Everything You Need to Know About the Bitizenship Portugal Fund

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Bitizenship's Portugal Fund is the first and largest Bitcoin Ecosystem Golden Visa Fund in Europe, a regulated, CMVM-registered private equity vehicle purpose-built for global investors pursuing Portuguese residency without abandoning their Bitcoin conviction.

As Portugal's Golden Visa market continues to grow in 2026, the Bitizenship Portugal Fund remains the only compliant fund structure that combines EU residency eligibility with indirect exposure to the Bitcoin ecosystem through a 100%-owned Portuguese portfolio company.

This article covers everything investors need to know about the Bitizenship Portugal Fund, from how the fund is structured and what it invests in, to the full residency timeline, eligibility requirements, costs, and how to get started.

Key Takeaways

Bitizenship's Portugal Fund is Europe's first Bitcoin Ecosystem Golden Visa Fund.
The minimum qualifying investment is €500,000 with a 14-day stay requirement.
The fund is registered as nr. 2089 before CMVM, managed by 3 Comma Capital.

What Is the Bitizenship Portugal Fund

The Bitizenship Portugal Fund is a closed-ended, Golden Visa-eligible private equity fund, and the only fund of its kind in Europe. It is registered as nr. 2089 before CMVM, Portugal's Securities Market Commission, managed by licensed fund manager 3 Comma Capital, with Bison Bank as depositary and BDO as auditor.

Bitizenship serves as the fund's promoter and sponsor, meaning the same firm that designed and built the investment vehicle is the one advising investors on it, creating a more medium-to-long-term alignment of incentives that does not exist in a placement-based advisory model.

The fund was built for one specific investor profile: globally mobile, Bitcoin-aligned individuals who want EU residency through a compliant investment structure without being forced into real estate or a generic private equity mandate that has no connection to the asset they hold conviction in. It is not an advisory service.

It is not a referral platform. It is the investment product itself, purpose-built, and fully operational.

What Does the Fund Invest In

The Bitizenship Portugal Fund invests in a 100%-owned Portuguese portfolio company whose activities are focused exclusively on the Bitcoin ecosystem. The portfolio company is a research and investment entity where investors gain indirect Bitcoin ecosystem exposure through the company's activities, not through direct Bitcoin purchases made on their behalf.

Annual distributions of profits may be possible at the end of each year, subject to a vote by the investors' assembly. Returns are not guaranteed, and the investment carries risk including the potential loss of capital. Investors should review the official fund documents for a complete breakdown of the investment strategy and risk factors before making any decision.

How the Bitizenship Portugal Fund Qualifies Investors for a Golden Visa

Portugal's Golden Visa program allows non-EU, non-EEA, and non-Swiss nationals to qualify for Portuguese residency through a qualifying investment in a Portuguese-registered private equity fund. The qualifying investment threshold for fund-based Golden Visas is €500,000, and the Bitizenship Portugal Fund meets the full legal criteria for Golden Visa eligibility under Portuguese law.

Once the investment is made and the application is approved, the investor receives a Temporary Residence Permit, commonly referred to as the Golden Visa card. This card grants the right to live, work, and study in Portugal, travel freely across the Schengen Area, and access Portugal's public healthcare and education systems.

Critically, the investor does not need to relocate. Portugal requires only 14 days of physical presence in Portugal every two years to maintain and renew the residence permit, one of the lowest stay requirements of any active residency program in Europe. The investor can continue living wherever they currently live and visit Portugal twice over a two-year cycle to remain compliant.

Family members can also be included under the same application. An eligible family unit covers the investor's spouse or legal partner, dependent children, and dependent parents, each receiving their own Temporary Residence Permit and the same rights as the primary applicant.

Bitizenship Portugal Fund: Full Details and Key Metrics

Fund Structure at a Glance

Investment: €500,000
Structure: Closed-ended private equity fund
CMVM Registration: Nr. 2089
ISIN: PTOISUIM0006
Fund Manager: 3 Comma Capital
Fund Promoter: Bitizenship
Depositary: Bison Bank
Auditor: BDO
Fund Cap: €30,000,000
Fund Close: 2032
Management Fee: 1.50% per year
Performance Fee: 10%
Minimum Stay Requirement: 14 days every 2 years
Subscription: Monthly

Additional Costs to Factor In

The €500,000 fund investment is the qualifying investment, it is not the total cost of the process. Investors should also account for the following when planning their budget:

Portuguese government Golden Visa application fees, which are set by AIMA and separate from the fund investment
Legal representation and immigration attorney fees for preparing and submitting the application
AIMA processing fees, payable at the point of application submission
The fund's annual management fee of 1.5%, which applies throughout the investor's holding period

Bitizenship provides guidance on the full cost picture during the initial consultation. Investors should always consult the official fund documents and a licensed immigration advisor for a complete and accurate breakdown of all applicable costs before committing.

Bitizenship's Portugal Golden Visa Program

Who Can Invest in the Bitizenship Portugal Fund?

Nationality and Residency Eligibility

The Bitizenship Portugal Fund is open to non-EU, non-EEA, and non-Swiss nationals. These are the investors for whom the Golden Visa delivers the most meaningful value, EU citizens already hold the right to live and work in Portugal under EU freedom of movement, making the Golden Visa unnecessary for them.

Applicants must be of legal adult age and must not hold Portuguese nationality at the time of application.

Financial Eligibility

The minimum investable capital required is €500,000, exclusive of additional fees and legal costs. Funds must come from a clean, documented source, Portugal applies strict AML and KYC requirements to all Golden Visa applications, and source of funds documentation is a non-negotiable part of the process.

Required documentation includes bank statements, tax records, and proof of asset origin. For Bitcoin holders specifically, this means exchange transaction history, proof of BTC-to-fiat conversion, and supporting compliance documentation. Bitcoin must be converted to fiat prior to investment, direct BTC transfer into the fund is not possible.

The conversion and its documentation must satisfy AIMA's source of funds requirements, and Bitizenship's team guides Bitcoin holders through this process as a standard part of onboarding.

Legal and Background Requirements

Clean criminal record in both the applicant's country of nationality and country of current residence
No prior visa violations or immigration non-compliance in Portugal or the broader Schengen Area
Full KYC and AML compliance, Bitizenship's team supports investors through the complete documentation process from the initial consultation through to application submission

The Full Residency Timeline: What to Expect at Every Stage

Step 1: Initial Consultation with Bitizenship

The process begins with a consultation with Bitizenship's team. This covers the investor's eligibility, investable capital, source of funds, family situation, and residency goals.

The consultation is the right time to ask every question about the fund structure, the program, and the full cost picture before making any commitment. You can book a demo directly through Bitizenship's website.

Step 2: Documentation Preparation

Once the investor decides to proceed, the documentation package is assembled in coordination with Bitizenship's team and the investor's licensed Portuguese immigration attorney. The package includes passport copies, criminal record certificates issued by the relevant authorities, source of funds documentation, and proof of investment readiness.

This stage typically takes 4 to 8 weeks depending on the complexity of the investor's documentation requirements.

Step 3: Fund Subscription and Capital Transfer

The investor subscribes to the Bitizenship Portugal Fund and transfers the €500,000 qualifying investment to the fund's depositary, Bison Bank. The fund operates on a monthly subscription cycle, investors must coordinate their entry timing with Bitizenship's team.

Upon subscription, proof of investment is issued and forms a core part of the Golden Visa application package.

Step 4: Golden Visa Application Submission to AIMA

With the documentation package complete and the fund subscription confirmed, the application is formally submitted to AIMA, the Portuguese Immigration and Borders Service. The submission includes proof of investment, the full documentation package, and a biometric appointment request for the investor and any included family members.

Step 5: AIMA Biometric Appointment

AIMA processes the application and schedules a biometric appointment in Portugal. Under current conditions in 2026, biometric appointments are scheduled approximately 11 to 15 months after application submission, reflecting AIMA's ongoing processing backlog.

The investor, and each included family member, must attend their biometric appointment in person in Portugal. This is the one stage that requires physical presence in Portugal before the TRP is issued.

Step 6: TRP Issuance (Golden Visa Card)

Following the biometric appointment, AIMA issues the Temporary Residence Permit, the Golden Visa card. The realistic total timeline from application submission to TRP issuance is 17 to 27 months under current AIMA processing conditions.

The TRP is valid and renewable every two years, with 14 days of physical presence in Portugal required in each two-year period to maintain eligibility for renewal.

Step 7: Permanent Residency Eligibility

After five years from the date of first TRP issuance, the investor becomes eligible to apply for Portuguese Permanent Residency. This is governed by the Foreigners Act (Lei 23/2007) and is unchanged by any 2026 legislative reforms.

Permanent Residency removes the renewal requirement and provides a more stable, long-term legal status in Portugal.

Step 8: Citizenship Pathway

For investors whose long-term goal is a Portuguese passport, the pathway to citizenship runs through Permanent Residency and is subject to all applicable requirements under Portuguese nationality law.

Under the new Portuguese nationality law promulgated on May 3, 2026, which was not yet in force at the time of writing, the applicable timelines from TRP issuance are:

Non-EU and non-CPLP nationals: 10 years from first TRP issuance
EU and CPLP nationals: 7 years from first TRP issuance

Citizenship requires demonstrating sufficient ties to Portugal, passing a Portuguese language test at A2 level, and maintaining a clean criminal record throughout the residency period. It is subject to all legal, language, residency, and integration requirements under Portuguese nationality law; it is a consequential pathway, not an automatic outcome.

Investors who submitted pending nationality applications before the new law's entry into force may be grandfathered under the previous 5-year rule. Anyone in this position should consult a licensed Portuguese nationality lawyer for specific guidance.

Full Timeline at a Glance

Consultation to fund subscription: 4–8 weeks
Application submission to biometric appointment: 11–15 months
Application submission to TRP issuance: 17–27 months total
TRP issuance to PR eligibility: 5 years
TRP issuance to citizenship eligibility (non-EU/non-CPLP): 10 years

What Makes the Bitizenship Portugal Fund Different from Other Golden Visa Funds

Bitizenship vs. Generic Golden Visa Advisory Firms

Firms like Henley & Partners and La Vida Golden Visas are well-established operators in the investment migration space. They are strong at holistic, multi-jurisdictional advisory, coordinating legal, tax, and relocation planning across multiple programs simultaneously, and for investors whose needs are broad, that breadth of service has genuine value.

Bitizenship is a different kind of firm. The firm that advises investors on the fund is the same firm behind the product itself, with in-depth technological and hands-on experience in the Bitcoin ecosystem, and this creates a more medium-to-long-term alignment of incentives.

In startup terms, Bitizenship owns the product: the Bitizenship Portugal Fund was designed and built by the same team that advises on it. That level of product ownership and accountability does not exist in a placement-based advisory model, where the advisory firm and the investment vehicle are separate entities with separate interests.

For an investor who wants a specialist, not a generalist, and who wants to work with a firm that has skin in the game on the product they're recommending, Bitizenship and a conventional advisory firm are structurally different propositions.

No other Golden Visa-eligible fund in Portugal, whether placed by an advisory firm or sold directly, is built around the Bitcoin ecosystem. That mandate does not exist anywhere else in the market.

Bitizenship vs. Portugal Real Estate Golden Visa Routes

Portugal closed its real estate Golden Visa routes in October 2023. Direct property investment is no longer a qualifying pathway for new applicants.

The fund route is now the primary qualifying investment pathway available, and among all compliant qualifying funds currently registered in Portugal, the Bitizenship Portugal Fund is the only one with a Bitcoin ecosystem mandate.

The Core Differentiator

For Bitcoin-aligned investors, a generic private equity fund with no connection to Bitcoin is a philosophically misaligned investment. The Bitizenship Portugal Fund was designed to resolve that tension, allowing investors to qualify for EU residency while keeping their residency investment aligned with the thesis they already hold.

Benefits of the Bitizenship Portugal Fund Beyond Residency

The Golden Visa card itself is the immediate outcome of the process, but the strategic value of what the Bitizenship Portugal Fund makes possible extends well beyond a residence permit.

1. Schengen Area travel

Portuguese residency grants the right to travel freely across all 27 Schengen Area countries without a visa. For investors currently navigating short-stay limits or visa requirements across Europe, this is an immediate and material quality-of-life improvement.

2. Family inclusion

A spouse or legal partner, dependent children, and dependent parents can all be included under the same Golden Visa application. Each family member receives their own Temporary Residence Permit and the same rights as the primary investor.

3. Access to Portugal's public services

Golden Visa holders gain access to Portugal's public healthcare and education systems, a meaningful benefit for investors who spend time in Portugal or who include family members who do.

4. No requirement to relocate

The 14-day stay requirement every two years means investors can maintain their current lifestyle without disruption. There is no obligation to move, change tax residency, or reorganize personal or professional life around the investment.

5. Permanent Residency pathway

After five years from first TRP issuance, the investor becomes eligible for Portuguese Permanent Residency, a more stable legal status that removes the renewal cycle entirely.

6. EU banking and business infrastructure

EU residency opens access to European banking relationships and the ability to register and operate businesses within the EU, an infrastructure advantage that is particularly relevant for Bitcoin-aligned investors managing cross-border wealth.

7. Strategic optionality

A second legal home in the EU is a durable piece of long-term mobility planning. For Bitcoin holders who think in decades and in sovereignty, that optionality is exactly the kind of asymmetric, low-maintenance position the Bitizenship Portugal Fund is built to deliver.

Risk Disclosure: What Investors Should Know

The Bitizenship Portugal Program is an investment in a private equity fund, and all the risks that come with that category apply. Investors may lose some or all of their invested capital. Returns are not guaranteed, annual distributions depend on the portfolio company's performance and require a vote by the investors' assembly.

The portfolio company's activities are focused on the Bitcoin ecosystem, which means the fund is exposed to the volatility inherent in Bitcoin and blockchain-related markets. Regulatory uncertainty can also affect the fund's operations or reduce returns over the fund's life.

The fund's cost structure includes a 1.5% annual management fee and a 10% performance fee. Portuguese government Golden Visa application fees and personal legal costs are separate from the qualifying investment and are borne by the investor independently.

AIMA processing timelines quoted in this article reflect current conditions as of 2026 and are subject to change. Citizenship and Permanent Residency are subject to eligibility, neither is automatically granted, and both depend on meeting all applicable legal, language, residency, and integration requirements at the time of application.

Investors should review the official fund documentation in full, engage a licensed Portuguese immigration attorney, and consult a qualified financial advisor before making any investment decision.

How to Get Started with the Bitizenship Portugal Fund

Step 1: Visit Bitizenship's website and book an initial consultation with the team
Step 2: Attend the consultation: cover eligibility, source of funds, family situation and timeline goals
Step 3: Receive Bitizenship's program overview and the official fund documentation for review
Step 4: Engage a licensed Portuguese immigration attorney, Bitizenship's network can assist with referrals
Step 5: Prepare the documentation package: passports, criminal record certificates, source of funds records, and any Bitcoin-to-fiat conversion documentation
Step 6: Subscribe to the fund and transfer the €500,000 qualifying investment to Bison Bank
Step 7: Submit the Golden Visa application to AIMA together with your attorney
Step 8: Attend your AIMA biometric appointment in Portugal
Step 9: Receive your TRP (Golden Visa card) and begin your residency period

Conclusion

The Bitizenship Portugal Fund is the only Golden Visa-eligible investment vehicle in Europe that gives Bitcoin-aligned investors a compliant path to EU residency without forcing a departure from their Bitcoin conviction.

From the fund's CMVM-registered structure and Bitcoin ecosystem mandate to the full residency and PR timeline, no other fund in the market is built for the same investor profile or to the same standard of alignment.

Get in touch with Bitizenship to book your initial consultation and find out whether the Bitizenship Portugal Fund is the right structure for your residency goals.

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FAQs:

1. What is the Bitizenship Portugal Fund and how does it qualify investors for a Golden Visa?

The Bitizenship Portugal Fund is a closed-ended private equity fund registered as nr. 2089 before CMVM that qualifies investors for Portugal's Golden Visa by meeting the €500,000 qualifying investment threshold required under the Portuguese residency-by-investment program. The fund invests in a 100%-owned Portuguese portfolio company focused on the Bitcoin ecosystem and is managed by 3 Comma Capital, with Bison Bank as depositary and BDO as auditor, providing the full regulated structure required for Golden Visa eligibility under Portuguese law.

2. How long does it take to get Portuguese residency through the Bitizenship Portugal Fund?

The Bitizenship Portugal Fund's residency timeline runs approximately 17 to 27 months from application submission to TRP issuance, reflecting current AIMA processing conditions in 2026, with biometric appointments typically scheduled 11 to 15 months after application submission, followed by final TRP issuance. Investors should factor in an additional 4 to 8 weeks for documentation preparation and fund subscription before the application is submitted, making the total time from first consultation to residence card issuance realistically between 20 and 35 months.

3. Why is the Bitizenship Portugal Fund a better option for Bitcoin holders than a generic Golden Visa fund?

The Bitizenship Portugal Fund is a better option for Bitcoin holders than a generic Golden Visa fund because it is the only CMVM-registered Golden Visa-eligible fund in Europe whose investment mandate is focused on the Bitcoin ecosystem, allowing investors to qualify for EU residency while maintaining strategic alignment with the asset class they already hold conviction in.

4. What happens to an investor's money once they subscribe to the Bitizenship Portugal Fund?

The Bitizenship Portugal Fund deploys subscribed capital into a 100%-owned Portuguese portfolio company focused on Bitcoin ecosystem research and investment activities, with the fund's depositary, Bison Bank, holding and safeguarding investor assets throughout the fund's life, which runs through 2032.

5. Can family members be included in a Golden Visa application through the Bitizenship Portugal Fund?

Yes. The Bitizenship Portugal Fund's Golden Visa pathway allows the primary investor to include eligible family members, including a spouse or legal partner, dependent children, and dependent parents, under the same application, with each family member receiving their own Temporary Residence Permit.

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‍Disclaimer:
This article is published by Bitizenship for informational and educational purposes only. It reflects Bitizenship's perspective on the investment migration market and is not intended as legal, tax, immigration, investment, or financial advice, nor as an offer or solicitation to subscribe to any investment product. Comparisons with other firms are based on publicly available information and our own assessment of structural differences in business models. We have aimed for accuracy, but descriptions of programs, regulations, and competitor offerings are necessarily summaries and may not capture every legal nuance. Program terms, eligibility criteria, processing times, tax regimes, and regulatory frameworks change frequently and vary by individual circumstances. The Bitizenship Portugal Fund is a regulated alternative investment fund registered as nr. 2089 before CMVM. Any investment decision should be made only after reviewing the official fund documentation (prospectus, KID, subscription agreement) and consulting independent legal, tax, and financial advisors qualified in the relevant jurisdictions. Past performance does not guarantee future results. Capital is at risk. Residency and citizenship outcomes depend on meeting all legal, language, residency, and integration requirements set by the relevant authorities and are never guaranteed. Always refer to official government and regulatory sources, and engage qualified professionals before acting on any information in this article.

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