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What's the potential impact of the 2025 Portuguese election on the Golden Visa program and pathway to citizenship?

On last 18th May 2025, Portugal held national elections that significantly reshaped the country’s political landscape. The center-right parties emerged as the most voted forces, with the Democratic Alliance (AD) taking the lead though without an absolute majority. In contrast, the traditional left-wing parties, known for their more critical stance on the Golden Visa program, suffered a major electoral defeat.

During the election campaign period, the topic of Portuguese nationality law reform surfaced prominently, with proposals of changes aimed at tightening access to citizenship. This debate gained additional momentum in the wake of the recent decision by the European Court of Justice concerning Malta’s Citizenship by Investment (CBI) program, a ruling that seems to have influenced the political agenda in Portugal.

As a result, it is likely that discussions around reforming the nationality law will resurface in the upcoming legislative term. However, such changes require approval by a majority in Parliament, and as things stand, there is still considerable uncertainty regarding possible alliances between political forces, given their well-known differences on key policy matters.

The proposal raised during the election campaign pointed to several potential amendments: i) extending the minimum legal residence period from 5 to 10 years, ii) increasing physical stay requirements in Portugal, and iii) introducing stronger ties to the country as prerequisites for naturalization.

It is crucial to emphasize that this is merely the beginning of a public and political debate. No formal decisions have been taken, and if any changes are to be implemented, they will likely take months to be finalized. Although few details are available at this stage, we are confident that the fundamental legal principle of protecting the legitimate expectations of Golden Visa investors will be upheld.

Just as in past legislative reforms, we expect any change to include transitional provisions. In practice, this means that investors who have already initiated their Golden Visa application—i.e., submitted their process—should not be affected. Although the residency permit and citizenship processes are legally distinct, it is our firm belief that the rationale adopted by the Portuguese government will continue to recognize and protect the expectations upon which these investments were made.

At NSM Lawyers, we have already filed, with a very high success rate, hundreds of court cases against AIMA (Portugal’s immigration agency), in order to expedite biometric appointments, initial residence card issuances, and renewals. The judicial decisions we’ve seen consistently defend the legitimate expectations of investors. The courts have repeatedly affirmed that any obstruction to these rights may “undermine the exercise of fundamental rights, freedoms and guarantees formally recognized by the Portuguese Constitution and international law, creating a situation of instability, uncertainty and insecurity… which is clearly incompatible with human dignity.”

Therefore, while we acknowledge the high likelihood of nationality law reforms being debated in the next legislative term, we also believe that those who have already submitted their Golden Visa applications will be protected—either by the government or, if necessary, by the courts. This underscores a clear sense of last call: those who wish to secure the rights and benefits associated with the Golden Visa program, including the path to citizenship, should act swiftly.

We also strongly advise that investors begin the process of obtaining their Portuguese language certificate (A2 level) and take steps to establish meaningful ties to Portugal. Based on legal precedent and the government’s historical approach to legislative transitions, we are confident that the five-year residency requirement for citizenship—counted from the date of initial application submission—will remain in force for current applicants.

At NSM Lawyers, we are fully committed to defending the rights and expectations of our clients, offering deep legal expertise and unwavering representation in the face of any future change.


If you have additional questions on this topic, feel free to post them below or reach out directly.


This is a companion discussion topic for the original entry at https://nomadgate.com/portugal/legal-questions/2025-election-impact-on-golden-visa
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Thanks for this analysis.

Curious what I should read into this statement , if anything:

“We also strongly advise that investors begin the process of obtaining their Portuguese language certificate (A2 level) and take steps to establish meaningful ties to Portugal.”

For someone who is just applying now do we need to accelerate this?

Is there any reason to get the A2 level language certificate now, if we have years to go until we can apply for citizenship?

Considering they might change the level required in this legislative session, we might have to get tested at another level, no? Or do you mean we should get tested now so that we can argue in court that we expected to only be tested at A2?

Thanks for the helpful article. Im a bit confused about this sentence:

Based on legal precedent and the government’s historical approach to legislative transitions, we are confident that the five-year residency requirement for citizenship—counted from the date of initial application submission—will remain in force for current applicants.

How will that apply vs say, people who have been resident for 3 or 4 years but not on a GV? Would they discriminate in that way? Or are they likely to leave teh 5 years in place for all current (legal) residents? Any idea?

@goncalomendesleal if I am due to apply for citizenship in first half of 2026 and already took the CIPLE exam, what other ties do I need to establish?

I did not apply for tax residency and NHR last year because I was told it isn’t necessary for citizenship. Now it would be very expensive to apply for tax residency without NHR.

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Two different PT lawyers, two different opinions. So we will be at the whim of capricious “Portuguese Judge Lotto” again… :sob:

Bolding is mine:

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https://www.bloomberg.com/news/articles/2025-06-06/portugal-considers-sweetening-incentives-for-golden-visa-program

An article published from Bloomberg today, here’s the GPT summary for those of you behind the Bloomberg paywall:

In contrast to Spain’s recent cancellation of its Golden Visa program, Portugal is considering enhancements to make its Golden Visa and special expatriate tax regime more attractive.

Minister of the Presidency Antonio LeitĂŁo Amaro stated that the government aims to bolster foreign investment and position Portugal as a top investment destination. While details are still under discussion, he emphasized that any reforms will be economically and socially fair.

Importantly, Amaro confirmed:

“There’s no plan to end it. It’s not on the table.”

The government is also working to streamline application processing — AIMA is currently clearing a backlog of nearly 45,000 pending cases. Golden visa approvals rose 72% in the past year, reaching a record 4,987.

This is a clear signal that Portugal remains committed to the Golden Visa program, even as other EU nations tighten or terminate theirs.

Thank you for your question. Once the A2 certificate is obtained under the current rules, the requirement is considered fulfilled. It cannot be made more demanding retroactively. That’s why we recommend securing it now—both to ensure compliance and to reinforce your legal position if changes are introduced later. Happy to clear this question with you on a Zoom call. You can get in touch with me directly.

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Thank you for your question. Given that the current rules and eligibility criteria are known at this stage, our view is that investors should consider accelerating their process. This includes obtaining the A2 language certificate and establishing ties to Portugal, to strengthen their position in light of potential legislative changes. Happy to debate this with you. Please book it by this contact form.

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Thank you for your question. While the final wording of any legislative change remains to be seen, any amendment should respect the legitimate expectations of those already in a legal residency process—whether under the Golden Visa or another permit. The principle of legal certainty should ensure that the five-year requirement remains applicable to current residents. Happy to join a call and debate it with you please contact me.

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Thank you for your message. In your case, I would recommend joining a Portuguese cultural, recreational, or professional association, club, or foundation as a way to demonstrate ties to the country. This is often accepted by the authorities and avoids the complexities are risks of tax residency. Please feel free to contact me directly.

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Thanks for this @Fesenjoon - mainstream news articles addressing PT GV issues are rare. A positive article is even more rare!

As pertains to this particular thread though, PT “enhancing” their GV does not preclude the government from upping the years required for citizenship from 5.

This is a well written summary by a lawyer who clearly has given this a lot of thought and cares about his work. As another poster noted, there are inconsistent opinions by other lawyers but this summary by Sr. Leal has, at least, some credibility in my opinion.

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This is a very informative summary and thank you @goncalomendesleal for writing it.

We applied for our GVs in November 2021, received our residency cards in April 2024 (with a little help from a kindly judge), moved here and signed the deed on our Lisbon property in July 2024, became tax resident with NHR in September 2024, my partner began employment in Lisbon in October 2024, I got my A2 certificate from PLA in March 2025, and we have just submitted our first tax returns online for the four required months of 2024.

[As an aside, we applied for GVs in 2021 when we were living in Asia and our future plans were uncertain so it seemed like a good hedge to give us options but in the event we decided we would move here permanently anyway.]

We will need to renew the residency cards in April 2026 and fully intend to apply for citizenship in November 2026.

Is there anything else we could or should be doing now to further de-risk this?

Non-paywall version of that Bloomberg article Mo cited earlier:

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He said AIMA is working on clearing a backlog of almost 45,000 golden visas applications currently awaiting review.
“We expect that by the end of the year this process will be largely taken care of,” he added.

Ah yes, it’s about time for the annual “the backlog, which is larger than ever, is about to be cleared” speech

:rofl:

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If you believe the recent stats about how many processes have been cleared, the backlog isn’t larger than ever.

Though, I agree, it’s best to be skeptical

I think the GV backlog still is.

Other visa types may have smaller backlogs, but this has always been the case, that GV is lowest priority while some other visa types are processed in a few months.

this sounds incredibly bullish. Although, i take anything the government says with a grain a salt. Nevertheless, a silver lining