On last 18th May 2025, Portugal held national elections that significantly reshaped the country’s political landscape. The center-right parties emerged as the most voted forces, with the Democratic Alliance (AD) taking the lead though without an absolute majority. In contrast, the traditional left-wing parties, known for their more critical stance on the Golden Visa program, suffered a major electoral defeat.

During the election campaign period, the topic of Portuguese nationality law reform surfaced prominently, with proposals of changes aimed at tightening access to citizenship. This debate gained additional momentum in the wake of the recent decision by the European Court of Justice concerning Malta’s Citizenship by Investment (CBI) program, a ruling that seems to have influenced the political agenda in Portugal.

As a result, it is likely that discussions around reforming the nationality law will resurface in the upcoming legislative term. However, such changes require approval by a majority in Parliament, and as things stand, there is still considerable uncertainty regarding possible alliances between political forces, given their well-known differences on key policy matters.

The proposal raised during the election campaign pointed to several potential amendments: i) extending the minimum legal residence period from 5 to 10 years, ii) increasing physical stay requirements in Portugal, and iii) introducing stronger ties to the country as prerequisites for naturalization.

It is crucial to emphasize that this is merely the beginning of a public and political debate. No formal decisions have been taken, and if any changes are to be implemented, they will likely take months to be finalized. Although few details are available at this stage, we are confident that the fundamental legal principle of protecting the legitimate expectations of Golden Visa investors will be upheld.

Just as in past legislative reforms, we expect any change to include transitional provisions. In practice, this means that investors who have already initiated their Golden Visa application—i.e., submitted their process—should not be affected. Although the residency permit and citizenship processes are legally distinct, it is our firm belief that the rationale adopted by the Portuguese government will continue to recognize and protect the expectations upon which these investments were made.

At NSM Lawyers, we have already filed, with a very high success rate, hundreds of court cases against AIMA (Portugal’s immigration agency), in order to expedite biometric appointments, initial residence card issuances, and renewals. The judicial decisions we’ve seen consistently defend the legitimate expectations of investors. The courts have repeatedly affirmed that any obstruction to these rights may “undermine the exercise of fundamental rights, freedoms and guarantees formally recognized by the Portuguese Constitution and international law, creating a situation of instability, uncertainty and insecurity… which is clearly incompatible with human dignity.”

Therefore, while we acknowledge the high likelihood of nationality law reforms being debated in the next legislative term, we also believe that those who have already submitted their Golden Visa applications will be protected—either by the government or, if necessary, by the courts. This underscores a clear sense of last call: those who wish to secure the rights and benefits associated with the Golden Visa program, including the path to citizenship, should act swiftly.

We also strongly advise that investors begin the process of obtaining their Portuguese language certificate (A2 level) and take steps to establish meaningful ties to Portugal. Based on legal precedent and the government’s historical approach to legislative transitions, we are confident that the five-year residency requirement for citizenship—counted from the date of initial application submission—will remain in force for current applicants.

At NSM Lawyers, we are fully committed to defending the rights and expectations of our clients, offering deep legal expertise and unwavering representation in the face of any future change.