As i mentioned earlier, i was only able to get the card in 2021
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No, I had actually tried to get a CdT just as a supporting document, but couldnât get an appointment to apply for one until a couple of months after I was eligible for citizenship, so I wasnât going to wait given all the impending eligibility changes. My lawyer said it wasnât needed anyway.
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Your lawyer is technically correct as CdT isnât necessary and you are in-principle eligible to apply for a citizenship after 5 years of initial application. However, IRN needs a confirmation from AIMA about that 5-year mark and they are super indecisive, It took them over 6 months to grant one for a friend of mine and the dates werenât consistent as the main applicantâs time was counted from the date of biometrics and the dependants time was counted from the pre-approval date. So, itâs bit risky to apply for a nationality if CdT hasnât been issued. Its nothing to do with the law (Which is super clear), its AIMA who is indeed a big trouble.
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Given IRNâs inefficiency, they will still check with AIMA, which is even less organized
No, thereâs a bit of misinformation on this forum about CdTs, so I want to clear it up. I think some people are making things harder for themselves than they need to.
When the citizenship law changes were announced earlier this year, a lot of people panicked and started scrambling to get CdTs because they thought it might help if their eligibility was later questioned. I did that too. It wasnât necessary.
CdTs donât matter for citizenship. They never did.
AIMA counts residence for administrative purposes, things like permits, renewals, and immigration status. IRN applies the nationality law for citizenship purposes.
IRN will check the dates in AIMAâs system and apply the nationality law to those dates themselves. IRN can see when you applied. They donât ask AIMA to do the counting for them. Under the current law, IRN counts from when the residence application was submitted. If the law changes, theyâll apply whatever the new law requires.
CdTs are how AIMA responds to requests from residents, employers, banks, courts etc to prove residence details. Theyâre not a citizenship eligibility document.
Itâs true that some CdTs were wrong in the past because local AIMA offices applied the rules inconsistently. And it seems that led some people to think getting a CdT was necessary to âfixâ something in the system. It wasnât. The issue was inconsistent issuance, not the underlying record. In any case, AIMA recently standardised how CdTs are issued, which has presumably reduced those errors, but that still doesnât change their relevance for citizenship.
Bottom line is a CdT has no impact on the citizenship decision. IRN doesnât rely on CdTs you submit, and they donât need one from AIMA to assess your application. CdTs are not binding on IRN. A CdT doesnât lock in a start date and it doesnât reduce risk. The only real reason to get one is personal peace of mind.
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Can you clarify what mechanism IRN uses to check the dates in AIMAâs system. Is that a shared-access database? And do we know when in the process that check takes place?
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Wow, when did IRN became so efficient? Poor lads in all the facebook and citizenship forum groups whoâs citizenship applications are pending AIMAâs response for over 2 years already at Analysis stage..
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@TommyReine I donât think weâre talking about the same thing. Iâm not saying IRN is efficient (Iâd probably be thrown off this site for trying to argue that!). Applications sit at âanalysisâ for years. We all know that. But that delay isnât because IRN is waiting for AIMA to decide eligibility or count residence time. Itâs background checks, document verification, queues, system backlog. Thatâs different from IRN outsourcing eligibility decisions to AIMA, which is the point Iâm making.
@cj807 I donât know how the systems work internally. I donât think anyone outside the agencies does. I would guess the IT is very messy. Might be shared access, mirrored data, or some internal lookup, but thatâs irrelevant to the outcome. What matters is that IRN isnât blocked waiting for AIMA to issue a CdT or do the counting in order to decide a nationality case.
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Do we have a source on the flow youâre describing @wood.collies.0j?
I highly doubt that it is the case.
Itâs literally written in the Regulations that the proof of legal residence is issued by AIMA and no one else (not IRN, nor the applicants themselves).
Look up Articles 19.2(b), 25.1 and 37.7(b) of the regs.
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@Garrett as described to me by our lawyers
@tommigun Ok let me restate this very carefully to avoid confusion about what Iâm trying to say.
Iâm not disputing that AIMA is the body that issues documents proving legal residence. I noted that earlier. I did not say that âproof of legal residenceâ is âissuedâ by IRN or anyone else. The regulations on that are clear.
What Iâm disputing is the jump from that fact to the claim that IRN is blocked waiting for AIMA to issue a CdT, that AIMA âdoes the countingâ for nationality, or that careful applicants should fact check AIMA by getting a CdT before applying.
You can obtain a CdT that reflects the correct data and submit it with your citizenship application, but that doesnât change how IRN assesses residence. IRN still relies on residence information sourced from AIMAâs records for its own assessment, regardless of whether a CdT is submitted, and applicants have no visibility into how that information is evaluated internally.
Thatâs why a CdT doesnât âlock inâ anything for citizenship purposes.
19.2(b) and 25.1 deal with who issues proof of residence when proof is required. They donât say a CdT is the only way IRN can verify residence, and they donât transfer the nationality decision to AIMA.
37.7 is the key procedural reg. It removes the requirement for applicants to submit AIMA documents when the information can be obtained electronically between authorities. It doesnât make IRN dependent on a CdT being issued.
The core point Iâm making is AIMA certifies residence for administrative purposes, but IRN applies the Nationality Law and decides eligibility. Nothing in the regulations says a CdT binds IRNâs assessment or that IRN has to wait for one. And the regulations you cited are explicit that applicants donât have to submit one. Thatâs why even though I understand why everyone thought they might be useful, they are ultimately a waste of time.
If you think there is some use in getting a CdT before applying, Iâm just not seeing it.
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this I agree with fully.
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I think by saying CdT you exclusively mean the piece that an applicant can receive from AIMA directly by appointment. While when I am saying CdT I mean that but also the same piece that AIMA sends to IRN âin the backgroundâ as per the regs. Otherwise we are on the same page 
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I clearly see one, not to waste 3 years of ctizenship application. If the response comes back from AIMA as less than 5 years of residency then IRN doesnât process the citizenship application. One have to start over all again. AIMA is the only entity who responds to IRN request and with the cdt you defenitely have a peace of mind. Remember, to appeal for the rejected citizenship application, is anoter ball game and it took over 3 years for one applicant on facebook group.
Got it, yeah I see that now. I think we are actually in agreement.
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@TommyReine I think thereâs confusion about what getting an âincorrectâ CdT from AIMA actually means.
AIMA has all your underlying records and knows your application date. The law right now is clear that your application date is the one to use. If a CdT you obtain shows the wrong start date (eg. your biometrics date), that doesnât automatically mean the underlying AIMA record is wrong or needs fixing. It means the human issuing the CdT chose the wrong date from your file when producing the certificate. Thatâs an error in how the CdT was issued, not in the residence data itself.
People started getting CdTs on their own in response to uncertainty about law changes and forum advice, not because of any legal requirement or advice that it will provide the basis for resolving any conflicting data IRN gets from AIMA.
IRN will assess residence based on the data it obtains from AIMA, regardless of what certificate you give them. I understand youâre trying to reduce risk, but thereâs no clear evidence that submitting a âcorrectâ CdT to IRN actually does that. Thatâs my point.
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Anyone get a CdT lately that shows the card issue date instead of the application date?
I found this post interesting recently and wanted to reshare. Someone was kind enough to crowdsource the nationality processes posted from the nationality facebook group from the Porto IRN. Current processing ranges from 1.4 to 3.5 years with a mean of 2.3 years on the completed processes. Iâm guessing this data is skewed as it doesnât take into account the pending applications, which explains the 3 to 4 years application processing time which is currently being mentioned.
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There was no need for CdT in the past as the time counted was straightforward from the date of the first residency permit and there was nothing to be disputed in that case until Organic Law 1/2024 happened in April 2024. The confusion started at that time as the inconsistencies of CdT issued by AIMA made genuine lawyers worried but not the lawyers who just want to grab the money. As of today, I am not aware of anyone whose nationality application has been approved who applied as per Organic Law 1/2024 was published on the DiĂĄrio da RepĂșblica website. Irrespective of whatever anyone claims or not, IRN doesnât analyze the time countedâthey do not have the resources or capability to do so. IRN takes the face value given by AIMA and all they do is check the boxes and thatâs it. Applicants under Article 6.1 are at the mercy of AIMAâs response to IRN and nothing else. However, for other articles where people are eligible for nationality in different ways like marriage/ancestry and more, IRN doesnât even bother to check with AIMA as they analyze the applications in a different way. Unfortunately, this is the fact and no foolproof method exists.
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Law started in April 2024.
The earliest CdT which utilised this law was in Oct 2024 (under my observation in FBsâ groups).
Letâs assume that people with CdTs issued in Oct 2024 also applied for citizenship in Oct 2024. Then, we need to wait at least until Oct 2026 to see the CdT-based-citizenshipâs outcome. As the bureaucracy has been built up significantly recently, I would expect around May 2027 - Oct 2027 for the final outcome.
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