What is a custody account for the Portugal Golden Visa, and how does it work?
The email from the fund is short and polite. “Before we can accept your subscription, please open a custody account in your name with a Portuguese bank.”
That’s all it says. No bank named. No word on what a custody account is, or why the account you already have won’t do.
Here’s what it means, and how the money actually moves.
The short version
- You hold your fund units in a custody account. You can’t send money to it or pay from it.
- You keep your euros in a current account, with a Portuguese IBAN you can send to and pay from.
- If your fund wants the money from a Portuguese account in your name, you need both. With our partner bank, you get both in one account.
- Whether you need one at all depends on your fund. Ask your fund first.
- On €500,000 you pay about €154 a quarter in custody, and €75 plus VAT for the bank’s declaration.
The fund route itself is €500,000 in units of a fund registered with the CMVM, Portugal’s securities regulator. You invest before you apply, and a Portuguese bank’s declaration proves the money came from abroad. The Golden Visa guide covers the rest of the application. This post covers the account.
What is a custody account?
A custody account is where you hold securities. For the Portugal Golden Visa, those securities are the participation units of your fund, registered in your name at a licensed Portuguese bank.
That’s all you use it for. You can’t send a wire to it, and you can’t pay anyone from it.
“Can I just wire the €500,000 to my custody account?”
No. You can’t wire money into it. Think of it as the register of what you own. Your euros go somewhere else, you pay them out to the fund, and what you get back is a line in your custody account saying you hold so many units.
How your money moves
You send from your home bank
Your euros land in your current account
You pay them to the fund
Your units come back to custody
The bank confirms it for your file
The exact route depends on how your fund takes the money.
Here’s what each account lets you do along the way.
Where you hold your fund units
Securities, registered in your name.
- You hold the units you subscribe to
- You can’t send a wire to it
- You can’t pay anyone from it
Where you keep your euros
Cash, with a Portuguese IBAN.
- You wire your money here from home
- You pay the fund and your AIMA fees from it
- You can’t hold fund units in it
You get both, in one place
What we help you open with our partner bank.
- You wire your euros in
- You subscribe to the fund
- You hold the units in your name
Illustrative diagram.
The third card is the account we help Golden Visa clients open: custody for the units and a current account with a Portuguese IBAN for the euros, in one place.
Why can’t a normal bank account hold Golden Visa fund units?
You keep cash in a normal current account. Golden Visa fund units are securities, and you can’t put them there. To hold securities, you need a custody account at a bank that is allowed to keep them for you, registered in your name.
So on the fund route, you need two things:
- Somewhere for the euros to land, with an IBAN your home bank can send to. That’s the current account.
- Somewhere for the units to sit afterwards. That’s the custody account.
With our partner bank’s account, you get both. You keep the money and the investment in one place, and the bank can confirm the whole thing in writing for your Golden Visa file.
How does €500,000 get from your home bank into a Golden Visa fund?
Your €500,000 reaches a Golden Visa fund in six steps, and step one is a NIF. This is the route through our partner bank’s combined custody and current account, with the cost at each step where there is one.
Open the account. NIF first.
You don’t need the €500,000 in place yet.
Portuguese tax number neededSend the investment from your home bank, in euros.
Money that arrives in dollars or pounds is converted at a 0.60% spread. Convert before you send.
About €3,000 on €500,000 if not in eurosSubscribe to your fund from the account.
You send the euros from your current account to the fund.
Bank’s transaction fee, per its price listYour units land in the custody account.
They are registered in your name at a Portuguese bank, which is what your Golden Visa application needs to see.
Registered in your nameThe bank confirms the investment in writing.
It issues the declaration for your Golden Visa file.
€75 + VAT in 3 working days, or €200 + VAT next dayYou pay your AIMA fees from the same IBAN.
AIMA is Portugal’s immigration agency. No second Portuguese account to open for the application.
Same accountYou can’t open the account without a Portuguese tax number. If you don’t have one, get your NIF before the account application starts.
The avoidable cost on that list is step 2. Send euros and the €3,000 never happens.
Does every Golden Visa fund need a custody account?
It depends on the fund, so ask yours how it takes the money before you open a custody account anywhere.
- Some funds take the investment from abroad straight into their own client account and hold the units for you. You may not need this account at all.
- Other funds accept the money only from a Portuguese account in your name. Then you need an account that can receive the euros and hold the units afterwards, which is the account this post describes.
“How do I find out?” Ask the fund three questions, in writing, before you subscribe.
Ask your fund, in writing
- ✓How do you take the money: from my bank abroad, or only from a Portuguese account in my name?
- ✓Where will my units be registered: in a custody account in my name, or held for me by the fund?
- ✓Who issues the bank declaration for my AIMA file?
You will also hear of two other routes:
- a pooled client account run by the fund’s management company
- a client account held by a law firm, which receives your money and makes the subscription for you
Both exist. Whichever route you take, your file needs the same thing: the investment made before you apply, as an international transfer proven by a Portuguese bank’s declaration.
If the fund’s answers leave you unsure what your AIMA file will contain, a consultation with our partner lawyer settles it before any money moves.
Is your custody account the same as the fund’s depositary bank?
No. Your custody account holds the units you bought, registered in your name. The fund’s depositary bank safekeeps the assets of the fund itself.
Works for you
Your custody account
Holds the units you bought, registered in your name, at the bank where you opened it.
Works for the fund
The fund’s depositary bank
Safekeeps the assets of the fund itself. It’s named in the fund’s documents.
Both involve a bank looking after securities, which is how the two get mixed up. The depositary named in the fund’s documents works for the fund. The bank holding your units is the one where you opened your custody account.
Can US citizens get a Golden Visa custody account?
Yes. Our partner bank holds Golden Visa fund units for US persons, and we’ve opened custody accounts there for US Golden Visa clients.
Some Portuguese banks won’t, because of US tax reporting rules (FATCA). So “I’m American, is that a problem?” is a fair question to put to any bank before you start.
What FATCA changes inside the account:
- It stops you doing one thing. As a US person, you can’t trade stocks and bonds through the account.
- It doesn’t touch your fund investment. You send the euros in, you subscribe to the fund, your units are registered in your name and the bank issues your declaration.
Confession: we used to send Golden Visa clients to one of Portugal’s large retail banks. One US file got stuck in round after round of extra document requests, with the client waiting each time.
We stopped. Every Golden Visa client of ours now opens this account, whatever their passport, with a bank that specialises in investment clients.
US tax reporting on a Portuguese fund (the PFIC rules and Form 8621) is one for your CPA. If the money is coming out of retirement savings, our post on using IRA and 401(k) money for the Golden Visa covers that route.
What does a Golden Visa custody account cost?
About €154 a quarter in custody fees on €500,000 of fund units. On top of that: a one-off fee for the bank’s declaration, the bank’s fee on the subscription itself, and a 0.60% conversion spread if the money doesn’t arrive in euros. Figures as of November 2026.
| What | What it costs |
|---|---|
| Custody of your fund units | 0.025% a quarter, minimum €25, plus VAT. About €154 a quarter on €500,000 |
| Account fee while your assets with the bank are under €100,000 | About €130 a quarter (€125 plus 4% stamp duty). Stops once you are over €100,000 |
| The bank’s declaration for your Golden Visa file | €75 plus VAT within 3 working days, or €200 plus VAT for next day |
| Converting money that doesn’t arrive in euros | 0.60% spread, about €3,000 on €500,000 |
| The bank’s fee on the fund subscription | Set out in the bank’s price list |
Three things worth knowing about those fees:
- You pay the account fee only in the gap. It runs while your assets with the bank are under €100,000. Once your units are registered, you are over that line and you stop paying it.
- You pay custody for as long as you hold the units. That’s a little over €600 a year on €500,000.
- You only need the €200 declaration if you’re in a hurry to file. Otherwise the €75 one does the same job in 3 working days.
Our fee for opening the account is €500 for one holder or €600 for a joint account. The full cost breakdown on the service page linked at the end of this post has the rest of what the bank charges.
We don’t advise on tax. For the Portuguese side of the tax questions a Golden Visa raises, book a tax consultation.
How long does it take to open, and do you have to go to Portugal?
About 2 to 3 weeks on a complete file, and you open the Golden Visa custody account from home. There are five stages.
About 2 to 3 weeks on a complete file. Translations and complicated source-of-funds questions add time.
“Do I need the €500,000 in the account before it opens?”
No. Open the account first and send the investment when you’re ready.
The bank makes its own decision on every application, and nobody can promise you an account, or a visa. Our part is the file. Our team checks it and our partner lawyer certifies it before the bank sees anything.
This is the account we help Golden Visa clients open with a licensed Portuguese bank: custody for your units and a Portuguese IBAN for your euros, with the bank’s written confirmation for your file at the end. You open it from home, in about 2 to 3 weeks on a complete file. If your fund has told you it needs a Portuguese account in your name, start here.
Frequently asked questions
Is my money protected while it sits in the account?
Cash deposits at the bank are covered by the Portuguese Deposit Guarantee Fund up to €100,000 per depositor. So while your €500,000 is sitting there as cash, the part above €100,000 is outside that cover.
That is the window between your wire landing and your subscription going out. After that, what you hold is fund units, registered in your name. The bank is licensed and supervised by the Bank of Portugal.
Am I tied to one fund manager?
No. You can hold units of any fund registered with the CMVM, Portugal’s securities regulator, in the account. Which fund you choose is your decision. We don’t choose funds and we don’t give investment advice.
Can I split my €500,000 across more than one fund?
The Golden Visa rules let you combine several qualifying funds to reach €500,000, and the account works with any fund registered with the CMVM. Which funds, and how much in each, is your decision.
Is there a minimum deposit to open the account?
No. There is no minimum deposit to open it. While your assets with the bank are under €100,000 you pay the account fee of about €130 a quarter, and that stops once your units are registered.
Can my spouse and I open a joint account?
Yes. A joint account is €600 instead of €500. It opens in two steps. The first holder’s account opens online, then the second holder posts the bank’s original forms to Lisbon, which adds about two weeks.
Can I pay my AIMA fees and other Portuguese bills from the account?
Yes. You get a euro current account with a Portuguese IBAN. You pay the AIMA fees for your Golden Visa application from it, receive transfers into it and make other payments in Portugal, so you fund the investment and pay the government from the same account.
Do I need a NIF before the account?
Yes. You can’t open the account without a Portuguese tax number, so you get your NIF before you apply for the account. If you don’t have one, we get it for you remotely through our partner lawyer, and it is step one above.
What will the bank ask me?
The bank’s own portal asks about your work, your income and where your money comes from. Those questions are about you, so you answer them directly. Documents in English, Portuguese, French or Spanish are accepted as they are. Other languages need a certified translation, and we tell you which documents those are before the bank sees anything.
Do I have to sign anything on paper?
Not for one holder. You download the bank’s account documents from its portal, initial every page, sign the last one and upload them back. Signing on a tablet is fine. Your signature has to match the one on your passport, with no corrections.
How quickly does the bank confirm my investment for AIMA?
Within 3 working days for €75 plus VAT, or next day for €200 plus VAT. The declaration confirms your investment in writing for your Golden Visa file.
Will the bank definitely accept me?
Nobody can promise that. The bank decides every application on its own checks, and where your money comes from is part of them. A request for more documents on the first round is normal. What we do is make sure the file it sees is complete and certified by our partner lawyer.
