Europe is adjusting border and residence rules that directly affect Brazilians — both travelers and investors and executives seeking residence. Three fronts deserve immediate attention: digital borders (EES/ETIAS), investment residency programs (changes in Spain, Greece and Portugal) and evolution of the long-term residence regulatory framework.
1) Digital borders: EES on October 12, 2025; ETIAS at the end of 2026
- The Entry/Exit System (EES) will come into operation on October 12, 2025, replacing manual stamping with biometric collection and automatic registration of entries/exits of third country nationals (such as Brazilians). Progressive implementation until April 2026.
- O ETIAS (autorização eletrônica para isentos de visto) foi adiado para o último trimestre de 2026 — não é necessário em 2025.
Practical impact: more travel compliance (biometrics, prior checks and stay history). For executives, families and investors, it will be crucial to plan travel (first entry may require more time) and align moving/residency deadlines to avoid inconsistencies between immigration status and business routines.
2) Residency by investment (RBI): reconfiguration of programs
- Spain officially ended the golden visa on April 3, 2025, with a direct impact on routes via real estate investment. Current holders preserve their status, but new entries per property are no longer possible.
- Greece raised real estate investment minimums to €800,000 in areas of high demand (e.g.: Athens, Thessaloniki, islands such as Mykonos/Santorini) and €400,000 in the rest of the country; exceptions of €250 thousand for specific restoration/conversion. Effective from 1st September. 2024, with consolidations in 2025.
- Portugal maintained the program, but prohibited the real estate route (since 2023). Alternatives remain such as regulated funds (of €500 thousand), job creation and cultural investment (e.g. donation of €250 thousand), which remain relevant in 2025.
Practical impact: investors need to replace real estate theses with regulated financial vehicles, job creation or cultural projects; due diligence becomes decisive (managers/funds, AML risks, governance). In markets with higher thresholds (Greece), equity/VC models and business structures gain traction.
3) Long-term residence in the EU: evolving framework
- The review of the Long-Term Residents Directive has not progressed uniformly; Member States continue to adjust national regimes. In other words, rules and deadlines may vary by country, requiring a case-by-case design for family stabilization and intra-EU mobility.
How LTC Group supports executives, families and family offices
- Mobility planning: EES/ETIAS schedule, document adequacy, input strategy and evidence (means of subsistence, insurance, bonds).
- New generation investment residency: jurisdiction and route selection (regulated funds in Portugal; sectoral alternatives in Greece), due diligence of managers/assets, risk mapping regulatory and ESG.
- Asset structuring and tax planning: compatibility between country of residence, source of income and jurisdiction of assets; mitigation of double taxation risks and economic substance.
- Governance and compliance: multi-jurisdictional legal support, KYC/AML, review of contracts and immigration documentation, as well as integration with business goals (expansion, M&A, talent mobility).
Key message for 2025–2026: anticipate changes (EES/ETIAS), review RBI theses and residency plan considering taxes, family and executive mobility. A robust project integrates immigration + tax + patrimonial + governance.
Sources: https://home-affairs.ec.europa.eu / https://euneighborseast.eu / https://www.abta.com / https://travel-europe.europa.eu / https://www.goldenvisas.com / https://investmentmigration.org / https://www.fragomen.com
