We are sharing the latest news on the 2025 Portugal Citizenship Law amendment and its potential impact on the Golden Visa program. It’s important to note that this is a preliminary proposal of law, which will therefore still undergo parliamentary discussion before the final version is approved and enters into force. In the meantime, the government is currently receiving feedback from various stakeholders. Below, we outline what is known so far, along with our proposals and recommendations. Our aim is to provide factual, non-alarmist information, offer constructive amendments, and help minimize any potential adverse impacts on investors.
The current Government, led by the Social Democrats, was responsible for the creation of the Golden Visa in 2012, and has expressed its intention to continue and improve the program during this term of office. With nearly 5,000 golden visas issued last year, it remains one of Europe's most successful initiatives in the attraction of foreign investment. The new immigration strategy seeks to manage low-wage, low-skill migration while reinforcing Portugal's appeal to high-skilled individuals and investors.
Extension of Residence Period for Citizenship from 5 to 10 Years
Most Golden Visa investors pursue the program with the ultimate goal of obtaining Portuguese citizenship after five years. While the current proposal suggests an extension of this period, we believe a ten-year extension is unreasonable, and violates legitimate expectations of immigrants and, in particular, of Golden Visa investors whose main purpose when taking the decision to invest in Portugal was the 5-year route towards a EU passport. We are actively advocating for a reduction of the proposed residence period to seven years for all immigrants, regardless of their home countries (Portuguese speaking countries or not), safeguarding the constitutional principles of equality and non-discrimination based on nationality.
Residence Period Clock to Start from Residence Card Issuance Date
A crucial aspect of the government's proposal is that the residence period required to apply for citizenship starts with the issuance of the resident card, revoking the current counting formula (approved in March 2024, just over a year ago!) according to which the counting would start from the application date, as a response to the massive delays from the national authorities in approving immigration applications since Covid.
This presents a significant challenge for individuals who have been waiting for over three years for their cards, for reasons exclusively attributable to the immigration authority and successive governments in solving the applications backlog. We consider this unfair and a blow to investor confidence in the country. Given that the government is legally mandated to process applications within 90 days after submission, we propose that the countdown should start from the term of this 90-day deadline, as delays are not the investors’ fault.
For investors who are still waiting for their appointments or residence cards for more than 3 years, this could mean an additional 3-4 years of delay before being able to apply for citizenship, on top of the 10-year residence period. If we bear in mind that citizenship applications processing times are currently reaching 3 years, this could mean around 17 years for some investors between investing hundreds of thousands in Portugal and receiving the Portuguese passport.
We are confident that the government is aware that Golden Visa investors have been constantly neglected over the past years, and that will have a negative impact in investor confidence and in the attractiveness of the Portugal Golden Visa program.
Impact on Children Family Reunification Proceedings
The current proposal also states that children, if over 18, must remain single and studying in order to renew residency every two years under the Golden Visa family reunification. With the potential extension to ten years (and especially when combined with the counting formula), this requirement becomes extremely difficult (if not impossible) to meet for the majority of the investors’ children. Therefore, we propose that an exception to this requirement is granted after the second renewal, bearing in mind that many investors seek the Golden Visa (and, in particular, the Portuguese Golden Visa) as a plan B for their children, giving them the chance to enjoy EU citizenship and freely travel, work and live in Europe.
Residence Cards Validity Remains Two Years, With More Renewals Now Required
Considering the high fees charged by the Portuguese Government for each residence card issued under the Golden Visa and its renewals, it’s crucial that either the validity of each card is extended, or the fees charged by the national authorities are reduced, under penalty of doubling or tripling the Golden Visa cost for investors and respective families, which would again break their confidence in Portugal and the legitimate expectations that were given to them when they decided to invest in our country.
No Permanent/Effective Residency Required
On a positive note, there are no intentions to alter the minimum residency requirements for Golden Visa applicants in Portugal, nor to require a permanent and effective stay in the country in order to apply for citizenship. This continues to position Portugal as one of the few European countries where the Golden Visa can lead to a passport without requiring long-term permanent residence (unlike Greece at seven years, and Spain and Italy at ten years). This means that while the waiting time for citizenship might extend to ten years, it's largely a passive waiting period, without the need to relocate to Portugal or become a Portuguese tax resident. This remains a significant benefit of the program.
Key Dates for the Nationality Law Approval Process in 2025
Please note that these dates are estimates and subject to change:
- General terms vote: Early July 2025
- Committee/Plenary review & amendments: July 2025
- Final approval by Parliament: End of July 2025
- Presidential promulgation: September 2025
Recommendations for Investors
We do not anticipate a transition period, as the submission of a Golden Visa application is not directly linked to the right to apply for citizenship under the rules in force as of the application date. Therefore, we advise investors who are currently applying to continue with their process, including opening bank accounts and onboarding with funds. However, it is prudent to wait until the final version of the law is approved before committing to capital calls and subscription of funds.
For those who are considering the Golden Visa but have not yet initiated the process, if a ten-year waiting period for citizenship is a deal-breaker, we recommend holding off until we have further clarity on the approved law.
We are always happy to provide more information. Please feel free to schedule a call with us to discuss your individual situation.