Portugal’s Golden Visa and citizenship framework has changed significantly, with property-based Golden Visa options already removed, tax regimes narrowed, and new citizenship timelines now enforceable for current and future applicants.
Portugal scrapped the property investment route for Golden Visa applicants in 2023. The program now relies on other investment categories, including fund investments and cultural contributions, which have recently become more common.
Tax regimes for people relocating to Portugal have also become more restricted and now apply only in more specific situations.
New citizenship timelines
New citizenship rules entered the legal system on 19 May after approval and signature by the president.
For Golden Visa applicants, the main change is a longer timeline before naturalization:
- 7 years for nationals of Portuguese-speaking countries and citizens of the European Union;
- 10 years for all other nationalities.
The new rules apply immediately. According to the transcript, there is no grandfathering and no transitional regime.
Citizenship clock now tied to residence permit issuance
Before the change, the citizenship timeline was understood to start from the date the Golden Visa application was submitted. This mattered because Portugal’s Golden Visa process has experienced major delays, so time spent waiting for approval still counted toward citizenship.
Under the new rules, the citizenship clock is expected to start only when the residence permit is issued.
However, the transcript notes uncertainty on this point. The new law is described as not fully precise, and there may be disputes over exactly how the clock should be counted in practice.
New culture and history requirement
The new law also introduces a requirement connected to knowledge of Portuguese culture and history.
A new regulation of the citizenship law is expected to define the test within 90 days. The transcript notes uncertainty over whether the government will meet that timeline, as previous updates to citizenship regulations have taken around one year to one and a half years.
The wording is described as vague, especially regarding what “Portuguese culture” will mean in practice.
Portuguese language requirement
The Portuguese language requirement remains the same.
Applicants must either:
- pass an A2-level Portuguese test; or
- attend a 150-hour Portuguese course that does not require a test.
This applies to both pending and new applications.
Impact on current Golden Visa applicants
The changes come on top of existing delays in Portugal’s Golden Visa system.
The transcript refers to extreme cases where residence permit delays may reach six years without cards being issued. These delays create practical problems for applicants whose citizenship timeline may now be pushed further into the future.
Complicated cases include:
- minors aging while families wait for residence permits;
- investors passing away before receiving residence permits;
- applicants needing to continue renewing Golden Visas for longer than expected;
- investments remaining locked for a longer period.
Renewals are described as costing approximately €3,700 per person, creating additional financial burden for applicants affected by the longer timeline.
Planned legal challenges
A group of law firms has organized a collective litigation strategy against the Portuguese state. The consortium began with four founding firms and has grown to eight law firms, with more reportedly joining.
The initiative has attracted strong interest, with more than 1,000 powers of attorney already gathered for the planned lawsuit.
The strategy is described as holistic, because applicants’ situations differ and may require different legal arguments.
Public advocacy
One part of the strategy involves public advocacy in Portugal.
The firms plan to contribute articles and opinion pieces to Portuguese media. The goal is to address what they describe as public misunderstanding about Golden Visa applicants and the practical impact of the legal changes on individuals and families.
Rights recognition lawsuit
A collective lawsuit is planned to seek recognition and clarification of rights.
Issues expected to be raised include:
- how the citizenship clock should start counting;
- whether the new rules can affect applicants already in the system;
- permanent residency timelines;
- legal uncertainty caused by the new framework.
The transcript says the law is not fully clear on how certain timing rules should be applied, even though the expectation is that public administration may count from residence permit issuance.
Ombudsman complaint
A complaint is also planned with the Portuguese Ombudsman.
The Ombudsman is described as a public entity with institutional powers involving other state bodies. It can also request a constitutional review of a law after it becomes enforceable.
This would not be a preventive constitutional review, but a challenge after the law is already in effect.
Investment treaty arbitration
The strategy also includes possible use of international bilateral investment treaties.
The transcript says these treaties may impose obligations on states regarding investment stability and protection of legitimate expectations. The plan is to activate claims against Portugal through arbitration centers in Washington.
Individual damages lawsuits
Separate individual lawsuits are also planned for damages caused by the changes.
Potential damages include:
- additional Golden Visa renewal costs;
- longer periods during which investments must remain locked;
- financial impact from increased timelines;
- other costs suffered by applicants already in the program.
These claims would be brought as civil liability actions against the Portuguese state.
Human rights arguments
The strategy also refers to possible proceedings before human rights courts.
Portugal is part of the European Convention on Human Rights, and the transcript argues that the state has obligations to treat people with dignity and exercise administrative power efficiently.
Practical implications
The changes make Portugal’s Golden Visa route less predictable for applicants who entered the program expecting a five-year citizenship timeline.
The key practical issues are:
- longer naturalization timelines;
- no grandfathering or transitional regime;
- uncertainty over when the citizenship clock starts;
- pending regulations for the culture and history requirement;
- continued administrative delays;
- additional renewal and investment-lockup costs;
- possible litigation over rights, damages, constitutionality, investment protection, and human rights.
The main takeaway is that Portugal’s Golden Visa applicants now face a changed legal environment. Anyone already in the system must assess their position under the new timelines, the residence permit issuance rule, renewal costs, and the possibility of legal action.
