Last month, all applicants with pending Golden Visa applications under review by AIMA saw their application status change to “Awaiting Submission.” This sudden update did not go unnoticed by the immigration legal community, which promptly sought clarification from AIMA about the situation.
A communication sent by AIMA directly to the applicants stated that the Golden Visa application process was subject to significant changes. These updates aim to streamline the procedure but have left many applicants and legal representatives seeking clarity. This guide provides an in-depth analysis and practical advice for navigating these new rules to secure a residence permit as efficiently as possible.
The recently updated procedure emphasizes a more digital and chronological approach, prioritizing older applications and introducing mandatory electronic submissions.
One important purpose of this communication from AIMA is to ensure that only active processes in which the applicants are still interested move forward in the system. The measure seeks to identify and close applications that have been abandoned or that, for whatever reason, have not been continued by the investors themselves. In our opinion, it is only destined for applicants who haven’t yet completed their biometric appointment.
By redefining procedures and requesting document updates, the aim is to optimize administrative and procedural resources and avoid a backlog of inactive cases. This approach benefits both the applicants who wish to proceed with their applications and the system by reducing delays and facilitating the management of pending cases.
What are the main procedural changes and what should I do?
1. Online Documentation Requirements
Applicants must provide their legal representatives with a complete set of updated certified and legalized documents.
Documents issued abroad must be translated into Portuguese or English and certified appropriately.
All files must be uploaded in the ARI portal and adhere to a maximum size of 2MB.
We recommend that all original documents are sent to your representative.
2. Biometric Appointments
After document submission, appointments for in-person biometric collection will be scheduled automatically based on application update dates.
These appointments are mandatory and will commence on January 15, 2025.
Bring all original uncategorized documents submitted online to the appointment for verification, as well as the application form, copy of all pages of the passport and airplane tickets for everybody in the Family.
There will be a prior notice for the appointments of no less than 30 days and not more than 90 days.
Due to the substantial number of appointments and for logistic reasons, applicants will not be able to choose the place where the appointment will take place.
Applicants that are not able to come to the appointment must present valid justifications (health reasons, lack of visa to enter Portugal to attend the appointment, etc.) and their appointments will only be scheduled for the second semester of 2025.
3. Fee Payments
The residence permit fee of 6045,20 € per person is payable during the in-person appointment if the documents uploaded online were submitted in a certified copy form. In case the documents uploaded are not certified, you must bring the original document to the appointment and a fee of €8.060,20 € may be applicable.
Payments are accepted only through card transactions (Visa, Mastercard, etc.). Therefore, applicants must ensure they have the necessary funds to proceed with this payment.
Ensure all transactions comply with your bank’s authorisation for foreign payments. We recommend using the Portuguese bank account for this payment.
What is the impact of these changes for future Applicants?
Future applicants will benefit from a more streamlined process but must adhere to stricter submission requirements. Here are the key takeaways for prospective applicants:
Complete Documentation at Initial Submission: Unlike the previous system, where partial documentation was often sufficient to start the process, the new system mandates that all documents be uploaded at the beginning.
Certification and Legalization Are Essential: Documents must be certified and apostilled (if applicable) before submission;
Reduced Delays: The upfront requirement for complete documentation is designed to minimize delays in scheduling biometric appointments and processing applications.
Documents can be submitted in English.
What are the Anticipated Outcomes and Timelines?
The revamped system’s digital focus and enhanced resources, such as increased appointment capacity (up to 6,000 daily), promise reduced processing times. However, applicants should anticipate potential delays due to the large volume of pending applications.
What are the consequences if I don’t do anything?
It is important to note that the case can be considered abandoned if no action is taken within the reasonable timeframe (6 months, as currently interpreted). In this case, a new application must be submitted under the rules in force at the time.
Conclusions
The new Golden Visa process reflects AIMA’s efforts to modernize and expedite applications. While the changes demand rigorous compliance with documentation and scheduling requirements, adhering to these guidelines will facilitate a smoother pathway to securing a residence permit in Portugal. Applicants are strongly advised to work closely with their legal representatives to complete all steps accurately and efficiently.
If you have additional questions on this topic, feel free to post them below or reach out directly.
For everyone else, Madalena also sent us a list of the documents that need to be present in the SEF portal, but it was a bit long to include above. I’ve included it here instead (click to expand):
Which documents should be updated in the portal as well as included in the new submissions?
Which documents should be updated in the portal as well as included in the new submissions?
Here is the list of documents that applicants should present in the portal for a Golden Visa application:
Investor (Investment Fund investment):
Criminal record of the country of nationality OR residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Declaration of Honor, by which the applicant declares that he/she will comply with the minimum quantitative and time requirements (5 years) of the investment activity in National Territory
Proof that the tax situation has been regularized by presenting a negative declaration of debt issued no more than 45 days previously by the Tax and Customs Authority and Social Security or, if this is not possible, a declaration that there is no record of this with these entities
Proof of a regularized contributory situation by presenting a negative debt declaration issued no more than 45 days previously by the Social Security or, if this is not possible, a declaration that there is no record of this with these entities
Proof of tax ID from the country of residence
Power of Attorney to the legal representative and copy of the lawyer’s license
Statement from the credit institution authorized or registered in Portugal with the Bank of Portugal, attesting to the actual transfer of an amount equal to or greater than the legal requirement
Certification from the bank attesting the ownership of the participation units, issued with less than 45 days
Declaration from the fund management entity attesting the golden visa eligibility and viability of the capitalization plan
Commercial registry certificate updated (in case the investment was done through a company)
Investor (Investment Arts & Culture):
Criminal record of the country of nationality OR residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Declaration of Honor, by which the applicant declares that he/she will comply with the minimum quantitative and time requirements (5 years) of the investment activity in National Territory
Proof that the tax situation has been regularized by presenting a negative declaration of debt issued no more than 45 days previously by the Tax and Customs Authority and Social Security or, if this is not possible, a declaration that there is no record of this with these entities
Proof of a regularized contributory situation by presenting a negative debt declaration issued no more than 45 days previously by the Social Security or, if this is not possible, a declaration that there is no record of this with these entities
Proof of tax ID from the country of residence
Power of Attorney to the legal representative and copy of the lawyer’s license
Statement from GEPAC attesting the eligibility of the project
Certification from the bank attesting the ownership of the participation units, issued with less than 45 days
Certification from the beneficiary entity attesting the donation / investment
Commercial registry certificate updated (in case the investment was done through a company)
Spouse:
Criminal record of the country of residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Criminal record of the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Marriage certificate issued less than 6 months ago, stamped by the Portuguese embassy or apostilled
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the primary applicant with a notarized signature
Minor Children:
Birth certificate issued less than 12 months ago, stamped by the Portuguese embassy or apostilled
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the primary applicant with a notarized signature
Authorization from the Parent (in case the Parent is not applying to the Golden Visa) dully notarized and stamped in the Portuguese embassy or apostilled
Certification of Adoption (If applicable) notarized and stamped in the Portuguese embassy of apostilled
Adult Children (more than 18 years old):
Criminal record of the country of residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Criminal record of the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Birth certificate issued less than 12 months ago, stamped by the Portuguese embassy or apostilled
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the main applicant with a notarized signature
Certification of Adoption (If applicable) dully notarized and stamped in the Portuguese embassy of apostilled
Proof of single civil status stamped in the Portuguese embassy or apostilled
Proof of university enrollment
Parents (below 65 years old):
Criminal record of the country of residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Criminal record of the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Primary applicants birth certificate issued less than 12 months ago, stamped by the Portuguese embassy or apostilled.
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the main applicant with a notarized signature
Proof of financial dependency from the main applicant
Parents (above 65 years old):
Criminal record of the country of residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Criminal record of the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Primary applicants birth certificate issued less than 12 months ago, stamped by the Portuguese embassy or apostilled;
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the primary applicant with a notarized signature
Parents in law (below 65 years old):
Criminal record of the country of residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Criminal record of the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Primary applicant’s Spouse birth certificate issued less than 12 months ago, stamped by the Portuguese embassy or apostilled
Primary applicants Marriage Certificate issued with less than 6 months, stamped in the Portuguese embassy or apostilled
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the primary applicant with a notarized signature
Proof of financial dependency from the primary applicant
Parents in Law (above 65 years old):
Criminal record of the country of residence for more than one year, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Criminal record of the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
Primary applicants Spouse birth certificate issued less than 12 months ago, stamped by the Portuguese embassy or apostilled
Primary applicants Marriage Certificate issued with less than 6 months, stamped in the Portuguese embassy or apostilled
Power of Attorney to the legal representative and copy of the lawyer’s license
Term of Responsibility signed by the primary applicant with a notarized signature
Also, Madalena will host a webinar to discuss this in more detail in a few days. Make sure to sign up here:
Many thanks @madalenamonteiro and Thomas @tkrunning. This still leaves a group of investors who had applied in 2021, and completed biometrics in the first half of 2023 (when biometrics schedules were opened), and did not sue.
See this post: Awaiting Final Approval (Stage 4) - #2153 by servettasman. The AIMA email does not say what happens with these investors, or how they are /will be processed.
The only statement referring to this group in the AIMA note is: "Caso o pedido de concessão de ARI já tenha sido formalizado, deverá desconsiderar a presente notificação. Vague at best.
@madalenamonteiro do you know if with this updated process, AIMA is intending to invite the whole family to the same appointment? Or do they need to approve the primary applicant before family members can be invited?
Fingers crossed it’s the former —the fact that families in most cases get split up for biometrics is one of the most pointless complications of this entire process up until now.
I don’t recall ever seeing this “Criminal record of the country of birth” requirement for spouses, adult children, parents, etc. We have never been asked for this (spouse in our case), even at our AIMA Lisbon Bios last December. Are you sure it’s required?
Criminal recordof the country of birth, issued less than 3 months ago, stamped at the Portuguese embassy or apostilled
When I applied in 2021 my lawyer asked for the following for my wife:
“Criminal record, translated into Portuguese and certified by the competent authority and duly legalized by the Portuguese Consulate (or with Apostille, if applicable) from the country of origin, and the country where the Applicant lives for more than one year, if different. This document must be issued within the three months before the submission of the process”
If I recall, it’s “or” for the primary applicant, but “and” for family members, due to a pecularity of language in the regulations.
Although I imagine a lot of AIMA officials don’t ask for it at biometrics if it’s not offered.
@madalenamonteiro , I would like to add my thanks for your post regarding the updated procedures.
I have now seen a couple of references to the fact that the requested documents must be translated into Portuguese or English. Can you please reconfirm if this is indeed the case, and that AIMA would now accept documents such as the US FBI background check and US marriage certificate in English? I understand the documents would still need to be apostilled.
Are the “residence permit fees” an additional fee related solely to this new process? We already paid an “initial application fee” (beyond our lawyer’s fees) when we first submitted in February 2023. Trying to figure out if this is something we would have paid anyway in order to get the residence permit, or if they’ve added another fee. Thanks!
How do you change your legal representation with AIMA? Do you have to have a legal representative or can documents and requests be sent directly to the applicant? I no longer want to work with the legal representative I used for the initial application
I’m still confused about the new requirements. When we submitted our application 18 months ago, all our documents were properly certified. Do we need to provide a new set of certified documents again? If so, how does this differ from applying from scratch?
How do you change your legal representation with AIMA?
Appoint a new lawyer, tell old lawyer to pass files over, new lawyer informs AIMA and new lawyer’s email entered into AIMA system ( that’s what I did)
Do you have to have a legal representative or can documents and requests be sent directly to the applicant?
At a guess, without legal representation you’d need to take uncertified documents to your AIMA appointment and pay the manual processing fee for them to be certified by AIMA ( i wouldn’t advise this and didn’t attempt this route)
Yes, we had to submit this (for the spouse). Got it done for the initial submission, then again for the biometrics. Hopefully we don’t have to get it done a 3rd time!
—the fact that families in most cases get split up for biometrics is one of the most pointless complications of this entire process up until now.