No, they will take contagem de tempo issued by AIMA and check two things: 1) if per that contagem de tempo you had 5 yrs at the time of applying and 2) if you have a valid residence permit at the time of checking
While on the second part, if missing, IRN will issue the letter with request for new additional documents, on the first - they will simply refuse yr application.
I would also suggest that if in the time of request they will see that reply depends on how treat the law, they will likely not reply until clarifications issued. They do not want legal suits and there is no deadlind for AIMA’s reply.
So worst case scenario is the following:
- the request sent before clarifications
- AIMA waits for clarifications and just do not reply to IRN
- Clarifications later not support yr case
- Application is refused
- You wait 6 month after refusal (as I remember it is obligatory period of waiting but not so sure)
- Submit new application
In general, you may lose more than 1 yr