This is true even inside the schengen area, only valid in PT territory. One can enter and exit PT ports only with an expired card within the 6 months grace period when the application for a renewal is requested. PT is more forgiving interms of expired cards, so we dont have to panic.
Just handed it over and they did their job. They commented as to what they were doing because of the expired card, and I agreed with them 
It was at FNC.
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I am not quite sure if you disagree with me on something, but FWIW let me quote the ultimate source again:
Yes, it is a subtle difference. The right of residence doesn’t expire, but the card has expired. So you can’t use it for the next six months to say, open a bank account, get a transit pass, etc. But you can stay legally in the country for the six months, after which, you are overstaying and dead for the future.
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My husband had a renewal in September and still hasn’t received his card. Has anyone else with a September renewal received their card?
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Mine renewal appointment was in late September 2025. No card yet.
mid-May appointment. Still no card. Feel like pulling out my hair.
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Purely speculation, but my guess is that AIMA has been instructed to drag its feet until the new law is passed. AIMA doesn’t even want biometrics for renewals so there is no issue with security, and with dependents there is no validation of the investment, so the review process of submitted documents should take 15 minutes.
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Overly optimistic. Just say “AIMA has been instructed to drag its feet”, it’s cleaner, and won’t create false hope of things speeding up in future.
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Same here : >
I have recently received an email from our law firm suggesting that we can go ahead with an early citizenship application submission, even though our 5-year date is mid-September. Here is their legal argument:
In practical terms, to clarify: the Constitutional Court states that the fact that an applicant began a residence process in 2020, 2021, 2022, 2023, and up to the date on which the new version of the Nationality Law is amended and published means, under Article 7(4) of the draft law, that he is allowed to submit the nationality process under Article 6 as it is currently in force. In other words, the applicant may rely on the requirement of five years of legal residency (along, obviously, with the personal documents and proof of sufficient knowledge of the Portuguese language), since the applicant had already begun the constitutive fact for the nationality process - namely, obtaining the residence permit (Golden Visa) — before the new Nationality Law entered into force and the decisive moment is not the submission date, but the decision date.
Apologies if this is posted on the wrong thread. I am typically late to the party. 
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What is your law firm?
Yes, I did a September renewal and received my card in December. I mentioned the details in an earlier post on this thread.
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I have received the same email and we may have the same lawyers. But to be honest, I have read it three times and have not understood it
Can you please update here again if you get more inputs and/or how your decision making is going?
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If the key requirement to being able to naturalize under the old law is this “constitutive fact of obtaining a residence permit before the new law entered into force”, then why is it important to submit the application early? Surely a submission after having the full five years is equivalent.
I find it hard to understand how the submission of a knowingly-invalid application has any legal effect.
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The new law (the draft of it) was going to specify that only the pending applications at the time of its entry into force would be treated under the old law. That was deemed constitutional and therefore was not challenged (of course).
However then the new law (the draft of it) was further clarifying that the decision on such applications would be dependent on the completion of the requirements as of the date of submission, which was found both unconstitutional and internally contradictory within the auspices of the same law. TC further specified that the date of submission and the date of decision are two separate dates and cannot be merged into one for the purposes of the law.
As a very basic practical example - today under the current law and regs, if IRN finds some document lacking or missing, they would request the applicant to re-submit. And later when they come to make their final decision, they consider the updated pack as of the date of decision. The new law was going to revert this, and force IRN to consider the pack as of the date of submission, which is both physically impossible and furthermore internally contradictory as the new law was referring to the old law but at the same time making it physically impossible to apply the old law in some scenarios.
Hope this is much more clear now 
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This was my thought exactly.
I’m afraid I’m not following the “consider the pack as of the date of submission”, so let’s use some fake dates.
Let’s say I fulfill my five years of residency on January 1, submit my application on February 1, but without the complete criminal records history. The Parliament change the law to require 10 years of residency on March 1.
When I complete the missing criminal records on April 1, what would they do, and what would the new law have made them do differently?
…
In the example above, the argument would be that because I actually did fulfill all requirements before the law change, my case should follow the old law. I was only missing some documentary proof of what was actually true (i.e., I’m not a criminal) on the day of submission.
But the “early submission” is different, because I have not actually fulfilled all the requirements. If the IRN acted on it the next day, the case would be rejected because I don’t have the five years! So why should such an application grant me any legal benefits?
(Taken to extreme, if somebody applies for citizenship the day after receiving a residence permit, why should that application date have any legal meaning?)
Got it on the third reading.
So what you’re saying is that the data of submission now (based on the TC decision and current draft law) is expected to grandfather the applicants based on the date of submission as long as their application is complete and all requirements are satisfied by the date of decision?
If so, how long has recently been the average lag time from the date of submission to the date of decision? Presumably not the full 2-3 years from application to date of grant, but some shorter time interval, right?
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Second renewal appointment completed this week, finally. Now the wait for a new card begins …
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