SEF - or, Serviço de Estrangeiros e Fronteiras - Portugal’s immigration and borders service has become somewhat of a hot topic for Golden Visa applicants. Specifically regarding the almost impossible task of getting hold of an appointment with them of late.
We know many applicants are a bit frustrated and anxiously waiting for an appointment spot to open up so that they can finally get their family’s residence permits approved, particularly when traveling is so on-and-off these days with COVID.
And so, we think it’s time we wrote an article about this — not because we are disgruntled foreigners who need a soapbox moment, but because we know so many people are faced with this problem, Golden visa or not. So, we thought it would be helpful to sum up the main points of this dilemma, provide some tips and advice, and hopefully give you some peace of mind.
2022 update: Things are looking optimistic as SEF has made some changes that will hopefully make the process a whole lot fairer. From now on, SEF will chronologically issue a notification when the investor is pre-approved and can schedule their biometrics. The appointment portal will not allow you (or your lawyer) to book an appointment until this has been received. You will then have 10 days to select an appointment in an allocated month.
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What exactly is going on?
In short, there are large-scale delays when getting an appointment with SEF. This has become a huge problem for, but not limited to, Golden Visa applicants awaiting their mandatory biometrics. According to SEF, as reported by ‘The Portugal News”, the delays are due to the pandemic situation and security measures that SEF had to adopt, meaning that a number of services had to be reduced.
At the moment SEF has not released any new appointments since March 2021 (covering the period until October 2021).
It’s also worth noting that SEF has gone on several strikes throughout 2020 and 2021, and while these strikes have primarily affected airport queuing and border traffic, there have also been some cases where it has led to a freeze on new appointment registrations as well.
However, there are dozens of canceled appointments showing up in the booking calendar most days—but these can be very challenging to snatch, typically only lasting in SEF’s booking system for at best a couple of minutes (often just a few seconds) before they get booked up. Also, many are for the next few days, making it hard to actually take advantage of them if you’re not already in Portugal.
We’ve also heard from applicants who have completed their biometrics, and they have informed us that the waiting time to receive the residence card from certain SEF offices can take upwards of 6 months. Still, other offices process these in three months or less. In general, it pays to avoid the Lisbon office and rather do your biometrics at a smaller office.
Even if SEF were to open a large number of appointment slots suddenly, there is still concern that these will not be around very long (again, only a few minutes).
What makes things particularly challenging is the fact that many applicants do not have access to the SEF portal themself, but rather their lawyer does. Considering just how time-sensitive it is when an appointment opens up, it leaves many no option but to just trust their lawyer to be diligent on their behalf. Some law firms likely have either employed paralegals to sit and refresh the SEF booking page around the clock or possibly, they may even be using a script to monitor the calendar, alerting them when any new slots open up.
Furthermore, the way SEF’s website is currently set up means that you can’t view all appointments at once, but instead, you have to check each branch’s calendar individually, making it almost humanly impossible to identify and book so many appointments that fast.
You can guarantee that as soon as new slots appear, those lawyers who either have an army of paralegals or access to technical expertise will book as many slots as possible for their clients — making it sort of a ‘battle of the most diligent (and perhaps tech-savvy) lawyer’.
One of the reasons cited by SEF as a contributor to the problem was that many appointments have gone unused, with people not showing up. This is likely the result of some law firms booking up more appointments than they need and taking unfair advantage of the flawed registration system.
Is everyone impacted equally?
Most definitely not. We’ve heard of people being able to get an appointment in just a few weeks and people who have waited more than a year for a slot. It all depends on the dedication/skills of your lawyer as well as your own flexibility for travel. For D7 visa applicants, it is somewhat easier, as appointments are scheduled as soon as the visa has been pre-approved, but for Golden Visa applicants, it is first-come-first-serve, with no consideration for who has been waiting for the longest or who has received pre-approval.
Another concern is travel restrictions and those who need a Schengen visa to come to Portugal. Appointment slot times are very arbitrary and could mean having to fly to Portugal with as little as a week’s notice or else face the risk of waiting months and months. If you need a Schengen visa to enter, this process could take much longer and make it impossible to get to Portugal on time. With Covid, as we all know, traveling is difficult enough as it is.
One more concern is for people who are trying to bring their family along as part of their investment visa. The rules state that you can bring your family along (spouse and children), but your children have to either be under 18 or enrolled in studies and supported by you at the time the visa is issued. Not only do those with families need to worry about scheduling multiple appointments, but considering the huge uncertainty around how long the whole process will take before the residence card is finally issued, it could mean that by the time everything is complete, your children will no longer be eligible to move with you, unless they enroll in studies or put their current studies on hold.
What can SEF do to fix things?
We know that it is not easy to make demands without a clear insider perspective, but we do have a few things on our wishlist that would make the whole process smoother and more efficient:
1. Be more transparent—apart from a few public comments on the situation, very little has been said from SEF as to how severe the situation is. We think it would be good if applicants had a bit more transparency as to what is causing the hold-up and what is being done about it.
2. Make a priority queue—the current registration site is poorly made, where it is easy to manipulate the site. They don’t even use simple website security features like CAPTCHA’s, meaning that anyone with some scripting knowledge could easily take advantage. A priority queue would allow those who have been waiting for the longest an extra advantage to book new appointments, getting rid of the first-come-first-serve approach.
3. Automatically give out appointments when applicants are pre-approved—This is already done for the D7 visa, so it should be easy to implement. Considering the amount of money that people invest into Portugal with this program, it deserves a similar process.
4. Allow biometrics to be done remotely at embassies instead of in-person—other kinds of bureaucracy can be done at embassies and consulates, so it would significantly improve upon SEF’s capabilities if this was allowed. An alternative is to deal with it like the Greek Golden Visa, where only the main applicant needs biometrics to get the initial permit, and the rest of the family can be done at a later stage.
What does it mean for your application?
If you are worried about the 2022 Golden Visa changes, the delays will not affect your eligibility here as long as you submit your application before the deadline. Also, after you have received pre-approval, you are already ok to move to Portugal while you wait to complete your biometrics and receive your residency card. Although, the time spent in Portugal before this will not count towards the time needed to acquire permanent residency or citizenship.
In other words, the delays don’t affect your ability to complete the visa application, but rather, they do have the potential to increase the overall time it takes to gain permanent residency or citizenship.
How can you still score a biometrics appointment without delay?
It could be described as a lottery in many regards, but you can still employ a bit of strategy to get an appointment.
If you are relying on a lawyer to book an appointment on your behalf, the first thing you should do is make sure they are aware of the situation regarding the trickery that some larger firms may be partaking in, and also maybe find out their current strategy for getting appointments.
Those who are able to travel to Portugal for a couple of weeks at the moment can let their lawyer know their plans and ask them to be on the lookout for last-minute cancellations. These are often for the next day or two, so you’d only really be able to take advantage if you’re already in the country.
Second, we do, in fact, have an active forum thread on this topic on Nomad Gate, which could be of interest. Many other readers are experiencing getting an appointment, their status, how long they have been waiting. Crucially, some people may alert the group if slots are open or if they are about to cancel an appointment that they have booked themself. It’s definitely worth keeping an eye on it if you are getting a little bit desperate for a slot.
While beggars can’t be choosers, if you do get lucky enough to come across multiple appointments at different branches, it may be wise to avoid appointments in Lisbon, as the processing time for the cards is notably longer. Getting an appointment in Coimbra, for example will significantly reduce your wait.
Is there light at the end of the tunnel?
We believe there is optimism to be found indeed, as most importantly, SEF is aware that there is a problem, and they are working on making some improvements. The only concern is that we have no idea as of yet when these improvements will be implemented and how fast we can expect things to improve once they are.
The government has announced that it plans to reorganize SEF and intends to create a new entity that deals solely with the bureaucratic side of things, while border patrol and other operative functions will be the responsibility of the judicial police and the national guard.
There is also the possibility that SEF will make the process for Golden Visa applicants similar to D7 visas (i.e., automatically booking an appointment based on pre-approval). They also recently started to schedule biometrics appointments for work visa applicants by calling them in the order they applied for the visa rather than letting them book online. It may be that they will apply a similar process for Golden Visa applicants in short order. The fact that they haven’t released any new appointments into the online booking system past October may point to this being a possibility.
So far, they have also alleviated some pressure by allowing applicants the possibility of booking appointments at any of their branches. Prior to this, applicants had to book appointments at the branch in the same region in which they had acquired their investment property. Since a large majority of applicants are investing in the Lisbon metropolitan area, this change should have helped reduce the appointment backlog significantly. Our only hope now is that they will find some way to allow applicants to do it through their national embassy instead of flying to Portugal.
If there is one thing to take from this article, it is the fact that SEF knows there are flaws in the system and that most of the chaos has been the result of the Covid pandemic and a lack of staff. While things may not be great at the moment, there is cautious optimism that things will improve at some point in the future.
As we all know, the Golden Visa program has been very successful for Portugal, and it is in their interest to keep the foreign investment coming. So hopefully, these new changes will come into place and will be able to improve the quality and pace. In the meantime, listen to your lawyer’s advice, join our community forum, and we will keep up to date with all the latest developments.
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