
＋ No minimum stay requirement
＋ Sponsorship for spouse, parents, and children
Taken together, these features make Bahrain an option for individuals and families seeking to establish a long-term base while maintaining flexibility in their international mobility and residence arrangements.
Greece: EUR 250,000, EUR 400,000, or EUR 800,000. The Entry Point Differs by Property
Greece’s Golden Visa is well known as a European investor residence scheme.
However, at present,
“buy real estate for EUR 250,000 in Greece and obtain a Golden Visa”
is not an accurate way to understand the scheme.
In areas such as Attica, Thessaloniki, Mykonos, and Santorini, and on islands with a population of more than 3,100, the qualifying real estate investment threshold is generally EUR 800,000. In other areas, it is generally EUR 400,000.
On the other hand, there is a special route starting from EUR 250,000 for certain properties converted from commercial or other uses into residential use. In this case, the property must be a single property, but the general route’s requirement of at least 120 square meters does not apply.
There is also another EUR 250,000 route for historic buildings and similar properties.
It is therefore easier to understand the current Greek system as having multiple entry points:
EUR 250,000,
EUR 400,000,
and EUR 800,000.
These are the multiple entry points that currently exist.
It should also be noted that an investor Residence Permit does not, in principle, grant the right to work itself.
It is necessary to confirm not only the minimum investment amount, but also the region and the type of real estate to be acquired.
Cyprus: Residence Rights Are Generally Indefinite from an Investment of EUR 300,000
Also in the Mediterranean, Cyprus has a scheme with a somewhat different character.
Under the Immigration Permit for investors who are third-country nationals, an investment of at least EUR 300,000 is generally required.
The eligible assets are not limited to residential property.
Several options are available, including new houses or apartments, real estate such as offices or shops, investment in Cypriot companies, and certain Cyprus investment funds. For houses and apartments, the property must generally be a First Sale from a development company.
In addition, the applicant is generally required to have stable annual income of at least EUR 50,000. An additional EUR 15,000 is required for a spouse, and EUR 10,000 for each dependent minor child.
The residence right itself is generally indefinite, while the Residence Permit Card is renewed every ten years.
However, there are important maintenance conditions.
If the applicant is outside Cyprus at the time of approval, the applicant must generally begin residing in Cyprus within one year of approval. If the applicant subsequently remains outside Cyprus continuously for two years, the right to Permanent Residence is said to be lost.
The scheme therefore differs in design from Bahrain, which expressly states that there is no minimum stay requirement.
Malta: Permanent Residence Is Not Completed by Real Estate Alone
Malta has the Malta Permanent Residence Programme (MPRP), which is available to non-EU, non-EEA, and non-Swiss nationals, among others.
As the name suggests, it is a scheme aimed at Permanent Residence.
The current qualifying real estate thresholds are:
purchase for at least EUR 375,000,
or
lease for at least EUR 14,000 per year.
These are the current thresholds.
However, Permanent Residence cannot be obtained simply by purchasing or leasing real estate.
At present, an Administrative Fee of EUR 60,000 and a Government Contribution of EUR 37,000 are required, and a donation of EUR 2,000 to a registered NGO is also required.
There are also asset requirements. For example, options indicated include Capital Assets of at least EUR 500,000, of which at least EUR 150,000 must be Financial Assets, or at least EUR 650,000, of which at least EUR 75,000 must be Financial Assets.
In other words, Malta needs to be understood as a package consisting of:
real estate,
a Government Contribution,
an Administrative Fee,
asset requirements,
and Due Diligence.
This is how the package should be understood.
It is not a scheme under which “buying a EUR 375,000 house gives you permanent residence.”
Portugal: The Scheme Has Changed from the Era of the “Real Estate Golden Visa”
Portugal is symbolic when discussing Golden Visas.
It was once known as a representative country for real estate investment-based Golden Visas, but after the 2023 legal amendments, the investments eligible under the current Residence Permit for Investment Activity (ARI) have changed significantly.
Representative investments that remain eligible include:
investment of at least EUR 500,000 in certain investment funds,
investment of at least EUR 500,000 in scientific research and similar activities,
investment of at least EUR 250,000 in arts, cultural heritage, and similar areas,
certain job creation,
among others.
Under the current scheme, real estate purchases are no longer among the representative eligible investments for a new ARI.
For that reason,
“buying a house in Portugal gives you a Golden Visa”
is not an appropriate image on which to judge the current scheme.
ARI also has stay requirements. AIMA currently requires a minimum stay of seven days in the first year and fourteen days in each subsequent two-year period.
This is also a good example showing that investor residence schemes are not fixed, but change with housing policy and the political and economic environment.
What Differs When the Five Countries Are Compared?
| Country | Representative investment / asset requirements | Characteristics of residence status | Stay and maintenance features |
| Bahrain | Real estate of at least BHD 130,000 (approx. USD 345,000) | Golden Residency (Permanent Residency) | No minimum stay requirement |
| Greece | Real estate of EUR 250,000 / EUR 400,000 / EUR 800,000, etc. | Investor Residence Permit | Conditions differ significantly by property and region |
| Cyprus | At least EUR 300,000 plus income requirements | Residence right is generally indefinite | May lapse after continuous absence for two years, etc. |
| Malta | Purchase of EUR 375,000 or lease of EUR 14,000 per year, plus Contribution, etc. | Permanent Residence | Multiple requirements beyond real estate |
| Portugal | EUR 500,000 fund investment, EUR 250,000 cultural investment, etc. | ARI | 7 days in the first year, then 14 days per two-year period |
Note: This table simplifies only representative routes. Each scheme has additional requirements, family requirements, investment maintenance requirements, fees, screening, and other conditions.
The Objective Is Not to Find the “Cheapest Golden Visa”
When comparing the schemes in this way, it is easy to focus on which country is the cheapest.
However, from a family office perspective, what truly matters is not only the minimum investment amount.
For example, when considering a “second residence” for a family, the following questions need to be considered together:
Where does the family want to live?
Where does it want to conduct business?
Where should assets be administered?
Where should children be educated?
In which country might the family live in the future?
Where should the family’s tax residence be located?
These issues need to be considered as an integrated whole.
A particularly important point is that residence and tax residence are not the same.
Obtaining an investor Residence Permit or Golden Residency does not automatically make a person a tax resident of that country.
Conversely, actual days of stay, a permanent home, and relationships with family or business may affect the determination of tax residence.
A Japanese resident’s acquisition of overseas residence status does not, by itself, mean that issues relating to Japanese income tax, inheritance tax, gift tax, and similar matters can be avoided.
That is why it is important not to judge residence schemes in isolation, but to consider legal, tax, asset administration, business, and education issues across disciplines.
The “Next” Competition After Golden Visas Shown by Bahrain
Comparing the five countries reveals another interesting change.
Countries are no longer competing simply by offering residence status.
When the Bahraini government lowered the real estate investment threshold for Golden Residency in 2025, it positioned the scheme as part of a national strategy to serve as a regional hub for long-term residence, business, and investment.
In other words, it is not only the residence status itself, but also:
Residence × Investment × Business × Financial Ecosystem.
By combining these elements, Bahrain is seeking to attract global investors and professional talent.
This is an interesting development for Japanese business owners and wealthy families who have watched Asian financial hubs such as Singapore and Hong Kong.
There is no need to think only in binary terms of “Japan or overseas.”
A family may keep Japan as the center of life while holding overseas assets.
Only the children may be educated overseas.
The family may have an overseas business base.
A second residence status may be secured.
Part of asset administration may be diversified overseas.
The necessary combination differs from family to family.
What matters is not going overseas in itself.
What matters is understanding what options exist around the world and then choosing what one’s own family needs.
Investor residence schemes should also be viewed as one of those options.
About This Article
This article compares the outline of investor residence schemes based on publicly available information from national governments, public authorities, and similar sources as of September 2026. These schemes may change in the future. This article does not recommend migration to, investment in, or acquisition of real estate in any specific country.
Please confirm individual application conditions, tax matters, legal matters, inheritance and gift issues, investment decisions, and related matters with the relevant government authorities and appropriate professional advisers.
Main references:
Bahrain Golden Residency
Greece National Registry of Administrative Public Services
Cyprus Migration Department
Residency Malta Agency
Portugal AIMA
