It’s not cut and dry and no attorney will advise you that moving to PT prior to at least having pre-approval is risk-free. There are also challenges, albeit maybe manageable ones, of moving between pre-approval but prior to having your card.
If you move prior to pre-approval, you run the risk that your application will either be rejected (if found not to have met the investment/application parameters), in which case you will likely have to leave. We also have no idea if/when AIMA will resume pre-approvals, which have been stalled for more than a year, so you run the risk of living with the below problems, which range from inconvenience to arrest, for an unknown length of time. You may choose to undertake those risks, but don’t let anyone talk you out of making that risk assessment for yourself or glibly say that you have a right to move to PT.
The real practical risks include:
-significant limitations (and potential risk of arrest) on your freedom to travel intra-Schengen or via a route that goes through another Schengen country, which risks are likely to increase when the EU introduces its ETIAS system;
-difficulties obtaining tax residency/registering for NISS/obtaining a numero de utente, and with all these things, increased difficulty obtaining a host of public services (health care, prescriptions, driver’s licenses, etc.) and generally navigating Portugal’s bureaucracy;
-potential increased challenges obtaining updated versions of your criminal background checks etc. if/when AIMA ever does get around to processing your application