I have never ever seen/read/heard from anyone or in any FB groups that someone could miss one document (either language certificate or criminal record or birth certificate) and the IRN staffs still accepted the application. Impossible!!!
Find me a post online/ or review of someone claiming that he did not have all documents and IRN still accepted his application.
Documents listed in the application form is always 100% checked by IRN officers. Missing one doc is not allowed. It is the first check when applying in person.
Some IRN staffs do check more carefully on stamps/ apostille/criminal records within 90 days/or even check the 5 year residency. Some do not check very carefully about stamps and apostille. But in term of bullet points, all documents must be available at the time of submission.
It’s is considered as the first check by IRN staffs.
The application will be then forwarded to the dedicated department in which more checks will be carried on i.e. validity of the language certificate, validity of the birth certificate and criminal records,…
If one wants to submit an application without having a complete set of required documents, using lawyer to submit online is the only way to get around.
Haha I don’t know why the long rebuttal, I said you might be right. The larger point is submitting at a counter in person doesn’t mean the file is “final” and it doesn’t stop IRN making later requests for more documents.
I doubt it can bypass via mail option. The clerk who opens the mail might do the checklist first and eliminate the application from opening-envelope-round . Not sure if one has ever tried this option to submit incomplete application.
But when they open, it could be eliminated from first round due to incompleteness according to checklist. And it could be that the clerk who opens envelopes is the same one who takes applications in person. He/she might spend 1-2 hours/week to open envelopes.
Having read the regulations myself, I would not recommend submitting a knowingly ‘incomplete’ application via any route.
There is a checklist of mandatory documents to be included, and so you have to include ‘something’ to cover each position, otherwise IRN is within their right to outright reject the application. We do not want to rely on the hope that they don’t reject.
Note that I am referring to the list of mandatory documents that IRN is supposed to check ‘on opening the envelope’ (formally within 30 days from submission).
Both of my children are under my GV with me and will reach the required residency period around March this year, so in principle they become eligible to apply for citizenship then. But one of the mandatory documents is the language certificate, and that’s where things get tricky…
Last year my daughter (19) attempted the A2 exam but unfortunately didn’t pass. My son was under 16 at the time, so he wasn’t eligible to take it yet. Now the 2026 exam slots are opening slowly, but realistically the earliest we’ll be able to get them both tested is May 2026, with results only coming out sometime around end of June at earliest and certificates in July…
On top of that, because of their school and university workload, attending long certified language courses just isn’t realistic for them.
Given the uncertainty around the upcoming citizenship law changes, I’m trying to decide on the safest strategy:
• Is it better to wait until the full document set is ready, including the language certificates, and submit in mid-summer 2026?
• Or is it safer to submit as soon as they become eligible in March, and include proof of a booked exam appointment, then add the language certificates later?
I’d really appreciate hearing from anyone who has dealt with this kind of timing issue…
It will be a big fail to not succeed this time… Their first cards are from January 2025, so in case the law changes are promulgated before we submit their applications, they are shifted 9 years forward, losing their dependency somewhere in the middle of the path (28 and 25y.o. in March 2035)…
Aren’t children under a parent’s Golden Visa considered dependent residents and therefore unable to apply for Portuguese citizenship independently unless one parent has already been naturalized?
If anyone has a confirmed case or legal reference showing otherwise, it would be very helpful to share.
Thanks
They can certainly apply for citizenship in their own right once they’ve had done their (currently) five years and provided they are over 18 when they apply.
I think that would only be true if the child had held an independent residence permit for the entire period, which I honestly doubt applies to most children on a GV as they’re almost always dependents rather than autonomous residents
The child has a residence permit that’s every bit as valid as their parent’s. The only proviso is that at each ARI renewal, they must show dependence. For citizenship, the law doesn’t care how they got their residence permit. So if the child qualifies by the number of years of residence (currently including the time from application), and they’re an adult when they apply, they are eligible. They don’t have to wait for their parents to become citizens. If they had to wait for that, there’d be no point anyone ever including a child on the ARI.
Thank you for taking the time to explain this clearly، I appreciate you sharing your perspective. I might be in a similar situation myself, so I’d want to double-check this with my lawyer.
If there are any lawyers here who can confirm this in practice, that would be much appreciated.
I am not a lawyer, but I can confirm that as the main applicant, I applied for citizenship last year after five years of residency (currently including time from application); at the same time my 18-year-old daughter who also had five years of residency was able to independently apply for citizenship. However, my 17-year-old cannot apply for citizenship (as per my lawyer: For applicants under 18 years old: Citizenship can only be requested after one of the parents becomes a Portuguese citizen or once the applicant turns 18.)
Have you applied for PR for your 17 year old? What is your plan for them once you get your citizenship? With the upcoming law change there is a risk your 17 year old will have to complete 10 years residency before applying as an adult. I’m assuming they’ll be 18 by the time you get your citizenship so they can’t apply as a minor either.
Some positive support for the ARI investor position. This link goes to a PT podcast (A Cor do Dinheiro) and was supported by one of the partners at Blue Crow. He and another fund manager from Optimize weighed in on the benefits accruing from ARI funds flow to Portugal and the issues that this community has encountered. As has been noted, there has been lots of support and activity in the background from some of the larger community, even if its not visible. This discussion was originally slated for March/April but Antonio pulled the recording up into December after our request for help. The discussion is in Portuguese, but for those without the language skills yet, the autotranslate subtitles does a pretty good job. I appreciate these guys stepping up.
I wonder if you could file early for citizenship- although it could possibly be rejected before your deadline - (maybe immediately refile if that happens), there is a maybe a chance? no one will look at it until after you qualify by old law- and then you might have a case to push it thru- they are going to be busy with all those biometrics this spring adn summer
. Not sure if one has ever tried this option to submit incomplete application.