Wait time now counts toward 5 year residency?

Some one in this forum got it from the day of the application. This is the first case I hear that it’s from DUC

DUC is payable for analysis fees when you apply for ARI.
https://ari.sef.pt/InfoEN/Investidor.aspx
My lawyers told me that will be the starting point for the Contagem de Tempo

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Somebody posted this in a FB group for people applying for citizenship, with the following comment: “information compiled from updates requested directly to Reg Centrais by group members”.

If taken at face value, it implies a waiting time of about 10 years for people who are applying now (around 100 days’ worth of applications being processed per year).

Apologies if this has been covered before, but let’s say you get to the 5 year point and apply for citizenship, but there is a long wait (say it’s 10 years per the prior post). Is it correct that you need to maintain the residency cards through that entire time? So you need to keep your funds invested (or whatever you did to qualify for GV), and also keep renewing your cards and spending the required several weeks in Portugal?

Havent we seen applications from far later than mid 2021 being processed?

I had a lawsuit from May 2024. Still no updates
 My friend had a lawsuit too after me. He won around September and already completed his biometrics. This country really drives me crazy.

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I recently received my “contagem do tempo”, and yes, the waiting time for my residence permit is not included - in my case, it’s almost a year. Here’s an interesting article from a Portuguese newspaper stating that no additional legislative acts or regulations are needed to start implementing this law.

As for the article, according to Portuguese legal hierarchy, a law must be applied immediately upon coming into force unless explicitly stated otherwise. A regulation, being a lower-level administrative act, cannot prevent the application of a law, and it would be absurd for a law’s application to depend on a regulation since regulations are hierarchically inferior to laws.

It’s absolutely baffling how the entire legal system works here.

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Same question here, do you have to maintain your investment and keep renewing cards until you have a passport in hand?

Thanks for sharing the infos.
What is the first counting date on your contagem do tempo? How did you get this document and which Aima has issued your contagem do tempo?

Well, I am a bit confused: is the waiting time counted or not? The article you referenced (thank you for sharing!) states that it is counted, but your experience states otherwise? Please clarify.

Yes, you need to have valid residence card when AIMA will reply to IRN, and the exact timing is not predictable. As for investment, it is a completely different question. Investment is needed to renew GV, but is not needed for citizenship. So it is all connected but not directly. Portuguese law doesn’t require you to be on the same type of residence. You can get other residence, e.g. usual permanent residence, not ARI, and then investment is not needed and could be sold.

My lawyer, who specializes more in citizenship applications than GVs, said that you only have to have a valid residence at the point of submitting your citizenship application. After that, it’s no longer required. I plan to sell my investments and not renew my GV at that time.

What does the IRN need from the AIMA? CertidĂŁo de Contagem do Tempo? My understanding is that you can request that from the AIMA directly and then include it with your citizenship application.

Well, why am I arguing? Go ahead!
Just the food for thoughts. First, contagem de tempo is not an obligatory document. On default, IRN asks AIMA if you are fine with the residence requirement. We actually do not know, if IRN skip that request to AIMA in case you attached yr contagem de tempo to the application. Second, contagem de tempo usually has the expiring date of your last card. So if IRN sees yr card expired during the process it asks AIMA anyway. With 2 yr GV it is a very common case, that card valid at application date is expiring during the process. For the new 3 yr card it probably would be ok, if the waiting period will not increase further. And we know cases, that AIMA replied “does not meet requirements” to people with expired cards. Current treatment of the law by AIMA is that you “are resident during at least 5 years”, but not “have been resident during at least 5 years”.

Regarding the time count from application date. It is really important. Could we live in Portugal before the residence is given? After applying? I think I have seen somewhere in the chat long time ago, that probably yes.
If the answer is no, AIMA would be 100% right not to include that period into time count. Because we are not only not residents, but we even could not be residents.
If the answer is yes, I would argue that this waiting period should be counted.

Who needs enemies when we have friends like you.

Have you seen the graph, the current delay in citizenship is 1000 days. Nowhere it says it takes 10 years once u r eligible to apply.

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Yes absolutely. I saw one reported recently approved that had taken about 14 months. Citizenship application times seem to vary dramatically depending on the basis on which someone is applying, and where / how they apply.

Yes, the 14 month record is of my close friend who applied under 5 year residency through lawyer in Feb 2023 and got her PT birth cert in Jun 2024.
I did look at the context of the chart in the same FB group and understood it is for other citizenship route (likely by descent).

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The start date on my certificate is just 4 days before my residence permit was issued.

Here’s how I got the “contagem do tempo” certificate.
Starting from May, I was writing emails to AIMA approximately once a week. In August, they responded to one of my June emails, scheduling an appointment for September 16th.

On September 16th, I went to AIMA and simply paid the fee. The certificate letter arrived on October 29th. So the whole process took 5 months (from late May to late October).

Interestingly, the certificate was signed by the director of AIMA Sul e Ilhas (South and Islands), even though I live in the Lisbon area.

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The waiting time is not counted in the contagem de tempo. This is exactly the main topic of this thread as we have a paradoxical situation here: while the law has already come into effect and should include the residence permit waiting time, it’s not being applied in practice, as evidenced by my contagem do tempo certificate.

What’s particularly strange is that the country’s lawyers aren’t protesting this, but instead just passively waiting for some kind of regulation. Yet the article clearly explains that no additional regulation is needed - the law is already in effect and should be implemented now.