You’ve likely seen the headlines about Portugal’s nationality reform. After a busy summer of rumours and half-drafts, we now have a concrete counterproposal from the Socialist Party dated 17 October 2025. It matters because it directly affects timelines to citizenship and, crucially, whether current Golden Visa investors would face any retroactive changes.
I’ve tried to summarise the key points below in plain English, focused only on what matters to GV investors: timelines, protections, and what to do before year-end. If the five-year path is important to you or your family, this is a very important read.
Executive Summary
- No retroactive shock for current GV investors under the Socialist Party (PS) amendments filed 17 October 2025: existing holders/applicants are expressly protected.
- Timelines: Proposed 7 years to naturalise for most third-country nationals; 5 years for EU and CPLP nationals. The government’s earlier idea of 10 years is off the table in the PS version.
- Grandfathering window: If you already hold or apply for residence before 1 January 2026, you can still complete citizenship on the 5-year clock, provided you file by 31 December 2026.
- Delay protection preserved: Time can count from the end of the 90-working-day decision deadline (once the permit is subsequently granted), shielding applicants from administrative backlogs.
Outlook: Reform still requires negotiation and a strong parliamentary majority; presidential review is likely. Timelines could slip into early 2026.
Bottom line for investors: If you want a five-year path, file your residence application before 1 January 2026. If you miss that cut-off, expect 7 years, not 10.
What’s Changing — and What Isn’t
- Current GV holders/applicants: shielded by transitional rules — keep the 5-year path if you file by 31 December 2026.
- Administrative delays: Your citizenship “clock” can start after the 90 working days the state has to decide your residence file (provided it is eventually approved). This prevents lost years due to backlog.
- Revocation & penalties: The PS text drops aggressive revocation ideas and keeps the existing bar for serious criminal convictions (≥3 years’ sentence).
- Civic integration: Language and civic-knowledge requirements will tighten, but these are manageable for long-term residents.
What the PS Removes from the Government’s June Draft
- No 10-year rule
- No delay-driven losses (clock would not reset to the date of residence card issuance).
- No unequal “probationary” revocations that would create two classes of citizens.
Protections That Matter to Golden Visa Investors
Grandfathering (Article 5 provisions):
If you already meet current eligibility when the new law enters into force, you have until 31 December 2026 to file under the current 5-year regime.
If you hold or have applied for residence when the law starts, your time keeps counting under the old rules.
Delay Counting (Article 15 concept):
The 90-working-day rule remains a safety net. Backlogs at AIMA shouldn’t add hidden years to your journey.
Investors with GV files in the system retain predictability, and newcomers still have a clear deadline to secure the five-year track.
Legislative Path & Timing Risks
- Votes required: Nationality law is an organic law, needing 116/230 MPs — cross-party support is essential.
- Process: Three committee readings, then a plenary vote; the President can request Constitutional Court review before promulgation.
- Target date: The PS text sets 1 January 2026 for entry into force. Any slippage in committee, plenary, or presidential review could push implementation into early 2026.
Investor takeaway: Treat 31 December 2025 as your operational deadline to lodge a residence application if you want the five-year rule.
Strategy for Investors
- If you have not applied yet:
File GV residence before 1 January 2026 to lock the 5-year path and access transitional protections.
Ensure your dossier is clean: source-of-funds, police clearances, apostilles, and investment compliance.
- If you’re already a GV holder/applicant:
Stay the course. Your time should continue counting under the current calculation method.
Keep all renewals timely; maintain continuous legal residence without gaps.
- Plan for both outcomes:
If reforms slip into early 2026, you may gain extra days to file — but don’t bank on it.
If you miss the cut-off, expect a 7-year naturalisation plan (still with the option of Permanent Residency after 5 years, which removes investment and relocation obligations).
- Documentation & language:
Start Portuguese language prep early; retain records proving residence continuity and compliance.
My View
The PS amendments materially de-risk retroactivity and preserve the investment case for Portugal. The decisive variable for new entrants is timing. If the five-year path is mission-critical, act before 1 January 2026. Otherwise, budget for a 7-year horizon and weight the PR option at year five.
Not legal advice. This briefing reflects the PS amendments tabled 17 October 2025 and may evolve with committee changes, plenary votes, or presidential review.
Next Steps
If you want a tailored plan (fast-track file readiness, counsel coordination, or investment selection):
• Book a consultation with our office
• We’ll provide a document readiness checklist, introduce counsel where needed, and coordinate submission timelines to meet your goals.
In short: the five-year path is protected for existing holders and those who file before 1 January 2026. If you’re still weighing Portugal, treat 31 December 2025 as your operational deadline to lock the current route. If you prefer to wait, plan on a seven-year naturalisation horizon, with Permanent Residency at year five still offering strong rights without ongoing investment or relocation.
If you’d like a quick plan tailored to your file — document checklist, counsel alignment, and submission timeline — reply to this email or book a short call by clicking here: If you prefer, we can include your lawyer to align all parties and finalise a submission timeline.
