Are you a golden visa holder?
This is so frustrating; you keep not answering the question.
If you are MI, we donāt care.
If you are ARI, then we want to know whether your start date is the date of your online application, the date of your biometrics or the date of your approval.
I donāt know what āSEF entry dateā means, and I donāt care.
I mean to be precise, not harsh about this.
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And it has nothing to do with language barrierā¦
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The cryptic replies continue.
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@Jay.Poulle congrats on your timeline. You posted earlier that you submitted ManifestaĆ§Ć£o de Interesse right? So the rules AIMA is applying to your Contagem de Tempo may be different from those of us with Golden Visas. It would help to clarify.
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Yes ManifestaĆ§Ć£o de Interesse. I donāt have golden visa.
Note:
Nuno Pinto Silva - Solicitor Immigration (Facebook)
ABOUT APPLY FOR PORTUGUESE NATIONALITY COUNTING FROM FILE LOCK (SUBMITED EXPRESSION OF INTEREST).
Well just ask AIMA one Certificate of legal time (CertidĆ£o de Contagem de tempo) and AIMA will issue one certificate mentioning that you are legal in Portugal since the day xx-xx-xxxx and that itās the date and that you should know and you will see that many cases itās the date you locked your file M.I.
So can you apply for nationality with just the papper of āSEF Entryā āExpression of Interestā āManifestation of Interestā: NO, because that papper not enough and because the regulamentation law was not approved after parlment approved the Law
But you can apply for nationality with the AIMA Certificate because in that Certificate of AIMA just mention the date you are legal from (even if that date itās the date you locked your file) and the Certificate of AIMA mention the date you are legal and what its important for nationality itās that date you are legal from.
So to apply for nationality, you can request to AIMA to give you one CERTIDĆO DE CONTAGEM DE TEMPO and in that papper its mentioned the date you are legal in Portugal where AIMA includes the time from lock the file.
Thanks
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Thanks for clarifying, @Jay.Poulle. However, this thread and forum category is dedicated to the ARI/GV, not MI. So unfortunately your experiences arenāt relevant to the other participants in the thread.
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Resided legally in Portuguese territory for at least five years. (Lei n.Āŗ 37/81, de 03 de Outubro)
Legal resident in national territory since XX.XX.2019. (Contagem do tempo)
What is the difference between the two?
I plan to apply for my nationality next month, letās see what happens?
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You should be OK to apply when you hit your five years, Jay. As a MI applicant the new law is clear. But your situation isnāt applicable to the rest of the people in this thread.
The Golden Visa works differently (you apply outside the country, no requirement to actually live in Portugal, etc) so thereās a certain uncertainty with regards to how the law will be implemented in practice for Golden Visa applicants.
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Aaand weāre back at square one 
. FWIW my lawyer said we shouldnāt expect any clarity until authorities are confronted with citizenship requests made 5 years from initial GV application and are forced to decide one way or the other. The lawyers claim some have been submitted already but they wonāt reach the top of the pile for a while. As with most things, the rules are whatever is being done at that moment.
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Yep, so we have only one person who recently received Contagem de tempo and it is from the DUC date. The process to get it takes 2-3 months, so hopefully we will have more examples soon.
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Does Contagem de Tempo expire? If not, why shouldnāt we all just request one now, just in case we get one with a favorable start date we can use later?
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It is what I am doing now. Why not? law does not prohibit anyone from doing it.
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I know the laws have yet to be interpreted, but as 2024 winds up I am wondering about the 14 day/2 year requirement as 2025 looms ahead. Our application fees were paid on 10/21/2022. We spent 5 nights in Lisbon in October 2023. If the Contagem de tempo begins from the date the fees were paid, would it be prudent to spend 9 additional nights in Portugal before 2024 ends? That way, if the laws are interpreted favorably to us, then I would have spent 14 days in Portugal in 2023 and 2024? Obviously this formula only works if AIMA uses calendar years (Jan 1-Dec 31), but I would hate to needlessly lose two years in this endless process. Just curious what people would suggest I do in this situation. Thanks!
The 7 days/year stay is only for renewing your card. There is no stay requirement until you have the card in hand.
No, it does not expire unless the last residence mentioned in it expires. I mean, it says āFor the question of citizenship, John Jones is the resident since xxxxx and a holder of a residence card xxxxxx with expiry date xxxxxxā. So, after the card expires, it apparently means that without info about new card, it could not be checked if you are currently resident or not, and the docs only says something about the past date. However, you still can use it in court proceeding in case latter Contagem de tempo will have less favorable date.
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Thatās great. So for example, I am already on my 2nd card which is valid 3 years. So my two cards alone add up to 5 years (2 + 3). My initial application was a year before my first card was issued. So if I can get Contagem de Tempo from the initial application that will already be 6 years. Is the extra year enough to apply for citizenship and get past the āchecking documentsā stage?
Thatās not a bad idea. Iāll be at 5 years in Oct '25 so maybe I should think about doing this soon too.
When was your initial GV application submission date?
Nope, at the moment 1 year is for sure not enough. Last periods are 2-3 years. Electronic submission and a new system might speed up a bit, but it is too early to say that and it is better to check the real situation at the time of application.
I have also met with anectodical evidences which indicate that if your card is to expire soon, it looks like IRN deliberately delay the process until that date to see if you renew it or not. It is really a bad idea not to renew your card during the citizenship process.
But in general, you do NOT need contagem de tempo in your citizenship application. The default procedure is that IRN will ask AIMA itself. It is very possible, that IRN may skip this step if you submit contagem de tempo, but we do not know this for sure. And it is not a standard procedure. But I suppose that with old contagem de tempo, IRN will ask AIMA anyway.
I do think so too. It is not anecdotical at all. They always want to make people suffer as much as possible. However, in contrary, there is a possibility that if someone now has a new fresh renewed card in hand with 3 years of validity and he applies for citizenship right after having the renewed card, the officer might get fed up with giving challenge when they see that his card has 2 year 11 months. And consequently he might (or might not) receive the citizenship outcome more quickly than usual. 
. It is only a possibility but it could happen.