that has not changed, its seperate.
I have been resigned to this outcome for a little while. But the one thing I’m really not sure about is what is going to happen with the private funds. How are they likely to deal with the situation where you’re have some people who want out, and some people who want to wait the full 10 years? I wonder if they will create some form of alternative vehicle to move people into. Does anyone have any thoughts or speculations?
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I’m wondering what’s going to happen to the ones who already applied. I’m sure AIMA, as inefficient as they are, will just start issuing blanket certificates to IRN inquiries based on card issuance—without lifting a finger to actually verify anything. And then what? Lawsuits, costs, sleepless nights… all on top of the $2M opportunity cost that’s already gone. Damn.
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I sent the following via the contact form (but DeepL translated it to Portuguese). Please everyone write a respectful letter to the President. If he vetoes it or refers it to the constitutional court he provides notes as to why. Those notes are the basis for the legislative to try to remedy the issue.
We want those notes to include concerns specifically tailored to Golden Visa holders so we are not lost in the crowd if legislation is revised since our claims are different and may be stronger.
Dear President Marcelo Rebelo de Sousa,
I write to express my concerns over potential unconstitutional passages in the recently approved changes to the Nationality Law. I am an ARI visa holder that recently moved my family to Portugal and I would have been eligible to apply for citizenship in March of 2026.
1. Until this recent change, the days until I could apply for citizenship were counted from the date of my application. With the changes yesterday, these days are lost and will not be counted. I believe this represents a retroactive change in the law and adds an additional year until I can apply for citizenship. This lost year is solely due to delays at AIMA/SEF and is in addition to the five years added by the new nationality law.
2. I made a significant financial investment in a commercial venture in Portugal to participate in the ARI scheme, with the legitimate expectation of being able to apply for citizenship in five years. That money will now have to be locked up in the investment for five additional years. This represents a financial loss. I am truly shocked by these changes not having a transitional provision. Additionally, all previous legislation had made it easier for immigrants to apply for citizenship. I believe this violates my legitimate expectations when the government marketed the ARI program to investors.
I ask that you please consider these items, as well as other issues written about recently by Professor Jorge Miranda, in your decision on whether to promulgate this law.
With best regards,
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I just asked our fund manager this very question. I’ll let you know what he says. But from what I can gather, they are working flat out yo come up with a viable strategy so they may not have an immediate answer.
One couldn’t possibly speculate as to what their intentions might be. I gave up long ago trying to unravel these complex bureaucratic questions. But you’re right, the opportunity costs of investing in this program are considerable. It’s not right.
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The fund managers who pocket their 2–3% a year no matter how terrible the PT market has been? Do the math — after 10 or 12 years, they’ve taken 20–30% plus VAT for doing absolutely nothing, and you might not even see that before taxes—assuming you don’t lose money in the first place.
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Public service announcement:
For anyone stuck at the frozen, non-functioning page for writing to the president of Portugal:
Navigate to:
https://www.presidencia.pt/pt/
That page is a 404, but that’s fine. Accept the cookie dialog. Then you can navigate back to the English site and the contact page, and it’ll work as expected.
You’re welcome. That took me about a half hour to debug. 
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Many thanks for this workaround/solution. I was stuck and about to abandon my email.
This is what I wrote…
The Honorable Marcelo Rebelo de Sousa
President of República Portuguesa
Dear Mr. President,
I write to express my concerns over potential unconstitutional passages in the recently approved changes to the Nationality Law. I am an ARI visa applicant that applied with my dependant family members for the ARI Visa in June 2023 for eventually moving to Portugal in due course when the ARI Visa is issued, and I would have been eligible to apply for citizenship as per the regulations and laws in place currently, in June of 2028.
-
Until this recent change, the days until I could apply for citizenship were counted from the date of my application. With the changes yesterday, these days are lost and will not be counted. I have waited patiently for over two years for the issue of this visa. I believe this represents a retroactive change in the law and adds an additional indeterminate time, until the ARI Visa / Card is issued by AIMA, until I can accrue the required time, to apply for citizenship. This lost time is solely due to delays at AIMA/SEF and is in addition to the five years added by the new nationality law.
-
I made a significant financial investment in property in Portugal, and in the rehabilitation and renovation of this property, and an addition to the long term lease/rental housing supply, to participate in the ARI scheme, with the legitimate expectation of being able to apply for citizenship in five years. That money will now have to be locked up in the investment for five additional years. This represents a financial loss. I am truly shocked by these changes not having a transitional provision. Additionally, all previous legislation had made it easier for immigrants to apply for citizenship. I believe this violates my legitimate expectations when the government marketed the ARI program to investors.
I ask that you please consider these items, as well as other issues written about recently by Professor Jorge Miranda, in your decision on whether to promulgate this law.
Respectfully yours,
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I did some quick analysis of NG’s GV timeline tracker to back up my (second) letter to the President this morning.
I wanted to illustrate how it’s completely unfair to ignore our time in AIMA purgatory w.r.t. counting years for Citizenship, because as Sr. Miranda says that’s totally “arbitrary” and nothing we can control.
fwiw, my letter (translated w/Deepl)
Thank you for your reply of 22-October. As of today, it falls to your Excellency to protect the Portuguese Constitution, after the main political parties have forsaken it.
I and thousands of others have invested billions into Portugal through the Autorização de Residência para Investimento.
Any investment involves a “contract” and expectations that both sides will honour their original agreement. Now Portugal wants to retroactively double the years required for Nationality. How can any investor trust Portugal when we are cheated like this?
O “pai da Constituição” Jorge Miranda has also made it very clear that starting our count of years for Nationality from the date of our residency approval would be arbitrary and unconstitutional.
My own “90 day” approval process is still unconcluded after three years waiting on SEF/AIMA, through no fault of my own. I am an active member of an ARI investors forum, and in a survey of 349 people who actually received their residency we found that SEF/AIMA has huge variances in ARI approval durations:
- 9 applicants received their ARI residency approval in less than 1 year
- 98 waited up to 2 years
- 111 waited up to 3 years
- 126 waited up to 4 years
- 5 waited 4 years or more
In the context of requiring 5 - or now 10 - precious years to qualify for Nationality, you can see that most of us lose 1 to 4 years waiting on SEF/AIMA bureaucracy that is totally out of our control! How can Portugal penalise us for Portugal’s own inefficiency?
I plead with you to please instruct the Tribunal Constitucional to review the huge injustices in the Nationality Law amendments that you have been presented with.
EDIT: Argh! I forgot to point out (as Sr. Miranda did) that someone who applies the same time as me can take 1-2 years more or less than me to get AIMA approval, again proving how arbitrary “date of approval” is for counting years. Maybe someone else can note that in their letter!
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We invested in three funds. Bluecrow took action at the turn of the year to amend its documents for the Growth Fund we are in to allow it to list on the Euronext exchange, allowing shareholders to sell shares there.
The other two, dunno.
They are performing OK-ish but not in line with the tech-heavy returns I have in the US. I was OK with that trade and the premise that return OF my capital was more important than the return ON my capital, as a means to the citizenship. Grrrrr.
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Exactly. I was OK with modest returns and relative stability of capital in exchange for the tradeoff of citizenship. Now, since I plan to abandon the program rather than sink tens of thousands of dollars into renewals and spending vacations in Portugal, the tradeoff isn’t worth it at all.
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Hi there I am a Dec 22 applicant and still awaiting analysis, this is what I have sent to the President (but in Portuguese):
Your Excellency,
I write as an individual investor and lawful resident applicant who responded in good faith to the Portuguese State’s invitation to participate in the Autorização de Residência para Investimento (ARI), commonly known as the Golden Visa, under the legislation in force in 2022.
In July 2022, I invested in Portuguese property in reliance on the legal framework then publicly promoted as a secure and transparent route to residence and, in due course, eligibility for the Non-Habitual Resident (NHR) tax regime. In December 2022, I formally submitted my ARI application, which remains pending due to administrative delays beyond my control.
I wish to express my deep respect for the Portuguese Republic’s sovereign right to amend its laws. My appeal is not against reform itself, but against any retroactive or transitional change that defeats justified reliance on the legal commitments in force at the time of my investment and application.
- Protection of Legal Certainty and Legitimate Expectations
The Constitution of the Portuguese Republic enshrines, at Article 2, the principles of legal certainty and protection of legitimate expectations (confiança legítima) as essential components of the rule of law. The Tribunal Constitucional, in decisions such as Acórdãos 575/2014, 602/2016, and more recently 128/2024, reaffirmed that the State must not frustrate justified reliance or destroy legal stability without compelling justification and proportionate transition.
When the Portuguese Government invited foreign investors through the Golden Visa programme, it did so on the express assurance that those who acted lawfully under the regime would be governed by the legal conditions then in force. Retroactive alteration of those terms — for instance by denying renewals, changing residence-period requirements, or altering the pathway to citizenship — would directly contradict the jurisprudence of the Constitutional Court, which has consistently protected acquired rights (direitos adquiridos) and legitimate expectations of residents.
- Administrative Delay and the Linked Expectation of NHR Status
My investment decision and ARI application were also made in reliance on the NHR tax regime, which was, at the time, a central feature of Portugal’s attractiveness to new residents. The NHR was explicitly presented by State agencies and professional advisers as complementary to the ARI programme — the fiscal component of the same strategic policy to attract long-term investment and human capital.
Because my ARI application remains under analysis, I have been prevented from formally registering for NHR. This delay is entirely attributable to administrative backlog, not to any omission on my part. In such circumstances, it would be contrary to the principle of good faith in administrative action (Article 266(2)) for the State to benefit from its own delay by subsequently abolishing or denying access to NHR for those who were already irreversibly committed to Portugal under the earlier framework.
To remove the NHR regime for individuals in this situation — who have already invested and applied under the pre-existing legal and fiscal environment — would amount to a retroactive deprivation of legitimate expectations, contrary to Articles 2, 103(3), and 266(2) of the Constitution and the reasoning in Acórdãos 575/2014 and 128/2024, which affirm that the State may not frustrate lawful reliance or profit from its own administrative delay.
- Proportionality, Equality, and International Credibility
Any change that penalises applicants still awaiting ARI decisions would create unequal treatment between investors whose files happened to be processed earlier and those delayed by State action. Such disparity would conflict with the constitutional principle of equality (Article 13) and the Court’s demand for proportionality (Article 18(2)) in legislative reform.
Moreover, Portugal’s international reputation as a stable, rules-based European democracy depends on honouring the commitments made under its own legal regimes. Foreign investors, professionals, and families have acted in good faith on the strength of those commitments. Retroactive disruption would undermine confidence not only in migration and tax policy, but in the broader predictability of the Portuguese legal order.
- My Respectful Request
I therefore respectfully urge Your Excellency, in your constitutional capacity as guardian of the Republic’s fundamental values, to ensure that any legislative changes affecting the ARI or NHR regimes:
Include explicit transitional provisions safeguarding all those who made qualifying investments or submitted ARI applications before the introduction of the new law;
Preserve the legitimate expectations of applicants prevented from completing NHR registration solely due to administrative delay;
Be subject, where necessary, to preventive constitutional review to ensure conformity with Articles 2, 13, 18(2), 103(3), and 266(2) of the Constitution and with the jurisprudence of the Tribunal Constitucional;
Reaffirm to both citizens and the international community that Portugal remains a State where legal certainty, fairness, and good faith guide the conduct of public power.
- Closing
Your Excellency, I chose Portugal because it is admired for its constitutional integrity, warmth, and stability. I remain committed to investing, living, and contributing here. I ask only that the Republic uphold the principle that those who acted lawfully under its laws should continue to be governed by them.
With the highest respect and confidence in your stewardship of the Constitution,
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Do you guys think it matters if the letter to the president is in Portuguese not English? I mean we are asking to become Portuguese citizens… what do you think?
If you’re fluent in Portuguese I suspect that would be the best way to communicate, otherwise I think a well articulated letter in English would be preferable to one in broken or machine translated Portuguese.
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Funny that he also states:
Por outro lado, prometeu continuar "a reforçar as medidas de integração humanista e a atrair talento qualificado que acrescente valor, inovação e futuro a Portugal". (On the other hand, he promised to continue “to reinforce the means of humane integration and attract a qualified talent which would increase the value, innovation, and future in Portugal”)
I always found “Portuguese logic” particularly peculiar. This is just a perfect example of governmental incompetency.
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Cognitive dissonance at its finest. It would be funny if it wasn’t so depressing. 
Interesting to note the justification given by the Presidency on the promulgation of the amended Foreigners Law:
- Considering that the decree, now revised and approved by 70% of the Deputies, minimally addresses the essential doubts of unconstitutionality raised by the President of the Republic and confirmed by the Constitutional Court, the President of the Republic also promulgated the decree of the Assembly of the Republic that amends Law No. 23/2007, of July 4, which approves the legal regime for the entry, stay, exit and removal of foreigners from the national territory.
So it appears the President had his own concerns last time, and that he also expected a super-majority to approve the amended law. Let’s see what he does this time round.
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Someone fill me in, el presidente has 20 days before he needs to decide veto, accept, or send to court right?
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Every since I read this post and the term “occasional Portuguese”, I have been annoyed. I wonder if that is what they call the numerous young professionals who have left the country in search of economic opportunity and building lives in other countries?
FWIW, I am on board with increasing the “ties to Portugal” requirement and being knowledgeable about the culture, history, etc. That can be done without screwing over the folks on this journey.
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