Yes, except that IRN asks AIMA for the contagem, so AIMAās interpretation of the law is relevant to this sub
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Our lawyers, (and many others) advise that at least 7 days of the 14 days in country requirement be done in the first year of the permit validity.
(Anecdotal observation that the first permits used to be valid for one year, so the first 7 days residency would happen then. The permit period changed to two years but there is an expectation that the first 7 days would happen in the first year. This is not written down anywhere, just referred to as common practice. )
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It is written down in the regulations, and even in the new law they passed in 2024 where they converted some GV to D2, they still specify itās a special D2 requiring only ā7 days in the first year and 14 years in the subsequent 2 year periodsā
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Does anyone know if the new ask to resubmit documents reset your application date to when the documents are submitted and the new fees paid?
recent email exchange with my lawyer about the wait time:
as always, to be taken with a grain of saltā¦
Good evening, Servet,
Some of these certificates (ācontagem do tempoā) have already by AIMA and the reference for the start date is the date of the initial application, more precisely the date the initial administrative has been paid.
In your case, this date will be 10 November 2021.
In this sense, you will be able to pay ā if you want ā for the Portuguese citizenship application after 10 November 2026.
I hope to have been of assistance.
Best regards,
Hi ā¦ā¦,
Did you see any ācontagem do tempoā issued to one (or more) of your clients applying for citizenship showing the start date as the residency application (paid DUC)? (rather than the start date of the first residency card).
Regards,
Servet
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Interesting semi-off-topic comment in todayās AIMA update call with lawyers about the new GV processā¦ could it be true? 
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It tracks with what we know is supposed to be the case currently, so most likely it is. Hopefully they will get the memo out to all the AIMA offices eventually.
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For those who are updating their documents online, there seems to be some ambiguity. Say someone who has been waiting for biometrics since Jan, 2021, and just updated the documents online in Jan 8 2025. Does the nationality clock start from 2021 or 2025?
AIMA confirmed in the meeting yesterday with lawyers that it starts from initial application payment date.
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Thatās the key partā¦ consistency, coming from a widely published (and adhered to!) directive.
AIMA is not good at consistency 
But then from our convoluted experience getting PT tax residency, neither is FinanƧas.
Hi everyone!
This thread has gone quiet, but it shouldnāt have. The time counting issue still hasnāt been resolved. After hearing news that someone with a manifestaĆ§Ć£o de interesse received the correct contagem do tempo, I requested another contagem. Today, I received a call (!) from AIMA SetĆŗbal to clarify something about my address, and I took the opportunity to ask from which date this contagem would start. She replied that it would be from the date of the first residence permit.
I read for her Article 15 aloud twice: āPara os efeitos de contagem de prazos de residĆŖncia legal previstos na presente lei, considera-se igualmente o tempo decorrido desde o momento em que foi requerida a autorizaĆ§Ć£o de residĆŖncia temporĆ”ria, desde que a mesma venha a ser deferida.ā
Her response was that she wonāt discuss this with me and the contagem will be from the start date of the residence permit.
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The women who answered the phone is not the one who issues the certificate. You only trust what it is written on the certificate itself.
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I got the opposite impression - that she does issue them, as she was well aware of my details and specified quite clearly what would be written in this certificate.
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Did you receive your certificate? If you have it in hand, then you know what the starting date is. Her words mean nothing. What lawyer says also means nothing. What is written on the certificate is what we care about.
If different AIMA offices are inconsistent, couldnāt you just request from several different ones until you get one with the early start date?
Sheās wrong, and it has been resolved. AIMA categorically stated during the meeting with lawyers etc. last month that the clock starts on application payment date. If an individual employee in AIMA makes an error because they are unaware of AIMAās position, then you push back to get it corrected.
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It takes time for you to know more about Portugal,come on.
@nat.andreeva Would you mind updating us all here when you receive your ācontagemā? As others mentioned, I would not place too many bets on what a random AIMA clerk told you over the phone.
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Good idea, but do you realize how long one request takes? The entire cycle takes approximately 3-4 months.
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Selina, what ways are there to push it back? Iāve sent countless emails, when I received the contact regarding the start date of my residency, there was no response. Iāve consulted several lawyers, and they all insist that without regulations, this doesnāt work. They still refuse to submit my application , saying that my eligibility date hasnāt arrived yet. Hereās part of their response:
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