Can we put any pressure on SEF for the biometric appointment delays?

@emstjohn . Just out of curiosity ā€“ March 2 2021 would have put you in Q1 2021 and you should have received an invitation from SEF for an appointment back in December or Januaryā€¦ did your lawyers mention if they received any email on your behalf from SEF? Iā€™m not sure if that puts you in a different category, but it might.

Hey, I am one of those waiting for the last renewal meaning that the article does not even touch or mention my problem, still I believe publicity around the current issue or at least part of the issue is better than nothing.

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I agree. No offense meant, but no one cares about your situation right now. As I stated, it takes stopping the fees to the agents and promoters to get some action so perhaps this is a good thing in the end that new applications are stopped as it will indirectly bring attention to your situation.

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We spoke with them in January and they explained the new chronological ā€œsystemā€ (which had us optimistic!) but they explained SEF was not calling our ā€œquarterā€ yet but they expected us to be called in Feb or March. It was shortly after that call that SEF stopped contacting people for apptsā€“iā€™m assuming at that time related to Ukraine? They claim there was never notification and they ā€œemail every weekā€ with no response from SEF. After finding this forum a few weeks ago I recently wrote them asking for clear thoughtful answers to a number of questions since weā€™ve had NO updates from them and weā€™ve yet to receive a proper response. Iā€™m just as frustrated with the lawyers as I am with SEF!

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@emstjohn Regarding ā€œnot calling your quarter yetā€ā€¦

Apologies, i had tried sorting the responses by application date but that seems to result in responses being submitted after that not displaying. Iā€™ll stop doing that. You should be able to see you responses now. Thanks

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@loheiman This database is great. I think the average days presented in the summary is misleading because its not picking up people who have been waiting but cannot get to the next step. For example, the time from submission to biometrics might show an average of 325 days, but if you look at the majority of entries the average is already well over 325 days in many cases. Is there a way to adjust the calculation logic to pick up this information in the averages?

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Oh wow thanks. sending to lawyers.

Thatā€™s an excellent point. Iā€™ve created another set of calculations that only consider timelines where that step has yet to be completed (thereā€™s many more of those data points at this time!). Be aware though that the accuracy of this data relies on folks going back and re-submitting the form when they in fact complete stages (as well as on me to delete their prior entry). Portugal Golden Visa Application Timeline Database - Google Spreadsheets

Good point there. If someone never returns and updates it will skew the results. That is something to be dealt with in the future. For now To be more statistically valid, another thing you should do is remove the lowest and highest response in each category. So if someone obtained their biometrics in 20 days, yes that is possible but its not likely repeatable.

I think it is reasonable to exclude any non-responses where the time elapsed is less than 75% of the median value. This way if someone applied today, it wonā€™t affect the average by showing 0 days from application to preapproval. Same for time elapsed is 200% of the median value for non-responses. This could mean that someone just never updated their entry. Once they submit a response it will include the response in the averages.

Check out the summary page now, Iā€™ve added histograms for each of step to help visualize things and identify outliers.

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I completely agree with @Garbonzo . The stoppage of the program in actually in our favor, because now the immigration industry has strong incentive to lobby the govt. Look at what they did in 2021: sending letters, sending more letters, and more letters. that only costed them a few euros.

What the industry really wants the gov to do now is to re-open the system for new application. The industry has little incentives to solve our old problem. That is why we have to have our own voice. We should also emphasize that now the biggest GV investor group comes from America. Portuguese society shares the wrong impression that GV investors are mainly corrupted rich people from China and Russia. Clearly not any more. And most likely it was never that way.

The future solution from the gov should give priority to those investors who have waited for so long. The easiest way is to allow the investors who have waited more than 1.5 years to choose their preferred appointment dates first, and then move on in a chronical order.

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thank you! great job!

There is clearly chaos at SEF. However, some of the investors in our pure VC fund (no property) have been approved this year and matters seem to be speeding up. I believe some categories of investment and fund are easier for them to process then others. And they have concerns that some investments are not truly meeting the requirements and are utilizing loopholes.

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That again unfortunately sounds like a SEF problem. If I were to quote our lawyers - we are meeting the letter of the law in terms of real estate investment, I donā€™t see how SEF could claim these applications are ā€œhardā€ to adjudicate. So SEF unilaterally decides that they are going to cripple the process.

I can see how a VC fund investment could have less documentation but unfortunately there has been no communication either from SEF or the government through rule making that going that route will get the applications processed quicker.

Fwiw Iā€™m happy for the people who did get their approvals.

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I donā€™t think VC fund or property makes much difference when it comes to the delay. Many people who applied through VC fund have waited for the biometric appointment for more than a years.

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I think the renewals angle is a strong oneā€¦ one that could appeal to international news media. Portugal made a promise ā€” for its own benefit ā€” and now a rogue agency is breaking that promise and poisoning the countryā€™s international reputation in the process.

Portugal is facing a demographic crisis, with many of its best and brightest leaving for better opportunities abroad because wages are so low. Most political players understand that foreign capital and skilled immigration are important tools to help solve that crisis. Immigrant-investors help broaden the tax base (i.e., help pay for social services for a graying population), inject money into the economy (by spending their money here on renovations, services and everyday living) while adding intangibly to the economy and society by bringing a wide range of skills and international connections.

Without skilled and/or affluent immigrants coming in, the young Portuguese nurses, architects, lawyers, accountants, etc who are leaving would be mostly offset by unskilled agricultural and tourism workers, which would only perpetuate the low-wage trap.

Coming back to renewals (especially of those who chose to settle in Portugal)ā€¦ here you have a group of people who read the glossy websites, followed all the rules, took a risk on Portugal. They were effectively invited to come to Portugal, yet now theyā€™re trapped in a bureaucratic nightmare. And the decision to rescind the invitation and fā€¦ them over isnā€™t even coming from the democratically-elected government. Itā€™s from an agency that, under the law, shouldnā€™t even exist anymore. In its feud with the government to save its turf, the agency is sending a strong message that affluent immigrants should go elsewhere in Europe.

Bloomberg, Reuters and the Associated Press all have bureaus in Lisbon, with their phone numbers listedā€¦

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I think itā€™s also important to email every reporter who publishes a story about the GV and tell them the real story on the ground, even if itā€™s after publication:

Some might do corrections, amendments or follow-ups.

Even the Portugal Resident reporter would probably appreciate more ā€œcolorā€

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I have made some further inquiries. This is all from one of the larger GV lawyers, so it is second hand and I cannot vouch for it, and may have misunderstood some. But for what it is worth it seems that the delays are caused by an unfortunate confluence of events - not all SEFā€™s fault. Although they are certainly far from blameless!

  1. SEF is going through a massive restructuring and this has resulted in a go slow by some staff. This has not only affected visa applications, but also border control at airports. The restructuring is expected to be completed soon.

  2. SEF has some concerns that some GV funds are not eligible. Portuguese law relies less on the letter and more on the intention than the law in say the US, so it is not as simple as just complying with the letter of the law, and the view is that possibly some investment options deliberately subvert the intent. This has meant increased scrutiny on most options, even those that are innocent. And all may be innocent and SEF may be overly cautious, there is no definitive claim that there has in fact been an attempt by any party to create a loophole.

  3. SEF have to do a lot more work when vetting a real estate investment so by itā€™s nature this takes longer.

  4. So some funds and most real estate options have had what looks like a freeze with few if any GV applications in these areas/funds being processed this year. Other funds are straightforward to process so are moving, but slowly due to the go-slow. Which explains why our investors have not experienced a freeze (although they have certainly experienced the go-slow) and to some extent we saw a speed up as SEF resources were diverted in our direction - which is why in my previous post I said that I felt matters are speeding up.

  5. What all investors, including ours have experienced is an inability to lodge an application online. This is because a new software system was installed by SEF, which was supposed to speed matters up, but there was a significant bug in the system. We are told that this will be rectified within a matter of days, but I am not betting on that. But this should only impact on those who lodged applications after the new software was installed - I believe beginning of December?

  6. There was a massive influx of investors in the last two months of last year, and this has overloaded SEF. So those who applied prior to beginning of November hopefully have received, or shortly will receive, pre-approvals. But those who applied after that will have to wait while the SEF python slowly digests the elephant it swallowed.

I hope that this makes sense, and alleviates some concerns?

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