Thanks, that makes sense, although my experience with my Portuguese lawyers has been positive overall. Theyāve been proactive with updates. No begging required!
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I assume itās possible to have a lawyer help you prepare the application, then submit it yourself? Thatās what Iām thinking of doing when the time comes.
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From our GV lawyer today:
"We have just received the following information:
Regarding the moment residence time starts counting for nationality:
On 5 March 2024, it was published the tenth amendment to the Portuguese Nationality Law, which regulates the attribution and acquisition of Portuguese nationality. Among the various changes approved, the length of residence for the purposes of applying to acquire nationality by naturalization will now be counted from the moment the first application for a residence permit is submitted.
Previously, residence time was only counted from the moment the residence permit was granted.
This change is intended to compensate the long waiting periods between the submission of the application and the actual granting of the residence permit, as, during this period, many applicants already reside in Portugal.
As such, due to these recent changes on the Law, AIMA understands - in our view correctly - that, under the new legal provisions, the counting of residence time begins with the submission of the application through the electronic platform, i.e., in the case of Golden Visas, from the date of payment of the analysis fee"
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Let me share my experience today at AIMA SetĆŗbal. I received a contagem do tempo with the date starting from the beginning of my residence. I showed the law to the employee, but she said this rule only applies to ManifestaĆ§Ć£o de Interesse and rudely stated that sheās not going to discuss or argue with me about it and that she had no other document for me.
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Thatās frustrating. Iām sorry. What type of visa is it?
Have you considered submitting a ālivro amareloā complaint about this incorrect application of policy? That would be my inclination if I had that experience.
Unfortunately our favorite agency does not participate in the governmentās online livro amarelo site (hardly surprising). You are required to submit a complaint at the physical office where the problem occurred.
Good luck ā¦ weāre all in the same boat! 
Followup note:
āAIMA finally added that the āYellow Book exists at all service counters. It is through this official and credible instrument that the Agency investigates the facts, the subject of the complaint, and provides a response to the complainantā.ā
via https://www.inlis.pt/post/aima-needs-18-months-to-finish-cases-it-got-from-sef
If Aima setubal issues the CdT, then it is not worth asking them. Go to other Aimaās branches and request a new CdT. From my experience, other Aimaās branches do not issue the CdT. They forward the request to Aima central in Lisbon. Then the CdT is processed and handled over there. Although we request and receive the CdT at branch, the document is signed and issued by aima central.
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Thanks for sharing!
What really concerns me is that lawyers talk smooth like honey. Itās OK that they share their opinions. I believe that your lawyer is a big law firm. Why hasnāt a big law firm had any Contagem do Tempo since April 2024 to justify their opinion?
My lawyer said the same thing as your law firm. We might even use a same law firm.
I asked my law firm about the most recent CdT that theyāve got for their clients. They never gave me any concrete response. I asked them how long it would take to request for CdT. Their answer was: āNormally it takes us 2 weeksā. Then I asked them to request my CdT and I will only use their service for citizenship if they get the CdT first. They said OK. However Iāve not received any response from my lawyer since then. Sometimes I must listen to my instinct. And while I was asking them, I was having huge doubt about them too. Time has answered me that I was correct. Immediately after asking my lawyer to request the CdT, I also requested myself and got mine CdT. I requested a 2nd CdT in a different Aima Branch. Hope to get it soon. If 2 CdTs from 2 different branches match, I have zero doubt about my starting date! If 2 CdTs are different, then I will bring it to court!
After all, what I receive in CdT is different from what my lawyer told me. So, who should I trust? I must trust AIMA over my lawyer. What lawyers say does not matter. What matters is what is written in CdT.
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I thought you said you did get the earlier start date (online application, not card issuance)? Contagem de Tempo - #2 by live2learn
How is it different to what your lawyers said? Arenāt your lawyers correct?
Yes. I did receive CdT and it goes my way luckily!
My lawyer said: starting time is the date of the payment for analysis of the initial application.
What is shown in my CdT is the date of submission of initial application.
What is shown in CdT is earlier than what lawyer said.
Conclusion: My lawyer is wrong!
It also means that lawyer has never ever obtained a CdT for a GV applicant. I am baffled about it. As a big law firm with hundreds of GV applications, they have never experienced a CdT since new law published. So what have they done since April 2024? Maybe they have been only speculating things as if they are AIMA. I expected that they should have obtained at least a set of 20-30 CdT from various GV applicants. Unfortunately they havenāt had any. If they had one, they would have given me a more precise answer: āCounting time starts from submissionās dateā.
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Iām reluctant to wade too far into this issue, but thereās really no reason anyoneās lawyer should have been requesting their clientsā CdT. Given that, I wouldnāt worry too much about your lawyer. The CdT isnāt a required part of a citizenship application, itās just an optional precaution in case someoneās citizenship is rejected on the grounds that they havenāt been resident long enough.
It seems clear that AIMAās new process hasnāt trickled down to every office, but it also seems unlikely that when IRN checks someoneās residency period that theyāre going to get a disgruntled clerk in Setubal.
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How much does it cost to take a CdT by lawyers?
Do I also need a valid card for CdT?
If a big law firm has over 100 GV clients, I am sure that most of them want to apply for citizenship as soon as possible. And they all ask their lawyers to confirm the starting date for citizenship. As a lawyer, the most concrete way to answer is to request a CdT, then from that point it is clear. But no, they did not request even one.
Of course, CdT is not required to submit citizenshipās application. But, please tell me, who dare to apply for citizenship under new law without having CdT in hand? If you accept the counting from residencyās date, then no need to be in this thread to discuss.
Therefore CdT is āmust haveā for ones who are going to utilise the new law. In case Aima rejects your application due to insufficient 5 years, you have a CdT in hand to fight back. If not having CdT in hand, you are facing a risk that you will be disqualified by Aima and have no weapon to protect yourself.
I would recommend you to ask your lawyer the same thing:
- have they ever requested a CdT for their client?
- if yes, then when was the most recent one? How long did it take?
- what is the content of the most recent CdT theyāve obtained? Could they show it to you (deleting all the private info)?
- Ask them to request the same CdT for you, and see how much time it will take ? Will it be as long as they promised?
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Has anyone successfully used the document to challenge a rejected citizenship application though? I only ask because there seems to be a lot of panic about the issue and the wait time for processing seems to have gotten out of hand, but AIMA only publicly stated their new guidelines a couple of weeks ago. I understand the rationale for wanting some kind of insurance, but given how badly AIMA is struggling to process applications and renewals I canāt imagine that having to deal with thousands of requests for an unnecessary document is helping things. In the case of a mistaken rejection, wouldnāt requesting a CdT at that point be just as good?
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New law was published in April 2024
Citizenship process lasts 2-3 years.
Therefore there has not been any reject and challenge yet. However, this issue is expected to come up in next 1.5-2 years.
If you accept the starting date is the residencyās date, then this document is unnecessary.
However, i want to apply faster. Hence CdT is a must have. I would not want to put myself into a weapon-less situation when fighting against IRN. If you want to wait until the IRNās rejection to request a CdT, I wish you all best of luck 
.
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To be clear, Iām a few years out from being eligible to apply anyway, so I donāt expect any of this to still be a question by the time I apply. I just want to clarify for the sake of anyone who hasnāt had time to read through this whole thread that requesting a CdT is strictly optional, and nobody knows if it would even help with a rejected citizenship application. By all means get it if it helps you sleep better, I just donāt want casual members of the community thinking that this is yet another hoop they have to jump through.
Okay but those dates are very close. Probably your lawyer is just quoting what AIMA promised, but the AIMA clerk you got was even nicer and gave you a slightly better date.
Compared to difference of first application vs first card, that is negligible.
Why not apply for citizenship and CdT in parallel?
I would not call it āAima clerkā. No such clerk in Portugal is allowed to sign for this kind of important documents. In my CdT, it was signed by a Director of a specific department in Aima. As I understand from the letter, that department is specialised in this matter. 100% not done by āclerkā.
Close does not mean accurate. Moreover it means that they have never obtained CdT after new law. I am still baffled about it. A big law firm with hundreds of GV clients but none of these clients asked for a date to apply for citizenship 
. Or clients asked but lawyer did not even apply for CdT and just speculated as if they were Aimaā¦
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It is not prohibited. If you choose that path, I also wish you good luck!