After several postponements and multiple amendments, the Portuguese Parliament has approved amendments to the Nationality Law, marking significant reforms in recent years. The new legal framework reshapes access to nationality through residency and introduces new obligations for applicants.

Although the law has been approved, the legislative process is not yet concluded. The text will be submitted to the President of the Republic, who may either promulgate it, veto it, or refer it to the Constitutional Court for review.

Given the absence of a transitional and grandfathering clauses, many legal scholars have raised constitutional concerns regarding the protection of applicants’ legitimate expectations.

At the same time, important progress has been achieved in the implementation of the Foreigner’s Law, particularly for Golden Visa holders and applicants, with the Portuguese Immigration Agency (AIMA) now actively clearing the appointment backlog for residence permits.

1. Nationality Law

The reform introduces stricter criteria for applicants pursuing citizenship through the residency route. Key updates include:

  • Longer minimum residence periods: 7 years for nationals of Portuguese-speaking countries and EU Member States; 10 years for all other nationalities (previously 5 years).
  • Cultural and civic knowledge requirements: Applicants must now demonstrate sufficient knowledge of the Portuguese language, culture, history, and national symbols, as well as of fundamental rights and duties and the political organisation of the State.
  • New ethical and legal obligations: A formal declaration of adherence to democratic principles is now mandatory.
  • Criminal and security restrictions: The disqualification threshold has been tightened, and a new ancillary penalty of loss of nationality has been introduced in the Criminal Code for serious crimes.
  • Residency period calculation: The qualifying period will now be counted from the issuance of the first residence permit, rather than the date of the initial residence application.

2. Impact on Golden Visa and Residency Applicants

These changes are particularly relevant for Golden Visa holders who have not yet applied for citizenship.

Applicants should note that, even under the new framework, access to nationality remains possible via the Permanent Residence by Investment, a five-year residence card that preserves all benefits of the Golden Visa scheme without new residency or investment requirements, according to the guidelines of AIMA.

We are assessing potential legal grounds to challenge the law should it enter into force without adequate transitional measures. We expect the President and the Constitutional Court to play a decisive role in moderating its final wording.

3. Foreigner’s Law and AIMA Developments

In parallel, there has been encouraging progress under the Foreigner’s Law, particularly regarding the AIMA biometric appointment backlog.

Following close coordination between the legal community and AIMA, the agency has begun clearing pending cases — a long-awaited development that directly benefits Golden Visa concession applicants.

As of this week:

  • Golden Visa applicants and their registered legal representatives have begun to receive notifications for biometric data collection appointments in Portugal.
  • These appointment notices are being released automatically and simultaneously.
  • Clients are advised to remain attentive to their inboxes (including spam folders), as notifications are expected to roll out over the weeks.

This marks a significant operational breakthrough, reflecting AIMA’s renewed commitment to streamline its processes and address delays that have affected many investors.

Final Note

The ongoing legislative process to amend the Nationality Law, while significant, are not intended to target Golden Visa investors but to address irregular immigration patterns and align Portugal’s legal framework with broader European trends.

At the same time, the Government has signalled its intention to streamline and enhance the Golden Visa regime through a separate legislative initiative — details of which are still awaited.