Important update (April 1st, 2026)
Following the prior intervention of the Constitutional Court, the Portuguese Parliament has approved a revised version of the amendments to the Nationality Law. The bill will now be submitted to the President of the Republic, who may promulgate it, veto it, or request further constitutional review.
From the perspective of Golden Visa investors, the approved text remains largely consistent with previous drafts and does not include transitional provisions for applicants who have not yet submitted their citizenship applications at the time of the law’s entry into force. These developments significantly increase the relevance of timing and procedural positioning, particularly in light of the change from 5 to 10 years required to access citizenship.
The points outlined above will be further addressed in the sections below, where we examine their legal and practical implications in a structured manner.
The Parliament Decision
The vote held on April 1st marks a further step in what has become a complex and iterative legislative process surrounding Portugal’s Nationality Law. Following the earlier intervention of the Constitutional Court, Parliament proceeded with a revised text that largely preserves the core policy direction initially proposed by the Government. The final version reflects a political alignment between the Government and the party CHEGA, whose combined parliamentary weight was sufficient to secure approval, notwithstanding the opposition expressed by other parties.
In practical terms, the amendments continue to signal an intention to recalibrate access to Portuguese citizenship, notably through the extension of the required residency period from 5 to 10 years and the reinforcement of integration criteria.
At the same time, the parliamentary outcome should be understood within a broader institutional context rather than as a definitive legal endpoint. The legislative process remains ongoing, with the President retaining the authority to promulgate, veto, or request further constitutional review. This follows a phase of constitutional scrutiny in which certain provisions were previously challenged, while others, including the longer residency timeline, were not invalidated. As such, the current decision reflects an evolving balance between policy objectives related to integration and system capacity and the constitutional principles that continue to frame and limit legislative action.
Next steps: Timeline for the future outcome
Following parliamentary approval, the legislative text will now undergo final technical consolidation and formal redrafting. This stage, while largely procedural, may still require adjustments to ensure coherence and alignment with prior constitutional guidance. In practical terms, this phase is typically concluded within one to two weeks, after which the bill is formally submitted to the President of the Republic.
At that point, the President may choose to promulgate the law, exercise a political veto, or refer the diploma once again to the Constitutional Court for preventive review. If such a referral occurs, the Court would generally take two to four weeks to issue a decision, depending on the complexity of the matters under review. Taking these steps into account, a more conservative timeline would suggest that the process could extend until the mid of May, or end of June if additional constitutional scrutiny is triggered.
Once promulgated, the law proceeds to publication in the official gazette (Diário da República), usually within a few days, after which it formally enters into force under the terms defined in the text.
What now? How this will impact your process
Based on the available information, the approved text does not include transitional provisions protecting individuals who have not yet submitted their citizenship applications. This is not a minor technical detail: it is the single most consequential element of yesterday’s decision.
In practical terms, this creates a clear distinction: applicants who submit their process before the law enters into force will place themselves in a more favorable legal position to actively defend their rights, whereas those who apply afterwards will fall under the revised regime (including the extended residency period to ten years).
Timing has therefore ceased to be a secondary consideration. It is now the central variable in determining which legal framework applies to your citizenship process.
Strategic Guidance: The Path Forward
In light of these developments, investors should approach the current framework with a heightened awareness of timing and procedural positioning. The absence of transitional safeguards significantly increases the importance of acting within the existing legal regime, particularly for those who are already considering or preparing a citizenship application.
From a legal perspective, the distinction between having submitted an application before the law enters into force and doing so afterwards is not merely procedural: it is substantive. Those who are able to meet the time requirements for the citizenship application under the current law (meaning their residence permit was requested at least 2.5 years ago) should file an early application to citizenship as soon as possible. Those who do not yet meet such threshold, will in due course have strong grounds to seek judicial protection, defending their legitimate expectations and their right to have the law applied according to the timeline under which they made their investment decisions.
In this context, strategic legal guidance becomes essential. At NSM Lawyers, we have been closely advising clients on how to structure and anticipate these transitions, ensuring that their position is not only compliant, but also defensible if tested. Where necessary, judicial avenues remain available but their effectiveness is inherently linked to the strength of the legal position.
Final note: Even in times of political shifts, the law remains a safeguard
For investors, this is not a moment of disruption, but one that calls for attention, informed judgment, and strategic planning.
Portugal’s framework is built on principles that do not shift overnight: legal certainty, proportionality, and the protection of legitimate expectations are enforceable constitutional standards, as the Constitutional Court demonstrated clearly in December 2025. Even in times of political shifts, the law remains a safeguard, ensuring that investors are not left without recourse. In practice, this is an area where experienced legal guidance becomes particularly relevant, not only to anticipate risks, but also to ensure that investors are properly positioned should their rights need to be defended, as we have been closely advising at NSM Lawyers.
At the same time, it is important to acknowledge that the rationale behind these amendments is, in itself, understandable. Access to Portuguese citizenship is a serious legal and political matter, and it is legitimate for the State to ensure that it reflects a genuine and sustained connection to the country. In that sense, a more structured pathway, combining periods of temporary and permanent residence before citizenship eligibility, may contribute to reinforcing that link and promoting a more consistent level of commitment from applicants.
Nevertheless, the legitimacy of the objective does not eliminate the need to safeguard fundamental legal principles. Any changes must respect the temporal application of the law and the protection of legitimate expectations, particularly for those who have already invested and structured their lives based on the existing framework. From our perspective at NSM Lawyers, this is where the current approach raises concerns.
Importantly, the broader political context should not be overlooked. The primary driver behind yesterday’s decision is not the Golden Visa program. It is the pressure generated by over one million individuals residing in Portugal under informal regularization mechanisms (the so-called manifestations of interest). This group represents a substantial pressure point in terms of administrative capacity and public services. Against this backdrop, from a social and political standpoint, any measures affecting Golden Visa investors, a comparatively small and highly regulated group, should be approached with particular care and proportionality.
For those already committed, and for those still evaluating their options, the key is to remain focused on structure, timing, and long-term objectives with the confidence that, where necessary, their rights are not only recognized but can also be actively upheld. Where political solutions fall short, judicial protection remains available and, as our experience has shown, it can be effectively pursued to ensure that the rule of law is not merely theoretical but applied in practice.
We recognize that these are deeply complex matters, with real implications for those who have trusted and invested in Portugal in good faith. If you would like to understand better how these developments affect your situation, we are fully available to provide a personalized analysis and guide you through your options. Feel free to reach out to us at NSM Lawyers: we are here to help.
If you have additional questions on this topic, feel free to post them below or reach out directly.
This is a companion discussion topic for the original entry at https://nomadgate.com/portugal/legal-questions/early-citizenship-application
but I strongly suspect the date of submission will be the date when your online application turns to the “Submetido” status, i.e. the date when the payment is made (the hint is in the name..).
