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

A2 is written into the current regulations

I wonder if knowledge of Portuguese to A2 level would be sufficient to pass a civics test, or would applicants need to have a much better command of the language? Could this new test be a de facto change to a language requirement?

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Interesting you should ask the question. I had cause to many times wonder during my recent EdPro course whether it was not also a civics one. We covered things like the national anthem, how AIMA (is supposed to) works, applying for jobs, hospital system, some history, pastel de nata, etc etc.

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I highly doubt, but ultimately we do not know how it would be designed.
If it’s a multiple-choice online test than people with A0 could pass it..

Couldn’t the regulations be updated with the new nationality law?

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Yes of course

For those with real estate investments and thus D2 conversion, the renewal is 3 years and much cheaper. In that case the PR becomes less attractive.

I’m in this category. But even so I’m considering PR because:

  1. As you said, it’s more stable
  2. Supposedly it lets you sell the investment. My investment is a hotel share with 0% return. The opportunity cost could offset the fee differential.
  3. Still to be clarified, but GV PR may have fewer / more flexible stay requirements compared to the 7 days / year.

If you are not in the D2 category, and not expecting citizenship in a few years, I think the GV PR is a great choice.

is it confirmed that you can sell the investment with a GV PR? I read a while ago on this forum that selling was only for a regular PR.

Many Golden Visa (GV) investors applied under a framework that allowed them to maintain their residency with a minimum stay requirement of 7 days per year. This condition was clearly defined and mutually accepted by both the investors and the Portuguese government at the time of investment.

While it is understood that governments have the sovereign right to amend legislation, such changes should not be applied retroactively in a manner that negatively affects existing investors—particularly those who committed significant capital based on the rules in force at the time.

Golden Visa investors typically maintain substantial investments for a minimum of five years in reliance on the expectation of a clear and stable pathway to permanent residency and, ultimately, citizenship. It would therefore be neither fair nor proportionate to require these same investors to maintain their investments for an additional five years to obtain permanent residency, and then wait up to ten years to apply for citizenship.

Furthermore, this situation has broader implications for families. Dependent children would only become eligible after the main applicant obtains citizenship, which could result in a total waiting period of up to 17 years or more under current processing conditions.

In my case, I invested in 2021 and, to date, have not yet received my residence card. Extending the investment obligation for an additional 5–6 years raises serious concerns regarding both fairness and the long-term value of the investment.

Such a retroactive application of new rules would be inconsistent with principles of legal certainty and legitimate expectations, and would undermine investor confidence. To my knowledge, measures of this nature have not been historically applied in comparable frameworks.

For these reasons, I believe that existing Golden Visa applicants should be protected under the legal framework that was in force at the time of their application

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I also think that D7/D8 residence permit holders should be protected as well. For those of us who came to live in Portugal, we would have to continue being tax residents for extra 5-6 years until we would be able to become citizens. Furthermore, each renewal we have to stay in the country without the ability to travel anywhere.

The Spanish CCSE is pretty straightforward—just 25 multiple-choice questions, and the PT one should hopefully be along those lines. You can usually prep for it over a weekend and pass.

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I wonder who is forcing people to maintain investment longer than 5 years? The law explicitly states 5 years, no matter what.
So do we know of some precedents where AIMA refused a GV renewal or issue of PR to someone who sold investment on their 5 years mark?

Mayyyyyybeeee, but as a reference point we have this: “National Survey Finds Just 1 in 3 Americans Would Pass Citizenship Test”

The Washington Post had a similiar survey and results. Given the vibe and that its not unreasonable to expect someone with citizenship status to have a general working knowledge of the electoral and governance systems, maybe some major points of cultural significance (when was the carnation revolution, why did it occur, what is its significance.) Dunno, maybe a quiz on the best pastel de nata, or who is Christiano Renaldo. But I am personally OK with having (and wanting) to school up a bit on the country where I aspire to spend a decent amount of time. I dont want to limit my experience to an expat enclave - I would be pleased one day if, when I walk into a restaurant, they dont hand me the English menu even before I say anything.

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There’s a huge difference between “pass without studying” which is what they’re testing here, vs “pass with studying”

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Indeed, i might pursue both.
But circling back on eligibilit, my elder son, is 14 now without biometrics, i guess he will be 17 or 18 when he gets his 1 st residence card. From that time he has to wait 10 years for citizenship at the age of 28. However, he would have aged out at the age of 24 when he finishes university and stop being dependent, hence might not qualify for citizenship and maybe not pr. Is my understanding accurate. Thanks

My understanding is that the requirement for citizenship is to have been a resident for 10 years.

The dependents will need to be … dependent … in order for the GV to be issued, renewed, and for the GV permanent residency to be issued. You can apply for the PR after 5 years the first RC was issued. So if the RC is issued when your kid is 18, then 5 years later when they’re 23 you apply for the PR. After that it doesn’t matter if they’re dependent or not.

I’m told that AIMA is pretty generous about determining dependency, as well. As long as your kid is unmarried and you’re paying for eduction (doesn’t have to be uni; could be a language class or something), they’ll qualify as dependent.

This is what I understand based on what my lawyer told me. It’s possible that I misunderstood, that my lawyer is wrong, or that the government will change the rules again.

You are right. It is a very tough situation. Maybe at the time of applying PR, he needs to be a full-time student again. You might have to register him in any kind of 1 year course (language, art,…) in order to get a letter indicating that he is being a student. Attending classes is not the question of Aima.
It is indeed a very tricky and nasty situation caused by the buraucracy. :face_with_spiral_eyes::face_with_spiral_eyes::face_with_spiral_eyes::face_with_spiral_eyes: I’ve never experienced this myself. Therefore, let’s learn from others how to tackle this issue.

Age out of what? He would have his PR in 5 years, i.e. at the age of 22 or 23 max.

The problem is that even if you maintain the investment for five years, you may only receive your first residence card after four years. In practice, AIMA considers that the five-year period required for permanent residence (PR) starts from the date of the first residence card, as this is what they define as “legal residency.”

Therefore, if you sell your investment after five years from the initial application, and then later apply to renew your residence or apply for PR, there is a significant risk of rejection. This is because, according to AIMA’s interpretation, you would not have completed five years of legal residency, and at the same time, you would no longer hold the qualifying investment.

This is my understanding of how the law is being applied in practice. Please correct me if I am mistaken.

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I totally agree with the reasoning here, as I believe any rational person would. The question is, convincing ourselves does not get us anywhere as AIMA will most certainly disagree, so how would a court judge react to these facts? I believe there is a good chance to prevail if all other requirements have been met and if our case is laid out as eloquently outlined here.
Furthermore, please correct me anyone, but to my knowledge the Nationality Law does not mention GV PR requirements, only citizenship. So could it be argued that the clock start at first residence card applies ONLY to citizenship, but not to our right to GV PR, which is not mentioned in the new law and therefore remains as in the old law ie. from application date? Or did I miss something obvious?