I have the same idea…Also between 01/01/2022 - 03/11/2022 ( the date that PM announced that GV will finish) will be very fast cause of less number of applicants(1/7 of applicants compare to 2021). But after 03/11/2022 to the end of GV date the applicant number is really high again.This is what i understand from the link.
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Adding our data point (don’t think I have done it so hopefully not a repeat post).
Applied and paid 2 Nov 2022. Expecting pre- approval na próxima semana
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I think it depends on if you’re the main applicant or family. For pre-approvals it seems to follow the main applicant’s application date but family application date for biometrics. My daughter’s application was submitted in Jan 22 and she was pre-approved in early May 22 along with the rest of our family. My application date was 31 Oct 21. Those in our family who applied in Oct / Nov 21 were invited for our biometrics end Dec 22 and had the appointments in Feb 23.
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I would guess you get pre-approval by around the 12 month mark from the date of your application, based how things are going now.
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Pretty amazing, but got preapproved! I really lost hope and stopped even checking the forum. Dec.3 2021 file date, preapproval 26.04.2023. Almost 16 months of wait. Now a new quest begins!
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Congratulations! 
At the same time , it saddens me that they are still sorting out the missed cases in the beginning of December 2021. When will the damn month be cleared!
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December 2021 is a never ending black hole.
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Not true, I applied Dec 29, 2021, it has been 16 months still waiting on Pre-approval
@DGHATIKACHALAM1 I think when you get your pre-approval, we know SEF are close to completing 2021! Please keep us posted of your pre-approval. Here’s sincerely hoping your pre-approval is imminent!
i am not sure if sef is processing in any kind of order. i am picturing a pile of applications at a bunch of sef employee desks and each employee is going through the pile of applications at their own pace.
i guess gv applications are at the bottom of sef’s priority list.
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While an individual SEF officer will be working through their own pile, at the end of that process they will submit the file to the Regional Director for approval, and then it goes to the National Director for sign-off. Who knows how the RD and the ND prioritise those.
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Your situation, being in the Dec 2021 black hole, is different. I expect things to move faster once SEF hits 2022.
There isn’t anything new that can be said about the delays in processing, but I’m also hopeful that the ratio of SEF employees working on GV cases to the number of applications they have to process will go back to how it was before late summer 2021. That, coupled with online renewals means there should be significantly more resources freed up to process applications.
Of course these are all theories at this point, so we’ll have to see what happens to the pace of approvals once anyone in 2022 starts to get approved.
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Question is: when will SEF get to 2022 applicants 
If the current law goes into effect never. Please see below of an analysis done by a group of legal experts on the proposed new Article 44 and 45.
This is one of many specific problems that will impact EVERY ARI/Golden Visa investor whether you have a residence permit or are just applying:
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Under new Artice 44 paragraph 5 all renewals will be converted to a residence permit for Entrepreneurial Immigrants in the terms of No. 4 of Article 89 of Law no. 23/2007 of 4 July in is current wording.
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No. 4 of Article 89 in its current wording states, “A residence permit is granted to a third party national who develops an entrepreneurial project, including the creation of an innovative based company, integrated in a certified incubator under the terms defined by an ordinance from the members of the government responsible for the areas of internal administration and economy…”
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Paragraph 3 of Article 45 (which applies to new applicants) states, "the requests referenced in the preceding paragraphs (i.e. applications that “remain valid” and requests that are pending procedures of prior control in the municipalities) are applied with the necessary adaptations (not defined) in paragraph 5 of Article 44. This is no. 2 above.
So that means all applications and renewals of existing residence permits will go before the competent authorities as defined in paragraph 4 and 5 of new Article 55 which are:
a) The Agência para o Investimento e Comércio Externo de Portugal, E. P. E; (The Agency for Investment and Foreign Trade of Portugal, E.P.E)
b) Banco de Fomento; (Development Bank)
c) The Agency for Competitiveness and Innovation, I. P. E;
d) The National Innovation Agency (ANI);
e) The Office of Cultural Strategy, Planning and Assessment (GEPAC);
f) Others that prove appropriate due to the subject matter.
Has any dealt with these authorities for your residential or commercial property purchase or rehabilitation project on a personal or commercial building, let alone investing the appropriate amount of money in a fund or equities?
Why is SEF or its successor AAMMP not specifically called out???..Oh, right these agencies approve Entrepreneurial Immigrant Residence Permits not ARI permits? Where in the law does it give these authorities the power to approve a real estate investment for an Entrepreneurial Immigrant visa which does not fit the definition in Article 98 No.4 (number 2 above)
In other words, we are a square peg the Government of Prime Minister Costa is proposing to try and stick in a round hole. This MEANS are applications and renewals will all stop because there is no law or decree that states they will move forward without complying with Article 98 no. 4.
We will all have to eventually go to court to enforce our rights under the protection of the confidence of trust in the actions of the government at the times we made our investments. Another FYI, it takes 1-4 years to get to an actual hearing at the first court level on your case in Portugal right now. If you need to appeal that takes another 1-3 years and so on.
Everyone needs to stop worrying about when their pre-approval and biometric date will be and realize the Government is trying to stop all of us from getting any permits in the way the new Article 44 and Article 45 are written.
Now is the time to call your lawyers and ARI advisors and demand they tell you what they are doing on your behalf to stop this and then demand as their client they call all of their friends and acquaintances who are connected to the political parties or Government of Prime Minister or Presidential Administration and demand a negative vote on the first reading on May 19 or make massive amendments during the committee hearings.
10,000-15,000+ law suits from ARI Investors/GV applicants over the next 2 years will seize their court system and while that happens our investments will be frozen in a foreign country which could go bankrupt (do they have $7Billion dollars laying around to pay us back) because under Article 22 of the Constitution if we win the Portuguese Republic must pay us due compensation.
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I expect things to move faster once SEF hits 2022.
From what I could tell, June 2022 when they started accepting applications again has a pile larger than December 2021. Are there any changes to the approval process from 2021 applications to 2022 applications?
If not, you can expect even worse wait times for anything post June 2022.
Where did you get your data regarding June 2022? My law firm says they processed significantly fewer applications in 2022, and our own forum database reflects that.
Would love to know more about your theory and its sources!
Does any one have experience/information on suing SEF for not sending out biometric appointment invite? Still waiting for an invite after application in Nov 2021 and pre approved in Jul 22.
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Sure, I got my information from: SEF Resumes Biometrics Appointment Bookings for Golden Visa Applicants (Except for Renewals) - IMI - Investment Migration Insider (imidaily.com)
Based on the article, there are about 1000 applications that were lodged on June 15th alone.
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@kai.kiyoto thanks for sharing the article. If indeed the numbers are even 1/2 of what the article states, those awaiting pre-approval could be waiting a long while.
Only time will tell!
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