How the New Nationality Law Impacts the Portugal Golden Visa
- Stephen James Mitchell
- 1 day ago
- 8 min read
On October 28, 2025, the Portuguese Parliament approved a set of amendments to the Nationality Law that, if enacted, will significantly alter the timeline and process through which foreign residents — including Golden Visa holders — may apply for Portuguese citizenship.
While these changes do not modify the Golden Visa (ARI) residency program itself, they reshape the long-term pathway to citizenship for investors who hold, have applied for, or are considering applying for a Portuguese Golden Visa. The adjustments reflect a recalibration of Portugal’s nationality process, rather than a restriction of its immigration model. In other words, the amendments may lengthen the path, but they do not change its direction.
The bill has not yet become law. It has moved from Parliament to the President of the Republic, who now has the authority to approve, veto, or refer the legislation to the Constitutional Court for preventive review. Until that process concludes, no changes have legal effect, and there is no need for individual action by investors or residents.
This article provides a factual and in-depth analysis of the amendments, their potential impact on the Golden Visa pathway, and their implications for three groups of stakeholders:
Current Golden Visa holders (residence card issued)
Applicants with pending cases (applied but card not yet issued)
Prospective applicants considering investment
It also outlines what steps follow next in the legislative process and explains why permanent residency now emerges as a critical milestone for strategic planning.
If you’re unsure how the proposed changes may affect your status or plans, now is the time to seek clarity. Talk to a citizenship consultant about the Portuguese Golden Visa to understand your position and plan your next steps with confidence.
Overview of the Approved Amendments (October 2025)
The amendments approved by Parliament on October 28, 2025, constitute the most significant update to Portugal’s nationality framework in recent years.
If promulgated as currently written, they will extend the residency requirement, change how residency duration is calculated, and introduce an additional integration test for applicants seeking Portuguese nationality.
1. Extension of the Residency Period
For non-EU and non-CPLP (Portuguese-speaking countries) nationals: The minimum period of legal residence required to apply for citizenship will increase from 5 years to 10 years.
For EU and CPLP citizens: The residency requirement will increase from 5 years to 7 years.
This change effectively doubles the qualifying period for most Golden Visa investors, who are typically non-EU nationals.
2. New Calculation of Residency Time
Under the current law, the five-year residency period is counted from the date the initial residence application is submitted.
The proposed amendment redefines this starting point:
Residency time will now be counted from the date the first physical residence card (permit) is issued, not from the application submission date.
Practical impact: Since Golden Visa applicants frequently experience administrative delays of one to three years between submission and issuance of the first residence permit, this change would eliminate that period from the citizenship countdown.
Consequently, the effective wait time for citizenship eligibility could extend significantly beyond ten years for some applicants.
3. Additional Integration Requirement: Civic Knowledge Test
Alongside the existing A2-level Portuguese language test, a new civic knowledge test will be introduced. This new test will evaluate applicants’ basic understanding of Portuguese history, culture, civic duties, and democratic principles.
The intention is to ensure that naturalization applicants demonstrate both linguistic and civic integration into Portuguese society. The specific format and administration of this new test have not yet been defined.
The Legislative Process: Current Status and Next Steps
The amendments approved by Parliament are not yet in force. For them to become law, several constitutional steps must occur.
1. Presidential Review
Once Parliament passes a bill, it is forwarded to the President of the Republic, who has three options:
Promulgate (Approve) – sign the bill into law.
Veto – return the bill to Parliament for reconsideration or amendment.
Refer to the Constitutional Court – request a preventive constitutional review to assess whether any parts of the bill violate the Constitution.
Given the potential retroactive application of these changes and the absence of transitional protections (“grandfathering clauses”) for existing and pending applicants, a referral to the Constitutional Court is widely anticipated.
2. Constitutional Court Review
The Constitutional Court could review the legislation for issues including:
Retroactivity – applying stricter rules to those who already applied under a different legal framework.
Legal certainty and legitimate expectations – protecting individuals who made investment decisions based on the five-year rule.
A constitutional review could result in the amendments being upheld, modified, or partially annulled before final publication.
3. Publication and Enforcement
Only after presidential promulgation and publication in the Diário da República (Official Gazette) does the law enter into effect. Until then, the previous nationality law remains in force, and no changes apply to current or pending cases.
Summary Table: Current vs. Proposed Rules
Category | Current Rule | Proposed Rule (If Enacted) | Practical Impact |
Residency Requirement for Citizenship | 5 years (all nationals) | 10 years for non-EU/non-CPLP; 7 years for EU/CPLP | Significantly extends the citizenship timeline |
Start of Residency Clock | From date of application submission | From date of first residence card issuance | Adds 1–3 years of administrative delay to total eligibility period |
Integration Requirements | A2 Portuguese language test | A2 language + new civic knowledge test | Introduces new civic integration assessment |
Golden Visa Residency Rights | 7 days per year average stay | 7 days per year average stay | Unchanged |
Permanent Residency Eligibility | After 5 years of legal residency | After 5 years of legal residency | Unchanged |
Portugal Golden Visa Framework Holds Steady Amid Citizenship Law Changes
The approved amendments represent a recalibration of the nationality process, not a restriction of Portugal’s broader immigration or residency framework.
They do not modify the structure or operation of the Golden Visa (ARI) program, which remains open and functional under existing conditions.
Golden Visa holders continue to benefit from:
Minimal physical presence requirements (7 days per year, averaged).
Eligibility for permanent residency after five years.
Freedom to live, work, and study in Portugal.
In short, while the path to citizenship may become longer and more complex, the core benefits of the Golden Visa (flexible residency, family reunification, Schengen mobility, and eventual eligibility for nationality) remain intact.
How the Proposed Changes Affect Different Groups
1. Current Golden Visa Holders (Card Issued)
Residency Rights: Unchanged. Holders retain the right to reside in Portugal, renew their permits on schedule, and fulfill the 7-day-per-year average stay requirement.
Permanent Residency: Unchanged. Holders remain eligible to apply for Permanent Residency (PR) after five years of legal residence under their Golden Visa. Once PR is obtained, holders can usually liquidate their original investment while maintaining residency rights.
Citizenship Eligibility:
Those who have completed five years and already applied for citizenship are likely to be assessed under the existing five-year rule, as the application was made under current law.
Those who have not yet applied may become subject to the new 10-year requirement, counting from the card issuance date, if the amendments are enacted unchanged.
Thus, current holders remain secure in their residency but face uncertainty about the citizenship timeline depending on when they apply and how the final law is implemented.
2. Applicants in the Pipeline (Applied but Card Not Yet Issued)
This group is most directly affected by the proposed changes.
Residency Rights: Applications in process remain governed by the existing Golden Visa framework. However, the start date for the citizenship clock would shift under the new rule.
Citizenship Timeline: If enacted, the 10-year period (or 7 years for EU/CPLP nationals) would start only upon issuance of the first residence card, not the date the application was filed.
Given typical administrative delays of 2–3 years, the total effective wait for citizenship could extend to 12–13 years from the initial submission date.
Legal and Constitutional Concerns: Applicants in the pipeline face the greatest uncertainty due to the lack of a grandfathering clause. Many legal experts view retroactive application of these changes as potentially unconstitutional, and a Constitutional Court challenge is likely if the final law retains this provision.
3. Prospective Applicants (Planning to Apply)
Golden Visa Availability: The program remains open, but its value proposition shifts. The Golden Visa should now be considered primarily as a long-term residency and investment pathway, not as a short route to citizenship.
Timeline Expectations: Applicants should plan for:
10 years (or 7 years for EU/CPLP nationals) of residency to qualify for citizenship, plus administrative processing time, and
5 years to qualify for Permanent Residency.
Strategic Planning: Those seeking the fastest possible EU passport will likely find other jurisdictions more aligned with that objective. Conversely, those prioritizing European residency stability, flexible stay requirements, and eventual citizenship as a secondary goal will continue to find Portugal’s Golden Visa attractive.
If you're weighing your residency and citizenship options in light of these developments, a strategic consultation can help you assess the best path forward. Speak with a citizenship advisor to explore whether the Portuguese Golden Visa still aligns with your long-term goals—or if alternative residency or citizenship programs may better suit your needs..
Permanent Residency: The Strategic Anchor
In this new legal landscape, Permanent Residency (PR) at the five-year mark becomes the key milestone for most Golden Visa investors.
Benefits of PR include:
Indefinite right to live, work, and study in Portugal.
Ability to end or adjust the original investment commitment.
Security and continuity without dependence on the 10-year citizenship horizon.
By obtaining PR, investors can maintain stable residency rights while awaiting clarity on constitutional and presidential outcomes regarding the new nationality requirements.
Expected Presidential and Constitutional Developments
The President of the Republic has historically taken a balanced and pragmatic approach to matters of migration and citizenship. The Presidency often moderates restrictive drafts coming out of Parliament.
For this reason, it is not expected that the version approved on October 28 will be the final text.
Likely next steps may include:
A refinement of timing and implementation details by the President or the Constitutional Court.
Possible inclusion of a grandfathering clause to protect existing applicants and uphold constitutional principles of legal certainty.
Clarification on the transitional application of the new civic knowledge test.
As these developments unfold, investors and residents are advised to remain calm. The constitutional process is designed to ensure proportionality, legality, and fairness before any changes take effect.
Navigating Legal Uncertainty: Stay Informed, Stay Prepared
At this stage, no immediate individual action or case-specific legal adjustment is required. The information summarized here reflects the current legal and political landscape as of November 11, 2025.
Until the President’s decision is issued and the final version of the law is published, this analysis represents a reasoned interpretation based on the legislative process and the text approved by Parliament. Investors and applicants are advised to monitor the situation and wait for formal confirmation of the law before considering any changes to their plans.
Recommended Next Steps
Stay Informed: Follow updates from the Presidency and Constitutional Court regarding this bill.
Maintain Compliance: Continue fulfilling residency obligations (7 days/year on average).
Plan for Permanent Residency: Treat PR at the five-year mark as a key strategic milestone.
Avoid Premature Legal Action: Wait until the law is finalized and published before pursuing case-specific measures.
Expect Refinement: Historical precedent suggests that final legislation may differ from the version approved by Parliament, particularly regarding retroactivity.
Conclusion
The proposed amendments to Portugal’s Nationality Law, approved by Parliament in October 2025, represent a structural change to the citizenship process—but not a restriction on Portugal’s open immigration framework. The Golden Visa residency rules remain unchanged, maintaining continuity for investors seeking European residence and mobility.
The primary shift lies in the extension of the citizenship timeline—from five to ten years for most non-EU/non-CPLP nationals—and the recalibration of when residency time begins, moving it to the issuance of the first residence card. The introduction of a civic knowledge test will further formalize integration requirements for those seeking naturalization.
For current and prospective Golden Visa holders, the strategic focus should now turn toward securing Permanent Residency after five years, which continues to offer long-term legal stability and flexibility, regardless of the evolving citizenship timeline.
As the legislation moves through presidential and constitutional review, no immediate action is required. Investors are advised to stay informed, monitor developments, and approach strategic planning with patience and clarity.
For tailored advice based on your specific goals and circumstances, speak with a citizenship advisor to assess whether the Portuguese Golden Visa—or an alternative Citizenship or Residency by Investment program—best supports your long-term residency and citizenship objectives.