Why did my Golden Visa application status change to Awaiting Submission? (New Golden Visa process)

Residencies & citizenships Portugal Golden Visa đŸ‡”đŸ‡č
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I believe that the quoted above is your personal opinion.
Hence I am also allowed to share my opinion here.

You make it sound like AIMA is helpfully/cooperatively doing a favor to the investors. Indeed, it is unfortunately an opposite. Instead of just giving investors 3 choices of dates for biometric or simply just giving lawyers 10 days/2weeks to book the biometrics as they used to do, AIMA asked all investors to refresh the documents. Is it easier for the investors? Absolutely NO. So far, all investors obeyed the law, followed the rules
 Now all of sudden, all of them run around to prepare the documents just like the beginings. The only party which not followed the rule was AIMA. And you are saying " AIMA’s effort
". What effort exactly is AIMA doing? To my understanding, AIMA must respect their own written rule i.e. no matter what they will eventually have to give investors an appointment for biometric. Asking investors to refresh the documents will lead to investors’ time and cost involved. From what I see it, it is never considered as “an effort” because literally it is somewhat “irresponsible” considering how the investors have been treated by AIMA throughout many years. Dão com uma mão mas tiram com as duas.

The new refresh documents and new submission will lead to a new topic - When is the initial counted date for the citizenship? Old submission’s or new submission’s date?

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I asked our GV advisor today about this new (to me!) “Criminal record of the country of birth” requirement


She said it’s a relatively new development that’s crept in at AIMA - and for the Primary Applicant not just dependants
 and for D7/Manifestação de Interesse/etc. not just GVs. I can’t confirm this, but @madalenamonteiro maybe you can?

As we’ve completed Biometrics, I asked if this is now something we’re supposed to conjure up too. She looked at our receipt (that “Recibo comprovativo de pedido de Art 90/A or etc.” piece of paper AIMA gives you at Bios), and noted there’s nothing in the bottom half listing missing docs that we have 10 days to supply. So to her mind nothing stated to be missing = nothing more to provide.

@cj807 - I note above your wife was asked for this back in 2021. Maybe an abundance of caution back then, or typical SEF/AIMA randomness? :crazy_face:

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If I understand this new process correctly it’s definitely an improvement.

Old process (from biometrics onwards):

  1. You were suddenly assigned a biometrics date which in some cases were only days into the future, though usually at least a few weeks.
  2. You scrambled to get your documents refreshed before this appointment.
  3. If you didn’t manage to get them all refreshed, you would need to submit retrospectively, leading to further delays.
  4. Then wait for months at best or several years at worst for final approval and a request for payment.
  5. Then finally wait a couple of weeks to several months for the residence card.

New process:

  1. You refresh the documents in advance, with no assigned biometrics date yet (so no extreme rush), send the legalized originals to your lawyer who certifies that they are valid at the time of submission.
  2. Hopefully not too long after this you’ll receive an appointment date (some sources seem to say it’s now likely that the full family is invited together, though let’s see how this works in practice), 30-90 days into the future. No need to renew the documents at this stage.
  3. You attend biometrics, and you would only need to show any documents if they weren’t legalized and certified by your lawyer prior to submitting online. If you follow the procedure, no physical documents need to be presented. During the biometrics appointment you already receive approval and pay the final issuance fee.
  4. Then finally wait a couple of weeks to several months for the residence card.

And it gets even better when you consider that for new applicants, the new step 1 is really step 1 (meaning it’s the initial submission of their application). That means only getting documents once and AIMA will accept them still at biometrics, even if they have expired in the meantime.

It seems AIMA will hold a meeting with the immigration lawyer community on Thursday to clarify things, so my interpretation could soon be proven wrong. But at least how I interpret things at the moment it seems like a huge improvement.

Although I will grant that it would be better if you could select your appointment yourself 30-90 days into the future instead of just being assigned one. But I assume that at least while trying to catch up they do it like that for organizational reasons.

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@PTbound

This isn’t new - it’s been floating around for years. Here’s my understanding, although some of this is reading between the lines


The reason is that the criminal record requirement appears in two different articles of the regulations (Decreto Regulamentar n.Âș 84/2007 de 5 de Novembro).

https://www.pgdlisboa.pt/leis/lei_mostra_articulado.php?nid=940&tabela=leis&so_miolo=

Article 61(1)(e) covers the primary applicant:
“Informação sobre antecedentes criminais do paĂ­s de origem, salvo quando os pedidos sejam apresentados ao abrigo das alĂ­neas b), c), d) e j) do n.Âș 1 do artigo 122.Âș da Lei n.Âș 23/2007, de 4 de julho, na sua redação atual.”

You read this in conjunction with Article 42(c):
"A informação sobre antecedentes criminais do requerente em países terceiros é comprovada nos termos seguintes:
a) AtravĂ©s de consulta ao sistema de informação do registo criminal do paĂ­s de nacionalidade ou do paĂ­s de residĂȘncia onde reside hĂĄ mais de um ano, consoante os casos; ou
b) Quando nĂŁo seja possĂ­vel aceder Ă  informação nos termos previstos na alĂ­nea anterior, atravĂ©s de certificado de registo criminal do paĂ­s de nacionalidade ou do paĂ­s de residĂȘncia onde reside hĂĄ mais de um ano, consoante os casos."

Family members are not applicants; they are instead treated under the family reunification provisions. In particular, Article 67(1)(f):
“Informação sobre antecedentes criminais no país de nacionalidade do membro da família e no país em que este resida há mais de um ano.”

So there’s a discrepancy in the terms: “ou” in the case of the primary applicant, but “e” for family members. There are a number of subs on this site discussing the issue dating back to 2021 or earlier - search “country of origin” and the like.

It seems that SEF/AIMA officials may not have been consistent about this - people have reported different experiences about what has been asked for. It’s also possible that the interpretation may have changed over time.

A final wrinkle - AIMA uses the term “OR” in its own website, talking about family reunification. I don’t know why.

https://aima.gov.pt/pt/viver/reagrupamento-familiar-com-familiar-fora-de-territorio-nacional-art-98-o-n-o-1

Interested in further input from lawyers (I’m not one, obviously).

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It was never mandatory to submit all documents at the moment of doing the biometric. In fact, the most important thing is that AIMA/SEF collects the biometric. Documents were always allowed to submitted later. I did submit my documents 1 month later for my first card and my renew. So did all of my dependents.

Since it is a new process, we will see if AIMA keeps their words or not.
Point 3: On the day of biometric, if you need to show documents that were not legalized before, then how could you get the approval in the same day? For sure, AIMA will need some times to check/verify the authentication of the document and consequently you will most likely have to wait for approval. It is too good to be true if authentication of the documents can be verified in the same day. We all know that under Portugal’s bureaucracy if AIMA takes 3-4 weeks to approve, it is already a huge success.
Point 4: Due to the mentioned matter in point 3, it is unclear how things will develop at this step.
And as I said earlier, it leads to Step 5: a bigger problem - What is the initial counted date for citizenship? Old submission’s or new submission’s date?..

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I haven’t seen anything to this effect, nor do we have any reason to think so. This isn’t a new application, just a refresh of documents.

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On another point, as primary application, do I need criminal record only for country of residence or country of nationality or for both?

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Same confusion for me as well

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Primary applicant - country of residence only.

Dependants - country of residence AND country of birth.

I had a situation where I needed to obtain a country of birth criminal check for one of my dependants, with them being neither a citizen nor ever a resident of that country. Found some local agency who helped to deal with it, fully remote (including apostille).

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I asked my lawyer about this and they said thy had followed the direction of AIMA They sent a screenshot , taken today,of my GV screen that showed “awaiting analisys” instead of “awaiting submission” Can that be all that needs to be done?

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Which year did you apply originally?

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@madalenamonteiro many thanks for the summary!

A question about the fees since these now need to be paid in person at biometrics:

If the primary applicant is already converted from GV to D2 before dependents are approved, do the dependents also pay the reduced D2 for their first card, or do they pay full GV fee for first card and D2 fee only after renewal?

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We’ll find out post-15th January how long the 30-90 day lead time lasts, but one of my concerns is getting the Schengen visa in time, for those of us that need it. In my city, there’s a 1-2 month wait time for appointments + 1 month for their processing, so there’s no way I can get a visa in time. I’ll have to fly to a different city and cut that down, but it’s still going to be take a month or so, cutting it way too tight. Does AIMA have any solution for this?

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My advice is to get a letter from your lawyers saying you are likely to have biometrics sometime in the next 6 months (even though you don’t have an appointment yet) and use that letter together with all your proof of GV application to request a visa with 6 month validity window.

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100 % agree

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One other alternate solution is getting a schengen appointment now itself and re-scheduling it for the countries which allow to do so. Some allow twice but money is lost if the appointment is not utilized.

If AIMA keeps it’s word for clearing the backlog in 1st half, at max 2 different appointments need to be secured and rescheduled till there is confirmation for individual investors.

The solution offered by you works but u are at mercy of the embassy staff on counter and in my personal experience not everybody is equally helpful.

I personally plan to do both simultaneously
what a waste of money but then AIMA hasnt left any choice.

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Thanks, that’s good advice, and something I’ve suggested to my lawyers. The real issue though is that we don’t get visas with 6 month windows, so it’s a bit of a stretch without official communication from AIMA or the Portugal government itself. The last time I visited Portugal in July 2024 for 14 days, I was given a window of only 17 days. Got grilled by the immigration officer in Germany!

I’m thinking about looking into countries which give you the usual 6-month validity visa, and just applying as a holiday. But ideally, AIMA should have some provision for this.

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In my case, well sharing this I feel even more frustrated and embarrassed but anticipating the situation i applied for multiple entry visa in december end since i used to have one prior to covid but now I got a single entry visa against all confirmed and paid arrangements in the month of march.So, if i dont get an appointment in March, i am royally 
well let us leave it at that. So dont bank on multiple entry.

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Well the official communication does say that if you can’t attend the biometric, they will reschedule for second half of 2025.

“You didn’t give me a visa to attend” seems like an ironclad excuse for not attending.

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What did officers in Germany do to you?
You had 17 days in your visa and you used 14 days. Then, what was wrong with it?