You’ve gotten this far and invested so much, it seems logical to follow through.
I would disagree, there is no way they are going to accept these early applications, it would then open the door to grandfathering which is not what they want. This is just lawyers taking your $$$$ one last time IMO.
3 Likes
I agree with you that early applications seems a mistep. I was talking about following through on the language test without waiting, and certainly not waiting to see what the law will be. I sat the test at the 2 year mark so I was ready at the five year mark.
4 Likes
Portugal’s got the strangest, most self-sabotaging policy circus I’ve seen.
They chase off serious investors with one hand… then rush D7/D8 paperwork with the other, smoothing out a path toward citizenship for €800–€900/month earners like the country’s desperate to import low economic value.
And here’s the cherry on top: if you park €500k, the only place I’ve seen banks milk you this openly is Portugal.
Now for context: I run a construction company in Canada. I used to hire Portuguese workers seasonally no problem. But after living through the Golden Visa mess and the way the system treats people who bring capital, I shifted my hiring elsewhere.
I ended up giving work to 800 people, and instead of Portugal, that work went to Poland and Italy.
That’s not ideology. That’s a business decision. Actions have consequences. Bless their hearts.
10 Likes
You’re one of many people I’ve spoken to who have expressed that they will not be doing further business in Portugal or investing any more money to the country. Not just people in the GV process, but even people who are on other visas or conducting business that depends on AIMA in any capacity. The negative press on the reliability of Portugal as a trustworthy and functioning nation is slowly permeating into my mainstream media circles, there’s only so much that propaganda outlets can do.
6 Likes
I second that, i was aware of another applicant who was in a GV limbo moved couple of thousand manufacturing jobs to Spain. Good for you mate, logic and business sense makes more sense than sentiments. If efficiency is what you are looking for, then you shall be staring at a rotting system called beuracracy in PT and nothing moves here.
2 Likes
I mean it’s obvious but maybe not to a lot of PT voters. The lower economic immigrants that are the polarizing topic however even with the changes they don’t have the funds or options necessary to change and will likely just stick out whatever change occurs. The wealthy do and will have adjustments because of this whole fiasco. I personally don’t think its very smart financially to make that play but hey good luck to them they have a history of overperforming relative to its eu counterparts… or maybe its underperforming… who knows 
1 Like
idk, I dont believe in collective punishment, which is ironically what GV investors are getting. But if it was to avoid portugal’s bureaucracy and ‘laws’, I understand.
I build large projects, and starting this year I stopped hiring from Portugal on purpose.
If the government treats me like garbage and the public cheers it on, then sorry: I don’t need Portuguese labor anymore. I’m genuinely happy with this decision.
People like me should move our businesses and investments away from Portugal and away from Portuguese banks and institutions because nobody there seems willing to say, “This is wrong. We’re misleading people.” Instead, it’s just “rich gringos” this, “rich gringos” that.
And I know I’m not alone. There are plenty of people like me doing the same thing and more who will follow
4 Likes
My lawyer reached out to me with the same plan, I am doing it. Are you? I would love to know others experiences with this strategy.. I am doing it.
2 Likes
How does it work in terms of paperwork? Let’s say you want to “preemptively” submit a citizenship application on Feb 15, 2026, 1-2 years before the 5-year anniversary of initial GV application,
- Suppose you gather your birth certificate and police records within 90 days before Feb 15, 2026. Then do you get these again within 90 days before the 5-year anniversary, and your lawyer is able to update these on the IRN portal then?
- Suppose you don’t have a GV residency card on Feb 15 (all you have is the years you’ve already clocked since initial GV application—but you haven’t clocked 5 years, so the example in the Constitutional Tribunal ruling does not apply if read narrowly). What does your lawyer submit to IRN in its place?
- Suppose you don’t have an A2 certificate in hand on Feb 15 either, but your PLA course has started before Feb 15. Does your lawyer submit proof of enrolment on Feb 15, and update it to the actual certificate later?
- I suppose IRN may request refreshed documents again at a later date, at which point your lawyers would re-send them over to IRN.
- Amazingly, the residence card is not a mandatory document to be submitted with the application. Regardless of the TC ruling.
- Yes. A2 certificates take some time to print out, so the same logic applies as in the case of crossing the border with an ‘expired’ residence card that has already been ‘renewed’ at the appointment with AIMA but not yet re-printed. (I have done such border crossing twice while I am waiting for the new card).
For the A2 certificate do you need to get a 2nd copy for Permanent Residence? I’m considering using a different lawyer for citizenship (my main lawyer is unwilling to try the premature filing strategy) but they said they would need to hold onto the A2 cert, would that make it hard to apply PR later through my regular lawyer?
1 Like
Good question.
I suppose you either ask your course/exam provider for a re-issued original.
Or you make a notarized copy of the first original.
1 Like
Portugal continues to amaze even after all these years 
For me, the decision will come down to what my litigation lawyer says about overall litigation strategy:
A.wait for the Nationality Law (to be revised) to get promulgated, and sue right away if the rug pull materialises (lawsuit against AIMA/IRN/Sr.Amaro yet to be determined); OR
B.preemptively apply for citizenship before the new Nationality Law comes into force, for IRN to reject it, so that I can sue.
I have no delusion that the “preemptive” citizenship application would magically work. IRN will have every incentive to make sure it doesn’t, otherwise it sets such a bad precedent for the future.
1 Like
Heres what my lawyers proposed.
Long story short, highly risky, not everybody can attempt this, but to me worth the shot. Heads up it’s VERY long;
“ We are contacting you once again regarding the ongoing legislative process to amend the Portuguese Nationality Law, following a more in-depth analysis of the ruling issued by the Constitutional Court, mentioned in our previous communications below, and a discussion of its implications with the legal community.
In this context, given the multiple interpretations that the ruling has given rise to, and in compliance with our ethical duties of diligence and information, we feel obliged to share with you one of the possible interpretations of the content of that judgment, which has already been circulating in certain groups and forums.
Simplifying some complex issues for ease of understanding, the discussion centres on Article 15(4) of the current Nationality Law, which states that “For the purposes of counting the periods of legal residence provided for in this law, the time elapsed from the moment the temporary residence authorization was applied for shall also be considered, provided that it is ultimately granted.”
One interpretation of the Constitutional Court ruling — so far not confirmed by any governmental or institutional entity — the current Nationality Law would allow, under the provision contained in Article 15(4), the filing of a citizenship application while the residence process (Golden Visa) is still pending. This would also be the reason why the judges considered that a transitional regime is not necessary for the application of the new law.
According to this interpretation of the constitutional court ruling, and without setting out here the full extent of its analysis, Article 15(4), by stating that “For the purposes of counting the periods of legal residence provided for in this law, the time elapsed from the moment the temporary residence authorization was applied for shall also be considered, provided that it is ultimately granted,” allows an applicant with a pending residence process to file a nationality application, on the expectation that the residence process will be approved during the pendency of the citizenship process, being the relevant moment the approval moment and not the submission moment.
Considering that citizenship applications are currently taking approximately 24 to 36 months to be granted, this understanding could “safeguard” applicants who filed their residence application at least 2–3 years ago (say, before 2024), allowing them to submit the citizenship process now, since the combined calculation of both waiting periods (residency and citizenship) would mean that the required 5 years, under the current law, would be met in the meantime.
However, even if this understanding may be viable, it is not certain that the Portuguese Civil Registry — the entity responsible for citizenship applications — will adopt this interpretation.
First, it is important to observe that the current platform through which citizenship applications are filed has mandatory fields relating to the residence permit – number and validity - data that those without cards do not have - so the submission of an application under these conditions would always have to be made with certain abstract data or left blank.
Second, it may be that the IRN automatically rejects applications for which five years have not elapsed since the application date or card issuance date.
Third, we suspect that many applicants who might want to apply during this window will not yet have a language certificate, which is required as part of the naturalisation application. (It may be helpful to have at least booked a language course to demonstrate a pathway to this certificate.)
We therefore conclude that submitting citizenship applications under this interpretation is not guaranteed and entails the assumption, by the Applicant, of a high level of risk of refusal. Refusal could come soon after application, or after many months in a later stage of the Civil Registry process.
If the application for naturalisation is refused, there are a couple of consequences.
Firstly, we note that the IRN is permitted to refuse to consider a second application within two years of the first if it is submitted on the same grounds. However, our view is that a second application, under a new citizenship law, would be one submitted on different grounds, so this two-year rule would not apply. Thus, an early application should not preclude a later application under the new law (presumably after 10 years from first card issuance).
Second, a refusal could be challenged by the applicant in Court. This court process would likely take two to three years to be resolved.
As such, this is a decision that entails A) the risk of refusal based on an “incomplete application” with the possibility to discuss it in court and the potential need to submit a new citizenship application in the future, as opposed to B) the risk of being subject to a further 10-year waiting period before being able to initiate the citizenship process, counted from the first residency card date.
Estimated timeline and possible outcomes:
a) Immediate citizenship application with a waiting period of 2 to 3 years based on an “incomplete application” until decision --» approval by Civil Registry
b) Immediate citizenship application with a waiting period of 2 to 3 years based on an “incomplete application” until decision + refusal by Civil Registry + 2 to 3 years for a court appeal --» approval or rejection
c) Waiting for residency application period + card issuance + 10 years under the new law + 2 to 3 years of citizenship application --» approval
We remind you that the legal provision supporting this interpretation is one of those the current Government intends to revoke within the scope of the ongoing legislative process. In that regard, the submission of citizenship applications under this interpretation would only be possible up until the entry into force of the new Nationality Law—a date not yet defined, but which is estimated only after the presidential elections (February).
In short, therefore, there is a brief window, until a new Nationality Law is promulgated during which those who applied for the Golden Visa could apply for citizenship despite not having waited for five years since application, under this interpretation.
We understand that this is a complex decision and share the frustration of not having more concrete data to share with you at this moment neither more useful time to execute it."
5 Likes
Thank you! This is super helpful.
1 Like
What firm are you working with?
1 Like
People who might be ineligible if the new law passes don’t really have anything to lose. But if that were actually true, everyone would be flooding the IRN—and even though they’re inefficient and sloppy, they’re not idiots. In my opinion, these lawyers are basically out of business and are just trying different angles to squeeze money out of people.
10 Likes
The part I left out was that they are not charging for this unless it succeeds. Thank you for your opinion and happy new year.
4 Likes