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How do you prove that you’ve met the minimum stay requirements under the Portuguese Golden Visa?

Residencies & citizenships Portugal Golden Visa 🇵🇹
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Under Article 90-A of Law No. 23/2007, dated July 4, Portugal offers a residency permit for third-country nationals engaging in investment activities without requiring permanent residence in the country. This residence type mandates a minimum five-year commitment to the investment activity.

Minimum Stay Requirements: To renew this residency permit, holders must meet the minimum stay periods outlined in Article 65-C of Regulatory Decree No. 84/2007, dated November 5:

  • 7 days (consecutive or non-consecutive) in the first year;
  • 14 days (consecutive or non-consecutive) for each subsequent two-year period.

However, in recent practice, initial residence permits have been issued for a two-year period (rather than one year, as was previously standard) and are subsequently renewed for two-year terms. This means that within each two-year period, the permit holder must stay in Portugal for a minimum of 14 days, presenting proof of presence during this time.

Proof of Stay Documentation: While neither the law nor its regulatory decree specifies the exact documents required to prove presence in Portugal, in practice, the AIMA (Portuguese Immigration and Borders Service) typically requests:

  • Boarding passes for entry and exit to and from Portugal;
  • Invoices with a Portuguese tax identification number for each day spent in the country, which may include receipts from stores, cafés, restaurants, hotels, and similar establishments.

Additionally, all family members included in the residency application are required to submit these proof-of-stay documents. For example, a single hotel stay of 14 days with the principal applicant’s tax identification number and the names of all family members may be sufficient. However, AIMA still requires individual boarding passes for each family member.

To ensure compliance, I recommend retaining all boarding passes and gathering one invoice per day to document your stay in Portugal.

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/prove-minimum-stay-golden-visa
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Can you clarify whether your arrival and departure day counts towards the minimum stay requirement?

In other words, if you arrive one Saturday at noon and depart the next Saturday at noon, does this count as six, seven, or eight days?

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Based on past experience with AIMA, there have been cases where eight days were accepted. However, to avoid any risk, it’s safer to count full days, as the outcome may vary depending on the person evaluating the case. So, in this case it is better to consider six days.

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Please could you address whether the stay requirements start from submission of your application online or receipt of pre-authorisation or your first biometrics appointment?

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If family members do not have a NIF, beyond boarding passes, how exactly do they document a receipt per day? We initially had them charge something on a credit card in their name but then was told AIMA does not accept that.

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Regarding stay requirements, with the change in the Golden Visa to essentially a 3 year D2, do you believe it is 21 days over those 3 years or do you suggest 7 days in year 1 and 14 days total in year 2+3?

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Could you please clarify if year means the calendar year it was issued or the year term from issue of the residence card?

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The stay requirements start from the date of issuance of the residence card and must be complied during the validity of the card (2 years).

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Beyond the boarding passes, we also require documents that include the names of family members along with the primary applicant’s name and tax identification number (NIF). Examples include a hotel invoice that displays the NIF and the name of the primary applicant as well as the names of accompanying family members.

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from issuance of residence card.

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For greater security, it is better to set 7 days in the first year and 14 days in the second and third years, as this aligns with the letter of the law.

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Thanks. Yes we own a flat so we don’t have any hotel receipts.

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In the initial post, the word “immediately” should be changed to “initially”.

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I am not saying any of this advice is wrong. But I would point out that it may be difficult for children, babies, minors to make purchases using a NIF. First, a NIF is not required for dependents to be eligible for ARI. For children who are dependents (literally by definition someone dependent on a parent to pay for their expenses), is it reasonable to expect them to have money and be able to make purchases , understand the cashier and provide a NIF in a foreign country? As for hotels, in my experience it is rare if not impossible for a hotel to list all guests on a receipt. In some cases I think their software literally does not support this function. Finally, the previous ARI manual has a description of which documents are required. It does mention some of the same documents listed by the OP but there is no such requirement on the scope or level of detail and precision indicated.

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Dependents do not have Nif. Then how can they have receipts with nif?

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Nothing stopping you from getting NIFs for your dependents as well… :wink:

But I’d be interested in getting @Margarida.Torres’s input here. I’m sure lots of people are in that boat.

Would taking a group selfie together with a daily Portuguese newspaper in front of some known landmark be a reasonable way of proving the whole family is indeed spending the required time in Portugal (in the case where not everyone has a NIF)?

Any other approaches that have been accepted by AIMA based on actual experience?

The OP has been updated!

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It is true that dependents can get Nif if they want. Howevet, i would strongly suggest that the dependents do not get nifs if they live outside Portugal. The reason is that it is impossible to cancel/delete the nif if you do not want to use them. Moreover, with nif, the problem of tax representation will arise and no having nif at all is best option to avoid all consequences.

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AIMA has been flexible and accepts boarding passes as sufficient proof for family members. However, if you can provide additional evidence, it would be even better. The suggestion of taking a group selfie together with a daily Portuguese newspaper in front of a recognizable landmark as a way to prove that the entire family is spending the required time in Portugal seems like a reasonable approach to me.

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It hasn’t been mandatory to appoint a tax representative just because you have a NIF for well over a year now. So I think, at least for other adult secondary applicants getting a NIF is well worth it.

For minor children I don’t think there’s any benefit.

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Since it is not mandatory, it is better not to involve from the first day. In addition to it, it is impossible to delete/cancel the tax ID.

To prove the stays 7 days/year, i would highly recommend that each adult books a hotel room individually so that the name of the peson displays on the booking and invoice. When submitting proof, each one has his own set of documents (boarding pass, entry stamp on passport in Portugal, and hotel booking). It is best that each can provide its own proof. It is even more concrete to eat all three meals per day during entire trip in hotel so that the final invoice from hotel shows 9 nights with all meals. Just trying to put AIMA in a position that they cannot argue or question anymore.