Portugal’s Parliament approved significant changes to the Nationality Law in late October 2025, marking the most substantial reform to citizenship requirements in years. While the law awaits presidential promulgation and official publication, Golden Visa investors need to understand what has changed, what it means for their pathway to citizenship, and most importantly, how to navigate these developments strategically.
At OptylonKrea, we believe in providing our clients with clear, accurate information during times of legislative change. This article breaks down the approved modifications and their practical implications for international investors.
The law still required several steps before becoming binding, but the legislative process has shifted due to recent parliamentary action:
On November 13, 2025, the Socialist Party (PS) invoked its constitutional right and sent the new Nationality Law directly to the Constitutional Court for
a preventive review, bypassing the President’s office;
This move suspends the law entirety, as it cannot be promulgated by the President, published in the Diário da República (Portugal's official government gazette, where all enacted laws, decree-laws, and ministerial orders that govern the country are published), or enter into force until the Court delivers its ruling;
The Constitutional Court now has up to 25 days to review the law’s constitutionality, during which time, every proposed change is inactive, and current rules remain in force for all applicants;
If the Constitutional Court upholds the law, it will then return to the President for promulgation (20-day period) and subsequent official publication and regulatory implementation (90 days after publication);
If judges rule portions of it as unconstitutional, the Parliament must amend or abandon those provisions.
For now, we will need to wait for constitutional experts to scrutinize the law’s potential retroactivity, fairness, constitutionality and equality implications. Until then, and its subsequent publication, current rules remain in force.
|
Category |
Requirements under current law (pre-2025) |
Requirements under new law |
|---|---|---|
|
Legal residence |
5 years for all foreign |
10 years (7 years for CPLP/ EU |
|
When the period |
From application |
From first residence permit |
|
Language |
A2-level Portuguese |
A2 exam plus civic integration |
|
Financial and |
Not consistently |
Mandatory for all applicants |
|
Criminal record |
Barred for prison |
Barred for any effective prison sentence; 10-year revocation window |
|
Birthright |
One parent resident ≥1 year |
One parent resident ≥3 years; explicit request required |
|
Application |
N/A |
No retroactive effect; current |
Legal Residence Requirement:
Before: 5 years of legal residence for all foreign nationals;
After: 10 years for most applicants; 7 years for EU and CPLP (Portuguese-speaking countries) citizens;
This is the most significant change, doubling the waiting period for most Golden Visa investors seeking citizenship.
When the Residence Clock Starts:
Before: counting began from the date you submitted your application;
After: the period now starts from the date your first residence permit is actually issued;
This change especially affects investors facing delays at AIMA (Portugal’s immigration authority), making efficiency crucial.
Language and Integration Requirements:
Before: only A2-level Portuguese language proficiency required;
After: A2 exam plus a civic integration test covering culture, history, and democratic values (details pending regulatory definition).
Financial and Housing Documentation:
Before: not consistently enforced;
After: mandatory proof of independent financial means and accommodation for all citizenship applicants.
Criminal Record Standards:
Before: naturalization barred for people with prison sentences of 3 or more years;
After: naturalization barred for people with any effective prison sentence; 10-year window for citizenship revocation after naturalization.
Applications submitted before the law’s effective date will remain under the existing, more favorable, five-year regime. Portugal’s ‘doctrine of acquired rights’ ensures pending applications won’t be retroactively affected.
Applied before mid-November 2020 – your five-year residence period may be complete. Contact your legal advisor immediately to expedite application before the new law takes effect.
Applied after November 2020 – citizenship may require a longer timeline, but permanent residency remains fully available after 5 years, offering almost all citizenship rights except voting and passport privileges.
AIMA Biometric Scheduling – AIMA has started scheduling hundreds of new biometric appointments for applicants from 2022 onward. Prompt action on notifications is essential.
Despite changes to citizenship law, Portugal’s Golden Visa program continues unchanged. The Minister of the Presidency of Portugal, António Leitão Amaro, confirmed there are no plans to end the program, and the government aims to make it “more effective and economically efficient”. With Spain, Ireland, and the Netherlands having closed their investor programs, Portugal stands out as one of Europe’s last remaining residency-by-investment pathways.
Since 2018, OptylonKrea has guided over 2,000 investors from 40+ countries through Portugal’s Golden Visa program, managing €2 billion in projects. Our experience shows that informed, strategic action and expert legal guidance secure the best outcomes.
Portugal’s robust legislative review means new laws undergo careful scrutiny prior to implementation. For investors, current applications are protected, permanent residency remains accessible after 5 years, and the program continues as a top EU pathway.
Contact our team for personalized guidance on your Golden Visa and citizenship planning.