How Golden Visa Advisors Really Get Paid

Golden Visa fund commissions typically fall into three categories:

1. Placement Fees (Finder's Fees)

A one-time payment from the fund manager to the advisor for bringing in a new investor.

• Typical range: 3–5% of the invested amount
• On a €500,000 investment: €15,000–25,000
• When paid: At the time of fund subscription
• Who pays: The fund manager, from the subscription fee or management company resources

This is the most common commission type in the Golden Visa space. The advisor introduces you to a fund, you subscribe, and the fund manager pays the advisor a finder's fee.

2. Trailer Fees (Ongoing Commissions)

An annual payment from the fund manager to the advisor for as long as the investor remains in the fund.

• Typical range: 0.25–1.0% of assets annually
• On a €500,000 investment: €1,250–5,000 per year
• Over a 7-year hold: €8,750–35,000 total
• Who pays: The fund manager, from the annual management fee

Trailer fees create an ongoing incentive for the advisor to keep you in a specific fund — even if better options become available.

3. Performance Fee Sharing

Some advisors negotiate a share of the fund's performance fee.

• Typical arrangement: 10–30% of the fund's performance fee allocation
• When paid: When the fund distributes profits above its hurdle rate
• Less common in Golden Visa funds than in traditional private equity

The Combined Effect

An advisor earning a 4% placement fee plus a 0.5% trailer fee on a €500,000 investment earns approximately €37,500 over 7 years from a single client referral. This creates a powerful financial incentive that may not align with the investor's best interests.

When investing €500,000 in a Golden Visa fund, you face multiple layers of fees. Some are charged directly; others are embedded in the fund structure and reduce your returns.

Direct Fees (You Pay Explicitly)

Embedded Fund Fees (Reduce Your Returns)

Hidden Costs (Rarely Disclosed Upfront)

Total Realistic Cost Over 7 Years

For a single applicant investing €500,000, the total outlay including all fees typically ranges from €550,000 to €620,000 — and that's before considering the impact of embedded fund fees on your net returns.

The difference between a low-fee fund and a high-fee fund can exceed €60,000 over 7 years. This is why fee transparency matters: an advisor earning commissions has no incentive to recommend the cheaper fund.

The EU's Markets in Financial Instruments Directive II (MiFID II) sets clear rules about advisor commissions. Here's what the law actually says:

Article 24(7): Independent Advice

When a firm holds itself out as providing investment advice on an independent basis, it must:

1. Assess a sufficient range of financial instruments on the market — not limited to instruments from entities with close links to the firm
2. Not accept and retain any fees, commissions, or monetary benefits paid by third parties
3. If any third-party payments are received, they must be passed through to the client in full

Only minor non-monetary benefits (e.g., generic market research) may be retained, and only if clearly disclosed.

Article 24(9): Non-Independent Advice

Advisors who are not independent may accept commissions, but only if:

1. The payment is designed to enhance the quality of service to the client
2. It does not impair the firm's duty to act in the client's best interests
3. The existence, nature, and amount of the inducement is disclosed to the client before the service is provided

Portuguese Transposition

Portugal transposed MiFID II into national law through Decreto-Lei 109-H/2021, amending the Portuguese Securities Code (Código dos Valores Mobiliários). The CMVM supervises compliance.

The asset management regime was further updated by Decreto-Lei 27/2023 and CMVM Regulation 7/2023, which entered into force on January 1, 2024.

Here's the critical nuance most investors miss: MiFID II only applies to regulated investment firms.

Many entities recommending Golden Visa funds operate as:

• Immigration law firms — regulated by the Portuguese Bar Association, not CMVM
• Immigration consultancies — not regulated as financial intermediaries
• Relocation agencies — no financial services regulation applies
• Marketing affiliates — operate under commercial partnerships with fund managers

These entities fall outside CMVM's MiFID II supervision entirely. This means:

• They have no obligation to disclose commissions under financial regulation
• They are not required to assess a range of instruments
• They can accept commissions without the quality-enhancement test
• They face no regulatory consequence for conflicted recommendations

Why This Matters

When your immigration lawyer recommends a specific fund, they may be earning a 3–5% commission from that fund manager. Under current regulation, they have no legal obligation to tell you this — because they are not a MiFID II-regulated investment firm.

This is a structural gap in investor protection that ESMA (European Securities and Markets Authority) has acknowledged in its supervisory convergence work.

What You Can Do

1. Ask directly: "Do you receive any payment, commission, or benefit from the fund you're recommending?"
2. Get it in writing: Request a written disclosure of all compensation arrangements
3. Compare independently: Don't rely on a single advisor's recommendation — use our fund database to verify claims
4. Check CMVM registration: Verify whether your advisor is registered with CMVM as an investment intermediary
5. Understand the difference: An immigration lawyer recommending a fund is not the same as a regulated investment advisor providing independent advice

Before accepting any fund recommendation, ask these questions and evaluate the answers:

About Their Compensation

1. "Do you receive any payment, fee, commission, or benefit from the fund manager or fund distributor?" — A "no" should be verifiable. A "yes" should include the exact amount or percentage.

2. "Are you registered with CMVM as an investment intermediary?" — Check their answer against the CMVM public register. If they're not registered, MiFID II disclosure rules don't apply to them.

3. "Can you provide a written disclosure of all compensation you receive related to this recommendation?" — Under MiFID II Article 24(9), regulated firms must disclose this. Unregulated advisors have no obligation, but their willingness to disclose is telling.

4. "How many different funds have you recommended in the past 12 months?" — If the answer is one or two funds across all clients, commission influence is likely.

About Their Process

1. "How many CMVM-approved funds did you evaluate before making this recommendation?" — An independent assessment should consider a meaningful portion of the 30+ available funds.

2. "What specific factors about my situation led you to recommend this particular fund over alternatives?" — Generic answers suggest a one-size-fits-all approach driven by commission relationships.

3. "Can you show me a fee comparison between this fund and at least two alternatives?" — If they can't or won't, they may not have done comparative analysis.

About Risks and Limitations

1. "What are the specific risks and downsides of the fund you're recommending?" — Every fund has risks. An advisor who can't articulate them hasn't done proper due diligence.

2. "What happens if this fund underperforms or I need to exit early?" — Understanding exit mechanics is critical, especially with the potential 10-year citizenship timeline.

3. "Do you carry professional indemnity insurance covering your fund recommendations?" — This reveals whether they accept professional liability for their advice.

Red Flags in Responses

• Refusing to answer or deflecting compensation questions
• Claiming "everyone recommends this fund" without explanation
• Inability to name alternatives they considered and rejected
• Pressuring you to decide quickly ("limited allocation remaining")
• Dismissing the relevance of fee differences between funds

Under EU regulation, there are two distinct advisory models:

Independent Advisors (MiFID II Article 24(7))

Tied/Non-Independent Advisors (MiFID II Article 24(9))

Unregulated Advisors (Immigration Consultancies)

The Key Takeaway

The advisory model determines whose interests are being served. An independent advisor paid only by you has a fundamentally different incentive structure than an immigration consultant earning 4% from a fund manager.

Neither model is inherently "wrong" — but you deserve to know which model your advisor operates under before trusting their recommendation.

We believe transparency is the foundation of trust. Here's our position on commissions:

We do not accept commissions from fund managers. Our revenue comes exclusively from advisory fees paid by investors. This means:

• We can recommend any fund — including funds that don't offer commissions
• We have no financial incentive to push higher-fee funds over lower-fee alternatives
• Our fund database covers all CMVM-approved funds, not just commission-paying partners
• Our success depends on your satisfaction, not fund manager relationships

We publish this page because we believe every investor deserves to understand how advice is compensated in this industry. Whether or not you choose to work with us, understanding commission structures helps you evaluate any advisor's recommendations.

For more on our approach, see our About page and case studies showing how independent advice has helped investors avoid costly mistakes.