The G-Lock Second Fund makes a promise you rarely hear from a venture capital wrapper: a fixed distribution target of 0.7% per month, 8.4% a year, for Category B units. It is GK Capital's follow-up to its first fund, a closed-end Portuguese VC vehicle (CMVM no. 2386) investing in fintech, AI and automation companies, with a €500,000 minimum set exactly at the Golden Visa threshold. Two things deserve equal billing with the headline yield: the KID rates the fund 6 of 7 for risk and says distributions are not guaranteed, and the fund's Golden Visa eligibility is flagged differently by the manager and by directory data.
Key takeaways
- Closed-end Portuguese venture capital fund (CMVM no. 2386) targeting fintech, AI and automation companies, with at least 60% committed to Portugal-based businesses and a €60 million target size.
- Category B units target fixed distributions of 0.7% per month, 8.4% a year; the KID states distributions are not guaranteed and rates the fund 6 of 7 for risk.
- €500,000 minimum subscription in €100,000 units, matching the Golden Visa threshold; 8-year term, extendable by up to 2 years, with no early redemption.
- No entry, exit or performance fees, but aggregate recurring costs of roughly 3% a year per the KID; the management fee is not broken out.
- The manager says the fund is Golden Visa eligible; movingto's database flags it as not eligible. The conflict is unresolved.
What does the G-Lock Second Fund actually invest in?
Companies with high development potential, preferentially in technology development, fintech and automation, held directly or indirectly. The policy targets businesses with more than 24 months of operating history, proven revenues and experienced management, taking either majority control or influential minority positions of indicatively 10-30%. At least 60% of capital goes to Portugal-based companies, and the fund is not an SFDR Article 8 or 9 product.
So this is not seed-stage venture. The screening criteria, revenues, track record, control positions, read more like lower-mid-market growth investing in tech-enabled businesses. That framing matters when you weigh the fixed distribution target below.
What you cannot yet evaluate is the portfolio, because there isn't one. The KID, produced on 19 November 2025, states the fund had not yet commenced activity, and it remains in its subscription phase. No team members are named on the manager's site either. The verifiable anchors are structural: the fund operates under Decree-Law 27/2023, Category B units carry ISIN PTLERKIM0006 (capital is divided into six categories, A through F, whose other terms are unpublished), the depositary is Banco BNI Europa and the auditor is Deloitte.
How do fixed monthly distributions square with venture capital?
Uneasily, and understanding why is the core of this fund. The manager markets fixed monthly returns of 0.7% for Category B, paid on the 8th of the month following the investment, with the KID's moderate and favourable scenarios showing around 8% average annual return after costs. A fixed monthly coupon from a VC structure makes the product behave less like classic venture capital and more like a private credit note wearing a VC wrapper.
That has two consequences. First, the economics: if portfolio companies are effectively paying a fixed charge on capital, your upside is capped near 8.4% while your downside is equity-like. The KID's risk class of 6 on a 7-point scale says as much. Second, the language: "fixed" describes the target set by the manager's investment policy, not a legal obligation. The KID states plainly that the amounts and periodicity of distributions are not guaranteed. A concentrated set of fintech investees failing to generate that cash flow is the direct way the monthly target breaks.
None of this makes the design illegitimate. Predictable income with a defined exit horizon is exactly what some Golden Visa applicants want. It does mean the right benchmark is other income-style products, not venture funds chasing multiples.
What do the fees cost you?
The headline schedule is unusually clean: the KID discloses no entry fee, no exit fee and no performance fee. For comparison, subscription charges and 20% carry structures are routine elsewhere in this database.
The substance sits in running costs. The KID estimates aggregate recurring costs at roughly 3.0% a year, combining the management fee, depositary, audit, legal and investment costs; the management fee alone is not broken out. On a €500,000 subscription, that is about €15,000 a year carried inside the fund, in the region of €120,000 across the 8-year term if the estimate holds. Against the typical 1.5-2% management fees seen across Golden Visa funds, a 3% all-in cost load is high, even allowing that all-in figures capture costs that headline management fees exclude. The KID's approximately 8% scenario returns are stated after costs, which is the number that matters, but the gross-to-net gap explains where a meaningful slice of portfolio earnings goes.
Liquidity, lock-up and the citizenship timeline
Capital is committed from subscription until liquidation. The term is 8 years, extendable by up to 2 years on the manager's proposal with approval of 75% of votes cast at the participants' general meeting. There is no early redemption at the investor's request; the single exception is an investor who votes against an extension. Units can be transferred privately, but with no periodic NAV publication disclosed (the latest unit valuation is available from the manager on request), pricing such a sale is genuinely hard.
Mapped against the citizenship timeline, the fit is reasonable on paper. Naturalization currently runs roughly six to seven years in practice, and the Golden Visa's five-year holding requirement sits comfortably inside an 8-year term. The friction point is the extension: a move to 10 years needs 75% of votes cast, and your redemption right if you vote against it is the safety valve. Investors should read exactly how that mechanism works in the fund documents before relying on it.
Is it actually Golden Visa eligible?
This is the question to resolve before any other diligence. The manager states the fund "is eligible for the Portuguese Golden Visa, meeting all applicable legal requirements", pointing to CMVM regulation, the 60% Portugal allocation and the absence of real-estate exposure, and the €500,000 minimum is transparently designed around the visa threshold. Directory data tells a different story: movingto's structured eligibility flag records the fund as not eligible, and the discrepancy is unresolved in public sources.
The manager markets the fund as Golden Visa eligible, but movingto's database flags it as not eligible, and the conflict is unresolved. Eligibility is the entire premise of a €500,000 subscription for most buyers of this product. Obtain the manager's written eligibility confirmation and an independent opinion from a Portuguese immigration lawyer before subscribing on a Golden Visa basis.
What should US citizens check before subscribing?
Everything, because nothing is published. There is no manager statement on accepting US investors, no US tax information, no word on QEF reporting and no IRA guidance. As a non-US pooled fund, the default expectation is PFIC status for US taxpayers. Without annual PFIC information statements enabling a QEF election, a US investor faces the punitive excess-distribution regime, and the fund's monthly distribution design would interact with those rules in ways worth modelling carefully. The checklist: written confirmation of US acceptance, written answer on QEF statements, and a US tax adviser's model of the after-tax yield before any commitment.
How does it compare with other Golden Visa funds?
Three things set it apart within the venture capital category. The minimum: €500,000 against the €100,000 typical across this database, excluding anyone not subscribing at Golden Visa scale. The return shape: an income-style fixed target rather than equity upside, unusual for the category. The cost shape: zero headline fees but roughly 3% a year in aggregate running costs, inverted relative to peers that charge visible entry and performance fees over a lower expense base.
Applicants drawn to Portuguese tech exposure but wanting different structures can compare the Digital Insight Fund, a VC sub-fund in Portuguese AI and software with a far lower entry ticket, or the Prime Insight Fund, which spans healthcare and applied technology. The full set is on the funds database. Against those, G-Lock trades diversification of structure for predictability of target income, backed, for now, by no track record.
The unknowns
Recorded for completeness; their weight depends on your own situation.
- Golden Visa eligibility conflict between the manager's statement and movingto's flag.
- Constitution date and current fund size; the fund had not begun activity as of the November 2025 KID.
- Management fee as a standalone figure; only the ~3% aggregate cost estimate is disclosed.
- Terms and ISINs of unit categories A and C through F.
- US investor acceptance and PFIC/QEF position.
- Team composition; no individuals are verifiable on the manager's site.
Next step
If a fixed income-style target inside a Golden Visa wrapper appeals, the sequencing here is unusually clear: resolve the eligibility conflict first, then the fee and team questions. Roots can walk you through that diligence and how the fund compares across the database, independently and at your own pace. This article is information, not investment, tax or immigration advice; capital is at risk, and distribution targets are not guarantees.
