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

Exactly - on this platform I believe most of are pursuing naturalization through years of residency. So just to reiterate my point, “for the time being” AIMA has not been providing the final green light & input for applications for Sep 23 and onwards. By the way people visiting IRNs in persons and several lawyers confirmed that; there has been a pause on citizenship processes (for the ones which the submission date is Sep 23 or later) and Porto IRN told few people that the only pending response is from AIMA..

They seem to be waiting for the discussion on the nationality law, but as I’ve written earlier this shouldn’t be an excuse to pause the process of existing applications, as the submitted cases should have been already grandfathered.

Is this date correct, do you mean next week Tuesday? So from next Tuesday, no more nationality applications can be submitted?

no, it’s a reference to September 2023.

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No way that it will shrink. It will only reduce the influx. Instead of millions coming in, with strict rule it might become 50k-100k. It only can shrink if at least 50% of the ones (who are already in the country) leave the country due to new proposed citizenship law which is never going to happen.

Even the number of GV applicants do not shrink and indeed it increases year after year regardless of rules, bad feedback, long waiting time,…..

Forget about “shrink”. It will continue increasing at slower pace. Just a little slower. Because the immigrants who are in the country now will generate lots of babies and these new born babies will also be considered as new immigrants.

So here is some very interesting news. The opinion of Jorge Miranda (aka “father of the Constitution”, drafter of the 1976 Constitution, lifelong constitutional scholar) on the nationality law changes was reported back in July, but the full text wasn’t available.

It has now entered the parliamentary record, so journalists have seen the whole thing, and apparently it’s even more scathing than initially reported. More than 80 pages arguing large parts of the draft changes are unconstitutional.

First, the retroactivity to June 19. He calls the government’s reasoning excessive and “offensive”, pointing out that people are fully within their rights to rely on a law as currently written until it is officially changed by parliament. He says that a government’s dislike of existing rules doesn’t erase them.

He rejects the claim that people should have anticipated tougher rules because they were discussed during the election campaign. He says campaign talk is not law and can’t be a substitute for legislation passed by parliament. He argues that reasoning diminishes the role of parliament, since it assumes they will just rubber stamp whatever the government wants.

He attacks the lack of any transition period (yes, really!). He says the legal consequences of state acts must come with guarantees of “predictability” and “determinability.” If there is no transitional regime, he argues the legitimate expectations of applicants are denied, both for those whose position is already “consolidated”, meaning they’ve fully met the requirements under the existing law, and for those on the verge of meeting the requirements but cut off by a sudden change.

He also says the idea of counting residence time from the approval date rather than from the application date is constitutionally “inadmissible”. He says that would give the administration full control by dragging out decisions and leaving people entirely dependent on bureaucratic timing. He says this is an affront to the principle of “human dignity” set out in Article 1 of the Constitution.

So really quite a striking and damning opinion that touches on a lot of the issues we have been screaming into the void about here. Even if the government changes the law, given who Miranda is, this document gives disgruntled ARIs a strong basis for legal challenge.

I couldn’t find the full opinion online yet, only commentary, but I would guess it will be published in parliamentary archives at some point. Article below (in Portuguese and behind paywall).

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That’s nice but it kinda seems like they could address his criticisms by

  1. Keep counting from application date
  2. Instead backdating to June 2025, forward date the start of the law to say Jan 2026

And it would still completely screw over everyone who applied after 2020…

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Thank you for this encouraging dose of good news. I’ll keep my eyes open for the full text of the opinion. Thanks in advance if anyone finds it and posts it here, with bonus points for an English translation.

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Further to my post from a week ago re: IRN President Rodrigues da Ponte’s address to the Committee on September 11… more Nationality process details/stats in this article:

  • citizenship applications are processed in 20 locations—the Central Archives of Lisbon, the Porto Registry Office, and 18 other locations. “Each of them has teams dedicated to a specific process, because with specialization, they can move faster,”
  • He assured that professionals analyze citizenship applications on a first-come, first-served basis.
  • delay in granting citizenship—some people have been on the waiting list for four years—and the instability in service are related to a lack of staff.
  • by the end of July, there were 522,000 active nationality applications. This represents 7,000 more than in June.
  • “Currently, we have 158,000 applications for Sephardic immigrants, 160,000 for length of residence, 71,000 for grandchildren of Portuguese immigrants, and 142,000 for parents born abroad”… Regarding Sephardic Jews, the IRN president indicated that the significant increase in the number of applications occurred from 2020 to 2021. “We had 50,000 applications for nationality in 2020, and in 2021, the number rose to 124,000”
  • in the last four years, there has been a significant increase in applications from foreigners residing in Portugal — coinciding with the influx of Brazilians to Portugal, which began in 2017
  • attorney Adriana Ayala recommends filing the application in cities far from Lisbon and Porto. "The further away, the more likely it is to be processed faster.
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I can’t find his full 80 pages (yet) either, but there was more from Miranda regarding the above in @tkrunning’s “Expresso exclusive” post from July:

“It creates a situation of uncertainty about the start date of the period, which is no longer in the hands of the citizen and is entirely in the hands of the Administration.” Thus, two people who submit a residence application at the same time may receive approval on different dates, thus having a completely different start date for access to nationality. “No discernible reason can be found for such a distinction”

…and let’s be clear here - when he says “a completely different start date for access to nationality” we’re talking years different in some cases.

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I wouldn’t jump straight to the worst case scenario.

I haven’t seen the pdf of the full text, just the secondary reporting. The full opinion is with parliament, but I can’t find a copy online.

The Portuguese quoted from Miranda in the article is “dos que estavam já perto de ver o seu direito constituído” or literally “those who were already close to seeing their right constituted”. “Close” is a legal status question, it doesn’t mean a set number of days or weeks. It depends on expectations the state created through laws and actions.

You can look up past decisions of the constitutional court involving “legitimate expectations”. They usually look at whether someone’s right was already “constituted”, or whether they had a solid legal expectation that it was about to be met. They’ve set out four criteria:

  1. the state created an expectation of continuity (normally through laws or consistent real life administrative practice, but sometimes applicants also point to government press releases or campaign statements, although it seems these usually carry less weight)
  2. that expectation was justified (a reasonable person could rely on it)
  3. people planned their lives in reliance on it (eg investments, residence, family decisions)
  4. there is no overriding public interest of sufficient weight to justify breaking it. If there is an interest, the change can still go ahead, but it has to be proportionate, and that’s where transitional periods are used.

None of this is to say we should expect the law to be frozen in a way we like it, but this kind of situation is a lawyer’s field day. Every one of those four points can be argued from both sides and tested in court.

There’s a grey zone between someone who just filed an ARI application this morning and someone who has already met almost all the conditions for citizenship. That will no doubt be argued in the coming weeks, and very likely in court if the changes go ahead. But keep in mind, it looks like Miranda is focused only on the constitutional issues. There are probably other grounds to challenge the changes eg procedural, administrative (like the unreasonable delays), or even EU law.

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Yes, mine was not quite years thankfully, but it was still over 14 months from application to approval, and as you point out that was fast compared to many.

Here’s the opinion, in Portuguese, and a translation by DeepL

Miranda20250702-PT.pdf (6.8 MB)
Miranda20250702-EN.pdf (1.4 MB)

The link is near the bottom of this page:
https://www.parlamento.pt/ActividadeParlamentar/Paginas/DetalheIniciativa.aspx?BID=315160

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Good find, thanks Chris!

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Mine was nearly four years from app to approval. I’ve only just gotten my first card lol

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Following dates are relevant to this thread, as the Annual Budget wrangling will preoccupy the PM and opposition with something that has to get sorted this autumn:

  • The 2026 State Budget will be submitted to Parliament by October 10th, then to Brussels,
  • and is expected to be voted on in general terms at the end of the month.
  • If approved, as everything indicates, there will be a vote on the specifics at the end of November, with the final overall vote in the last week of that month.

Update - specific 2026 Budget dates:

  • October 9: OE 2026 delivered to Parliament
  • October 24: Assembly of the Republic hearings with Ministers
  • October 27 and 28: general debate on the Government’s State Budget proposal for 2026 in parliament
  • November 27: final global vote
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If this reasoning is persuasive to the legislature, then we can hope for no retroactivity.

Otherwise, I think there is a strong argument that could be taken to the courts unless there is:
-set start date for time counting for citizenship at date of application.
-at least a 6 month transition period after the law is enacted before any of it is effective.
-carve out for ARI with regard to 5 year timeline for citizenship
-carve out for ARI with regard to family reunification restrictions

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I know others have reported the larger points (i.e. retroactivity, legitimate expectations), but these were some interesting bits I found.

Under 16 J (bottom of page 14) of the English translation:

(For the purpose of citizenship) Determined that all periods of legal residence in Portuguese territory should be taken into account, and not only periods of residence under a formal residence permit;

But on pages 72-75 discusses the back and forth over the starting date for the citizenship clock bases an application date. Seems to be “you published that law, no taking it back unless you do it for new residence applications going forward?” Tough to read because the law here has gone back and forth and not officially been published.

  • Is this why there is discrepancy in some Contegem de Tempo?
  • Would this give us an additional leg to stand on (if they never publish the rule for starting the clock at application) for some people that could live in Portugal with their application pending due to COVID processing delays? I think that was a narrow application time window, but I can’t remember the dates.
  • Or since they were supposed to process applications within 90 days, argue for application date +90 to be the start?

The top of page 18 it is good to see he does not see GV as running afoul of the EU like Malta’s program did.

On the bottom of page 23 he is against a cultural test for citizenship.

Page 24 is where he argues against the different year “tiers” for citizenship based on country of origin (CPLP/stateless/non-Portuguese), but then on the bottom of page 47 seems to conclude the opposite?

In this context, there is constitutional support for the possibility of giving special consideration to citizens of Portuguese-speaking countries (Articles 7(4) and 15(3)). Other criteria for differentiated treatment may be introduced, provided that there is sufficient and constitutionally valid reason for doing so.

Continuing onto page 47, that differentiated treatment seems to be the argument he cites for giving favorable regulations to GV holders.

I do like his position of citing all the historical changes to the nationality law as always favorable to immigrants so (my interpretation) this sudden restrictive change is a shock and goes against legitimate expectations without a far ahead announcement/transition period. Page 63

Over more than 20 years, the legislating State has engaged in behavior capable of generating expectations among foreign citizens of continuity in relation to a favorable evolution of the regime for granting nationality.

After reading his opinion I come away believing more in the legitimate expectations argument. He clearly states that residency and citizenship are different processes, but argues for a long lead announcement or transition period to cover people who have started the residency process. What steps you need to have taken in the form of years of residency, an investment in a house or GV, and/or passing a language class/integrating to qualify under the current 5 year rule will seem to be left for debate.

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Can you send me the link to this, would love to send this to my lawyers that keep pointing out residency law is separate to nationality law and that it was always crystal clear.

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Here’s the old advert from SEF:

Here’s the current advert from AIMA:

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Thanks for sending it over