Early Applications for Citizenship

Residencies & citizenships Portugal Golden Visa
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413

Correct, and that was the rationale given for the change in the law in 2024.

414

When requesting the certificate using AIMA’s Modelo 7 form, there is a section where you can specify the reason for the request and exactly what you want the certificate to state.

Could you please check with your lawyer whether they specifically requested a certificate confirming:

  1. the date of submission/application for the residence permit under the Investment Activity / Golden Visa process; and/or
  2. the date from which the ARI process has been pending or approved?

This is important because a standard residence-time certificate may only show the residence card issue date, unless the request explicitly asks AIMA to certify the ARI application/submission date or the date from which the process should count for nationality purposes.

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415

That is extremely helpful context! And a good reminder of when I should and shouldn’t DIY. My lawyers didn’t request it - I did. And I didn’t think to ask it in that way. My goal was to have an official document issued prior to the change in the law confirming my qualification for the 2021 start date.

416

Hopefully, the dimwits at IRN will request it correctly.

417

I’ve also mea culpa’d to my lawyers and asked them to help.

418

When did you apply?

419

The government probably instructed them to yeet out all the early applications as part of their ongoing F■■■ You initiative.

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420

The government probably instructed them to yeet out all the early applications as part of their ongoing F■■■ You initiative.

If I created a marketing initiative (social media accounts, websites, fb groups, etc) that aims to show people Portugal for what it really is, would I be able to get funding?

At some point it can become a non profit corp that aims to prevent people from getting screwed by scams pulled by governments like portugal

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421

There is no more WhatsApp group, the community moved to telegram. Nobody could get into the WhatsApp as it was full. Telegram: Join Group Chat

422

Around 1 May

423

That was fast, I thought others here said it takes several months up to a year.

424

The late check
The later check that starts 10-25 months after submission is the real technical review. If they need something, they issue an exigencia.

The early check
There’s a new pre-validation check under Art. 27(3) for a summary rejection (“indeferimento liminar”) before it even gets as far as technical review. This 27(3) indeferimento liminar is what we’re colloquially calling “faltas”, and they’re coming swiftly after submission, within 2-6 weeks from the Lisbon conservatoria (Registo Centrais), and potentially slower from Porto.

There is now an AI tool that IRN uses that flags missing or invalid documents almost immediately, within hours of submission. Then a human sends the faltas after reviewing the flagged document and checking the AI didn’t trigger a false positive. This human step is what leads to the 2-6 weeks delay for issuing faltas. Then your lawyer has 30 days to cure the missing/invalid document.

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425

who invented this falta word?

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426

how did you learn that? :slight_smile:

427

It is well documented:

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428

It’s just what’s commonly used in WhatsApp and telegram, possibly because some lawyers use it.

Case 1. IRN may issue a demand letter for additional documents, which happens later in the process. This is “exigencia” which literally means “demand”.

Case 2. IRN may issue a notice of summary rejection due to missing documents, unless cured in 30 days as per Article 27(3). The IRN letter literally says: “NOTIFICAÇÃO
 indeferimento liminar
 Não foi acompanhado do(s) seguinte(s) documento(s), necessários para comprovar os factos que constituem o fundamento do pedido” which says “Notification
 summary rejection
 It was not accompanied by the following document(s), which are necessary to substantiate the facts constituting the grounds for the request”. Lawyers are calling this “falta” which literally means “missing”, which captures the essence of “Não foi acompanhado”.

429

You said “There is now an AI tool that IRN uses”

Article you linked is from 3 years ago.

430

I mean all the sources talk about using AI, but there is nothing about “late check” and “early check”.

We are simply in uncharted territories right now and this could be the only check for all we know.

431

It’s Portugal, nothing is built overnight. The first link announces the plan in Feb 2023. The second link announces the software release in Nov 2024. The third link points to teething problem in 2025. My guess is it took them a further 1yr after release to work out the basic teething problems. So it’s still quite new, under a year old.

Moreover, IRN made a change in April 2026 so that “numero processo” is assigned almost immediately, instead of months later. My suspicion is that as part of that April 2026 software plumbing to get numero processo so quickly, it also meant the AI document check now runs much sooner, since it probably ran soon after the numero processo gets assigned, and therefore only ran 6-8 months after submission until recently when it can run immediately after submission due to the much faster numero processo.

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432

You are portuguese?