I spoke to someone very senior in the Portuguese government today, and for what it is worth:
- SEF restructuring is long overdue and no one has had the courage to take it on till now. But the new Minister has taken the bull by the horns. SEF is deliberately being obstructive, and there are likely to be strikes over the next few months. But it is a short term pain to create a long term fix, and he has public support behind him. Good on him to do this - not many countries where the Minister is prepared to take such bold action and make such sweeping changes to deal with underperforming bureacrats. So things may get worse before they get better, but they are going to get considerably better.
- Delays are not only on SEF side. So many people waited till the last minute to invest and apply that everyone is overwhelmed, including the lawyers. And some of the applications are not straightforward (the investment option chosen may take longer to assess/approve).
- As we have seen above in this thread, we are getting pre-approvals for November and December. So there is a 6 month backlog, but certainly not the freeze that the media is suggesting.
- So if you have invested in a straightforward and non controversial investment like a pure VC fund and have been waiting for much longer than 6 months for a pre-approval there may be an issue with your lawyer or your application. Although they don’t seem to be dealing with these in a chronological way so this is not necessarily the case. And not necessarily a serious issue, just one that makes them move it to the back of the pile whilst they go through easier ones first.
- Once your application has been confirmed as received the 5 year clock is ticking, so there is no rush. There is a bit of debate as to whether you actually need pre-approval or biometrics and I don’t profess to be confident on this though and someone else may have a better take.