A home in Europe, on someone else’s timetable
For many families, a home in Europe was meant to offer freedom: sunshine, a slower pace of life and room to breathe, not more red tape. An apartment on the Costa Blanca, a villa in the Algarve, a farmhouse in Provence or a chalet in the Austrian Alps – somewhere to spend the winter, gather the family in summer and, one day, perhaps retire.
For British owners, Brexit changed that picture almost overnight. For owners from the United States, Canada, Australia and elsewhere outside the EU, the same rules have always applied, but they are now enforced more strictly than ever before.
Whether you already own a home in Europe, are thinking of buying, or hope to retire there, this guide explains the restrictions non-EU owners now face and the practical difference German citizenship can make. We draw on examples from Spain, Portugal, France and Austria, some of the most popular destinations among our clients, but the same principles apply across most of the European Union.
The restrictions non-EU property owners now face
The 90/180-day rule
Citizens of the UK and other visa-exempt countries outside the EU can spend a maximum of 90 days in any rolling 180-day period in the Schengen area. Owning a property does not change this.
Those 90 days are counted across all Schengen countries combined. A week in Paris or a weekend in Rome uses the same allowance as time spent at your own property. For British owners who once spent the whole winter in the sun, this has been one of the most painful consequences of Brexit.
Border checks are now automatic
Until recently, the rule relied on border officers checking passport stamps by hand, and enforcement was inconsistent. That has changed. The EU’s Entry/Exit System (EES), fully operational since April 2026, records non-EU travellers’ entries and exits digitally using fingerprints and a facial scan.
Your days are now counted automatically. Overstaying can lead to fines, entry bans and difficulties on future trips.
A further system, ETIAS, will require visa-exempt visitors to apply online for travel authorisation before they travel. Its launch has been delayed several times, and no start date has yet been announced.
Buying a home no longer leads to residence
Several countries once offered non-EU buyers a so-called golden visa in return for buying property. Portugal removed property purchases from its scheme in 2023, and Spain, where buyers investing at least €500,000 could qualify, closed its golden visa to new applicants on 3 April 2025. In both countries, buying a home no longer offers a route to living there.
Non-EU nationals who want to stay longer than 90 days must now apply for a visa, such as Spain’s non-lucrative visa or Portugal’s D7 visa for people living on pensions, savings or investments. These visas involve minimum income requirements, consular applications, renewals and restrictions on working locally.
An uncertain future for non-EU buyers
Housing has become a major political issue in Spain, and some proposals have targeted non-EU buyers directly. In January 2025, the Spanish government announced plans designed to deter non-EU buyers who do not live in Spain from purchasing homes there.
That proposal has since stalled in parliament and is not law. However, it shows the direction of political debate, and it would not have applied to EU citizens.
What a German passport changes
German citizens are also citizens of the European Union. Wherever you own property in the EU, that gives you the same rights as any other EU national.
No more counting days
The 90/180-day rule does not apply to EU citizens. You can stay at your home in Spain, Portugal, France or elsewhere in the EU for as long as you wish: a long winter, a whole summer with the grandchildren, or most of the year.
If you hold German citizenship alongside another nationality, enter and leave the Schengen area on your German passport, so that you are treated as an EU citizen at the border.
Simpler border crossings
As an EU citizen, you are not registered in the EES and will not need an ETIAS travel authorisation. Where airports provide them, you can also use the passport lanes for EU, EEA and Swiss travellers.
The right to live in another EU country
EU citizens have the right to live in any other EU country without a visa, subject to the conditions that apply to EU citizens, such as showing that you can support yourself. Many countries, including Spain, require you to register with the local authorities if you stay for more than three months.
There is no investment threshold and no visa to renew. After five years of continuous legal residence, you can acquire permanent residence.
The right to work
EU citizens do not need a work permit to take up employment, become self-employed or run a business in another EU country. For owners who would like to work from their home abroad, or start something new locally, this can make a real difference.
Buying on equal terms
In popular destinations such as Spain, Portugal and France, non-EU nationals can also buy residential property, so the main advantage of EU citizenship is the right to use your home and live in it. EU citizens buy on the same basis as local nationals, and EU law protects that right, which also places you outside the scope of measures aimed specifically at non-EU purchasers, such as the Spanish proposal.
Elsewhere, citizenship can affect the purchase itself. In Austria, EU citizens are generally treated like Austrian nationals, while buyers from outside the EU and EEA usually need official approval. Croatia similarly requires government authorisation for non-EU buyers.
Freedom to change your plans
Your rights are not tied to Spain. If you later decide to sell and buy in Portugal, France or Italy, or to divide your time between several countries, your EU citizenship goes with you, including the right to live in Germany itself.
Three common situations, and what changes
1. “We already own a home in Europe”
Imagine a couple who bought an apartment on the Costa Blanca in 2015. For years they spent October to April there, returning home for the summer. Since Brexit, they have had to plan every trip around the 90-day limit, cutting their winters short and missing family occasions in Spain to protect their allowance.
With German citizenship, that calculation disappears. They can arrive in October and stay until spring, add a summer visit, or spend a few weeks travelling elsewhere in Europe without worrying about the count.
If only one partner is eligible, it is still worth exploring. Family members of an EU citizen who lives in another EU country may themselves have rights of residence there, subject to conditions.
2. “We’re thinking of buying”
Buying abroad is a major decision, and it makes sense to understand your rights before you commit. Buying a property does not give you EU citizenship. As a non-EU buyer, owning a home does not automatically entitle you to stay longer than 90 days, and you remain exposed to future changes aimed at non-EU purchasers.
As an EU citizen, you can choose a property for the life you want rather than the time you are allowed. You buy on the same footing as local nationals, can use the property as much as you like, and keep the freedom to move there permanently later.
3. “We’d like to retire in Europe”
For non-EU nationals, retiring abroad usually means applying for a long-stay visa through a consulate, such as Spain’s non-lucrative visa or Portugal’s D7 visa. Applicants must demonstrate sufficient income, may face restrictions on working and must renew their residence permits while continuing to meet the relevant conditions.
For an EU citizen, the process is far simpler. You move, register as a resident and get on with life. There is no visa application, no consular appointment and no renewal cycle, and you remain free to work part-time, consult or volunteer if you wish.
Plans also change. If you later want to move closer to family, return to the UK or try another country, your EU citizenship remains. You can come back, or move anywhere else in the EU, without needing a visa.
What a German passport does not change
EU citizenship removes many of the barriers non-EU owners face, but it is not a shortcut around local rules. It is worth being clear about what stays the same:
- Local law applies. Buying, owning and letting property remains subject to national and regional rules, such as holiday-letting licences in many parts of Spain and restrictions on holiday homes in parts of Austria.
- Formalities remain. EU citizens staying for more than three months must still meet the relevant conditions and, in many countries, register with the authorities.
- Rules vary across the EU. A few countries, such as Denmark and Malta, restrict property purchases by people without a residence history there, including EU citizens.
- Professional advice is essential. Before buying or relocating, take independent advice from a qualified lawyer in the country concerned.
Could German citizenship open the door for you?
Many people with German family roots do not realise they may be entitled to German citizenship. Depending on your family history, a route may be available under Article 116(2) of the German Basic Law, Section 15 of the German Nationality Act, or by declaration under Section 5 of the German Nationality Act.
Applicants under these routes are generally permitted to keep their existing nationality under German law, so you may be able to hold German citizenship alongside your current citizenship. The law of your other country should always be checked first.
If you are unsure whether this applies to you, read Do I Have German Citizenship Without Knowing It?
Your home, on your terms
German Citizenship Restoration specialises in helping eligible individuals and families restore or acquire German citizenship. We support cases involving former German citizens or residents affected by Nazi persecution between 1933 and 1945, their descendants, and families affected by historic gender discrimination in German nationality law.
If you believe you may have a German parent, grandparent or earlier ancestor, contact us for a no-fee initial consultation to assess whether there may be a route available to you.
This article provides general information only and does not constitute legal or tax advice. Property regulations, taxes and residence requirements vary by country and individual circumstances.