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If you're not requiring any compatibility criterion between the real and complex structure, then the only obstruction is in fact orientability. Every smooth projective real algebraic surface is a smooth compact real 2-manifold (without boundary). If it's orientable, it must then be a surface of genus $g$ for some $g$. But every surface of genus $g$ admits a complex structure, and every Riemann surface is algebraic.

I don't study real algebraic geometry much, but I'm not aware of a good compatibility condition to impose on your complex structure. If you've got something in mind, let me know.

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If you're not requiring any compatibility criterion between the real and complex structure, then the only obstruction is in fact orientability. Every smooth real algebraic surface is a smooth real 2-manifold. If it's orientable, it must then be a surface of genus $g$ for some $g$. But every surface of genus $g$ admits a complex structure, and every Riemann surface is algebraic.

I don't study real algebraic geometry much, but I'm not aware of a good compatibility condition to impose on your complex structure. If you've got something in mind, let me know.