What Happens to Your Money If a Golden Visa Program Closes?

Understanding Golden Visa Program Closures

Golden visa and citizenship-by-investment programs can close with little warning. Portugal announced major changes to its popular golden visa in 2023. Ireland shuttered its program in 2023 after years of operation. These closures leave many applicants wondering: what happens to the money I've already invested or paid?

The short answer is that it depends on your application stage, the specific program rules, and what types of fees you've paid. But understanding the general principles can help you navigate this uncertain situation.

Different Types of Fees Face Different Outcomes

When you apply for a golden visa or investment migration program, you typically pay several categories of fees. Each may be treated differently if a program closes.

Government Application Fees

Government processing fees are usually non-refundable once submitted, even if a program closes before your application is decided. These fees cover administrative costs the government has already incurred while reviewing your file.

However, some governments have made exceptions during program closures. The specific refund policy often depends on how the closure is announced and whether your application was officially received before the closure date.

Due Diligence and Background Check Fees

Due diligence fees paid to governments are typically non-refundable regardless of program closure. These cover the costs of background checks, document verification, and security screenings that have already been performed.

Investment Amounts

This is where outcomes vary significantly. Your main investment—whether in real estate, bonds, business ventures, or government funds—is usually protected by the structure of the investment itself rather than by the visa program.

Real estate investments: If you've purchased property, you own that property regardless of program closure. You may not receive residency rights, but your ownership remains valid. You can typically hold, rent, or sell the property according to local real estate laws.

Government bonds or funds: Many programs require investments in approved government bonds or funds. If a program closes, you generally retain ownership of these financial instruments. The terms of redemption follow the bond or fund agreement, not the visa program timeline.

Business investments: Capital invested in businesses or job creation programs remains invested according to your commercial agreements. The closure of a visa program doesn't automatically dissolve business contracts.

Legal and Professional Fees

Fees paid to lawyers, agents, and facilitators like Citizenships.legal are typically for services already rendered. Our licensed partner lawyers perform legal work throughout your application process—document preparation, filing submissions, correspondence with authorities, and advisory services.

Once these services are delivered, the fees generally aren't refundable due to program closure. However, the specific terms depend on your service agreement and what stage of work has been completed.

How Application Timing Affects Your Situation

The stage of your application when a program closes significantly impacts what happens next.

Applications submitted before closure announcement: Many countries honor applications that were officially submitted before a closure date. Your application may still be processed under the old rules, though timelines might extend. In these cases, your fees and investments proceed as originally planned.

Applications in progress but not submitted: If you've paid fees but haven't officially submitted your application when closure is announced, you face the most uncertainty. Some governments provide grace periods; others do not.

Applications not yet started: If you've only paid initial consultation or preparation fees when a program closes, you've typically only paid for advisory services you've received. The substantial government fees and investment amounts wouldn't have been paid yet.

What Governments Typically Do During Closures

Based on historical program closures, governments generally follow a few patterns:

• They announce a closure date and may provide a brief window for final applications
• Applications officially submitted before the deadline are usually processed
• Government fees submitted before closure are rarely refunded
• Investment structures remain intact, though they may no longer qualify you for residency
• Some governments offer transition options or alternative programs

The government ultimately decides each application based on its own policies and procedures. No facilitator or advisor can guarantee outcomes, especially during program transitions.

Protecting Yourself When Applying

While you can't eliminate the risk of program closure, you can take steps to understand your exposure:

• Review the refund and cancellation terms in all agreements before signing
• Understand whether investments are held in escrow until approval
• Ask about the timeline for when various fees will be paid
• Stay informed about political discussions around your chosen program
• Work with experienced professionals who monitor program stability

At Citizenships.legal, our licensed partner lawyers who handle the legal aspects of applications stay current on program changes and can advise on the risk landscape. We manage the legal process while keeping you informed of developments that might affect your application.

The Bottom Line

Program closures are relatively rare but not unprecedented. When they happen, complete loss of all money is unusual. Government fees paid for processing work already performed are typically non-refundable, while investment amounts are usually protected by the underlying investment structure.

The key is understanding what you're paying for at each stage and what the terms are. The government makes the final decision on your application and any refund policies—not advisors or facilitators.

If you're considering a golden visa or investment migration program, understanding these risks is part of making an informed decision. Explore the current programs available and discuss your specific situation with qualified professionals.

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