New Frontiers Energy Fund II is a closed-end, CMVM-regulated fund from Lisbon manager FundBox that buys shares in early-stage Portuguese solar projects on the government's "Acordo" priority list, develops them to Ready-to-Build stage and sells them on, targeting 10% net per year to a November 2033 maturity. Two things stand out in its file: one of the clearest US-investor postures in our database, with annual PFIC materials promised in writing, and a 25% performance fee that only triggers if the fund actually averages its 10% target. The main item to resolve first is basic: sources disagree on whether the subscription window is still open.
Key takeaways
- Closed-end solar development fund launched November 2025, maturing November 2033; invests in early-stage Portuguese solar projects on the government "Acordo" list and exits at Ready-to-Build stage.
- Fees are investor-friendly by segment standards: 1.5% management, a one-time 1.125% subscription fee paid externally, and a 25% profit share that applies only if the fund averages 10% a year over its life.
- Explicitly open to US clients, with all required PFIC materials supplied annually per the manager's investor snapshot.
- No interim distributions; all profit is paid at maturity, and early exit exists only for investors who quit the Golden Visa programme.
- One aggregator says subscriptions closed in May 2026 while the manager and another directory still show the fund as open; confirm availability in writing before planning around it.
What does the fund actually invest in?
The strategy is solar development, not solar ownership. Per the manager's materials, the fund buys shares in early-stage photovoltaic project companies in Portugal that appear on the government-guaranteed "Acordo" list, meaning grid access is guaranteed by 2030. It then helps develop those projects to Ready-to-Build status and sells them, capturing the value uplift between raw permitting-stage assets and construction-ready ones. Projects are co-developed with origination partners including Shannon Energy.
That model matters for how you should read the risk. The fund does not hold operating plants earning contracted revenue; its value depends on projects clearing development milestones and finding buyers at RTB stage. The government list de-risks one specific bottleneck, grid connection, but not the others.
Because the underlying assets are shares in project companies rather than real estate, the fund is marketed specifically for the €500,000 Golden Visa fund route, and the manager says several leading Lisbon law firms have approved it for their clients.
One structural wrinkle is optional diversification. Investors may divert up to 40% of their commitment into an affiliated "AWDR" structured-products fund. That softens the single-country, single-technology concentration, but it also means part of your money would sit in a different strategy with its own terms; anyone considering that option should diligence the AWDR vehicle separately.
What do the fees cost you over the fund's term?
The disclosed stack is short and, by Golden Visa standards, friendly. Management is 1.5% per year, taken internally from investment monies. Entry costs a one-time 1.125% subscription fee, paid externally out of pocket per the manager's snapshot (one directory lists 1.25%; we record the manager's figure). Directory data records no early-redemption fee, though that is not confirmed in manager materials.
Run the arithmetic on a €500,000 Golden Visa subscription held to the November 2033 maturity. The subscription fee is €5,625, paid once. The 1.5% management fee is €7,500 per year, roughly €60,000 over the full eight-year term, or about €45,000 to €52,500 if you measure only a six-to-seven-year citizenship window.
The performance fee is the distinctive part. There is a 25% profit share, but it triggers only if the fund averages a 10% annual return over its lifetime, in which case profits split 75/25 in investors' favour. Below that bar, investors keep everything above the flat fees. Most peers charge 20% carry over a much lower hurdle, so the incentive geometry here is unusual: the manager earns its share only by hitting the headline target. The mirror image is worth stating too. If the fund does average 10%, a quarter of the profit goes to the manager, so net outcomes around the target compress accordingly.
The minimum ticket is €100,000, with enhanced terms offered from €250,000; Golden Visa applicants need €500,000 in qualifying units regardless. Subscription is possible without opening a Portuguese bank account, which removes one of the slower steps in a typical fund-route application.
Liquidity, lock-up and the citizenship timeline
This is a hold-to-maturity commitment. The fund runs a growth strategy with no interim distributions; all profit is paid at maturity in November 2033. There is exactly one documented early exit: investors who elect to quit the Golden Visa programme can withdraw, on 45 days' notice per directory data. That is a safety valve for abandoning the visa, not a liquidity feature.
The timeline fit is workable for current subscribers. Naturalization via the Golden Visa tends to run roughly six to seven years in practice. A 2026 subscription held to November 2033 spans about seven and a half years, which covers that window for most applicants without needing a reinvestment plan at maturity. Applicants who expect a slow start, or who subscribe later in the fund's life, should ask what happens to units and visa compliance if the residency process outlasts the fund.
The most decision-relevant open question is whether you can still get in. One directory lists the subscription period as having ended in May 2026, while the manager's site and other directory data reviewed in June 2026 still present the fund as open. Before engaging lawyers or moving money, obtain written confirmation from the manager that new subscriptions are being accepted, and on what closing timetable.
One more calibration point on expectations. The manager reports 10% annual performance in 2024 and 2025, but describes it as unrealised portfolio valuation uplift, independently evaluated, and both years predate this vehicle's November 2025 inception; they appear to relate to the predecessor New Frontiers strategy. No audited fund-level return exists yet for NFEF2 itself. Past performance, realised or not, does not predict future results.
What should US citizens know?
This is the fund's strongest documented feature. The manager's investor snapshot states plainly that the fund is open to US clients and that all required PFIC materials are supplied annually to US investors. In a segment where most funds leave the US question blank, that is a materially better starting position, and directory data independently records confirmed acceptance of US persons.
The mechanics still need one confirmation. "All required PFIC materials" ordinarily means QEF annual information statements, which let a US taxpayer elect QEF treatment and pay tax on a pass-through basis instead of the punitive default PFIC regime. But the QEF election is not named explicitly in the published materials, so get written confirmation that the annual package includes QEF annual information statements before relying on it. Forms 8621 and 8938 will apply either way, and FATCA reporting through the fund's custodian, Banco BNI Europa, is routine.
IRA and self-directed IRA eligibility is not addressed anywhere in the public file. If that is your intended route, raise it with the manager and your SDIRA custodian before anything else, since it determines feasibility, not just tax outcome. And regardless of route, have a US tax adviser model the PFIC/QEF result on a fund that pays everything at maturity in 2033.
How does it compare with other Golden Visa funds?
Within our database's clean energy category, NFEF2 sits at the development-risk end of the spectrum. Its €100,000 minimum matches the typical segment ticket, and its 1.5% management fee sits at the lower edge of the usual 1.5-2% band. The 25% profit share looks high on paper but applies only above a 10% lifetime average, a hurdle far above the segment norm, which makes the flat-fee scenario the realistic base case for cost comparisons.
Its profile contrasts usefully with income-oriented peers. Greenpower Fund holds operating Iberian solar and wind assets and distributes income during the hold, where NFEF2 develops projects and pays everything at exit. Solar Future Fund III offers another solar-focused comparison point from a different manager. The full clean energy set is in our fund database.
The other differentiator is the US posture described above. Few Portuguese Golden Visa funds put "open to US clients" and annual PFIC materials in their own documents; for American applicants, that alone narrows the field.
What the fund has not published
Listed for completeness; how much each item matters depends on your situation. Fund size and capital raised to date are unknown, as is the target size (one directory's AUM figure is a clear data-entry error and we do not record it). Whether the subscription period has closed is contested between sources, as flagged above. The precise legal form, FCR or another AIF type, is not stated, and the fund's constitutional documents are not public. IRA eligibility and explicit QEF election support are unconfirmed. The ISIN reported by one directory (PTFXOLIM0003) does not appear in manager materials. The CMVM registration number 2358 comes from the manager's snapshot and directory data; we have not verified it against the regulator's registry. Monthly NAV publication and the zero early-redemption fee rest on directory data alone.
All of it is answerable during subscription diligence. Request the fund regulation, the audited accounts once available, and written answers on the subscription window and QEF statements, and treat those documents as the fund.
Next step
If development-stage solar with a hard 2033 maturity fits your Golden Visa plan, the sensible next move is to confirm the subscription window and then review the fund regulation line by line. Roots can walk you through NFEF2's documents alongside comparable clean energy funds, independently and without a sales agenda. This is information, not investment, tax or immigration advice; capital is at risk, and targeted or reported returns are not guaranteed.
