I’ve said everything I have to say re “na sua atual redação” / “as amended” in my previous posts.
You can argue that you reasonably relied on all the laws as a package (ARI, NHR, Nationality Law, etc.), the versions that were in force as of the time you made your GV investment. I will add that I additionally relied on the Jan 2025 statement from the head of AIMA, that the 5-year clock starts from the day of my GV application, in an attempt to convince me (1) not to freak out that all the MI applicants were processed before my very old 2022 GV application, and (2) not to sue AIMA. This line of reasoning might or might not work—I don’t know PT law well enough to say, and PT lawyers seem to have different opinions.
But “as amended” the language does not get you a “you can argue both sides” treatment in court. There is nothing murky about it.
If Portuguese lawyers all tell me as a technical point that (1) PT constructs legislations with a completely different philosophy, and (2) “na sua atual redação” is not used in the same way as “as amended” at all, then I’m happy to be convinced.