CHANGES!!! – Hungarian Guest Investor Residence Permit

Everybody, who is interested in the Hungarian Golden Visa, is waiting for 1^st of July, when the program starts. Due to the some questions which were unanswered even after the acceptance of the new law and the government decree it is understandable that there are some changes, additional information. We summarized all of the major changes which may have influence on the application process.

1. One of the main changes is that real estate investment will only be available from 1 January 2025 instead of 1 July 2024.
2. Furthermore, in the case of real estate investment, the acquisition of ownership can only take place from 1 January 2025, and ownership acquired before 1 January 2025 cannot be recognised.
3. The validity of the Guest Investor Visa will be 6 months instead of 2 years.
4. The investment of the chosen investment must be made within three months of the first entry into Hungary on a guest investor visa.
5. There is only one “and” word in the change, but it was already obvious that if the applicant makes a declaration of intention to make an investment, then the application must be accompanied by proof of the source of income, so the amendment clarified that both (declaration + proof) are required.
6. Proof that the investment has been made within the time limit shall be verified by a department of the immigration authority with specific responsibilities and powers. In the previous version of the legislation, the immigration authority was designated. The change is probably intended to reduce the burden, which is certainly a positive step towards ensuring that applicants receive their residence permits as quickly as possible.
7. The amended legislation retains the condition that the real estate fund manager must be on the list of qualified market operators, but no longer requires a simplified site security certificate.
8. In relation to real estate fund investments, the following changes have been made, which mainly concern fund managers:

A real estate fund manager that qualifies as an alternative investment fund manager (in Hungarian: alternatív befektetési alapkezelő, ABAK) and that is authorised to manage an alternative investment fund (in Hungarian: alternatív befektetési alap: ABA, hereinafter: AIF) in which the value of the assets under management

1. exceeds a total threshold of EUR 100 million (including leveraged assets), or
2. exceeds the threshold of EUR 500 million in aggregate, where the AIF’s portfolios consist of AIFs which are not leveraged and for which redemption rights cannot be exercised within five years of the date of the initial investment in each AIF.

In addition to the above, a fund manager may also act as an investment fund manager under the applicable legislation, if it also manages a real estate fund in which the total value of assets under management exceeds the threshold of EUR 600 million.

9. The National Card is also available to Serbian and Ukrainian citizens who, as owners or managers of companies, cooperatives or other legal entities, carry out actual work. Until now this was possible on the basis of an employment relationship.