Portugal's new citizenship clock: what it means for Golden Visa holders

Portugal built much of its Golden Visa's appeal on one line: citizenship after five years, with only a few days a year spent in the country. That line no longer holds. After a year of votes, a Constitutional Court ruling, a presidential veto and a second vote, the amended Nationality Law entered into force on 19 May 2026.

This article explains the new rules as of 30 September 2026 for investors who hold, or are considering, a Portugal Golden Visa. It is general information; your own timeline depends on dates in your file, so we check them individually.

What the 2026 Nationality Law changed

The reform is Organic Law no. 1/2026 of 18 May, which amends the Nationality Law of 1981. Its core change is the length of legal residence required before you can apply for Portuguese citizenship by naturalisation:

For investors from the Middle East, the CIS and non-EU Europe, the relevant number is ten. For EU citizens — who rarely need a Golden Visa to live in Portugal — it is seven.

How the law got here

Parliament first approved the reform on 28 October 2025. On 15 December 2025 the Constitutional Court struck down four provisions, including a transitional rule that would have judged applications already pending by the new standard, which the Court found violated legitimate expectations. It did not strike down the seven- and ten-year periods. The President vetoed the text, Parliament approved a revised version on 1 April 2026, and it was promulgated on 3 May and published on 18 May 2026.

The clock now starts at your first residence card

The second change is quieter but, for Golden Visa investors, just as important. A 2024 amendment had allowed residence time to be counted from the date you applied for your first temporary residence permit, provided it was later granted. The 2026 law repealed that rule. Only legal residence under a residence title now counts, which law firms read as time running from the issuance of your first card.

That matters because of how long AIMA, Portugal's immigration agency, has taken to issue first Golden Visa cards. Advisers report 12 to 36 months between application and first card, with the biometrics appointment alone often taking a year. Under the old rule, that wait counted towards citizenship. Under the new one, it does not.

Some advisers estimate that the realistic path for Golden Visa holders is now eleven to twelve years from the initial investment. Separate periods of residence can still be added together if they fall within a twelve-year window for non-EU nationals (nine for EU and CPLP), so a short gap between permits does not reset the count — but a long one can.

Three timelines under the new rules

To make the change concrete, here is how the earliest citizenship application date moves for three typical non-EU investors. Each assumes permits are renewed on time and no gaps occur.

Investor B is the group most affected: they met every rule they were given, but had not yet reached the five-year mark on 18 May 2026. Investor C should now plan around permanent residence at year five and treat citizenship as a long-term option rather than the goal of the investment.

Who keeps the old five-year rule

The transitional regime is narrow. Applications for citizenship that were pending on the date the law came into force — in practice, filed with the Registry and Notary Institute (IRN) on or before 18 May 2026 — are decided under the old rules. The Constitutional Court's ruling made this protection unavoidable.

There is no protection for:

• people who were legally resident but had not yet applied for citizenship;
• investors whose five years would have been complete had AIMA issued their card on time;
• anyone who had only registered an interest, rather than filing a complete application.

When the President promulgated the law, he stressed that pending cases must not be affected and that State delays should not compromise legal deadlines. That statement has no legal force on its own, but it is the basis of the challenges described below.

New conditions beyond the waiting time

The law also adds conditions that every applicant must meet, whichever timeline applies to them:

• a test or certificate showing knowledge of the Portuguese language, culture, history and national symbols;
• knowledge of citizens' fundamental rights and duties and the organisation of the State;
• a solemn declaration of adherence to the principles of a democratic state governed by the rule of law;
• the ability to support yourself financially;
• no effective prison sentence of three years or more for serious crimes such as terrorism, organised or violent crime;
• no security concern and no UN or EU sanctions.

How these are proven — the level of the language test, the format of the civic test, what counts as sufficient means — depends on an implementing regulation that was due within 90 days of the law. As of late September 2026 it had not been published. Expect the language requirement to settle at around A2, in line with the permanent-residence standard, but treat that as a forecast.

The Golden Visa in 2026: still open, still useful

The Nationality Law did not close or change the Golden Visa itself. Since the 2023 reform, real estate and simple capital transfers no longer qualify; the remaining routes are:

The minimum stay is unchanged: seven days in the first year, then fourteen days in each following two-year period. The Golden Visa still gives you the right to live in Portugal and to travel within the Schengen area, and it is still a route to permanent residence after five years — with basic Portuguese — after which the investment can be sold.

Your options if you already hold a Golden Visa

Keep every permit valid and renew on time

Continuity now matters more than ever. File renewals early, keep proof of the minimum stay, and keep copies of every card and receipt. A gap that falls outside the twelve-year aggregation window can cost you years.

Plan for permanent residence at year five

Permanent residence removes the need to keep the investment and fixes your right to live in Portugal. Whether Golden Visa holders also qualify for the separate EU long-term resident status, which requires continuous residence, is assessed case by case because of the programme's low stay requirement; ask for a legal opinion before relying on it.

Consider the collective challenges

In June 2026, a group of nine law firms filed a complaint with the Ombudsman on behalf of 1,260 Golden Visa clients, and hundreds of holders are preparing litigation over the loss of time caused by administrative delays. Lawyers expect these cases to take three to five years. They may help; they should not be the plan.

Use the courts to force a decision on pending permits

If your first card or a renewal is still pending, Portuguese courts can order AIMA to decide within a set period. They cannot order an approval, but for investors whose clock has not started, a faster decision is now worth real time.

Should new investors still choose Portugal?

If citizenship within five to seven years is your main goal, Portugal is no longer the obvious choice for non-EU investors. If your goal is secure, flexible European residence with a light stay requirement and an eventual permanent status, it remains competitive. Compare it honestly with:

• Greece Golden Visa — residence through property, no minimum stay, but a seven-year path to citizenship with genuine integration requirements;
• Malta Permanent Residence — permanent status from the start, with a larger upfront cost;
• citizenship by investment — if a second passport is the actual goal, a direct programme may now be faster than any residence route.

Finally, remember that a residence permit does not by itself change where you pay tax. We explain why in residence permit vs tax residence.

Portugal citizenship: questions investors ask