Portugal Citizenship Law 2025: What New 10-Year Rules Mean for Golden Visa & Fund Investors

Overview: What Changed and Why Investors Care

On 28 October 2025, the Portuguese Parliament approved a reform to the Citizenship Law that extends the standard residence requirement to:

• 10 years for most applicants;
• 7 years for citizens of CPLP countries and EU nationals.

This reform does not abolish the Portugal Golden Visa or other residency permits. Instead, it fundamentally changes the path to Portuguese citizenship and EU passports for those planning around a five-year horizon.

For investors using CMVM-regulated investment funds or real assets as a basis for long-term EU mobility, this is not a reason to panic—but it is a reason to recalibrate strategy, timelines and family planning.

Is the Law in Force Yet? The President & Constitutional Court Timeline

As of 12 November 2025, the law is not yet fully in force. On 11 November, the decree left the Assembly of the Republic and was formally sent to the President of the Republic for review.

Under the Constitution, the President has up to 20 days to:

• Promulgate the law (approve it);
• Veto it and return it to Parliament with comments; or
• Request a constitutional review from the Constitutional Court.

If the President refers the law to the Constitutional Court, that step must occur within 8 days of reception. Once seized, the Court has up to 25 days to issue its decision.

Several legal scholars have highlighted potential concerns, particularly the absence of a clear transitional / “grandfather” clause for people already in the pipeline. As a result, a Constitutional Court review is seen by many observers as more likely than not.

Until the legislative process is completed, the current citizenship law continues to apply to applications already filed under existing rules—subject to how the final law and regulations define transitional arrangements.

Permanent Residency After 5 Years: The “Plan B” for Investors

One of the most under-appreciated features of Portugal’s legal framework is that Permanent Residency remains available after 5 years, independently of the citizenship debate.

After five years of legal residence under the Golden Visa, investors generally have two main Permanent Residency (PR) routes:

1. Regular Permanent Residency (general regime)
   • Lower fees.
   • Typically requires evidence of effective residence in Portugal.
   • Each family member holds an independent PR card.
2. Investment Permanent Residency (for Golden Visa holders)
   • Higher fees, but designed for investors with limited physical stay.
   • Waives the classical “full-time resident” expectations tied to PR.
   • Each family member again holds an independent PR permit.

Assuming you opt for the investment PR route:

• The PR card is typically valid for 5 years, renewable.
• A2-level Portuguese is required, but there is no new investment obligation and no full-time residence requirement.
• You can, in principle, divest from your qualifying investment after securing PR, while maintaining your residency status.

For many families, this structure supports a two-step strategy: Golden Visa → Permanent Residency → optional citizenship over a longer time frame.

For a broader context on citizenship and EU mobility beyond the Golden Visa, see also our analysis: “Portuguese Citizenship, Legacy & EU Mobility 2025”.

What to Expect Next in 2025-2026

The next steps in the legislative and administrative process include:

• Presidential review within the constitutional deadline;
• Possible Constitutional Court review, focusing on transitional rules and potential retroactivity issues;
• Publication of secondary regulation defining the civic test, documentation, and detailed procedures;
• Operational implementation by AIMA and the civil registry offices.

In parallel, there are important administrative moves already in motion:

• AIMA has accelerated long-delayed biometric appointments for Golden Visa applicants.
• Many principal applicants who had been waiting since 2022-2025 are now being scheduled in the first half of 2026.
• For now, dependants are often not being scheduled at the same time—something that investors and advisors are tracking closely.

Processing times and experiences still vary significantly from case to case. For investors, this reinforces the need for documented compliance and realistic timelines, rather than marketing-driven expectations.