⚠️ Note: This is a developing topic. We will strive to keep this article updated with the latest developments as they unfold.

By now I’m sure you’ve already heard a lot about the proposed changes to the Portuguese Nationality Law that were presented in June.

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So why am I writing an article about this now?

Well, as we also saw in the case of the Mais Habitação law that made significant changes to the Golden Visa program in 2023, there are a lot of misunderstandings or plain misinformation floating around.

Plenty of news articles made it sound like the proposed changes had already passed parliament in June or even become law.

That’s not the case. Only the proposed amendments to the Foreigners Law were so far approved by parliament—but they were subsequently struck down by the Constitutional Court.

Separately, a new police unit inside the PSP was created to help with immigration and border control.

The proposed amendments to the Nationality Law—which are of more concern to current and prospective Golden Visa investors—were put on hold until the second half of September to allow additional input from stakeholders and constitutional experts.

The proposed amendments to the Nationality Law

These are the main proposals from the original draft law presented in early July:

  • Increased residence requirement for naturalization: 10 years for most applicants; 7 years for CPLP nationals. (Practical impact: doubles the citizenship wait for most Golden Visa holders.)
  • Clock starts ticking from the first residence card: The time towards citizenship eligibility to start at issuance of the first residence permit, no longer at the time of the initial application.
  • Separate integration test: While the Portuguese language requirement is set to remain at A2, the draft proposed adding a separate Portuguese culture/history and rights & duties knowledge test, plus a declaration of adherence to the democratic rule‑of‑law.
  • Jus soli tightened for newborns with foreign parents: A child born in Portugal to foreigners only gets nationality if at least one parent has at least three years of legal residence (currently one year) and the parents formally declare that the child should be Portuguese.
  • Loss of nationality (post‑naturalization): Courts may revoke nationality if, within 10 years of naturalization, the person is convicted of a serious crime with an effective prison sentence of at least five years.

The first two are of particular interest to Golden Visa holders and applicants, as—if they were passed as initially drafted—would significantly increase the time it takes to qualify for naturalization.

The practical impact would be even worse for those affected by the endless delays. For someone who applied in 2021 and just received their first residence card in 2025 after a nearly four-year delay would now be able to apply for citizenship in 2035 rather than in 2026. That’s an increase of a whopping nine years.

The third is also relevant as it would add an additional civics test to be eligible for naturalization.

Understandably, this proposal was met with significant pushback from both the political opposition, constitutional scholars and various stakeholders.

It is very likely that the proposal will undergo significant changes based on stakeholder input before being discussed again in late September.

Who, if anyone, will be grandfathered into the old rules?

In short, we don’t know.

The best case would be that anyone (Golden Visa investor or not) who already applied for residency before any new nationality law enters into effect would keep the original 5-year timeline to citizenship, counting from when the application was submitted and paid for.

The worst case would be that only those who have submitted their citizenship applications by the time a new nationality law takes effect will be protected.

My guess is that reality will be somewhere between these two extremes.

It’s possible (though in my view not likely) that there will be special exemptions for Golden Visa applicants. That was the case in the Foreigners Law amendments discussed earlier.

Personally, I think the best-case scenario I describe above is quite unlikely. At least I haven’t found any examples of other EU countries making similar accommodations when increasing their naturalization requirements. At most they have grandfathered those who already met the residency requirement at the time the law changed, even if they hadn’t yet applied.

That being said, Portugal’s legal and political reality is of course unique, so we cannot rule anything out based on what happened in other countries.

Another possibility is that the Socialist Party wins the next election and reverts most of the changes implemented during the current term.

Should you apply for Portugal’s Golden Visa today?

This is a question many people are asking themselves currently.

Unfortunately, I’ve seen too many examples of apparently shameless Golden Visa promoters making it sound like anyone applying for their ARI residence permit before any potential changes to the Nationality Law enter into force will be guaranteed a 5-year timeline to qualify for naturalization.

Granted, I’m not a lawyer, but my understanding is that this is not the case unless the law adopts specific transition clauses to this effect.

Keep in mind that the Golden Visa/ARI program is a residency-by-investment (RBI) program with the unique feature that you only need to spend an average of seven days in Portugal per year to maintain your legal residence.

Currently, the Nationality Law requires five years of legal residence to qualify for citizenship (not actual residence, unlike other countries offering a Golden Visa in Europe), but this is legally separate from any residence right granted by an ARI permit. We’ve been highlighting this difference in our Golden Visa guide for years.

With that being said, there may still be some people who should consider applying for a Golden Visa today.

First, it is possible that certain accommodations will be made for existing investors. While I think it’s unlikely that current investors are fully grandfathered into the five-year timeline, I think it’s somewhat more plausible that the time you wait for your first residence permit would still be counted if you apply before the new law enters into force.

The current government is generally very pro-Golden Visa, so hopefully they will come to their senses and realize that screwing over current investors isn’t a great way to attract new investment to the country.

So if you’re willing to spend a few thousand euros in upfront costs (for legal fees, etc) and choose a liquid investment (like an open-ended fund), you can always back out with minimal costs if the changes to the Nationality Law end up being unacceptable.

Second, if you are not in any particular hurry to qualify for citizenship, you may still consider applying now. However long the wait ends up being, you’ll at least secure your spot in line. This may be the case for someone who primarily wants a base in Portugal with the flexibility to spend as much or as little time in the country as they please.

If that sounds like you, but you’re planning to move to Portugal now, you could apply for e.g. a D7 (passive income) or D8 (remote worker) visa first—which currently have shorter processing times—then switch to a Golden Visa afterward.

But if you’re not willing to deal with the current uncertainty and the change to a seven or ten-year timeline for citizenship eligibility would be unacceptable, then I don’t think you should apply today.

Sure, you may miss out on potential transitional relief if it does materialize. But going through with an investment may not be worth the effort and expense you’ll put into a slight chance of better terms.

An alternative approach may be to line up the needed investment now—including onboarding, KYC, bank account opening, etc. Then if transitional measures are announced you could be ready to pull the trigger and submit your application before any cutoff.

Frequently Asked Questions (FAQs)

Do I need to maintain my investment until I qualify for citizenship?

No. If you apply for permanent residence (PR), you can liquidate your investment. You qualify for PR after five years of legal residence (meaning the wait time to receive the first permit does not count), and it also requires that you’ve obtained an A2 Portuguese language certificate.

What will happen if my currently dependent children don’t remain dependent (unmarried, in education, etc) until we qualify for citizenship?

With the proposed extension of the naturalization qualification timeline there is an understandable worry for many parents.

Again, one potential solution is to apply for permanent residence (PR) once you qualify. At this point, residence permits of all dependents will be considered independent of the main investor, so changes in age and life circumstances no longer impact their residence rights or citizenship eligibility.

Do we need to live in Portugal to apply for permanent residence (PR)?

With permanent residence permits becoming more relevant than previously if the Nationality Law is amended as currently drafted, you may wonder what strings are attached.

There are actually two residence permits available to ARI holders and their dependents.

They both share some benefits, such as letting you liquidate your investment and giving each family member an independent residence status. They are both permanent statuses (unless revoked), although the residence card needs to be renewed every five years.

Where they differ is in terms of costs and required time spent in Portugal.

The “normal” PR is only available to those who have made Portugal their primary home—spending seven days per year in the country won’t cut it. It is also markedly cheaper, only costing a couple hundred euros compared to the more than €8,000 price tag of the special PR for investment activity.

The conditions under which the permanent residence status can be revoked also differ—and this is the main benefit of the special ARI version of the permit.

The regular PR can be revoked if the holder is absent for more than 24 months in one go, or for more than 30 months in any 36-month period. (Note: This is independent of the five-year card renewal cycle.)

The special ARI version of the PR does not have this limitation, making it suitable for those who do not live in Portugal.

Cover image credit: Ricardo Rocha / Depositphotos