Yes, I think that’s correct.
I’ve taken advice related to this, it only applies to those who move to PT before issue of a residence card ( as I have done).
The feedback was that if I made a citizenship application this would rejected, but should I appeal with proof of legal residence in PT for the period before the card was issued I should be successful (this would require paying taxes in PT and probably 183 in-country but didn’t go into details.)
It could effect anyone like me who applied before January 2022 and subsequently moved to PT.
(I’m along way off any of this but trying to assess any ‘cost’ to SEF delays.)
I wonder if anyone else has similar feedback…