Legal Update – Portugal Golden Visa – July 2025

Table of Contents

I wanted to provide an update following the government’s meeting with AIMA’s Golden Visa team. Here’s what you need to know:

1. A Fresh, Fully Digital System Coming in January 2026

AIMA has awarded a contract for a brand-new application portal. From early next year, new applicants will be able to submit everything online—forms, payments, even biometric scheduling—streamlining what’s now a multi-step, partly paper-based process.

2. Legacy Cases Stay on the Current Platform

To avoid data-migration headaches, ongoing and renewal applications will remain on the existing system. Importantly, AIMA plans to clear all renewal backlogs by October 15, 2025, and resolve pending concessions by December 31, 2025.

3. Behind-the-Scenes Efficiency Gains

Although you might not see it immediately, significant back-office optimizations are underway. These improvements will translate into faster processing in the coming weeks.

4. Queue Management & Court Rulings

  • Standard Processing: Files are still handled chronologically by DUC payment date.
  • Exceptions: Cases with favorable court judgments or a small number of “pilot” files under new internal rules move ahead of the queue.
  • Court Filings: Positive decisions now require proof of actual residence in Portugal. AIMA is still working through 2024 court cases due to the volume.

5. Re-Submission Rollout

Once AIMA publishes the list of re-submitted dossiers, they will send out appointment notifications in order of re-submission. Expect September 2025 to mark a turning point. New criminal-record certificates won’t be requested unless an internal review flags an issue.

6. Staffing & Internal Guidance

AIMA has bolstered its legal team and issued fresh internal guidelines to ensure uniform treatment of renewal versus concession applications.

7. What’s New in the Renewal Process

  • For now, only principal investors can apply on the new form; family-member renewals will follow later.
  • Your appointment notice will specify whether you must appear in person or can be represented by counsel.
  • Full documentation and proof of the minimum-stay requirement remain mandatory.
  • Renewals of now-extinct investment routes incur the standard fee (not the Golden Visa rate) but still enjoy the 14-day minimum-stay benefit.

8. Family Reunification & Permanent Residency

  • Family-member permits only proceed once the principal’s application is formally approved.
  • Permanent residence post-GV no longer requires holding the original investment. AIMA will soon issue a formal clarification on the 0- versus 14-day stay rule.

9. Technical Glitches & How to Report Them

If your DUC payment isn’t reflecting or your file won’t reopen, please have your lawyer compile all issues into a single email. Limit follow-up requests to once a month to avoid overloading the system.

10. No Penalties for Waiting

Holding proof of submission or a scheduled appointment protects you from fines or “blacklisting” during the waiting period.

11. Legislative Changes on the Horizon

  • Immigration Law Amendments: Final text pending presidential sign-off and possible Constitutional Court review; applies only to new cases.
  • Citizenship Law Updates: Delayed until late September for stakeholder feedback.
  • Golden Visa Framework Review: Slated to begin after summer, aiming to improve program efficiency.

In Closing

Although the day-to-day pace may feel the same, substantial improvements are in progress—and you will see them soon. AIMA’s team is working extra hours to clear the backlog, but they rely on all of us to minimize exceptions: avoid incomplete filings, redundant court cases, or repeated emails on the same point. Every interruption pulls resources away from routine processing.

Thank you for your patience and cooperation. We share your goal of wrapping up these delays—ideally before Christmas 2025—and will keep pushing until that happens. As always, feel free to reach out if you have any questions or need assistance.

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