Assuming the law gets promulgated as-is… For Golden Visa holders - I have 5 years from my application in December so my dilemma is to do either of the following:
1.File now (early): The old law is still technically in force today — Seguro has not yet signed. Filing while Article 15(4) still exists in statute means the application is anchored to a legal framework that counted residency from your GV application date, not card issuance. A skilled lawyer can structure the submission to assert that my application-date count satisfies the 5-year requirement, forcing IRN to reject specifically on the new law rather than on a residency basis — which is precisely the rejection needed to trigger a clean Article 204 constitutional challenge. You also gain queue position, arriving at the litigation stage months earlier than if you wait.
-OR-
2. Wait until December 2026: My constitutional argument is actually strongest when I have unambiguously and factually satisfied the old 5-year requirement — no IRN procedural ambiguity, no disputed counting methodology, just a clean record of someone who met every condition that existed when they made their investment, waited years through AIMA’s broken process, received their card only in July 2025, and is now being told to wait until 2035. That is a 9-year retroactive extension imposed on a person who did everything right, and it is the most compelling legitimate expectations argument a Portuguese administrative court judge will see. Filing early adds a layer of legal complexity that could muddy that narrative; filing in December lets you walk into litigation with a single, constitutionally airtight claim already validated in spirit by the December 2025 Constitutional Court ruling.
I know a lot of lawyers are happy to file early per scenario 1. But might it be that scenario 2 is actually a stronger case to make for those whose 5-year date from application falls just after the law promulgates? Thoughts?
This is still unresolved. I wonder if it is true to say that no one so far has had a citizenship application successfuly approved based on GV application date?
From my research I agree that #2 is the stronger option and have decided against option #1. I am an October 2022 applicant so you are much closer than I am. If the original application date is not accepted, I believe 90 days after the application date may technically begin the five-year clock (that was the statutory deadline AIMA/SEF was legally required to meet for processing applications).
I have reached out to @madalenamonteiro about this issue but have not heard back. Several Nomadgate members hired her to file the amicus brief presented to the Constitutional Court. I wonder if she would be interested in taking on another group of clients in this category. I still have not received my card over 1,000 days past the statutory processing deadline, which I believe strengthens this argument considerably.
Yes, and that may mean two things about whether it will ever be given effect. First, anyone hitting five years from application after April 2024 wouldn’t have gotten approved yet, so we don’t have evidence that IRN has ever accepted the idea that it didn’t need the regulations or some other landing requirement. Second, only applications after April 2024 might have an argument that their legitimate expectation was five years from application date.
I have seen someone in Nomadgate that applied in 2024 from application date and has gotten his passort. It took 14 months to conclude the process. Some IRN offices have a citizenship completion rate of 12 months to 18 months. Unfortunately, Porto and Lisbon is 2.5 years to 3 years and that’s where the lawyer can apply for their client.
Can someone recommend a lawyer to file my naturalization early? I would be eligible for 5yrs in October 2026. I foolishly stayed optimistic but now I’m scrambling to do something before the door closes. I have my birth certificate (not apostilled) and police clearance (apostilled in 2022), and I have not yet signed up for a language course!
We applied for the Golden Visa in September 2023 and our initial biometrics appointment (for the main applicant) is finally scheduled for June 2026 — after 2 years and 9 months!!!
We recently consulted with a legal firm, and they advised us to apply for citizenship now, even before the biometrics appointment. Their reasoning is that the 5-year residency clock may already be running based on our application date. The worst case, they say, is that the application gets denied and we may face a 2-year ban before reapplying — but given the new nationality law currently awaiting the President’s signature, that may not be a major setback anyway. If passed, we’d be looking at 10 years from the date the first residency card is issued, which resets the timeline significantly regardless.
Has anyone else in a similar GV situation been given the same advice or considered this approach? Would love to hear your experience.
Recommend starting the document process ASAP: birth certificate apostilled and police clearance refreshed and apostilled. They’ll ask for a police clearance from all countries where you’ve spent 6 months or longer since turning 16 years old.
For the application, you’ll likely want to submit the existing docs as placeholders, to be refreshed later. As you say, the door is (maybe) closing…
Hello everyone, I paid for my GV in 24 May 2021 so my eligibility date is a month from now. I also filed a lawsuit against SEF to accelerate biometrics and won it. I got my first card issued in July 2024. What do you suggest? And can you please send me the link of the WA group? Thanks so much
Apply within the next few days if possible, the president could sign the law any day now. You can apply with outdated birth certificate, criminal record etc and your lawyer can send updated documents to IRN by mail.
There were news that PS already referred one of the proposals to the court (not the one about waiting time for naturalization) This may affect the day count i guess.
Hi Matt, are you able to DM me the WA group link as well pls? Apologies in advance, as probably you may have been receiving many such requests, but grateful if you could oblige. BR/Jayanth
