Portugal: Permanent Residence Permit for Investment Purposes

Residencies & citizenships Portugal Golden Visa
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41

I’ve just reading Thomas’s email about the full rug pull. There are some concerns about the GV PR.

Here is the scenario:

Main applicant applies for GVPR and finally gets it in hand. Then he sells the investment. However, his dependents are on 2nd normal GV card and their cards are going to be expired in 6 months. So when the dependents’ cards are expired, how are the renewals going to be for them? Obviously they only finish 4 years of residency and will have to apply for a normal GV. What are the exact required documents that need to be prepared in this case? I just cannot find it on Aima’s website. Whenever the topic is about GVPR, I find it very murky and dodgy because with 8k fees/card there is no clear published information on Aima’s website. Or maybe there is but I did not see it…

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42

If the position is that dependents’ GVs can only be renewed whilst the primary applicant remains on GV, then the primary applicant needs to keep the GV and not apply for PR until their dependents have renewed for the last time.

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43

Probably the answer lies in (as per what I have read on WA and on this forum) that GVPR is distinct from a regular PR. So the primary applicant continues to be on GV in a sense. This is conjecture. So please do confirm independently.

44

Good question. Did you watch the first webinar I linked from the email (the one hosted by Prime Legal/PAIIR)?

They discuss this very issue during that webinar.

I haven’t watched the webinar since it came out, but IIRC dependents can continue renewing their GV while the primary has GVPR.

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45

Thanks Thomas. I’ve watched. But it is only lawyer’s words. They did not quote and show any concrete documents from Aima to prove their statement. Maybe they got the information from some Aima’s staffs. However, it means nothing to me if Aima does not explicitly publish it on the website.

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46

That’s a big deal if so - because my understanding is that a dependent wouldn’t be able to renew their GV if the investment isn’t held anymore.

47

Continuing on the subject of PR, i have one more question.
The counting time for PR starts from the date written on first resident card. Then the gap between renewals is also counted? Or only time on card is counted?

For example: one has to wait 1 year to renew first card and it take another 6 months to actually receive card in hand. Assuming that first card expires in May 2024 but 2nd card starts in Nov 2025. Then 1.5 year gap is counted or not?
If not, then there is a significant amount of time extra that needs to be kept in mind and to achieve 5 years card-based counting one might actually need to spend 7 years (or even more).

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48

Been wondering the same myself. Happy to get clarification on this as well.

49

The past gaps between cards have all been covered by the ‘COVID’ legislation up until Oct 2025. Since Oct 2025 any gap between cards of less than 6 months is covered by the ‘normal’ regulations of the Foreigners law.

So yes, the gaps between cards are counted in as part of ‘legal residence’.

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50

I would be bery cautious with the term “legal residence”. Although “waiting for cards is consider a period of legal residence”, it only can be counted to the total time when applying for citizenship under the current law. But to apply for PR, we need more concrete text from Aima to conclude. The number of PR holders are already a very limited number and a number of GVPR holders probably is less than 1% of PR. Therefore it is almost impossible to have feedbacks and enough data to draw up a conclusion.

51

It’s probably cheaper for them if you pay for it too :slight_smile:

52

Agree. The legal validity of (inter alia) residence permits was extended by Decree. Gaps up to 15 Oct 2025 would count as legal residence, assuming of course that other criteria, such as minimum time in Portugal etc, are met. It would apply equally to citizenship and PR. I looked into this quite thoroughly in 2023, but balked at being bilked the ridiculously inflated GV PR price, when I already had a citizenship application in. Of course, I didn’t expect that 3 years later I’d still be waiting for decision :roll_eyes:

53

Maybe relevant to this thread, but I was reading on reddit that someone said that AIMA has not made any appointments available for permanent residence for nearly a year / it’s impossible to get an appointment. Wondering if anyone has more information on that.

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54

Thought I would compile the excellent advice in this PR thread (and others, plus my own research) into a table so it’s easier to compare. At some point this should probably become a Wiki, but it’s still early days.

In particular I wanted to sanity check GV Promoter claims that “Permanent Residence is almost as good as Citizenship,” now that PT Citizenship may get much harder to attain.

:warning: table below is still in draft, especially items in [square brackets]. Helpful corrections/additions are welcome!
Aspect Temporary Residence ARI (‘Golden Visa TR’) Permanent Residence ARI (‘Golden Visa PR’) Permanent Residence (regular, non-ARI) Citizenship (Nationality)
Minimum time required in PT 7 days/year (average) 7 days/year (average) [6+ mo./rolling 3y period?] (@tkrunning) No
Proof of available PT accommodation required No (other than for above 7d/year) Yes Yes No
Maximum time allowed in Schengen (other than PT) 90 days in past 180 (not counting days in PT) 90 days in past 180 (not counting days in PT) 90 days in past 180 (not counting days in PT) Freedom to work, reside in other EU countries. (If >3 mo, need to be employed, self-sufficient or enrolled student. After 5y can get PR in 2nd country.)
Protection from future PT Nationality requirement changes No (e.g. 2025 Foreigners Law, and Nationality Law proposals) No (e.g. 2025 Foreigners Law, and Nationality Law proposals) No (e.g. 2025 Foreigners Law, and Nationality Law proposals) Lifetime, but

2026 Nationality Law (tbd): revoked if commit major crime in 1st 10y?
Eligibility for EU Long-Term Residency No No: need 6+ mo./year in that non-PT EU country, but can’t due to Schengen (above) (@anonymous69).

Must apply for and be granted LTR (i.e. new residency application) in other country, no automatic right to it. (@lala)		 No: need 6+ mo./year in that non-PT EU country, but can’t due to Schengen (above) (@anonymous69).

Must apply for and be granted LTR (i.e. new residency application) in other country, no automatic right to it. (@lala)		 Yes
Visa-free access to many other countries No No No Yes – in 2026, 121 other countries visa-free, 43 visa-on-arrival, 9 with e-Travel Auth
Application to granting – estimated time In 2025: anywhere from 1 to 5 years Unknown so far.

Jan. ’26: AIMA launches ‘Long-Term Residence Permit’ appointment request form		 Unknown so far.

Jan. ’26: AIMA launches ‘Long-Term Residence Permit’ appointment request form		 In 2025: anywhere from 1.5 to 5 years
Permit/card duration Initial: 2 years

Renewals: 2 years (ex. old Real Estate ARI, which becomes 3-year D2 on renewal, see Lei 56/2023 42.º)		 5 years 5 years Lifetime

2026 Nationality Law (tbd): revoked if commit major crime in 1st 10y?
1st permit/card cost (2025) €605.10 application +

€6045.20 permit		 €5643.00 €350.00

(@lala)		 €250
Renewal costs (2025) €3090.40

(ex. old Real Estate ARI D2 conversion = €181.70 for renewal)		 €4326.30 €150.70 [?] N/A (ex. ~€65 passport renewal every 5-10y)
Renewal requirements Maintain ARI investment, 7d/year average in PT, no PT tax/NISS debts, criminal checks, etc. Proof of available PT accommodation, 7d/year average in PT, no PT tax/NISS debts.

Administrative act only (@tkrunning)		 [same as ARI PR?] N/A
Renewal delays (at AIMA, etc.) In 2025: 5+ month waits for in-person AIMA renewal appointments. As of Oct. ‘25: 3-6+ month additional delay from renewal fee payment to receiving new card. [supposedly simple Administrative act, but no empirical evidence how quick/slow in reality] [supposedly simple Administrative act, but no empirical evidence how quick/slow in reality] N/A
Risks of travelling on expired permit/card (due to renewal delays) If ‘caught’ ex-PT, may risk record of being irregular in Schengen Area. [same as ARI TR] [same as ARI TR] N/A
Other risks of expired permit/card (due to renewal delays) No visibility on renewal status, or where new cards are.

PT Banks may have issues w/expired visa.		 [same as ARI TR] [same as ARI TR] N/A
Aspect Temporary Residence ARI (‘Golden Visa TR’) Permanent Residence ARI (‘Golden Visa PR’) Permanent Residence (regular, non-ARI) Citizenship (Nationality)
Years PT residency required before eligible to apply N/A 5 years 5 years In 2025: 5 years

2026 Nationality Law (tbd): 7 years for CPLP/EU, 10 years for all others
Start date for counting years to eligibility N/A 1st (Temp.) resident card date (never application date) 1st (Temp.) resident card date (never application date) In 2025: 1st application date (but applied inconsistently!).

2026 Nationality Law (tbd): 1st resident card date
Gaps allowed between permits/cards (i.e. renewal delays) in counting years to eligibility N/A [presumably same as Citizenship, but no empirical evidence] [presumably same as Citizenship, but no empirical evidence] Up to 15 Oct ‘25, gaps count as legal residence, assuming other criteria, such as minimum time in Portugal etc, were met (@Lala).

Post 15 Oct ’25 Foreigners Law, gaps <6 mo. covered in regs (@tommigun).
Ability to dispose of ARI investment during permit term Must hold investment during entire Temp. residency (i.e. until granted PR or Citizenship) Can sell investment upon PR, but still need proof of PT accommodation for PR appl’n/renewal (@tkrunning). N/A N/A (not bound by ARI terms)
Aspect Temporary Residence ARI (‘Golden Visa TR’) Permanent Residence ARI (‘Golden Visa PR’) Permanent Residence (regular, non-ARI) Citizenship (Nationality)
Dependent implications – permits/visas Spouse and children (<18 or enrolled in study and supported by Primary).

Parents/in-laws supported by Primary.

All must meet same criteria upon every renewal (child ‘aging-out’ risk here).		 Can continue on Temp. ARI while Primary has Perm. ARI (@tkrunning).

Can apply for Perm. ARI after 5y on Temp, thus becoming independent of Primary (@anonymous69).		 Can continue on Temp. ARI while Primary has Perm. ARI (@tkrunning).

Can apply for Perm. ARI after 5y on Temp, thus becoming independent of Primary (@lala).		 [Spouse (Art.º 3) and minor/incapacitated children (Art.º 2) can live in PT or other EU countries with Primary (Art.º 6.1 for PT Naturalisation), even if they are not EU citizens?]
Dependent implications – eligibility [todo] [todo] [todo] Their own Nationality (not just residence) requires “connection to PT community” (e.g. married 6+ years, children attend PT school for 5+ years) (@anonymous69)
Dependent implications –renewal costs Same as Primary (e.g. €3090.40) for each Dependent Same as Primary (e.g. €4326.30) for each Dependent Same as Primary (e.g. €150.70) for each Dependent N/A
Dependent implications – education [todo] Equal treatment w/nationals w.r.t. education & vocational training (@lala) Equal treatment w/nationals w.r.t. education & vocational training (@lala) [todo]

[children’s access to Uni in other EU countries?]
Healthcare – PT Serviço Nacional de Saúde (SNS) [Yes?] Yes Yes Yes
Healthcare – EHIC access across all 27 EU states (90 day limit) No Need to reside in PT. Also need NISS which is now harder to get if no PT income (@tkrunning). Need to reside in PT. Also need NISS which is now harder to get if no PT income (@tkrunning). Yes [same residency req’s as PR?]

Last updated: 25-Jan 2026

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55

There is no confusion in the PR eligibility, the text is crystal clear and the clock starts from the date of First permit issuance and the gaps are absolutely fine:

“Titularidade de autorização de residência temporária há pelo menos 5 anos”

56

Obviously it is not clear at all here since gaps are not mentioned at all. One could only have “titulo de residência” with total time of 4 years (1 st card of 2 years + 1 year waiting to renew + 2nd card of 2 years) but the date of the first permit was 5 years ago.

Unless AIMA changes the wording, it’s difficult to conclude…

57

This I take issue with the tax residency. Having accommodation in PT does not give rise to tax residency.

Renewal requirements

7d/year average is disputed. Because the PR is “permanent” and the only condition required to renew is biometrics. Waiting for clarification from AIMA whether they will require proof of 7 days per year.

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58

Thanks Terrence - the compilation is a work in progress!

PT tax residency implications of PR - I removed, as can’t find where I first read about that anymore.

7d/year renewal requirement for GV PR… I got from articles like the following RFF Advogados note. Some other people doubted whether anybody actually checks for PR, however.

60

Does anybody know if old Real Estate ARI converts to D2 (upon GV renewal) would thus be non-ARI Permanent Residents if they applied for PR?

I assume if you want the GV benefits like only 7 days/year in-country, then you’d need a GV PR. But as a D2 would you only be allowed a regular PR?

I realise that accurate details on the PT PR are as rare as those for the Loch Ness Monster… heard of it, never actually seen one :sauropod:

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61

Yes real estate GV is eligible for GV PR. You can read it for yourself in Article 42 of Mais Habitação law:
https://diariodarepublica.pt/dr/detalhe/lei/56-2023-222477692

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