Half of the advice online about European golden visas is out of date. Spain's programme is gone. Malta's citizenship route has been repealed. Portugal's path to a passport has doubled in length. If you are an American reading a 2023 article about buying a Lisbon apartment and collecting a passport five years later, none of that is true any more.

Here is where the major programmes actually stand in 2026, and the one issue that matters more for a US citizen than any of the immigration detail.

Spain: closed

Spain abolished its Golden Visa with effect from 3 April 2025. Applications filed before that date are still processed under the old rules, and existing permits remain valid and renewable, but no new investor visas are being issued.

Americans moving to Spain now use one of two routes. The non-lucrative visa requires passive income of roughly 28,800 euros a year for the main applicant plus 7,200 per dependant, and it does not permit remote work of any kind. The digital nomad visa, created by the 2022 startups law, requires around 2,442 euros a month and does allow you to keep a US employer. Choosing the wrong one is the most common mistake I see.

Portugal: open, but the passport now takes ten years

The Portuguese programme still exists. Real estate does not. The property and 1 million euro capital transfer routes were removed by the Mais Habitacao law in October 2023. What remains is a 500,000 euro subscription into a qualifying non-real-estate fund, 500,000 into scientific research, 250,000 into cultural heritage, 500,000 into a Portuguese company creating five jobs, or the creation of ten jobs.

The bigger change is citizenship. Under the nationality law that took effect on 19 May 2026, naturalisation requires ten years of residency for US citizens, up from five. Applications already pending stay under the old rules. Portugal still works as a residency. As a passport plan it is now a decade-long commitment.

Greece: open, and tiered

Greece restructured its thresholds in 2024. It is now 800,000 euros in Attica, Thessaloniki, Mykonos, Santorini and the larger islands, 400,000 in the rest of the country, and 250,000 for converting commercial property to residential or restoring a listed building. The two higher tiers require a single property of at least 120 square metres, and short-term rental of the qualifying property is prohibited.

Italy: open, but the tax regime got more expensive

The investor visa starts at 250,000 euros into an innovative startup, 500,000 into an Italian company, 1 million for a philanthropic contribution or 2 million in government bonds. What changed is the tax side. The flat substitute tax on foreign income rose to 300,000 euros a year for anyone taking up Italian residency from 1 January 2026, against 200,000 for 2025 arrivals.

Malta and Cyprus

Malta's citizenship-by-investment scheme was ruled unlawful by the Court of Justice of the European Union in April 2025 and repealed by Maltese law in July 2025. The separate residency programme is unaffected and remains open. Cyprus still offers permanent residency at 300,000 euros plus proof of 50,000 a year of income from outside Cyprus. Its citizenship route has been closed since 2020.

The part that matters most if you are American

Almost every article on this subject stops at the immigration rules. For a US citizen, the immigration rules are usually the easy part.

Portugal's dominant remaining route is a 500,000 euro fund subscription. Portuguese qualifying funds are, with very few exceptions, Passive Foreign Investment Companies under US tax law. That means punitive treatment under section 1291, interest charges on deferred gains, taxation at top marginal rates, and an annual Form 8621 for every fund you hold. Cyprus category D fund units raise the same issue.

In other words, the most popular route into the most popular programme is, for an American, a tax trap that can quietly consume a meaningful share of the return. The cultural heritage route, the job creation route and the company formation route avoid it entirely.

None of these programmes reduce your US filing obligations. You are taxed on worldwide income as a US citizen wherever you live, and FBAR and FATCA reporting continues. What changes is the foreign side, and whether the foreign tax you pay is creditable against what you owe the IRS.

How to choose

Decide what you actually want first. Residency and a passport are different products with different timelines. Then work backwards from the US tax treatment of the specific investment rather than from the brochure. A programme that looks cheap and turns out to be a PFIC is more expensive than one that looks expensive and is not.

I work alongside immigration counsel on the visa itself and handle the financial and US tax side. If you are weighing one of these routes, model the after-US-tax outcome before you commit capital.