Portuguese Citizenship Law – Amendments 2024

Great news for our Golden Visa clients! On January 5th, the Portuguese Parliament voted on amendments to the Portuguese Citizenship Law, bringing about positive changes that significantly impact Golden Visa applicants.

The Change of the Start Date of Legal Residency

One of the key changes approved is in Article 15 – Residence. 

New Rule – (4) For the purposes of counting the legal residence periods provided for in this law, the time elapsed since the moment the temporary residence title was requested is also considered if it is approved.

This means, the time elapsed since the request for a temporary residence permit is considered when calculating the legal residence period. This is a game-changer, especially given the notorious delays in the first-time approval on Golden Visa application, sometimes lasting 2 to 3 years. The government acknowledges the impact of these delays and aims to address them through this administrative and automatic measure.

Below is an interpretation of our partner law firm on this amendments.

 In practical terms, the waiting period for visas under the “D” programs shall start counting from the date of the appointment before the Immigration Services in Portugal, and not when applying for a visa at a Consulate or a VFS.

Thus, Applicant A, having applied for the visa on January 1st, having the visa granted on March 20th and having an appointment on May 8th, the period for accessing nationality would start to run from May 8th.

For Golden Visa applicants, we interpret that the 5-year counting period begins with the payment of the analysis fee during the online application submission.

This interpretation is supported by:

i) the legal requirements regarding execution of investment and clean criminal record are satisfied at the time of the application;
ii) at that moment a process number is assigned to the application;
iii) the online platform itself, owned by the Immigration Services, indicates that its functionality is “Register the application for the Residence Permit for Investment Scheme (ARI) and respective Family Reunification”;

iv) the proof of payment of the analysis fee expressly states “TITULO DE RESIDÊNCIA ACT. INVESTMENT” (title for golden visa permit); and
v) the platform designates the form as “requerimento” (application).

Therefore, the Golden Visa applicant who submits his/her application on the platform on August 2nd, and pays the analysis fee on August 4th, can, from this last date, start counting the 5-year period to submit his/her application to the Portuguese nationality.

Assuming this interpretation, Golden Visa applicants with processes submitted online, for example, in January 2021, can apply for Portuguese nationality in January in 2026, provided that the Golden Visa process has already been subject, in the meantime, to a notification of approval and payment of the issuance fee for their residence title.

Note: We have clients already asking how will the 7 days of stay requirement be counted with the new changes. Please note that there was no details on this in the amendments of the laws. Details shall be stipulated in the changes to the Portuguese Nationality Regulation.

We have to note that the amendments still need the President of the Republic to sign off.  The government will make necessary changes to the Portuguese Nationality Regulation within 90 days of these amendments’ publication.

We will follow up this matter closely and will update you with any updated news or understanding of the new amendments!


Embarking on your journey towards Portugal’s Golden Visa is a significant decision, and we’re here to guide you through the process with clarity and ease.

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