I don’t see how legally there could be a requirement to count days in Portugal before issuance of the first card.
The 7/14 day requirement comes from the Regulations, Article 65-C, and it’s about renewals.
For the purposes of renewing a residence permit, the applicant citizens referred to in Article 90-A of Law no. 23/2007, of 4 July, amended by Laws 29/2012, of 9 August, 56/2015, of 23 June, and 63/2015, of 30 June, must comply with the following minimum periods of stay:
a) 7 days, consecutive or interpolated, in the 1st year;
b) 14 days, consecutive or interpolated, in the subsequent two-year periods.
Up to now, this has meant in practice that you maintain five years of 7/14 day count up until citizenship application, given that you renew the card for the third time at the five year mark.
There’s nothing in the Law 23/2007 (relating to ARI issuance) or in the Nationality Act, that talks about the 7/14 days. The Nationality Act doesn’t mention ARIs at all, it just requires a valid residence title for the five years (and the language requirement etc). With this new change to the Nationality Act, the period from application to first card will be deemed to be valid residence.
So suppose someone applied in Oct 2021, had biometrics in Feb 2023 and is finally approved in, say, June 2024. The first renewal would be June 2026, at which point the question would surely be “during the period of validity of the first card, did you meet the day count test? If so, here’s your new card”. Because as far as the ARI Regulations are concerned, that’s all that matters.
And then if this person applies for citizenship in Oct 2026, the analysis is: you had valid residence from June 2024 to Oct 2026, but the law says we also take the period Oct 2021** to Jun 2024 as valid too.
Usual not-a-lawyer disclaimer applies.
** Lawyer opinion differs about whether the start date is Oct 2021 or Feb 2023 in this case.