Portugal citizenship reform: insights from Immigrant Invest lawyers

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7 min

Portugal citizenship reform: insights from Immigrant Invest lawyers

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Summary

Portugal’s parliament approved amendments to the nationality law on October 28th, 2025. The proposed changes extend the required residence period for citizenship 5 to 10 years for most foreign nationals. The law now awaits the president’s decision.

Paul Lauber, Consultant and Compliance Anti-Money Laundering Officer, and Marielle Burti, in-house advocate at Immigrant Invest, explained how the amendments could affect current and future Golden Visa holders.

What are the main changes in the new law?

Portugal’s new citizenship law raises the residence requirement for naturalisation applicants from 5 years to:

  • 7 years for EU and Portuguese-speaking country nationals;

  • 10 years for citizens of other countries.

The new law also changes how the qualifying period is counted. The required residency period previously started from the date of application. It will now begin from the date of issuance of the first residence card[1].

This shift could have significant implications for applicants who filed years ago but are still waiting for biometrics or residence cards due to administrative delays at the Agency for Integration, Migration and Asylum, or AIMA.

Watch the video version of our experts’ talk on how Portugal’s new citizenship law affects investors

Why is the citizenship law considered controversial?

Marielle Burti noted that several Portuguese legal institutions, including the Bar Association and the Council of Magistrates, have raised concerns about the constitutionality of the amendments.

The Constitutional Court may be asked to review whether the changes can retroactively affect those already in the process.

Marielle Burti

Marielle Burti,

In-house advocate at Immigrant Invest

The amendments may violate the principle of equality and legitimate expectations. Two applicants who filed on the same day could now have entirely different citizenship timelines depending on AIMA’s backlog.

What should Golden Visa holders do now?

No immediate action is required until the president’s decision is published.President Marcelo Rebelo de Sousa has 20 days to either promulgate the law, veto it, or refer it to the Constitutional Court for review.

Preparation remains essential. Paul Lauber stressed that applicants should act promptly while the current rules still apply. For those who already have biometrics scheduled, it’s important to complete all documentation and proceed with appointments.

Once biometrics are completed, residence permit cards are typically issued within 2 to 4 weeks after biometrics.

Marielle Burti

Marielle Burti,

In-house advocate at Immigrant Invest

For those approaching the 5-year mark, we advise beginning the Portuguese language course or A2 exam preparation at least 6 months in advance and arranging proof of address in Portugal, such as a rental or loan-to-use agreement.

Does the new law affect permanent residency?

Golden Visa investors can still apply for permanent residency after 5 years, even if citizenship becomes available only after 10[2].

Portuguese permanent residency grants almost all the same rights as citizenship, including residence, study, and work. The only exceptions are voting and obtaining a passport.

Permanent residents may later apply for citizenship once they meet the extended residence requirement.

What are the residence and investment requirements?

Golden Visa holders must maintain their investment until receiving permanent residency. The recommended physical presence remains 7 days in the first year and 14 days every 2 years thereafter.

Proof of address is mandatory, but the property can be located anywhere in Portugal. Airbnb contracts, however, do not qualify. Immigrant Invest’s legal experts recommend having at least a 1-year lease or loan-to-use agreement before applying for PR or citizenship.

What are the costs of applying for permanent residency?

Current official fees are:

  • €8,463 — for the initial Golden Visa issuance;

  • €4,326 — for renewal;

  • €3,090 — for permanent residency.

Fees are updated annually by AIMA. It is important to check the latest rates before submitting an application, as fees may change annually due to administrative adjustments and inflation[3].

Individual cost calculation for residence by investment in Portugal

Individual cost calculation for residence by investment in Portugal

How long does it take to get permanent residency?

With proper follow-up, permanent residency cards are now issued quickly — usually within a month. However, efficiency depends on having a legal team that monitors the process in real time and communicates directly with AIMA.

Immigrant Invest’s close cooperation with local authorities allows faster resolution of issues such as unrecognised payment receipts and system errors that can delay applications for months.

What is the best course of action for investors?

Staying informed and prepared is the most practical approach. Investors should keep their residence and investment documentation up to date and coordinate closely with their legal and financial advisors.

Paul Lauber

Paul Lauber,

Consultant, Compliance Anti Money Laundering Officer, certified CAMS

Applicants should consult their legal team and fund manager to align the investment maturity with the expected residence timeline. If the law is enacted, strategy and timing will make all the difference.

Once the law is officially published, investors should reassess their path with updated information and remain proactive to secure their status.

The proposed Portuguese nationality law may double the naturalisation period, but Golden Visa investors still retain the right to permanent residency after 5 years.

Until the president’s decision is announced, preparation and close coordination with qualified legal professionals remain the safest path forward.

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About the authors

Written by Paul Lauber

Consultant, Compliance Anti Money Laundering Officer, certified CAMS

Paul performed preliminary Due Diligence checks for more than 1,000 investors. All the investors who passed the preliminary Due Diligence checks obtained citizenship or residence permits under state investment programs.