- Governed by Council Directive 2003/109/EC on the status of long-term resident third-country nationals.
- Requires five years of continuous legal residence in an EU Member State.
- Grants secure residence, equal treatment, and limited intra-EU mobility.
- Implementation varies; Ireland and Denmark are not bound by the Directive.
- National permanent residence programmes (e.g. Malta MPRP) grant settlement from the outset but lack EU-wide mobility.
- Strategic planning is essential to align residence, tax, and integration goals.
What Is EU Long-Term Residence Status?
EU Long-Term Residence (EU LTR) provides indefinite residence rights for third-country nationals who have legally and continuously lived in a Member State for five years. The status harmonises key rights in employment, education, and social access, while strengthening security of tenure.
“A third-country national who has resided legally and continuously for five years in the territory of the Member State concerned shall be eligible to acquire long-term resident status.”
— Article 4(1), Council Directive 2003/109/EC
EU LTR holders enjoy:
- Equal treatment with nationals regarding work, study, and services.
- The right to reside in another Member State under simplified re-qualification.
- Stability of residence and potential eligibility for citizenship under national law.
Implementation, however, is not uniform; some Member States apply stricter integration or income tests, and Denmark and Ireland have opted out.
How National Permanent Residence Schemes Differ
Alongside the EU LTR system, many Member States operate domestic permanent residence regimes. These are national frameworks available through investment, property ownership, or retirement income—typically granting permanent status immediately rather than after five years.
National schemes generally:
- Provide permanent residence from approval, without a qualifying period.
- Offer no intra-EU mobility beyond Schengen visa access.
- Rely on national legislation, with differing renewal and citizenship rules.
- Are often linked to economic or real-estate contributions.
Countries Offering True (National) Permanent Residence
Malta
The Malta Permanent Residence Programme (MPRP) grants non-EU nationals permanent residence through a combination of property investment, government contribution, and due-diligence vetting. It allows residence and Schengen travel and can lead to EU LTR eligibility after five years of legal residence.
Cyprus
Cyprus offers a Permanent Residence Permit via qualifying property purchase. While separate from the EU LTR regime, it grants indefinite stay and simplified renewal for dependants.
Greece
The Greece Golden Visa allows residence through real-estate investment with five-year renewable permits and Schengen mobility. Holders may apply for EU LTR or national PR after sustained residence.
Golden Visas vs Permanent Residence
The term 'Golden Visa' is a commercial term coined to describe a one-year (temporary) residence, with possibility of EU LTR after 5 years according to European Law.
Portugal
Through the Golden Visa or D7 Passive Income route, Portugal provides temporary residence with eligibility for EU LTR or Portuguese PR after five years, subject to physical-presence and integration tests.
Spain
Spain’s Golden Visa Programme grants residence to investors meeting property or business thresholds. The initial residence is temporary but may progress to national PR or EU LTR after five years.
Comparing EU LTR and National PR Frameworks
EU Long-Term Residence
- Based on Directive 2003/109/EC.
- Requires five years continuous residence.
- Grants intra-EU mobility (subject to re-qualification).
- Provides equal treatment with nationals in core areas.
- Acts as a stepping-stone toward EU citizenship.
National Permanent Residence
- Based on national immigration law.
- Often available immediately upon investment or qualification.
- No EU-wide mobility beyond Schengen access.
- Rights, renewal, and citizenship rules vary by country.
Strategic Considerations for Global Families
When planning European settlement, non-EU nationals should consider:
- Time horizon – immediate settlement versus five-year residence build-up.
- Mobility needs – whether intra-EU employment or relocation is required.
- Integration objectives – language or cultural assimilation for future citizenship.
- Family composition – inclusion of dependants under each regime.
- Tax and relocation planning – differing residence and domicile rules across jurisdictions.
How Our EU Immigration Lawyers Can Help
Our EU Immigration and Mobility Lawyers assist individuals, entrepreneurs, and family offices in selecting and securing the most suitable long-term residence or permanent residence option within the European Union.
We provide:
- Strategic residence and relocation planning across multiple EU jurisdictions.
- Legal advice on EU Long-Term Residence and national PR eligibility.
- Integrated tax, family, and succession planning for internationally mobile clients.
- Representation in Malta, Cyprus, Greece, Portugal, Spain, Italy, the UK, and Switzerland.
About the Author
Dr Jean-Philippe Chetcuti is a Maltese lawyer and founding partner of CCLEX. With over 25 years’ experience in international tax, immigration, and private client law, he has advised HNW and UHNW families, entrepreneurs, and family offices on residence, citizenship, and cross-border structuring within the European Union and beyond. Dr Chetcuti has served as Chairman of STEP Malta, contributed to STEP Journal and Investor Migration Daily, and frequently lectures on EU residence and citizenship law and international tax planning. He is recognised for his leadership in shaping Malta’s immigration and private client frameworks and for his practical, multidisciplinary approach integrating legal, tax, and relocation strategy.
Copyright © 2025 Chetcuti Cauchi. This document is for informational purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking any action based on the contents of this document. Chetcuti Cauchi disclaims any liability for actions taken based on the information provided. Reproduction of reasonable portions of the content is permitted for non-commercial purposes, provided proper attribution is given and the content is not altered or presented in a false light.
