Email I just received re: SEF requested document:
Dear Kari,
They asked for an updated land register (it has not been updated on the date of submission, as it takes almost 2 months after the deed to get the answer from the Register office).
But weĀ“ve already resolved everything, so now it is just necessary to wait a bit. 
Since when arenāt commercial properties covered by the new rules? Arenāt commercial property rules identical to residential property rules, except you can buy commercial in more places?
I spoke to someone very senior in the Portuguese government today, and for what it is worth:
If this is true, this is great news.
I do not believe anyone has ever had this confirmed at all, let alone in writing from anyone in the government before. In fact, much guidance from law firms, etc, has been the opposite (that it does not start till the card has been issued). So if your contact has any way to make that happen - provide written guidance saying so, that would go a long way toward quelling the unease.
However, even if that is the case, I think it would be very hard to file a citizenship application with less than 4 years of actual residency. How will I show I have been there for the requisite 7 days a year if my 7 days do not start until 1 or perhaps 2 years in?
Also, it is quite disingenuous for them to blame the surge at the end of the year for the problems, that has nothing to do with the biometrics delays which have, on average more than a year waiting period, which seems to be expanding.
Thanks for the update.
Point 2: You are saying many people waited the last minute to invest. Please understand that GV applicants are never more than 2 thousands per year. I invested in April 2020 and only half of family got the Biometric. The rest of my family has been waiting for years. It has nothing to do with the influx of GV in the last two months of 2021. And it has nothing to do with the complexity of my application, they have given pre-approval. But they just do not want to give Biometric Appointment. You cannot argue that Biometric is a complicated thing.
Moreover, 40k Ukrainians came to PT and got the resident card within days proves that SEF has the ability to deal with high demand. Their ability is always ready to clean this mess.
SEF portal is now operational, accepting new applications. But Iām not sure if it is updated for the new regulationsā¦
SEF portal is now operational, accepting new applications. But Iām not sure if it is updated for the new regulationsā¦
Iām curious if this means theyāre now processing pre-approvals as well or if they simply reopened to more new applications (without processing the backlog of us who were already in the system, but not pre-approved).
So, partial good newsā¦SEF has started taking the GV applications again. Means they have started working and hope the pre-approval will also move along now. Hope for the best.
It is for me not something really good at all. What SEF is doing is that now they are getting more applicants i.e. they want to get more money from people. However, once they get what they wanted, they will repeat the same nasty game as they have been outplaying all the investors i.e. taking years to wait for the biometric appointment.
live2learn, I agree! All theyāve done is removing the error message from the ARI site. Nothing has changed on the site, not even the wording of the Golden Visa investment requirement to reflect that changes in 2022.
I just received a marketing email from The Golden Portugal. Here is the text exactly (copied and pasted):
** Start of quote **
Good News!!
A lot of you may know that the SEF had stopped taking in new online applications submission from their portal from the beginning of this year, due to the changes of the regulations.
During this period, you can still add dependents, resubmit documents as requested and so on. But new applications via funds and property investment have stopped.
After a long five and a half months waiting, SEF has finally resumed their portal for online application submission!
Hooray!!!
Those clients who have been preparing for the application are just one button away from submission. Meaning, those who started the process in February and March and have everything by now, are right in front of the queue as if they had their applications submitted in January 2022!
And for some who were a bit worried about this need not to be anymore.
Kick start your application process now!
The earlier you start, the earlier you can submit your application, and the earlier you get your pre-approval and biometric appointment.
Itās a virtuous cycle!
** End of quote **
If true it is good news, although I donāt know if this means that biometric appointment bookings have now also been re-started for those already pre-approved.
Anyone with more information do share please!
Doubt SEF cares about the fees. Also, they get 10x the fees from issuing residence permits as they do for the applications.
SEF will most likely not lose any fees once they put the investors in the ālock-inā mode. Once inside that mode, eventually the investors still have to pay fees no matter how long the process is. Probability that someone abandons GV is very mininal.
I agree. If this is truly the case, I think we would have heard from individuals that can confirm this by now? The GV program has around since 2012 so that means that anyone who applied in the first 5 is now eligible for to apply for citizenship. However, if they did make your residency start on the date you submitted your application, that would a long way to putting people at ease. And to be honest, thatās the fair thing to do. After investors have submitted their application, there is nothing the investor can or needs to really do to satisfy their obligation and itās 100% on Portugal/SEF. Their delay should not impact our timelines.
There is a reason you have an āapprovalā stage towards the end, where once biometrics are taken and the Director (of SEF? today) signs off on the application, your clock has ālegallyā started. It would be, practically speaking, the approval date that matters.
I am sure given the backlog of applications, there must be some pressure on the government to consider pre-approval as the start date, but I would not pin my hopes on that.
All said and doneā¦we havenāt yet heard any pre-approval since we last heard on 19th May. Latest application date who got pre-approval in this forum is for 15th November 2021. Assuming there are many in this forum who have applied between 15th November till 31st December, we donāt see any movement for pre-approvals. As if pre-approval has stopped after 19th May and for applications dated after 15th Nov.
Actually in the google form, there was one submitted on 11/17/2021 and pre-approved on 06/03/2022. This is the latest one I think.
Hello everyone,
I am just back from Portugal after three-weeks vacations. Beautiful country and very nice people, and so, IMO, you made a right choice to consider it for your future plans. I also had an opportunity to meet with my attorney to whom I posed many of the pressing questions we all have concerning perpetual delays and unresponsiveness of SEF. Here are her responses and explanations:
What are the reasons for delays?
The primary reason is still COVID-related backlog. The secondary is the re-organisation of SEF proposed by the previous government. The tertiary ā change of government and budget approval delays.
The new government has now postponed the elimination of SEF indefinitely since there is simply no money in the budget to carry it through. Instead, the pending proposal is to create a special task force within SEF to help expedite the processing of GV applications. The government recognises the benefit of GV programme for the economy and is prepared to take steps to ensure its survival and viability.
When does the five-year clock start ticking?
Originally it was when final approval was granted. However, the government has been pressured to change that practice and consider pre-approval date as the start of the five-year count. The group of immigration attorneys (mine including) made a case for the change due to unusually long delays unfairly caused by SEFās inability to cope with the backlog of applications, appointments, etc. This might not yet have been enshrined into a law, but it has been understood and, according to her, can be argued if necessary, during application for residency/citizenship.
When will biometric appointments resume?
Since SEF is now under pressure to deal with the delays, it is expected that biometrics will resume in Q3 of this year.
Furthermore, recognising the long nature of the process of securing appointments, the new scheme of temporary residency cards has been changed for the initial one good for two years, and the subsequent one for three years (instead of one year, two years, and two years).
Can you move to Portugal ahead of the receipt of temporary residency card under GV?
Yes, you can. A document from an attorney stating that you are in the process of applying for residency is all that is required. However, this will not allow you to travel through Schengen areas if your tourist visa expires.
And so, the morale of the story is that the programme is alive albeit has not been functioning as well as expected in the post-COVID environment. The steps have been taken to remedy the situation, but like everything else in Portugal ā it will take timeā¦ Lots of time.
Take it for what it is worth to you, but perhaps considering the glass to be half-full might be more beneficial.