Golden Visa Update: Progress, Legal Stability, and What Lies Ahead

Residencies & citizenships Portugal Golden Visa
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Editor’s note: This guest post is written by Vanessa Rodrigues Lima, Vice President of PAIIR and Co‑Founder & Partner of Prime Legal. It summarizes key updates from a meeting between AIMA and PAIIR, combined with recent legal developments from Portugal’s Constitutional Court.

Disclaimer: It is for general informational purposes only and does not constitute legal advice. The content reflects the situation as of August 2025 and may change. Please consult your legal advisor for case‑specific guidance. -Thomas

2025 has become a pivotal year for Portugal’s immigration framework. On the one hand, AIMA is rolling out reforms to resolve backlogs and modernize processes for Golden Visa applicants. Portugal’s Constitutional Court also stepped in to strike down provisions of the new Immigration Law that violated constitutional protections.

On the other hand, there’s the looming uncertainty surrounding the proposed changes to the Nationality Law that may see the residency requirement jump to as much as ten years.

Together, these developments bring both operational improvements and legal safeguards, providing some hope for Golden Visa holders during a period otherwise characterized by uncertainty.

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Golden Visa Update: AIMA Progress, Constitutional Court Ruling & Permanent Residency

Hosted by: Prime Legal on Aug 29, 2025

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1. Digital Transformation Ahead

  • A new, fully digital Golden Visa platform is scheduled to launch in January 2026.
  • Features: complete online application, integrated payments, and with biometric data collection only after approval.
  • Important: This will apply only to new cases; ongoing and renewal processes will remain on the current system.

2. Backlog Management: Key Targets

  • Renewals: AIMA has received 2,867 form submissions and already scheduled 2,190 appointments. Family renewals will follow once these are completed.
  • Initial Applications: All concessions are targeted to be scheduled by December 2025.
  • No‑Show Policy: Missed appointments will result in draft rejections unless justified by force majeure.

3. Payments & Technical Fixes

  • As of July 31, 2025, all DUC payments up to mid‑June have been updated in the portal.
  • Any missing payments will be flagged for correction—a significant step in resolving past administrative delays.

4. Processing Order

  • Applications continue to be processed largely in chronological order (by DUC date).
  • Exceptions apply to:
    • Cases with positive court rulings.
    • Select files used for system testing.

5. Constitutional Court Ruling: Investor Rights Protected

On August 8–9, 2025, the Constitutional Court declared five of seven provisions of the Government’s Immigration Law amendments unconstitutional.

What Was Blocked - Exclusion of spouses or partners from family reunification. - A rigid two‑year waiting period before reunification. - Judges found both measures violated constitutional protections of family unity and proportionality.

What Was Upheld - Provisions preserving immediate family reunification rights for holders of specific residence permits, including the Golden Visa and HQA. - The Court confirmed these distinctions are non‑discriminatory and constitutionally sound.

Political Outcome - President Marcelo Rebelo de Sousa vetoed the bill and returned it to Parliament for revision. - Debate will resume in September 2025, with reforms required to align with constitutional principles.

6. Renewals, Representation & Legal Opinions

  • Current renewal forms apply only to investors; family renewals will follow later.
  • Appointment notices clarify whether personal attendance or legal representation is required.
  • AIMA is preparing a legal opinion on the rights of GV family members in the event of an investor’s death—a long‑awaited clarification for succession planning.

7. Family Reunification

  • The Constitutional Court ruling further safeguards the family reunification right, ensuring spouses and children cannot be excluded and timelines cannot be arbitrarily delayed.
  • In the future, ARI family reunification rules will likely be enforced more strictly according to the law, meaning the primary investor receives approval first before adding dependents.

8. Resubmissions

  • Starting September 2025, resubmitted applications will move forward in chronological order of resubmission.
  • No new criminal record will be required unless flagged by internal checks.
  • AIMA has reinforced the GV unit with new legal staff.

9. Court Cases

  • Applicants proving physical residence in Portugal continue to see success in court.
  • However, AIMA is still working through a backlog of court‑mandated cases filed in early 2024.

10. Golden Visa Permanent Residency

  • Applicants seeking Permanent Residence through the Golden Visa do not need to maintain their investment.
  • A formal AIMA guideline will soon clarify the applicable minimum stay rule (0 vs. 14 days per year).

11. Citizenship Law: Still Pending

  • The Constitutional Court’s ruling applied only to Immigration Law amendments.
  • Proposed changes to the Nationality Law—such as extending residency requirements for citizenship—remain under discussion and are scheduled for parliamentary debate in late September 2025. PAIIR has already met with the political parties and will continue to do so during the first two weeks of September.

Final Thoughts: Stability Amid Change

While Golden Visa applicants continue to face significant delays, two encouraging trends are clear:

  1. Operational progress at AIMA, from DUC updates to appointment scheduling, is finally producing visible results.
  2. Judicial safeguards from the Constitutional Court have reinforced family rights and confirmed the constitutionality of Golden Visa privileges.

As these reforms unfold, PAIIR acknowledges that the immigration services team now managing the program has shown genuine goodwill and determination to resolve long‑standing issues. Their commitment to getting the system back on track inspires confidence that the Golden Visa framework can soon operate with greater efficiency and stability. PAIIR will continue to actively assist in the improvement of the program, serving as a bridge between the immigration services, investors, and legal representatives to ensure clarity, fairness, and long‑term success.

In addition, PAIIR remains fully committed to defending the Golden Visa program and the rights of its investors and their families. We will continue to engage with policymakers, monitor legislative changes, and actively lobby for solutions that promote legal certainty, efficiency, and the long‑term success of Portugal’s investment migration framework.

This is a companion discussion topic for the original entry at https://nomadgate.com/paiir-aima-meeting-golden-visa-update
12 Likes
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Thanks for this post and all the clarifications. At this point, it feels good to receive any news.

  • If I may ask, did they provide a reason for stopping the approvals in August all together?

  • In your opinion, how realistic is the December 2025 target given the AIMA’s track record of continuously missing their targeted date?

  • For the biometrics appointment, you mention “Missed appointments will result in draft rejections unless justified by force majeure”. To my understanding, AIMA doesn’t really give you a lot of choice when scheduling these. What if I have an important business meeting on that day or some prior commitment which simply cannot be missed?

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@kai.kiyoto Where did you see that they stopped approvals in August?

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For family members who can’t yet resubmit documents, does AIMA have any plan? I already have my card since 2022 but our child added in 2023 is still in limbo and it seems there is no way to resubmit for them?

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The resubmission, as is my understanding, was for primary applicants and their familes who hadn’t had biometrics. At the begining if 2025, these people had to resubmit all of their documents or risk having their applications considered abondoned. I don’t think your dependant falls within that catagory.

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Our kid has not had biometrics, so they should be in this category? But I heard the portal is only open for primary applicants.

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I can’t speak to your specific situation. My gut tells me that your dependant didn’t need to resubmit because you were already approved, but I’m just some dude on a message board, not an expert.

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Is this a new ruling? And are you talking about the specific version of PR only open to golden visa holders?

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This was a clarification made by AIMA during their meeting with PAIIR last month.

My guess is that it applies to both variants of the PR, but perhaps @vanessa.lima can clarify?

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Hello! This was always a grey area in the Immigration Law in what concerns PR for GV holders. During the meeting held with AIMA, it was confirmed that as soon as the Investor is granted with GV PR, there is no need to maintain the investment. We will talk about this in the webinar session. Thanks!

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Correct. For those applicants with biometrics already executed, there is no need to resubmit. These cases are currently being processed by the task force as the processes were distributed among several AIMA offices.

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Hi!
Is there any way to know which AIMA office the case was assigned to? Perhaps we can go to any AIMA office to confirm this information and check the status?
Thank you.

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Thanks @vanessa.lima. Will we be able to view the webinar online after the event? I can’t join at that time.

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In principle, the legal representative only has access to that info if a notification is issued requesting additional docs/info or informing of the approval.

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@tkrunning may assist you with this question :slight_smile:

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We’ll share the recording with everyone who registers for the webinar as soon as we receive it from Prime Legal, no matter if you’re able to attend live or not.

You can also submit any specific questions you have when registering so that @vanessa.lima can address them during the webinar.

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@vanessa.lima thank you for the updates

Would you have any idea regarding the timeline for final approval for those who did their first biometrics in 2023 and 2024 in Lisbon AIMA?

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Thanks for the update, after an expectedly quiet August, good to see there’s some action. Of course, remains to be seen how the execution is. A couple of questions:

  1. Assuming a change in the Nationality Law, will the PR still be eligible after 5 years? When does the counter for this start, application submission, or residence card date?

  2. For the resubmissions, are the application dates null & void, and the chronology will only be resubmission date? Is the December 2025 deadline for scheduling of appointments, so the actual biometrics can be in 2026?

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for PR, 5 years start from the printed date on the initial card.

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