Early Applications for Citizenship

[richn4 (RG)]

@kipper_tucking0a

More and more faltas are pouring in now. It was a trickle, but becoming a flood. SNIP The govt seems to be targeting April and May applicants. Lawyers are also in shock, they expected this in 4-10 months, not weeks.

Let me, for a moment, highlight the extreme hubris of many of the GV law firms that have been so confidently prominent in this exercise. I changed law firms earlier this year with the specific aim of renewing my GV residence permit that was pending expiration. They only wanted to focus on submitting an early citizenship application and whipped me up into a froth of stressful activity to get PCCs and apostilles from multiple different territories which was never going to happen under pressure of time completely neglecting the activity required to renew my RP in a timely manner.

Fast forward a few months and I inevitably failed to get the PCCs (I actually only had one in hand by the change in law date) and got nowhere near submitting the early citizenship application. Presumably I would have already been on the receiving end of an early “falta” now.

I felt a lot of pressure from lawyers to do this early citizenship application and take no pleasure in the additional pain it is now bringing GVers who did go down this route and are now being roughly rejected - some may say predictably rejected. I hope the lawyers who so gleefully applied this pressure are now realising the very real human cost of such actions when they make a bad situation worse.

[PTbound (A L)]

Well to be fair, lots of people kept saying that the PT government (or Tribunal Constitucional) would be equitable, reasonable, and grandfather existing GV applicants. Naysayers were called pessimists. So “early nationality applicants” held off.

@goncalomendesleal

Just as in past legislative reforms, we expect any change to include transitional provisions. In practice, this means that investors who have already initiated their Golden Visa application—i.e., submitted their process—should not be affected. Although the residency permit and citizenship processes are legally distinct, it is our firm belief that the rationale adopted by the Portuguese government will continue to recognize and protect the expectations upon which these investments were made.

In the end, it turns out to be more like this:

Early Applications for Citizenship

I’ve come to the conclusion that this is basically a Polymarket/Kalshi-type bet that the IRN will continue to be f’d up (or even more f’d up than it is now!) for years to come. That’s probably a safe bet However the bet also requires that the IRN will accept the logic that Thomas noted above - and will abide by the TC’s (obtuse!) intimation that they should only start counting back 5 years when they eventually get to your Nationality application, years from now. Who knows? …

[rahaskli (Ray)]

@richn4

I hope the lawyers who so gleefully applied this pressure are now realising the very real human cost of such actions when they make a bad situation worse.

Yes, many of these people are nothing more than charlatans. Their core line of business has collapsed on them — after failing us for years — and now they have resorted to a hundred other ways to extract money from the same people they already let down.

I am beyond frustrated. I would have named and shamed my own lawyers, but the story is almost too typical: they do not respond even after dozens of reminders, yet they recently had no problem sending me a cheerful email asking me to pay them to file my taxes going forward — something they never even did for me in the past.

That tells you everything you need to know.

[live2learn]

@FilmMaker

For what is it worth I have a fully document complete (5 year from application date w/expired card) online application into this Lisbon office that lists “submetido” on 06-05-2026 that has not moved to “Em analise.”

Your application did not move to “em analise” does not mean that irn did not start analysing your application. It usually means for the time beings your application is complete under first round (non-technical checking i.e. basically just checking if you have all documents at the time of the submission - the validity/content of these documents are not checked/verified at this round) and was forwarded to next round of “more technical analyses”. In the subsequent rounds of technical checking, if they need you to provide sth, they will update on platform. If nothing is needed, you will get “em analise/para decisao/ concluido” all in one day (example below). This happens a lot recently. So just wait and see!

[kipper_tucking0a (NK)]

Below is an example falta someone shared for not having an apostille on their birth certificate.

Assunto: Pedido de nacionalidade portuguesa respeitante a (name) - NOTIFICAÇÃO
Nos termos do disposto no nº 3 do artigo 27º do Regulamento da Nacionalidade Portuguesa (RN), aprovado pelo Decreto-Lei nº 237-A /2006, de 14 de dezembro, notifico V. Exª dos fundamentos que conduzem ao indeferimento liminar do requerimento apresentado ao abrigo do disposto no artigo 6º, nº 1, da Lei nº 37/81, de 3 de outubro, a fim de que, no prazo de 30 dias úteis, se pronuncie, por escrito, sobre as questões suscitadas, podendo requerer diligencias complementares ou juntar documentos:
1 - Não foi acompanhado do(s) seguinte(s) documento(s), necessários para comprovar os factos que constituem o fundamento do pedido (cfr. nº2 do artº 27º do RN):
a) Certidão do registo de nascimento da sua constituinte, emitida pelas competentes entidades do registo civil dos Estados Unidos da América, devidamente legalizada pelas entidades consulares de Portugal naquele país, nos termos do disposto no artº 37º, nº 9 do Regulamento da Nacionalidade Portuguesa e artº 440º do Código de Processo Civil Português, ou com a apostilha aposta pela autoridade competente, prevista na Convenção de Haia, relativa à Supressão da Exigência da Legalização dos atos Públicos Estrangeiros, concluída em Haia, em 5 de Outubro de 1961.

Mais se informa que o não cumprimento do solicitado no(s) ponto(s) nº 1 no prazo referido, acarretará o indeferimento liminar do requerimento não havendo lugar à devolução da quantia paga.

Com os melhores cumprimentos,
O/A Oficial de Registos

The type of falta for missing A2 certificate is possibly different.

[live2learn]

@kipper_tucking0a

Below is an example falta someone shared for not having an apostille on their birth certificate.

It is 100% normal because if this person were to apply in person at IRN office, he would be denied immediately. The IRN staffs do the non-technical checking when people come over to apply for citizenship. Missing either one stamp or one document means refusal.

[kipper_tucking0a (NK)]

A lawyer chimed in on the group chat about why some faltas are 10 days and some are 30 days:

10 days when the document is from Portugal
30 days when it is a foreign document

So A2 is 10 days but apostille or refresh of a PCC is 30 days.

And she also clarified on two more things:

• it is 10-30 working days, not calendar days
• if multiple docs are falta, it’s the greater of the two. So if A2 and PCC is falta, you get one notice for 30 days mentioning both.
• a marriage certificate is required if the name on the birth certificate does not match the name on the passport.

[PTbound (A L)]

Hi @kipper_tucking0a. The “falta” example you provided was from Conservatoria dos Registos Centrais - so Lisboa. I assume there’s also Arquivo Central do Porto examples?

Some say that the Lisbon IRN is faster than Porto (i.e. less f’d up). So I’m wondering if Lisbon is more on the ball with this pre-screening/reject effort?

[cj807 (Chris J)]

Data point: I’m Porto and still under analysis. My wife is Lisbon and received a falta yesterday for both A2 and lack of marriage certificate. Both submitted April 30th

[padel09 (padel)]

Has any early applicant actually received a falta yet for lack of the required 5 years of legal residence?
If not surely that’s a positive sign?

[anonymous104]

@kipper_tucking0a

So if A2 and PCC is falta

What happens if the date of the A2 certificate is after the date of enactment of the new law? Is there any examples of this happening yet?

[kipper_tucking0a (NK)]

@anonymous104

What happens if the date of the A2 certificate is after the date of enactment of the new law?

Doesn’t matter. IRN released a public statement on their website that they will consider any Submissao date before the new law was enacted as grandfathered under the old laws. Adding documents later doesn’t change that. The date inside those documents doesn’t affect the Submissao date of the application.

[kipper_tucking0a (NK)]

@padel09

Has any early applicant actually received a falta yet for lack of the required 5 years of legal residence?

No. And IRN can’t. CdT is calculated by AIMA. It takes months. I’ve heard rumors that there’s a project to automate it for December 2026. But it’s very manual right now.

[edandmegan (Ed M)]

Well - not sure what to do and looking for some guidance. When we applied for the GV, the “start date” for residency was the date the 1st residency card was issued (in our case, 2023). In 2024, AIMA changed that provision in our favor, stating that the start date would be the date of application (in our case, 2021). Early this month, because of the (then-impending, now implemented) 2026 nationality law changes, we recently (a) submitted a citizenship application, and (b) applied for the Certidão de Contagem de Tempo de Residência in order to show our start date . We received them today, dated 13 May 2026. These certificates showed that our start date is 2023 — not 2021. I realize that under the new law, the start date is back to 2023, but on 13 May we were still under the old law.

Do we need to formally challenge their determination of our start date? If so, does anyone know how I start that process?

Obrigado!

[layover_guy (M M)]

it’s no longer just a rumor, i am in that telegram group and seeing few people posting their falta request with 30 days notice.

Basically, if you have filed early application and are missing A2, Birth Certificate or PCC (later 2 must be apostiled) you are getting Falta asking you for submission of these documents within 30 days, could be a 10 days in some cases.

The way i am treating this informations, i have submitted early application and pretending like i got falta request this morning and i have 30 days. I am figuring out if its posisble to even get the A2 certificate if i start now, seems like there is a way if you want to spend a lot of money.

With that mindset, every day is an extension. So i am in this special scenario, where i am the only one who might get 5-10-15 or even 30 days extension on top of falta request.

[rahaskli (Ray)]

Someone in a Telegram group mentioned that he is on a Golden Visa and recently received his Certidão de Contagem de Tempo.

According to him, they considered him a legal resident from the date his first residence card was issued, not from the date his application was approved.

His application was approved in February 2020, but he only received the card in July 2022. He then applied for citizenship in September 2025.

I see many people here saying their Contagem de Tempo started from the application date or payment date, not the card issue date.

So why would his case be treated differently — other than the obvious answer.

Counting only from the date the first residence card was issued seems totally unreasonable, especially when card issuance delays were outside the applicant’s control.

[rahaskli (Ray)]

Have your lawyer frame this as a transitional-law issue and request corrected CDT from AIMA based on 15(4) . I am now assuming I am going to face the same problem.

[Guy-man]

It might be a mistake from AIMA. He should request another one from another AIMA office and also explain to the officers if he has access to them.

[kipper_tucking0a (NK)]

Here’s statistics on how many received faltas so far:

So far, 100% of the faltas have been issued from Lisbon (Registo Centrais). But it’s likely Porto is just slow and may issue them as well, just a bit later.

The falta letters are issued under Article 27(3) and threaten “indeferimento liminar” (summary rejection) if the missing/invalid docs are not cured within 30 working days.

[PCERoman (Roman)]

Also, if you were applying in 2021, i.e. during COVID, there was a Dispacho in-place that gave all applicants equal rights with the citizens. It was meant more for those already residing in Portugal, but you could probably use it as well to argue your case.