Do we take this to mean that it is just a question of days until promulgation then?
President has his own timeline… hopefully he takes all of it…
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I hope so too, but 21 is the deadline to refer at least, so Tuesday is the main day we should be watching, I doubt he veto’s.
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Yeah, going after funds is not wise.
It sounds like the best appoach as mentioned here by someone is to take your case to court to try and get citezship based on the current law rather than the new one potentially coming in. Maybe a collaborative approach / case is a good idea?
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That approach was mentioned by me.
I am not sure that the approach will work, but I think that it is the only possible solution. As per the nature of this approach, a class action lawsuit is not possible. Only individual lawsuits can be opened. The good thing is, if three individuals open and win such lawsuit, it is deemed “Força Obrigatória Geral”, and it becomes a binding precedent.
What we can do is, if and when the new law passes without any grandfathering clause, which I believe it will, we collectively support the first three individuals opening such lawsuit, and make sure that they are represented by best of the best administrative lawyers (not immigration lawyers). It will take 2 years maybe, but once the lawsuits are won, we have a Força Obrigatória Geral, a binding precedent.
I am not in a position to provide legal advice, but I strongly believe this is the only solution we have.
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Seems like I wasted 50€ on lobbying effort
If you watched the town hall from the GoFundMe they are pinning their hopes not on the law being unconstitutional, but on the regulations for the law (which are written by PSD a few months after, Chega and PS not involved) adding in some grandfathering. Apparently the same thing happened with NHR, the initial law had a hard cutoff, but the regulations extended the window to apply.
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Have attended a couple of them now… sometimes feels like a lot of wishful thinking, some of which has already not turned out as hoped 
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It’s my pleasure and I appreciate your response.
Yes, the SDIRA issue is massive. I’ve researched it extensively including as part of my graduate studies. I’ve also actively tried to solve it. This includes multiple conversations with SDIRA custodians and asking the U.S. Department of Labor in June 2025 for an opinion on the issue. (The DOL governs IRAs. The IRS enforces the rules.) At the root is that IRAs are trusts, a common law structure, and IRA assets must be titled to the IRA. Portugal is a civil law country that does not recognize trusts and therefore has no mechanism to title assets to trusts/IRAs. Therefore, we have a jurisdictional impossibility. I had hoped for feedback from the DOL that identifies a safe harbor for investors due to this jurisdictional impossibility. The DOL has not provided this.
The market wants to argue that IRA-funded investments are fine and that the prohibition on self-benefit is a “grey area.” It isn’t, and that argument is a waste of time that misses much larger structural problems. The titling impossibility is a non-starter. It begets the self-dealing prohibited transactions you mentioned. None of the “workarounds” in the market solve this. Even if they somehow had, there are asset custody practices that appear indefensible with respect to IRA regulations.
As for real estate investors, U.S. securities law per the '33, '34, '40 Acts is unlikely to provide relief because real estate is not a security. Some RE-based GV investment opportunities were securitized, however, (such as RE funds) and those could have relief under the '33, '34, '40 Acts. Enforcing one’s rights under these Acts requires action in the U.S. federal courts.
If it was a direct sale (not a security), was there advertising to the U.S. market? Did you work through an intermediary? Was there any nexus to the U.S.? There are state consumer protection and unfair and deceptive acts and practices (UDAP) laws that could be useful. Those are beyond my expertise.
Beyond U.S. law, Portuguese consumer protection or contract law could be potential avenues to explore if you were misled or if there has been a breach of contract.
*not legal, tax, or investment advice.
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I know, I’m certain, and I completely agree with you that we (ARI members) chose this for the sake of citizenship, not some cheap plastic temporary card that’s easier to obtain by other means. This isn’t pessimism but my personal view of reality; I still hope for the best, but I’m working on the assumption that the government doesn’t want to give us what was promised and what we were all counting on when we brought them our money. They don’t want this for their own internal reasons, and we can all see how the process of amending the law is going, and in which direction. They do not provide for any special conditions for ARI. Therefore, if the bill comes into force, they will say: ‘Get a residence permit, be happy, that’s all.’ Furthermore, if you want a passport, follow the current rules and wait 10 years for citizenship. If you disagree, read the law: there has never been citizenship for ARI, only a residence permit after 90 days. To argue otherwise—without any basis in current legislation, going against the government’s policy, invoking the principle of legitimate expectations in the country’s constitution, and relying on the arguments of legal experts (or even the framers of the constitution)—is not at all what we had in mind. It seems unconvincing to me that participation in the ARI, which guarantees only a residence permit and relocation to Portugal, is sufficient to claim citizenship ahead of schedule if the law is amended. Just as, for example, it would be unconvincing to demand exemption from import tax on an electric car if the vehicle is delivered after the government has changed the law and introduced a tax on its import (currently it is zero), and so on. It is a strange position to argue that I moved to live in a country when the tax was zero and the government changed it, thereby violating my right and the principle of legitimate expectations. Spending several years of my life in court battles with a highly uncertain outcome, generously funding local lawyers, is certainly not something I would wish to do. The previous rejected bill (which is similar to the current one for ARI) had already been before the Constitutional Court, but I could not find in its ruling any protection of the legitimate expectation of a 5-year citizenship period specifically for ARI, as you mention. In this situation, I wouldn’t count on our rights being upheld in court. . This is the only 100% guarantee that this bill will not come into force, or that they will remember the difference between ARI participants and migrants and amend it for us. Good luck to us all.
But we didn’t manage to do it in time. We should have attended the GV earlier; then everything would have worked out. After all, some people had already received their passports or applied for them. Everything was done in strict accordance with the law.
You may be talking with irony, but in truth it was never easy. We had applied long before covid and yet still here.
In that case, you’re in luck – since five years have passed since you submitted your application, you can go to the IRN, and in a couple of years you’ll have your passport in your pocket.
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You cannot apply for kids.
We are mostly on the same boat. People should stop whining about previous applicants who are said to be lucky but in fact they were not, and focus on the real problems.
Even if the new law is vetoed, there will be new obstacles. The tide has changed. Life will be difficult for immigrants in all countries.
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In that case, you 're lucky
If the main applicant is lucky, what about the spouse and kids? I have applied and probably, my spouse before end of next week but what of the kids? Personally, getting the passport for the kids is one of my main objection and now, they are under 18, they have to wait for another 7 years before applying for citizenship (if the law pass in its state now) because their TRC was issued in 2023, 2 and half years after application. One of the kids will be 18 in 4 months. In fact, this law will not pass, there must be grandfathering by God’s grace at least for GV applicants. I believe in it.
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I’ve got a few questions about my situation, which I’m hoping someone here might be able to shed a little light on.
The way this has all played out in the Portuguese legislature has been very disappointing, but I may end up being lucky. I’m reluctant to pay the lawyers to file early since I don’t see that as likely to be successful. The process has taken long enough that it may not be necessary. I first applied for the Golden Visa in late April 2021, and even if the president signs the current legislation I may still manage to file before it takes legal effect. But the timing is going to be close.
According to the online AIMA portal, the Data a pagamento is 14-04-2021 and the payment was received on 28-04-2021. I believe that means I’ll complete my five years of residency and am entitled to apply for citizenship on April 28th. Am I understanding that right?
I also saw from earlier in the thread is that even if the president signs the bill, there’s a period of about a week before the law is published and takes legal effect; is that correct?
Finally, my lawyers assure me that it’s possible to file all the paperwork and then swap in things like apostilled originals for copies without altering the submission date. That would be great, as I’m scrambling to get the documents assembled in the United States and it would be better if I could bring them over myself in early May when I return to Portugal. But is it risky?
For something like this check directly with your lawyer on the date you fulfill the five year requirement. With my lawyer they indicated it was the date the payment request was generated, but then said to wait a few days after to be safe, even though each payment date was 2 days after each payment request was generated. I had assumed it was the date on my payment receipt since that completed the application, but by waiting I was covered either way. That may mean you can apply today.
Either way, you do not have much time. Grab all the documents you can, scan them, email them to your lawyer, then overnight mail the originals they need. Don’t wait to bring them over yourself unless told to by the lawyer. If they are confident on being able to switch documents out later I would instruct them to file at the latest possible date they feel comfortable with to allow you to gather the most documents and maybe hit 29-04-26 if possible. Assuming the President does not refer/veto it, I am not sure how much wiggle room after promulgation you have. The president Promulgates, then it is published officially, then the day after publication it is in effect. I am not sure if it can promulgate and be published in the same day, but that leaves little heads up for them to complete an application.
IT person here 
Old-style technology like what AIMA and the IRN seem to use can get very slow - or just fall apart - under heavy load.
Even on an ordinary day, sometimes sh** happens with computer systems. Just ask AIMA 
I would not chance waiting until the last day(s) before the new law’s publication to apply. The IRN portal will undoubtably be very popular in the last-minute rush.
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Let’s hope these things keep Seguro preoccupied this week 
- Lisbon, April 19, 2026 (Lusa) - The President of the Republic, António José Seguro, arrives in Madrid today for his first official visit abroad, during which he will meet with King Felipe VI and the Spanish Prime Minister, Pedro Sánchez, on Monday [20th].
- Lisbon, April 18, 2026 (Lusa) - The President of the Republic, António José Seguro, will receive social partners in Belém on Wednesday [22nd], starting with the CGTP-IN, on the eve of a meeting of the UGT national secretariat to vote on the final version of the labor package.
Just a reminder that:
- April 21: 8 days after the president received [latest proposed changes to Nationality Law] would be the deadline to refer to the Constitutional Court ← still hoping for this!
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Unfortunately, it may be the case that I don’t have much time between qualifying for the application and the law taking effect.