Were You Told About Portugal Golden Visa Processing Delays Before Investing ?

agree, especially regarding the conflict of interest. If the same organization benefits from investors’ capital remaining invested longer, while simultaneously advising those same investors, the question naturally becomes whether all material information known at the time was fully disclosed before investors signed contracts and transferred funds.

In my view, that issue deserves at least as much scrutiny as the government’s delays. If enough investors experienced the same pattern, a coordinated legal action against the private parties involved may be just as important as any claim against AIMA.

The problem is that the law governing this transaction is entirely subject to the whims of the counterparty (the State of Portugal).

It’s like signing a contract with your landlord but your landlord is also the Supreme Dictator of whatever country you live in. You literally have no recourse.

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I agree that holding a government accountable can be difficult. However, I don’t think investors are without recourse.

My focus is increasingly on the private parties who promoted these investments. Regardless of what the Portuguese government later did, promoters and their lawyers still had legal obligations to provide complete and accurate disclosure of material information before investors committed hundreds of thousands of euros.

If information that was known internally was not disclosed before investors signed contracts and transferred funds, that is a separate issue from the government’s actions and deserves careful scrutiny under the applicable laws.

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The only entity that can ultimately give investors what we thought we were buying — a credible and timely path to residency, PR and citizenship — is the Portuguese government. So it seems more productive to work with the intermediaries, law firms and investor groups to press the government for a practical remedy, rather than attacking the intermediaries.

Mercan has a structural conflict of interest because the delays arguably work in its favor. That said, investors are central to its business model, so we’ll see whether it chooses to act. IAS, in theory, has no such conflict and should be representing its clients’ interests. My understanding is that both Mercan and IAS are considering complaints. Hopefully we will see some concrete action.

I respectfully disagree. That ship has sailed. The legislation has already been passed and signed into law. Continuing to focus solely on lobbying the Portuguese government does nothing to address whether promoters and their lawyers fulfilled their legal duties before investors committed hundreds of thousands of euros.

The issue now is accountability. Investors deserve to know whether material information known to the promoters and their legal representatives was fully disclosed before contracts were signed and funds transferred. If those disclosure obligations were not met, responsibility does not disappear simply because the government later changed the law.

I can’t help but notice that some discussions keep redirecting attention exclusively toward the Portuguese government. While the government certainly bears responsibility for its actions, first there is nothing we can do about a law that has been passed and second that should not become a convenient distraction from examining the conduct of the intermediaries who aggressively marketed these investments and had their own independent legal and professional obligations.

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I guess all depends on what outcome applicants like us are pursuing:

  1. We cannot make State of Portugal to change the law that has been passed. The state answers to their voters - GV applicants are not voters, so our voices cannot make the government change their acts. GV applicants money can influence economy, which will in turn affect voters’ life from general economic conditions in Portugal. The domino effects will take time to settle in, but the direction is no doubt.

  2. I as an applicant would like see that my investment is not taken for a ride just to please voters by the State. Portugal can argue that citizenship was never explicitly promised in the GV program, then I want to hold the State accountable for what they indeed promised - ie. Residence by Investment for the amount of funds, and length of time promised, or within a reasonable variation. The ultra long delay of processing, plus funds taken in but time not counted in, is a clear breach of the promise under the program. The Statement must be held accountable in this regard.

  3. Citizenship: for those who do not intend actually live in Portugal but want the overall EU mobility with an EU passport, can use the EU Long Term Residency program once you get the PR residence, while wait for the PT citizenship, or a government change to shorten the citizenship time (when economy shows pressure of outflowing GV applicants funds).

For those who intend to bring multi-generation family to live in PT, the extra time to wait of citizenship isn’t catastrophic but still sucks. But life can go on in Portugal as PR, especially for younger generation to tuning into a new culture and new day-to-day life.

  1. Even if we succeed in holding the marketers / intermediaries accountable, what can we get in return? Refund some of the fees? Return of Capital in shorter time frame, but ultimately the State still have the final say on ‘what is considered eligible for PR status’ - locked funds in until the day you get your PR card? Or locked funds for required investment time (5-6 years) then live wherever you want, while wait for the state to sort out its paperwork someday eventually??

The State of Portugal has to be held accountable to its offered GV program terms for its monetary amount and the invested length of time. It cannot make GV applicants (as net economic contributors) to pay for the state’s lack of efficiency. My biometrics appointment in Lisbon in 2026 had about 3-mins time with the officer behind the glass, that includes 2 mins for me to sort out my bank blocked the large sum transfer so I had to verify the transaction on the banking app on my phone. 3-mins actual face-time for the appointment vs. 3 years behind the scene waiting. This is a shame for a modern country on how to run its affairs. Look at Spain - apparently Spain can legitimize 500,000 people in a short few weeks by processing through paperwork. What Portugal is lack of, if Portugal wants to be a place for investors / businesses want to invest in this country??

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Rachel, I agree. My concern is that if Portugal can change the rules after accepting billions of euros from investors, what prevents it from doing so again? Trust, once lost, is difficult to restore.

My focus is no longer citizenship. It is accountability. I believe promoters and their affiliated lawyers should be held accountable if they failed to disclose material risks before accepting hundreds of thousands of euros from investors.

There is also a very real financial risk. The longer our capital remains tied up, the greater the risk to investors. Developers can experience financial distress or even bankruptcy,as has happened in many jurisdictions and investors could face significant losses. That is why I am seeking the return of my capital, reimbursement of my expenses, compensation for the loss of use of my funds, and any other remedies & penalties available under the law.

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I personally think Portugal will not move the citizenship pole further down, from the current 10 years. The matter is the starting pole - if Portugal continues to neglect its own delays, and keep moving the starting pole, essentially it is also moving the finishing pole, be it PR or citizenship.

The current move by Portugal to ignore the investors’ waiting time and money locked-in time wasted, already cut down the country’s credibility not just in the field of immigration, but also in investment world.

Imagine Portugal keep the passed law as is, do not count the sunk-in waiting time to get 1st residence card to the 5 year ‘investment time’, future investors will NOT choose Portugal to park their money - what is there to choose for? Endless waiting, a quite small economy, a language spoken by very small population worldwide, and the country apparently already under housing / health care pressure by in-flooding immigrants by D2 /D7 visa etc..And look around in EU, Italy and Spain can be just equivalent options, and more arts to enjoy in Italy, closer connections to other low cost countries such as Greece, Turkey or eastern Europe. Spain is no less attractive - Spanish language widely spoken in many nice weather countries worldwide appealing for retirement and vacation, and apparently the country’s affairs are run in far far more efficient than Portugal.

If Portugal state is run by politicians with clear heads about where the growth of its economy is originated, and how to keep the momentum going in this de-globalization era, I doubt they will further kill their own economy engines beyond what they have self inflicted so far. However, we never know what politician will do when they are too eager to please the mass - that is written clearly in the European history in the past 80 years.

I think for someone having invested for 2+ years and have got biometrics appointment done, the current focus can be ‘pushing intermediaries to act as investors’ advocates to keep the starting pole stay at the ‘funded date / online submission date’. This way, we get our counting finishing line for PR moved up and get funds unlocked sooner to really invest for other meaningful ROI, and we can get citizenship finishing line moved up too, , if PT citizenship still desired in 10 years.

If Portugal keep on their current track, neglecting the time wasted in waiting (the state has to publish detailed execution rules for the law passed in May 2026 within 90 days - that will be by late Aug 2026) every investor with funds locked up for 3+ years already indeed should calculate their sunk cost vs. future opportunity cost to decide if ‘call it a day, and pursue compensation’ is the most sensible way to be done with this GV fiasco. For me, THAT Portugal will no longer be a country that I will proudly and even wish to call myself a citizen of.

Rachel, for me this is no longer just about the 10-year rule. Once a government changes the rules after taking billions from investors, it cannot be trusted again. Today it’s the timeline; tomorrow it could be higher fees, new requirements, or something else entirely.

That is why I believe our focus should be on holding the promoters and their affiliated lawyers accountable for what they disclosed or failed to disclose before taking our money. The longer our funds remain locked up, the greater the financial risk to every investor. These companies are not to be trusted with our funds any longer and the must pay the price of not delivering on what their promised and lack of material investor disclosures.

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This is only an issue to real estate investors who applied before October 2023

I was also informed that the biometrics process would be completed within 90 days from the date of my first payment to AIMA, which I made on 19 November 2022 .

  • Investment: September 2022
  • Project: Mercan – Algarve Project

Before the war: I received a biometrics appointment for 8 April , but due to the US–Iran war and the resulting airport closures, I was unable to attend.

Current status: Our lawyer has been communicating with AIMA to secure a new biometrics appointment, but unfortunately, we have not received any success or response to date.

I am extremely disappointed with the prolonged delays and the way this entire process has been handled.

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I’m sorry this happened to you. Based on your timeline, it appears you may have been given expectations that were difficult to reconcile with what was already known about the delays at that time.

Rather than each of us approaching Mercan individually, I think we would be much stronger if we first identified everyone who received similar representations and then retained one law firm to evaluate whether there is a common misrepresentation and disclosure claim. That would allow us to share costs, preserve evidence, and present a unified case instead of negotiating separately.

If others are interested, I’d be happy to help organize a list of investors with similar timelines and documentation so we can explore joint legal representation.

I agree all related parties benefiting from the unreasonable delay must be held accountable.

I am only willing to part with my funds for up to 6 years as contracted with Mercan via IAS, with 180 days to process actual redemption. If this means my eligibility for PR will be negatively affected, I will go all the way for legal actions.

Personally, I do not see any value in Portuguese PR. A government that changes the rules after taking investors’ money has demonstrated that its commitments cannot be relied upon. If it happened once, it can happen again through new laws, new fees, new conditions, or further delays. For me, that trust is gone.

My focus is no longer on obtaining Portuguese PR. My focus is on holding the merchants who promoted this lie and did not provide proper disclosure about investment accountable before taking hundreds of millions of euros from investors. My intention is to bring other investors who feel the same way together so we can pursue independent legal representation and hold the responsible parties accountable collectively.

Would you mind sharing your investment type / amount and date paid?

Myself paid 280K Euro for Mercan hotel project back in Aug 2023.

I wonder if investment paid to Funds vs commercial real estate may indicate different legal remedies?

I invested €350,000 in the Mercan Moxy Lisbon Park project in early 2022, and my application was submitted in June 2022. I also went through IAS.

I think the investment type may matter legally, but what may matter even more is whether investors, regardless of the specific project, were given materially misleading timelines or whether known processing delays were not disclosed before they committed hundreds of thousands of euros.

It would be helpful if everyone shared their investment date, project, promoter, law firm, application date, and what timeline they were given before investing. We may start seeing a pattern.

I invested € 290,000 in the Holborn The Navigator - Palm Oasis Alvor (then Yellow Tulip) low density / renovation project in April, 2023. I’d been in talks with both Holborn and La Vida (Mercan) since early 2022, but ended up going with Holborn because I liked this particular investment option better.

Both agencies had told me to expect the ARI card within a year of application. Neither hinted at any processing delays beyond that. Now, 3 years and 3 months later, I finally had biometrics this past February but am still waiting for the card.

Jeff, thank you for sharing your experience. Your timeline is important because it shows that investors across different promoters were apparently being given similar expectations. By late 2021 and certainly throughout 2022, the processing problems were already becoming significant. That raises a legitimate question that deserves independent scrutiny: what did each promoter and their legal representatives know about the delays when they were marketing these investments, and what was disclosed to investors before they committed their funds?

If multiple investors received the same assurances despite growing delays, this may point to a broader pattern rather than isolated cases. Investors from all promoters, not just Mercan, should compare their timelines, emails, and marketing materials. If there is a common pattern of inadequate disclosure, there may be value in coordinating with independent counsel to evaluate potential claims and share the cost of representation.

I invested €280k in Mercan Evora Hilton in June 2021. Got my residency card finally in March 2023 , which expired in March 2025 and now waiting for second card to be renewed (applied March 2026 when I managed to get an appointment)
Instead of 2026 (5y from application) I now need to wait for 2033 (5y from residency card)- it’s a mini-disaster in terms of time and money spent on the application and renewal docs (attestation, apostillation each time) and the opportunity cost of the funds invested .

The rational approach (though I am not quite there yet :grinning_face:) would be to treat it like a sunk cost, focus on getting the investment back from Mercan and move on in life . Even 3rd world countries have displayed a greater commitment to the rule of law - nothing can be assumed to be sacred with this lot - they may tomorrow for example chose to tax PR’s on capital gains at 40% instead of 28% .

Tks

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