Citizens have voting rights. Petitions are for anybody. This government platform requires to put your ID number. Since I am still waiting for my first residence card, I used my NIF. It worked. I don’t think there is a hard rule on the required number of signatures. It is just like any other petition I believe.
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@croiato is right - what it is called matters. I also suspect that this is exactly the argument that Portugal made to the European Commission some years ago when it was investigating countries “selling” citizenship.
People have joined/re-joined this forum because these amendments are a huge issue for all of us - probably the biggest in the history of the GV. More voices and perspectives should be welcomed, rather than dismissed as trolling.
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This guy is doing some serious drugs if he thinks making talented people 10 years to get citizenship, and not being able to see their family for 2 years (along with the AIMA delays), is going to not “have any significant impact”. I would literally just head to Germany if I were a HQ talent.
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Caribbean CBI programs are starting to add residency requirements: https://www.imidaily.com/caribbean/saint-kitts-announces-cbi-residency-clause-as-dominica-breaks-silence-on-us-travel-ban/
Yes, you’re right that counterarguments need to be taken seriously. Many of us have been debating these issues here for a long time, sometimes heatedly, and I don’t think anyone is suggesting the arguments are too complex to explain. But they are complex enough that reducing them to soundbites in a forum post risks misrepresenting them. The format here has its limits. As you acknowledge, this isn’t the right place to lay out a legal case.
As a lawyer, you know that legal reasoning involves interpretation, procedure, administrative practice, context, and how they interact. It can’t always be summed up in a few lines, especially when some of the counterarguments we see here are framed in very simple terms like “it is called a visa, not a passport” or, as you put it, “the obligation is on the investor to do their due diligence.” Even that last sentence opens up a debate about the scope of obligation in regulated immigration schemes. Whether it absolves a government of responsibility when it has set the rules (and missed its own mandated processing deadlines) is a question that depends on administrative law, state conduct, and procedural fairness. That’s not something that can be meaningfully resolved here.
I’m sorry you were burned and that it messed up your family plans. I’m sad to hear that applicants had it tough even going as far back as 2014. That really sucks. Everyone here has experienced setbacks in some way, and, even now, everyone is working from incomplete and often conflicting information. That includes me. We don’t even have the text of the proposed law yet.
But I don’t think it’s reasonable to suggest that users discussing broad legal arguments are somehow acting under the spell of “so-called legal advice” or are “valorizing lawyers". We’re all aware of the dysfunctions in Portuguese bureaucracy and the arbitrary legal system. For what it’s worth, this isn’t my first time going through a migration process, and, if it comes to that, won’t be my first legal case involving a failed investment. I don’t need someone policing my level of skepticism. It’s already hardened by experience.
I’m glad you have your citizenship applications in. I will hit 5 years residency in a few months, so am watching the bridge be pulled up in front of me. That’s why I’m looking at every means available to challenge these reforms.
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Global Citizen Solutions published a similar opinion here:
A huge concern for current temporary and permanent residency permit holders is how it will affect their timeline to citizenship, especially if they are close to the current five-year waiting period. According to the government’s announcement:
- The revised citizenship regulations will not affect naturalization applications submitted before June 19, 2025.
- Applications submitted after 19 June, or incomplete submissions could be subject to the new regulations once they are officially enacted.
I’d be interested to know on what grounds they claim that these rules should apply from a date prior to their actual approval by parliament. If they don’t actually pass them until next year, there will have been several months of legal limbo where new rules are not approved but old rules no longer apply. Until legislation is formally presented, debated, passed, and published, it’s hard to see how retroactive effect could be justified, especially on something as serious as nationality rights. That might be a matter for the constitutional court.
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That particular point is likely to be unconstitutional under EU retroactivity principles. But I suspect that wouldn’t help the majority of people here, because even if it takes them 3 months to pass the rug pull, it seems like the vast majority of us on the forums either haven’t received our cards yet, or received them in the last couple years. So we’re still collectively f■■■ed.
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There was a similar situation in 2024. The residency requirement for citizenship for Sephardic Jews was increased from 1 year to 3 years. Parliament approved it Jan 5, 2024. It was published in the Diario da Republica on Mar 5, 2024. They grandfathered only those who apply for citizenship before April 1, 2024.
So, at least with that situation, there was very little grandfathering, just basically a few weeks after it was published in the Diario da Republica.
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That’s true. But the Sephardi program was symbolic and discretionary, not based on investment and with no physical requirement before changes made in 2024. The government could change or tighten the requirements without violating any legal expectations. ARI applicants made major financial commitments, signed contracts, had basic residency requirements that established a connection to Portugal, and required that they structured their lives around that commitment prior to application. Those differences could matter when you’re arguing about retroactive effects.
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But the strange thing is that they didn’t provide grandfathering for, say, Sephardic Jews who acquired a residency permit in July, 2023 and would’ve qualified for citizenship by July, 2024. The cut off for grandfathering was April, 2024. In this hypothetical, they may have uprooted their entire family, moved, signed a rental contract, etc., and then see their citizenship eligibility change to a much later date.
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Much of that financial or logistical activity you mention was voluntary and occurred after legal residency had already been granted. The government framed it that way when it defended the lack of grandfathering for Sephardi visa holders in that case, and from what I understand courts have generally upheld that distinction in past cases. In contrast, ARIs made significant financial commitments up front to qualify for residency. These financial decisions were directly incentivised by the state. After approval, we had to meet ongoing obligations like maintaining the investment and minimum stay requirements. And that program was promoted through official channels with clear legal timelines and high financial thresholds. Unlike the Sephardi pathway, this created economic expectations based in law and policy. Legally, there is a meaningful difference between a low-cost-of-entry program like the Sephardi visa that only required some forms and one like ours that required huge upfront investment and ongoing commitments. It’s not a bulletproof argument, but there is a strong case that a different standard of legal protection should apply.
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I agree if we can show that (1) the large upfront investment for ARI was tied not only to residency but a reasonable expectation of citizenship in 5 years (albeit not guaranteed), and (2) this reasonable expectation was set by the Portuguese government itself, then: the draft law is retroactive and we suffer real harm over a decision we never would’ve made if the Portuguese government hadn’t advertised and prepped us to reasonably expect citizenship in 5yrs, even if not guaranteed in fringe cases.
Do we have evidence or documentation that the government set such expectations, or was it just the industry that set our expectations?
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I would push back a bit on framing “reasonable expectation” as if we need to find a smoking gun where the government said, word for word, “your residency is explicitly and always tied to eligibility for citizenship in 5 years.” That isn’t always how legal standards like legitimate expectation work. What matters too is how a government’s actions, language, and policy structure lead people to form reasonable beliefs.
The conduct and communication of the Portuguese government led many of us to believe that a stable 5 year pathway to citizenship existed under the ARI regime. We weren’t just being gullible. Multiple official sources, including SEF/AIMA, and Portuguese consulates, consistently described the program as offering residence for a minimum of 5 years and the possibility to apply for citizenship if other conditions were met.
That wasn’t casual language, it was repeated and official. Many investors chose regulated funds based on timelines that matched the 5 year residency rule. Others made major decisions about taxes, relocation, and family structure on the same assumption. When a state designs and promotes a legal pathway that involves large financial commitments, it doesn’t need to give a written promise for people to form legitimate expectations. The structure of the law, the way it was described by official sources, and how it functioned in practice all matter.
I’d argue the “harm” is real and measurable. People made major financial and personal decisions based on the 5 year citizenship track. Some invested in illiquid funds with that exact timeline. Others relocated families or restructured their tax affairs. Changing the outcome now, especially after long delays caused by the state, and potentially replacing it with some sort of PR or another 5 years of ARI instead of citizenship, puts them in a completely different legal and practical situation than the one they signed up for. Citizenship offers rights and protections that ARI and PR do not. The cost of that shift is financial, legal, opportunity, and emotional, as is obvious from the frustration and anxiety many are expressing in this forum.
A legitimate expectation claim is about acting in reliance on a stable legal and administrative framework set by the state. If that framework is later undermined just as people reach the expected milestone, especially after delays caused by the government itself, then it raises serious concerns under EU principles of legal certainty, proportionality, and non-retroactivity.
All that said, I know the Portuguese legal system is a casino. And the government has a track record of pushing the boundaries of what is legal, then dragging its feet to remedy the situation. I’ve always put citizenship as a 50/50 proposition. But I think this is a fight worth taking up. I’m happy when people put up strong counterarguments, but some of the pushback here over the years seems less about setting reasonable expectations or testing ideas, and more about rage at the system and frustration at being sucked in by bad lawyers. While I get the impulse, I don’t think that mindset helps our case.
I don’t have much more to add until we see the text. I’m on vacation somewhere warm and should probably go outside 
Many have been down this rabbit hole before on these forums and a lot of the arguments are searchable.
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Yes, it was officially and explicitly advertized by SEF before:
and by AIMA now:
https://aima.gov.pt/pt/viver/autorizacao-de-residencia-para-investimento-art-90-o-a
They could have simply omitted any mention of citizenship from these pages, but instead they decided to advertize and promote it to attract investors.
The summary of ARI insvetments between 2012-23 was provided by SEF here, it amounts to approx €7.32B:
As this stats have been discontinued since AIMA took over, we can estimate the total ARI investment to-date at €8.65B.
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When they closed down ‘old NHR 1.1’ some deadlines were based on the date of the draft proposal announcement - not the final vote or implementation dates. To head-off the last-minute rush.
I think it went like this:
- 2-Oct, 2023 - PM Costa publicly stated that NHR would be phased out in 2024
- 10-Oct, 2023 - State Budget proposal solidified this intention
- 29-Nov, 2023 - final Budget vote officially embedded the phase-out and transitional provisions into law
If you wanted to qualify for old NHR you needed to have your property lease or purchase reservation, or your dependents enrolled in a PT school, by 10-Oct - i.e. the draft proposal date, not the law enactment date.
So PT has form closing the door before they officially lock it. And NHR certainly factored into people’s financial/investment decisions, if that’s an important legal threshold.
I remember that happening when I was looking at applying 
But changing someone’s tax rate, like with the old NHR regime, is different from changing their legal status or path to citizenship. The NHR program was always meant to be flexible. It could be revised each year through the state budget, and it was adjusted more than once for people who already had status. Most people expect that kind of thing in tax policy.
Nationality law grants legal status and long-term rights, not temporary benefits. When the state sets out a defined path to citizenship in law, it creates a legitimate expectation that those rules will apply if they meet the conditions. Not exactly the same, but the government’s partial reversal on the Manifestação changes might actually be more relevant here if we want to argue for a transitional period. That episode, the legal pushback and its resolution reinforced the principle that retroactive application of law shouldn’t harm people who have relied on existing rules. I wouldn’t assume the politicians and bureaucrats have learned from that administrative debacle or that they aren’t making the same mistake again.
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Meanwhile, at the Nationality Registry office…
In short, the situation is “chaotic and without precedent” in the history of the Institute of Registrars and Notaries, and has already led to “total rupture” and the temporary closure of a number of registry offices.
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Do we have confirmation what “na sua atual redação” (“in its current wording”) really, truly means in a Portuguese legal sense for us GVs?
- That the wording was “locked-in” on the particular date each of us applied for our GVs years ago,
- or that whatever law is “current” at the time of our nationality applications will apply?
I was in a meeting with some Brits and Americans yesterday, and it was decided to meet “biweekly.” Half were positive that meant every two weeks, other half were positive that meant twice a week 
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It does not matter what it means “in the legal sense”, because we as investors only read what we see on that page published by SEF/AIMA, and we reasonably interpet this in our favor, whereas SEF/AIMA create reasonable and legitimate expectations on our part.
All we can do (as investors reading that page) is to look up the ‘actual edition’ of the current Nationality Law, and all we see there is 5 years counted from the time of application. This is sua atual redação, and I cannot foresee what some possible future atual redação could become. It may become 100 years or 200 years or never, but I (as investor reading that page in 2021 and even now in 2025) can only physically know the current law.
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