Note that the acceptance date by SEF may not be the date of electronic filing. We filed on March 27, but the date of the “ARI - Notificação de Aceitação”, was May 12th. That had the following statement: “Informamos que, em 12-05-202X, foi admitida a candidatura de Autorização de Residência de Investimento (ARI)” with my name.
My lawyer believes this will be the date used. Her reasoning there is that it is after SEF has confirmed that the packet is complete, and that they wouldn’t want to allow someone to gain priority with a packet that was missing major documents. Because it is the signal that you can apply for the biometrics appointment, where most of the delays actually were, it still provides the relief intended by the parliament, but without creating an opportunity to game the system.
Whether this is how it plays out, I don’t know. But that was her take on it.