While I would love for that to be true for GVs, I’m not so sure yet.
That particular page “is aimed at foreign citizens who, having entered Portugal without a residence visa, wish to remain here for more than one year in order to carry out a professional activity.” So not GVs, which is my situation/concern.
The DN article I posted earlier agrees with you that this new legislation to count wait time in your 5 years stems in large part from the campaign by Brazilian immigrants to recognise their (long) time in the queue.
But that same article notes “In practice, this means that the time will be counted from the date of acceptance of the Expression of Interest (IM)” and “…the Government has already approved the request after evaluating the required documentation.”
When you first apply for a GV, SEF/AIMA only verifies that they got their application fee money, then tosses your request on the pile. I’d dare say they don’t even look at the documents uploaded with your GV application until Pre-approval, much less “evaluate” them.
As with last year’s changes to what investments are allowed for GVs, this legislation also seems to have holes that may need court challenges to clarify.