Wait time now counts toward 5 year residency?

Here. Waiting for 4 years without biometric. Quite typical among Chinese applicants due to the pandemic. I believe the majority of the applicants don’t come to this forum at all.

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I don’t mean to be rude but I am confused why this is even a question. Of course they want you to actually have a visa before they grant you citizenship? When would the reverse make sense?

Edit: wow 4 year wait! I can see why one would want them to grant it after 5 years, but I doesn’t seem realistic to me. Not that I know anything.

It does seem like most applicants are Chinese and not on this forum. Would they be discussing on wechat or is talk of immigration to europe forbidden?

It’s a shame they aren’t here because it would really improve our data!

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always here

My wife is a Chinese family grouping applicant. She has waited 25 months still no pre-approval. Applied exactly one month after the Dec '21 hoard.

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Before we all get too excited about the laws passage, I think we need to take a breath and realize “this too shall pass” :slight_smile:

If nothing else, this process has taught me that patience and equanimity are necessary to deal with Portugal - nothing is as it seems/advertised and more importantly it changes often. So unless you are at the 4.5 year mark and getting ready to apply for citizenship, I would not celebrate just yet.

It is not unlikely that in the next 2-3 years, another law will pass that realizes that they gave this benefit to golden visa people as well as the Brazilians and clarifies that only Brazilians get this benefit :slight_smile:

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I believe this is correct, however it likely still helps most of us. Consider a hypothetical case: you applied in 2020, pre approved in 2022, biometrics in 2023, received your card in 2024. Now you can apply for citizenship in 2025 instead of 2029. If you’d had a longer wait and got the card in 2025, then you could apply immediately. So it’s still helpful.

Where was your biometrics? I applied end of Oct 2021, Bio in Jan 2023 in Lisbon and still waiting


Sorry, biometrics in Porto. Positively speedy.
My son was Lisbon in Feb 23 and we’ve heard nothing, though parent has been asked for more paperwork after an 11 month Lisbon wait.

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No need to make any hypothesis. It is reality indeed. My wife’s data is exactly what you’ve tried to say. She’ve just got her card. Mine is about to expire this year. Both me and my wife applied on 2020 and we hope to apply citizenship next year


From now till end of this year, there is going to be a battle for the clarification of the law. What exactly it means by saying “start counting from the time of submission” will be argued intensively. However, I still lean towards the date of submitting GV’s application provided that applicants paid the fee and have the receipts/confirmation of payment from SEF.

I also believe that this law will not last long. Maybe 5 years max - or just 2-3 years depending how much noises and fuss it might cause publicly. They will soon publish another updated version to cover this loophole. It will still benefit some, but not all and of course not going to last forever.

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Haven’t fully kept up with the back and forth on interpretations here but Get Golden Visa, for what it’s worth, pretty definitively said it’s from initial application date.

It’s too early to conclude one way or another. I’d consider the motivations of anyone pretending otherwise.

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Someone flogging the GV taking the most optimistic interpretation?. I am shocked, I tell you, shocked

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Just sharing, not confirming.

For what it’s worth, my attorneys have said the same.

Wow. Is that because you couldn’t travel outside China during Covid to attend biometrics?

The thing is, Article 15 starts off by referring to persons who are living in PT for five years, with their status regularized by the authorities. The Article is now amended to say, for purposes of Article 15, they will be taking account from the time of application. People seem to be reading this as one will be treated as living in PT since the time of application. But it might be more logical to say their status will be treated as being regularized from the date of application, if the application is granted, rather than from the date of grant. That is consistent with the Brazilians who have been resident in PT for five years, filed the manifestation and have been held up by processing.

Then for GV, since we are treated as continuously resident if we meet the 7/14 requirement, that means, as some have said, you will have had to meet the 7/14 from the time of application even before the application is granted.

So we will have to see what the regs say, when they come out.

The thing is, ICN looks to AIMA to verify the five years, and they can certainly deal with the regularization item, and post-grant GV residency, but they have no process in place to track pre-grant GV residency. So I can see AIMA saying they will certify the five years from grant date but not pre grant date. Will they establish a process to allow people to establish 7/14 pregrant? Will ICN allow GV’rs to establish it. They don’t have to do either for the Brazilians, so we could easily be separated from them.

But I am sceptical that people can satisfy the 5 year residency with less than 5 years in country.

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This is also my forecast. I think that this law will not last for many years. When laws like this are promulgated to effect a relief to certain groups, there is at least a sunset clause or expiration date (e.g. Spain’s Law on Historical Memory). Not sure if the previous government forgot the clause; they might be rushing to pass the law knowing that the government will be dissolved and need to woo future citizens who could vote for their party in the next election. (Speculation).

What I am hoping for is that, should future governments decide to patch this loophole, I hope those who applied before or when the current law is in effect, would be grandfathered.

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Not sure how this is different from the situation without this law
 This law is expressly trying to change this exact issue?

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Just to reiterate what’s been said before in this thread (e.g. here), the genesis of this legislation was over 300,000 (mostly Brazilian/CPLP, but not all) immigrants in Portugal, many of them already working, paying taxes and social security, in an irregular situation from a legal residence perspective. This is the “wrong” looking to be “righted.”

How this might affect other potential immigrants visiting Portugal for a few weeks a year is still TBD.

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Since the vast majority of non-EU immigrants to Portugal apply under Article 88.2/89 (from Brazil, South Asia, as described earlier) and the nationality law change was for their benefit, I thought it would be instructive to compare the stages and timelines of immigration under Article 88.2/89 with ARI. They are remarkably similar. (Time periods quoted are typical, several extreme cases we’ve seen on this forum extend far beyond the typical, especially during covid)

Step 1: Application
88.2/89: Register on the SAPA portal, upload NIF, NISS, work contract etc. and get an acknowledgment. AKA Manifestação de Interesse, Expression of Interest, “file lock”. This happens pretty quickly, a few days perhaps. With the MI number, the applicant can work, pay taxes, etc.
ARI: Register on the ARI portal, upload docs, proof of investment, etc. Get acknowledgment, followed by a request to pay the analysis fee. This is also a matter of days. The investment has started contributing its mite to the economy.
Long Delay 1: We enter the long dark teatime of “analysis”. It used to be a few weeks in 2018/19 but has now stretched out to an average of about 18 months or more for both 88.2 and ARI applications.
Step 2: Application analysis is successful.
88.2: The applicant gets an “IM acceptance” email, also known as “first email from SEF” in South Asian forums.
ARI: Applicant gets the pre-approval mail, titled “ARI - Notificação de Aceitação”
Short Delay 1: usually a few weeks
Step 3: Applicant gets a notification asking them to book biometrics appointment.
88.2: AKA “second mail from SEF”
ARI: AKA “Biometrics opened”
Short Delay 2: usually a few weeks
Step 4: Biometrics
88.2: Updated documentation, evidence of job and paying taxes, etc.
ARI: Updated documentation, evidence of maintenance of investment, etc.
Long Delay 2: This could be as short as a few months but can easily take longer than a year or two, depending on where you gave biometrics. Delays are of the same order for both types of applications. More complications possible with 88.2 because of blacklisted employers, investigations, etc.
Step 5: Final approval. This is the point where you pay the fees for card issuance.
Short Delay 3: a few weeks to a few months, same for both.
Step 6: First residence card arrives.

TLDR; the ARI application lifecycle is very similar to that of Article 88.2/89. Both applications face two instances of long delays.

The text of the amended law says (official parliament proceedings): For the purposes of counting legal residence periods provided for in this law, it is considered also the time elapsed since the moment the temporary residence permit was requested, as long as it is granted.

For the vast majority of cases (i.e. 88.2), the simplest interpretation of the law should cover both long delays, and the date considered would be the date of the acknowledgment on Step 1. This is logical and just, since migrants under 88.2 are living, working and paying taxes at least from that date. For the rest - we few, we happy few - might be dragged along in their wake, with the not-quite-as-strong justification that our investment has similarly been working and paying taxes, and we have been subjected to uncertainty and delays beyond the prescribed legal limits. Or we may not :person_shrugging:

Anyway, I think ARI cases will either be backdated to Step 1 or not at all. Not seeing the logic of backdating to Step 4 or 2.

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