So, this is not quite what I’m hearing, but the difference is somewhat subtle. First, the law firm expects the current draft of the law to be found unconstitutional. They think that the government is reacting to EU pressure as much as local pressure, though, so they expect to see changes that bring the Portuguese requirements closer to other EU states.
To handle that, they expect D2 to be changed to allow for renewals from former ARI investor, without requiring a business plan or any of the other steps. Essentially, if you had an ARI, you are assumed to match the “new D2” and can renew within it. To get around the problem of the very different residency requirements, they expect the “new D2” to have a requirement for fiscal residency (which normally occurs with 183 days) but to have a process to allow someone to acquire fiscal residence by declaration if they are “new D2” holders.
The logic here is that the EU is complaining in part about lost tax revenue. By pushing these holders to become fiscal residents, the tax issue is reduced to some degree. With NHR, this isn’t a big deal for Portuguese visa holders in their early years of residence.
My lawyer’s take on this is that this “new D2” allows the government to kill the thing called a golden visa, but to construct a visa with many of the same characteristics almost immediately; the only difference will be that buying real estate won’t be allowed as an investment for new holders.
The firm is somewhat politically connected, but I don’t think this is a revelation of a state secret; I think it is cynical projection after a close read of the landscape. Take the rumor with the usual grain of salt.