<!-- Appendix D — from "After the EU's Golden Passports", Kestrel Private, 6 August 2026. Canonical: https://kestrelprivate.com/research/after-the-golden-passports -->

# Appendix D — Family Cost Models

This appendix re-runs the cost model of Chapter 10 for each of the family shapes assessed in Chapter 11, using one line structure throughout so that the shapes may be read against one another. It introduces no figure that does not appear in those chapters: every line carries the section it derives from, and the qualifications the chapters attach to a figure travel with it here. The models are known-base models — statutory and published official charges only — and are working sheets for a client-specific model, not quotations. A quotation exists only after the full Chapter 10 model has been re-run with the exact family composition, the government schedules in force at the date of application, the selected property and written quotations from the providers instructed (§10.1, §17.9). The reference figure of approximately €375,000 is an illustrative single-applicant planning model. It is not a family price: every per-person line in the models below is additional to it (§1.5, §10.1, §11.9). It is also exceeded for the single applicant it was built for — on the re-footed stress test at §D.2 it is exceeded by €225 on the leanest assumption set and by €22,088 and €35,888 on the other two.

## D.1 How to read these models

Each model in §D.2–§D.7 uses the same five known-base lines, in the same order:

| Line | Source of the charge | Behaviour as the family grows | Section |
| --- | --- | --- | --- |
| Qualifying Greek property | Article 100, Law 5038/2023, as amended by Article 64, Law 5100/2024 — statutory minimum of €250,000 for the change-of-use category | Fixed; does not scale | §10.5, §7.4 |
| São Tomé and Príncipe contribution | Anexo I, Decree-Law No. 07/2025 | Steps at the second member and again beyond the fourth | §10.3, §11.1–§11.7 |
| São Tomé due-diligence and processing fee | Anexo I §2, Decree-Law No. 07/2025 — US$5,000 per application | Flat per application; the screening behind it is per person | §10.4, §11.8 |
| Greek permit fees | Articles 95 §2 and 171, Law 5038/2023 | Accumulates per person; minors exempt from the permit fee | §10.7, §11.2–§11.6 |
| Greek residence cards | Official administrative record for the change-of-use category, €16 each | Accumulates per person | §10.7, §11.3 |

Four rules apply to every table below. First, all euro conversions of US-dollar amounts use the report's working planning assumption of €1 = US$1.15 (§10.2); the dollar amounts govern and the euro figures are illustrative conversions only. That rate is a planning assumption set below the prevailing market rate, and is neither a market rate nor a forecast: the European Central Bank's euro foreign exchange reference rate for EUR/USD stood at 1.1535 on 3 August 2026, so converting a dollar charge at 1.15 states a slightly higher euro cost than the market would (European Central Bank, euro foreign exchange reference rates (EUR/USD), daily series, accessed 4 August 2026 — full citation at §10.2 and Chapter 11 note 19). Secondly, the known base excludes every banded and unknowable item of Chapter 10 — transfer tax, notarial, registry, legal, agency, technical, translation, legalisation, insurance, currency-conversion and professional-engagement lines (§10.6, §10.8–§10.12, §10.15) — and excludes both the per-person items registered at §D.8 and the licensed submitting agent's retainer allowance, which sits inside the allowance rather than in the known base and must not be confused with the gazetted due-diligence and processing fee carried in every table below (§10.4, §D.2). Thirdly, the €16 card charge is modelled per person including minors: the Article 171 §2 exemption concerns the permit fee, and the treatment of the card charge for minors requires confirmation at the date of application (§11.3). Fourthly, Kestrel Private's professional engagement fee is one of the excluded allowance lines and appears in no known-base table here. It is a fixed fee, agreed in writing before work begins, and it is charged per application: each programme applied to is a separate application, being a separate body of work, a separate set of counterparties, a separate schedule of disbursements and a separate government making a separate decision. The reference structure comprises two applications — the São Toméan citizenship application and the Greek investor residence application — so the reference case carries two fees — €10,000 and €8,000, €18,000 in all (§10.11, §11.9). A client instructing only one of the two programmes pays one fee of €10,000. The optional company, banking and tax layer is not a programme application and carries no Kestrel Private fee at all; its cost is entirely third-party. It sits outside the €375,000 reference case and outside every model in this appendix. Because the fee attaches to the application and not to the person, it does not scale with family size: it is €18,000 in every model below alike, from the single applicant to the family of six, and no table here should be read as varying it with headcount.

The structural point the tables are built to show is stated at §11.1 and §11.9: the €250,000 property component does not scale with family size — nor does the São Toméan due-diligence and processing fee, nor Kestrel Private's professional engagement fee, both being charged per application — while the contribution tier steps, the Greek fees accumulate per person, and the soft costs of §D.8 scale with headcount and, in part, recur annually or at each renewal.

## D.2 Single applicant — the reference case

| Cost component | Amount |
| --- | ---: |
| Qualifying Greek property | €250,000 |
| São Tomé contribution — single applicant, US$90,000 | €78,261 |
| São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 |
| Greek permit fees — main applicant €2,000 | €2,000 |
| Greek residence cards — 1 × €16 | €16 |
| **Known base subtotal** | **€334,625** |
| Delta from the single-applicant reference case | — |

Assumptions: €1 = US$1.15, a planning assumption below the prevailing market rate (§D.1, §10.2); contribution and fee per Anexo I, Decree-Law No. 07/2025; Greek fees per Article 171, Law 5038/2023 and the official administrative record for the change-of-use category, as at 2 August 2026, subject to the schedules in force at the date of application. Derived from §10.1, §10.3–§10.7 and §11.1 without re-derivation. Excludes all banded and unknowable items (§10.6, §10.8–§10.15) and the per-person items at §D.8. Within the approximately €375,000 planning figure this base leaves about €40,375 for every other cost line.

Two of that allowance's lines are Kestrel Private's own. The professional engagement fee is charged per application, and the reference case comprises two applications, so €18,000 of the €40,375 is committed before any third-party cost is counted (§D.1, §10.11). A third line is committed in the same sense without being Kestrel Private's: an application to the São Tomé and Príncipe programme is filed through the programme's designated application channel by a licensed agent, and Kestrel Private's own cost model carries an allowance of US$5,000 (€4,348) for that agent's retainer. That allowance is published in no instrument and is gazetted nowhere; it requires a written quotation before engagement and confirmation at the date of application (§10.4, §10.14). Together the three lines commit €22,348 of the €40,375 — 55.4% of it — before any other third-party cost is counted. Re-footed on that basis, Chapter 10's allowance stress test stands as follows.

| Allowance item set | Lean | Heavy | Top |
| --- | ---: | ---: | ---: |
| Kestrel Private professional engagement — citizenship €10,000 + residence €8,000 | €18,000 | €18,000 | €18,000 |
| Licensed submitting agent's retainer — allowance of US$5,000, distinct from the gazetted due-diligence and processing fee in the known base above | €4,348 | €4,348 | €4,348 |
| São Tomé post-approval documents — US$750, reported on the programme's official site and in no gazetted schedule (§10.4, §11.8) | €652 | €652 | €652 |
| All other allowance items (§10.6, §10.8–§10.10, §10.12, §10.15) | €17,600 | €39,463 | €53,263 |
| **Allowance total** | **€40,600** | **€62,463** | **€76,263** |
| Against the €40,375 available | **−€225** | **−€22,088** | **−€35,888** |
| **All-in total (known base €334,625 + allowance)** | **€375,225** | **€397,088** | **€410,888** |

Assumptions: allowance items as built at §10.6 and §10.8–§10.15 on the lean, heavy and top assumption sets of §10.14; two professional engagement fees totalling €18,000 — €10,000 on the citizenship application and €8,000 on the residence application instructed alongside it (§10.11, §D.1); the submitting agent's retainer at the US$5,000 allowance of §10.4 and the post-approval documents at US$750, each carried in all three columns; known base €334,625 as above; €1 = US$1.15, a planning assumption below the prevailing market rate (§D.1, §10.2). Chapter 10's line-by-line footing is reproduced here without re-derivation: lean 7,725 + 2,480 + 1,250 + 3,100 + 0 + 300 + 372 + 150 + 0 + 350 + 496 + 372 + 1,005 + 652 + 4,348 + 18,000 = €40,600; heavy 7,725 + 3,720 + 1,250 + 4,650 + 7,750 + 1,500 + 600 + 900 + 3,000 + 800 + 496 + 372 + 6,700 + 652 + 4,348 + 18,000 = €62,463; top of every band 7,725 + 3,720 + 1,250 + 6,200 + 12,400 + 1,500 + 1,000 + 900 + 3,500 + 800 + 496 + 372 + 13,400 + 652 + 4,348 + 18,000 = €76,263. The penultimate row measures the allowance total against the €40,375 available; the €40,375 itself is unchanged, being a function of the known base, which has not moved. The lean column exceeds the €375,000 planning figure by €225; the heavy and top columns exceed it by €22,088 and €35,888. The figure is therefore exceeded in the single-applicant case even where every controllable cost falls at the bottom of its band, and by a wider margin on any less favourable set — and no column here carries a second person. The exchange-rate assumption does not alter that finding: at the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026 the known base is about €334,374 and the allowance about €40,626, the lean allowance items about €40,585, so the lean case sits about €41 below the €375,000 reference rather than €225 above it, with a lean all-in of about €374,959. The heavy and top cases exceed the allowance on either rate (§10.2, §D.1).

## D.3 Married couple

| Cost component | Amount |
| --- | ---: |
| Qualifying Greek property | €250,000 |
| São Tomé contribution — family application of two, US$95,000 | €82,609 |
| São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 |
| Greek permit fees — main applicant €2,000; spouse (type O.1) €150 | €2,150 |
| Greek residence cards — 2 × €16 | €32 |
| **Known base subtotal** | **€339,139** |
| Delta from the single-applicant reference case | **+€4,514** |

Assumptions: as §D.2. Spouse eligibility differs between the two components and is qualified on the São Toméan side. The decree includes the spouse by reference to Article 10(5) of Lei n.º 7/2022, which applies Article 6 of that Law. Article 6(1) requires cumulatively a marriage of more than five years **and** that the marriage be under the regime of community of acquired property (*comunhão de bens adquiridos*); Article 6(2) admits a de facto union of more than three years recognised by the Civil Court, and carries no property-regime condition. The programme's official site publishes a broader class, a spouse in a monogamous marriage or a de facto partner, and the site states no durational condition and no property-regime condition. No published instrument reconciles the two. A recently married spouse's inclusion, and the inclusion of a spouse married under separation of property, therefore rest on administrative practice requiring applicant-specific legal confirmation at the date of application; how the Article 6(1) property-regime condition is applied to a foreign marriage contracted under a different matrimonial regime is not addressed in either instrument and requires São Toméan advice before a spouse is priced into an application (§11.2, §14.8, §16.2). On the Greek side the spouse or cohabitation-agreement partner is a statutory family member under Article 95 §2, holding a family permit that expires simultaneously with the sponsor's (§11.2).

## D.4 Couple with one child

| Cost component | Amount |
| --- | ---: |
| Qualifying Greek property | €250,000 |
| São Tomé contribution — family application of three, US$95,000 | €82,609 |
| São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 |
| Greek permit fees — main applicant €2,000; spouse €150; minor child exempt | €2,150 |
| Greek residence cards — 3 × €16 | €48 |
| **Known base subtotal** | **€339,155** |
| Delta from the single-applicant reference case | **+€4,530** |

Assumptions: as §D.2 and §D.3; child under 18 at application, within the gazetted São Toméan dependant class (minor children at the naturalisation act, Articles 10(4)–(5) of Lei n.º 7/2022) and an unmarried child under 21 under Article 95 §2 of Law 5038/2023, exempt from the Greek permit fee under Article 171 §2. Card charge for minors requires confirmation (§D.1, §11.3). Derived from §11.3.

## D.5 Couple with two children

| Cost component | Amount |
| --- | ---: |
| Qualifying Greek property | €250,000 |
| São Tomé contribution — family application of four, US$95,000 | €82,609 |
| São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 |
| Greek permit fees — main applicant €2,000; spouse €150; two minor children exempt | €2,150 |
| Greek residence cards — 4 × €16 | €64 |
| **Known base subtotal** | **€339,171** |
| Delta from the single-applicant reference case | **+€4,546** |

Assumptions: as §D.4; both children under 18 at application. A family of four remains within the two-to-four-person contribution tier, so the third and fourth members add no contribution — the tier structure's most visible family effect (§11.4). Beyond the fourth member the contribution rises by US$5,000 (€4,348) for each additional qualifying dependant, taking a couple with three minor children to a known base of €343,535 and a couple with four minor children to €347,898 (§11.7).

## D.6 Family including an adult dependent child

This shape is the one on which the two components diverge most, and the point at which the appendix separates published law from published administration. On the São Toméan side the gazetted dependant class is the spouse and children under Articles 10(4)–(5) of Lei n.º 7/2022; neither Decree-Law No. 07/2025 nor the Nationality Law contains any provision for dependent children up to age 30, a category that appears only on the programme's official site. By a memorandum of the programme unit's director dated 10 April 2026, reported in industry press, passport issuance for adult dependent children aged 18 and over was placed on hold pending a revised dependency framework; no evidence that the framework has been enacted, or the hold lifted, had been located as at 2 August 2026 (§11.5). The model below accordingly does not price an adult child as a São Toméan dependant; the São Toméan contribution shown is that of the principal applicant and spouse alone.

| Cost component | Amount |
| --- | ---: |
| Qualifying Greek property | €250,000 |
| São Tomé contribution — family application of two, US$95,000 (adult child not priced as a São Toméan dependant) | €82,609 |
| São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 |
| Greek permit fees — main applicant €2,000; spouse €150; adult child aged 18–20 (type O.1) €150 | €2,300 |
| Greek residence cards — 3 × €16 | €48 |
| **Known base subtotal** | **€339,305** |
| Delta from the single-applicant reference case | **+€4,680** |

Assumptions: as §D.3; unmarried child aged 18–20 at application, includable under Article 95 §2 of Law 5038/2023 and no longer within the Article 171 §2 minor exemption. Article 95 §2 contains no exception for an adult child lacking legal capacity: the list of family members is closed, being expressed as a derogation from Article 84 §1, and is age-limited; whether such a child may be accommodated under the humanitarian category (type "Α.4") is a separate question on separate conditions and fees and requires applicant-specific legal advice (§11.5). A child who reaches 21 while included may receive an independent three-year permit (type O.2) plus the €16 card — a later-cycle cost, not a known-base line. Article 171 §1(β) sets the fee for types O.1 and O.2 at €150, reserving €450 for the three-year independent permit granted under the *first* sentence of Article 90 §5, whereas Article 95 §2 grants the investor's child that permit by analogous application of the *second* sentence; the fee applicable to this route is therefore €150 on the face of the Code, and the €450 figure circulating in practice requires confirmation against the administrative record at the date of application. On the second-sentence reading no further renewal is permitted, after which any further residence must rest on a category of the Immigration Code for which the child qualifies in his or her own right (§11.5, §16.4). A child aged 21 or over at application, with legal capacity, is not a statutory family member under Article 95 §2. On the citizenship side, a family wishing to include a child aged 18 or over must treat that inclusion as unconfirmed administrative practice, to be verified together with the status of the passport hold at the date of application, on applicant-specific legal advice (§11.5). Were the inclusion admitted, the published tier would absorb the child within the two-to-four band at no additional contribution; this report does not present that as a statutory entitlement and does not carry it in the table.

## D.7 Family including dependent parents

The asymmetry runs the other way for parents. In Greece the direct ascendants of the sponsor or of the spouse or partner are statutory family members under Article 95 §2, each receiving a family permit expiring with the sponsor's. In São Tomé and Príncipe, parents and grandparents aged 55 and over are a category published on the programme's official site with no visible basis in either gazetted instrument, the decree's dependant class being the spouse and children only (§11.6).

| Cost component | Amount |
| --- | ---: |
| Qualifying Greek property | €250,000 |
| São Tomé contribution — family application of two, US$95,000 (parents not priced as São Toméan dependants) | €82,609 |
| São Tomé due-diligence and processing fee, US$5,000 per application | €4,348 |
| Greek permit fees — main applicant €2,000; spouse €150; two dependent parents (type O.1) 2 × €150 | €2,450 |
| Greek residence cards — 4 × €16 | €64 |
| **Known base subtotal** | **€339,471** |
| Delta from the single-applicant reference case | **+€4,846** |

Assumptions: as §D.3; two dependent parents of either spouse, included under Article 95 §2 of Law 5038/2023 at €150 plus the €16 card each — the additional known Greek fees of €332 stated at §11.6. Were a São Toméan inclusion of parents admitted in administrative practice, the published tier structure would price each parent as a family member within the two-to-four band, or at US$5,000 (€4,348) beyond the fourth member; this report cannot present that as a statutory entitlement, and the position requires confirmation at the date of application (§11.6, §16.5). One cost line deserves particular attention for older family members: the Greek private health insurance required of every applicant and family member is priced by age, with reported minimum-compliance cover at roughly €70–€300 per adult per year, materially more from age 65 and reported as potentially unavailable beyond age 75 — written quotations are required before any family including parents is modelled (§11.6, §11.8, §10.10).

## D.8 Per-person items outside the known base

The lines below sit outside every table above. They are the register of costs that scale with headcount, and they are the reason a known-base delta understates the cost of adding a person. Amounts are reported bands or reported official-site figures, subject to confirmation at the date of application, and each requires a written quotation or the issuing authority's current schedule before use.

| Item | Basis | Scaling | Section |
| --- | --- | --- | --- |
| São Tomé citizenship documents (certificate, passport, national identity card) | US$750 per applicant, approximately €652, published on the programme's official site; the amount appears in no gazetted schedule | Per person included in the citizenship component | §10.4, §11.8 |
| Due-diligence screening | Fee flat at US$5,000 per application; checks performed on every applicant and, where applicable, on those dependants who are criminally imputable under São Toméan law (Article 11(1)), with interviews possible in person or by video (Article 11(2)). The age at which criminal imputability begins is not stated in either instrument and requires confirmation | Per person, at no separate published charge | §10.4, §11.8 |
| Police certificates | Required from every country of nationality and every country of residence during the previous five years, issued within the three months before submission; costs vary by issuing state | Per person, per issuing state, with per-person sequencing | §11.8, §16.8 |
| Medical certificates | One per applicant under the decree's application requirements | Per person | §11.8 |
| Certified translations | Into Portuguese or English for the São Toméan file; into Greek for the Greek file at published rates of roughly €15–€60 per page plus 24% VAT | Per person and per document | §10.9, §11.8 |
| Apostille and legalisation | United Kingdom £45 per document (£35 e-apostille); South Africa legalises public documents without charge, notarial fees additional for private documents | Per document | §10.9, §11.8 |
| Entry and biometrics (Greece) | On the proxy route, the applicant and each family member must enter Greece within an exclusive 12-month period from filing and give fingerprints; a second failure to attend a summoned appointment results in rejection | Per person, plus travel | §10.7, §11.8, §17.11 |
| Entry visa where the client's own nationality requires one | Schengen visa €90 per adult, €45 per child aged six to below 12; national entry visa €180 consular fee where used | Per person | §11.8 |
| Greek private health insurance | Coverage minimums fixed under the predecessor Code and still applied in practice, subject to confirmation; reported premiums roughly €70–€300 per adult per year for minimum-compliance cover, age-loaded | Per person, per year, and again at each renewal | §10.10, §11.6, §11.8 |
| Recurring permit costs | €2,000 main-applicant fee at issuance and at each five-year renewal; family permits expire with the sponsor's and are renewed alongside it at the fee schedule then in force; fresh insurance and new cards at each renewal | Per person, per cycle | §10.13, §11.8 |
| Multiple-nationality screening | No grant to a person already holding more than two foreign nationalities (Article 11(1), Lei n.º 7/2022); acceptance of applications from persons holding three or more foreign nationalities was placed on hold from April 2026 | Screened family member by family member | §11.8, §13.2, §14.8 |

Assumptions: reported figures as at 2 August 2026, subject to confirmation at the date of application; €1 = US$1.15, a planning assumption below the prevailing market rate (§D.1, §10.2). Sources as identified in §10.4, §10.9–§10.10 and §11.8. Post-approval additions are separately priced in Anexo I — US$10,000 for the spouse of a citizen, US$5,000 for other qualifying dependants and US$500 for a newborn child up to one year — and the chapeau to Anexo I item 4 requires those amounts to be paid *in addition to* the Anexo I due-diligence and processing fee of US$5,000 per application, with the US$750 document charge applying per applicant. On that basis a spouse added after approval in principle carries US$10,000 + US$5,000 + US$750 = US$15,750, and another qualifying dependant US$5,000 + US$5,000 + US$750 = US$10,750. The programme's official channel publishes the same US$5,000 charge as a "Submission Fee (except newborns)", so a newborn addition is published at US$500 + US$750 = US$1,250; the gazette contains no newborn exemption, and on the gazetted text read literally a newborn addition is US$6,250. Which governs requires confirmation at the date of application (§11.7, §16.6).

## D.9 Comparison by family shape

| Family shape | Contribution (US$ → €) | Greek fees and cards | Known base | Delta from single applicant | Delta as share of the €40,375 allowance |
| --- | ---: | ---: | ---: | ---: | ---: |
| Single applicant (§D.2) | 90,000 → 78,261 | €2,016 | €334,625 | — | — |
| Married couple (§D.3) | 95,000 → 82,609 | €2,182 | €339,139 | +€4,514 | 11.2% |
| Couple with one child (§D.4) | 95,000 → 82,609 | €2,198 | €339,155 | +€4,530 | 11.2% |
| Couple with two children (§D.5) | 95,000 → 82,609 | €2,214 | €339,171 | +€4,546 | 11.3% |
| Family with an adult dependent child aged 18–20 (§D.6) | 95,000 → 82,609 | €2,348 | €339,305 | +€4,680 | 11.6% |
| Family with two dependent parents (§D.7) | 95,000 → 82,609 | €2,514 | €339,471 | +€4,846 | 12.0% |

Assumptions: every row includes the fixed €250,000 property component and the US$5,000 (€4,348) per-application due-diligence fee; €1 = US$1.15, a planning assumption below the prevailing market rate (§D.1, §10.2); Anexo I, Decree-Law No. 07/2025; Articles 95 §2 and 171, Law 5038/2023 and the official administrative record, as at 2 August 2026; children under 18 unless the row states otherwise; card charges modelled per person, including minors, subject to confirmation (§D.1). In the last two rows the adult child and the parents are priced on the Greek side only, for the reasons given at §D.6 and §D.7; neither inclusion is priced as a São Toméan dependant. The allowance share is the delta expressed against the approximately €40,375 residual inside the approximately €375,000 single-applicant planning figure (§10.14) and is shown to scale the additional person's known cost against that allowance, not to suggest that the allowance covers it. That residual is unchanged, but €22,348 of it is committed before any other third-party cost is counted — the two professional engagement fees of the reference structure and the submitting agent's retainer allowance (§D.1, §D.2) — leaving about €18,027 for third-party allowance items; and on the lean assumption set of §D.2 the allowance is already exceeded by €225 before a second person is priced at all. There is accordingly no headroom for a delta to consume: every delta in this table adds to an overrun of the €375,000 figure that exists already in the single-applicant case — the married couple's +€4,514 takes the lean all-in from €375,225 to €379,739 before any item at §D.8. The engagement fee itself is identical in every row, being charged per application and not per person. Known bases only: the items at §D.8 and all Chapter 10 banded and unknowable items are additional. Larger families are modelled at §11.7 (couple with three minor children, €343,535; couple with four minor children, €347,898). Derived from §11.1–§11.9 and re-footed here.

## D.10 Identifiable first-year additions

The table below adds to each known-base delta only those per-person items that carry a published amount: the reported US$750 (approximately €652) programme document charge for each additional person included in the citizenship component, and a first-year minimum-compliance insurance premium of roughly €70–€300 for each additional adult. These are illustrative sums of the components stated, not quotations, and they precede police certificates, medicals, translations, legalisation, entry visas and travel, which vary with each person's nationalities and residence history.

| Family shape | Known-base delta | Document charges | Additional adult insurance | Identifiable first-year addition |
| --- | ---: | ---: | ---: | ---: |
| Married couple (§D.3) | €4,514 | €652 (1 × €652) | €70–€300 (1 adult) | €5,236–€5,466 |
| Couple with one child (§D.4) | €4,530 | €1,304 (2 × €652) | €70–€300 (1 adult) | €5,904–€6,134 |
| Couple with two children (§D.5) | €4,546 | €1,956 (3 × €652) | €70–€300 (1 adult) | €6,572–€6,802 |
| Family with an adult dependent child aged 18–20 (§D.6) | €4,680 | €652 (spouse only) | €140–€600 (2 adults) | €5,472–€5,932 |
| Family with two dependent parents (§D.7) | €4,846 | €652 (spouse only) | €70–€300 (spouse only) | €5,568–€5,798 |

Assumptions: €1 = US$1.15, a planning assumption below the prevailing market rate (§D.1, §10.2); document charge per §10.4 and §11.8 (official-site figure, requires confirmation at the date of application); insurance band per §10.10 and §11.8 (reported, written quotations required). The principal applicant's own document charge and insurance premium sit in the single-applicant reference case and are not repeated. Kestrel Private's professional engagement fee contributes nothing to any figure in this table: it is charged per application and not per person, so adding a family member does not add to it (§D.1, §10.11). Children's insurance premiums are not banded, and the parents' premiums in the final row are excluded because they are age-loaded and reported as potentially unavailable above age 75 (§11.6) — that row therefore understates the position by the whole of the parents' cover. In the last two rows no document charge is carried for the adult child or the parents, because neither is priced as a São Toméan dependant (§D.6, §D.7). Chapter 11 states the married-couple and two-children sums, rounded outward to the nearest hundred, as approximately €5,200–€5,500 and approximately €6,500–€6,900 (§11.9); the arithmetic is reproduced here unrounded.

## D.11 Qualifications that travel with these models

Each of the following travels with any use of the models above and may not be resolved in the client-specific model without the confirmation named.

| Open point | Position as at 2 August 2026 | What is required | Section |
| --- | --- | --- | --- |
| São Toméan dependant definitions | The gazetted class is the spouse and children under Articles 10(4)–(5) of Lei n.º 7/2022; the programme's official site publishes children up to 30 and parents and grandparents aged 55 and over. No published instrument reconciles the divergence | Applicant-specific legal confirmation at the date of application; extended dependants are not priced as statutory anywhere in this appendix | §11.5, §11.6, §16.5 |
| Spouse durational and property-regime conditions | Article 6(1) of Lei n.º 7/2022 requires cumulatively a marriage of more than five years **and** the regime of community of acquired property (*comunhão de bens adquiridos*); Article 6(2) admits a court-recognised de facto union of more than three years and carries no property-regime condition. The official site states neither condition. Whether the property-regime condition is applied to a foreign marriage contracted under a different regime is unaddressed in both instruments | São Toméan advice before a spouse is priced into an application, and confirmation at the date of application | §11.2, §14.8, §16.2 |
| Adult-dependant passport hold | Passport issuance for adult dependent children aged 18 and over placed on hold by the programme unit's memorandum of 10 April 2026, pending a revised dependency framework; no evidence located that the framework has been enacted or the hold lifted | Confirmation of the current position at the date of application | §11.5 |
| Card charge for minors | The Article 171 §2 exemption concerns the permit fee; no source states whether the €16 card charge is levied for minors. Modelled here per person | Confirmation at the date of application; retotal the affected rows if the position differs | §11.3 |
| Family-permit renewal fees | The €2,000 investor fee applies at issuance and at each renewal; the family-permit fee at renewal is carried as "the schedule then in force" | Confirmation at the date of application | §11.8, §10.13 |
| Post-approval additions | Anexo I publishes US$10,000 for a citizen's spouse, US$5,000 for other qualifying dependants and US$500 for a newborn child up to one year, and its item 4 chapeau requires each to be paid in addition to the US$5,000 per-application fee of item 2; with the US$750 document charge the totals are US$15,750, US$10,750 and — on the official channel's newborn exemption from the US$5,000 — US$1,250, against US$6,250 on the gazetted text read literally | Confirmation of which instrument governs the newborn addition, and of the schedule in force, at the date of application | §11.7, §16.6 |
| Programme document charge | US$750 per applicant, published on the official site, in no gazetted schedule | Confirmation at the date of application | §10.4, §11.8 |
| Licensed submitting agent's retainer | An application is filed through the programme's designated application channel by a licensed agent. The US$5,000 (€4,348) carried in the allowance at §D.2 is an allowance in Kestrel Private's own cost model: it is not published, not gazetted and not sourced to any instrument | A written quotation from the agent before engagement, and confirmation at the date of application | §10.4, §10.14, §D.2 |
| Amendment of the São Toméan schedule | The responsible ministers may alter the Anexo I fees and minimum amounts by joint order; an update does not affect processes already admitted | Confirmation of the schedule in force at the date of application | §10.3, §14.2 |
| Greek health-insurance minimums | Fixed under the predecessor Code and still applied in practice | Confirmation at the date of application; written premium quotations per person | §10.10, §11.8 |
| Greek family-member documentation | The per-member documentary list is fixed by the common-documents decision carried forward under the current documentation joint ministerial decision | The exact list confirmed at the date of application | §11.8, §16.10 |
| Multiple-nationality cap | No grant to a person already holding more than two foreign nationalities; acceptance of applications from persons holding three or more foreign nationalities on hold from April 2026 | Screening of each family member before any model is relied on | §11.8, §13.2, §14.8 |
| Sequencing for children aged about 17 to 21 | The Greek 21-year limit and the São Toméan one-year post-majority window interact | Addressed in the implementation plan, not in a headline figure | §11.5, §17.5 |

Assumptions: statements of position as at 2 August 2026, on the sources cited in Chapters 10 and 11. Nothing in this appendix promotes a qualified statement into a bare one, and no figure here is a quotation, a fixed price, an all-inclusive price or a guaranteed maximum cost (§10.1).