Following the initial proposal of the 2025 Citizenship Law amendment, we now have further clarity on the legislative process and its next steps. While some concerns remain, recent parliamentary and governmental actions provide signs of openness to dialogue and adjustments.
Parliament Postpones Approval to September, Opens Detailed Discussion Phase
The Portuguese Parliament has postponed the general approval of the law to September 2025, instead opting to lower the proposal to a discussion in detail stage. This means that the law will be debated article by article, allowing room for adjustments. The Government has publicly committed to seeking the broadest possible consensus, a position also encouraged by the President of the Republic, who emphasized the importance of a balanced approach in immigration and citizenship matters.
During this extended period, Parliament will hear key stakeholders, including lawyers who have raised concerns about the unintended consequences of the current draft on Golden Visa investors.
10-Year Citizenship Clock: A Constitutional Debate
One of the most sensitive points of the proposal remains the start date of the residence period for citizenship eligibility. The draft law suggests counting the required 10 years from the issuance of the residence permit, rather than from the legal deadline for approval (90 days from submission).
Several constitutional law experts have argued that this approach is unconstitutional, as it penalizes applicants for delays attributable solely to public authorities. Investors should not suffer from multi-year backlogs in residency issuance. We expect this issue to be addressed in the final law, with the residence period counting from the term of the legal deadline for the public authorities to approve the immigration application (currently 90 days after submission). This would restore fairness and predictability.
Political Support for Golden Visa Remains Strong
It is important to note that the motivation behind the proposed changes to the nationality law stems from a massive wave of unskilled immigration, driven by a legal loophole that allowed foreigners to enter Portugal merely by submitting a “manifestation of willingness to find a job.” This mechanism enabled many individuals with no prior ties to the country to initiate residency procedures and ultimately gain access to Portuguese nationality, using Portugal as an entry point into the EU, with the goal of obtaining freedom of movement within the Schengen area.
This unregulated influx placed substantial pressure on public services, housing, and infrastructure, prompting the government to propose stricter controls over the pathway to nationality, including extending the required period of residence.
In this broader context, a proposal by Bloco de Esquerda, a far-left party, to abolish the Golden Visa program altogether was put to a vote in Parliament on July 4th, 2025. The motion was overwhelmingly rejected, with only 5.2% of deputies voting in favor—limited to the far-left spectrum (BE, PCP, PAN, and Livre). The major parties across the political spectrum, including PSD, PS, CH, IL, and CDS, voted against the proposal or abstained, reflecting a broad consensus on the importance of attracting foreign investment and skilled labor through well-regulated programs like the Golden Visa.
This result clearly reaffirms that Portugal remains committed to investment migration as a strategic policy, distinguishing it from unqualified migration and reinforcing its role as a platform for international investors and talent.
What to Expect Going Forward: 5 → 10 Years Likely, but Mitigated by Permanent Residency
While the final residence period for citizenship is not yet decided, we expect the current 5-year period to be extended to 10 years. There may be political compromises that bring the number down to 7 or 8 years, but we don’t foresee the Government backing down on the increase of the current 5-year period.
In the meantime, as illustrated in the timeline below, Golden Visa holders may apply for Permanent Residency 5 years after the first resident card is issued, providing them with a stable and renewable status in Portugal. The Investment Permanent Residency card is valid for 5 years and does not require a permanent stay in the country, allowing investors to maintain their status in Portugal until they are able to apply for citizenship, while requiring the investment to be kept.
Timeline and Delays: What to Expect in Practice
Please note that the 2-year gap between the Golden Visa application and the issuance of the first residence card—as shown in the timeline—is only an estimate based on current conditions. Legally, AIMA (the immigration agency) must issue the card within 90 days of the application being submitted. However, due to a massive influx of unskilled immigration in recent years, the system has been overwhelmed, leading to significant delays.
The government is now implementing structural reforms to address this, including:
- restricting unqualified migration,
- reinforcing immigration services with more personnel,
- and streamlining internal procedures.
As these measures take effect, we expect the timeline to normalize back to 3 to 6 months, which was standard in earlier years.
Understanding the Timeline
The chart below visualizes a likely path under the revised rules, assuming a Golden Visa application is submitted in 2025:
- 2025: Application for the Golden Visa is submitted.
- 2027: First Golden Visa residence card is issued, marking the beginning of the legal residence period (delayed due to current administrative backlog).
- 2029: First renewal of the residence permit (after 2 years).
- 2031: Second renewal of the residence permit.
- 2032: Eligibility for Investment Permanent Residency, which is valid for 5 years and does not impose minimum stay requirements.
- 2035: Expected year when an application for Portuguese nationality may be submitted, assuming a 10-year residence requirement is enacted (counted from the first residence permit in 2027).
- 2037: Expiry of the permanent residency card.
- 2038: Estimated issuance of the Portuguese passport, allowing full EU citizenship benefits.
This roadmap provides investors with long-term security in Portugal, even in the event of extended nationality requirements, and highlights the importance of transitioning to permanent residence status after 5 years.
Permanent Residency vs Nationality
As investors consider how to navigate the extended residence period for citizenship, it is important to understand the key differences between Permanent Residency and Nationality (Citizenship) in Portugal. While both confer long-term residence rights, their scope and implications differ significantly.
| Aspect | Permanent Residency (for GV holders) | Nationality (Portuguese Citizenship) |
|---|---|---|
| Status | Foreign national with permanent residence rights | Portuguese citizen |
| Residence Validity | 5-year renewable residence permit | Permanent, lifelong |
| Minimum Stay Requirement | 14 days per 2 years (same as Golden Visa) | None |
| EU Mobility Rights | No automatic freedom of movement in the EU (travel allowed for tourism/short stays up to 90 days, but work/study residence permits required in other EU countries) | Full EU citizenship rights: work, reside, and study freely in all EU countries |
| Voting Rights in Portugal | Local elections only (in some cases) | Full voting rights (local, national, EU) |
| Portuguese Passport | No | Yes |
| Access to Portuguese Consular Protection Abroad | No | Yes |
| Tax Residency Impact | Can maintain non-resident tax status if living outside Portugal | Same (tax residency determined by actual residence, not citizenship) |
| Inheritance Rights | As per resident status | As Portuguese national |
| Eligibility Timeline | Eligible after 5 years of legal residence | Eligible after 5–10 years of legal residence (pending final law) |
| Application Process | With Immigration Services (AIMA) | With Civil Registry (IRN) |
Key Takeaways for Investors:
- Permanent Residency is a solid interim solution, allowing investors to reside in Portugal flexibly while waiting to meet the eventual citizenship requirements.
- Nationality, once granted, removes the need for any future residence renewals and grants full EU citizenship, including a Portuguese passport and expanded rights across the European Union.
- Importantly, the Golden Visa’s flexible stay requirements remain in place for Permanent Residency, meaning investors do not need to relocate to Portugal full-time.
Next Steps
The coming months will be critical. Hearings, committee discussions, and detailed debates will shape the final version of the law. We will continue to engage with relevant stakeholders and advocate for investor-friendly adjustments.
For now, investors should remain calm and monitor developments. The fundamentals of the Golden Visa remain intact, and the permanent residency workaround offers a clear path forward.
If you'd like to discuss how this may impact your situation, feel free to schedule a consultation with our team.