After the recent proposed changes to Portuguese immigration law, we thought it would be important to update you on the Portuguese government’s meeting with AIMA’s Golden Visa team. Here’s what you need to know:
1. A Fresh, Fully Digital System Is 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, and 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. Note that the DUC (Documento Único de Cobrança) is a Portuguese document used for single payments to various government entities, including courts and the Finanças tax authority) 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 primary applicants can apply with 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 primary applicant’s application is formally approved.
- Permanent residence post-Golden Visa no longer requires holding the original investment required to apply for the Golden Visa. 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, you can have your lawyer compile all issues into a single email. Follow-up requests should be limited 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.
To find out more on Golden Visa and AIMA updates, Jason Swan will be hosting a public webinar with live Q&A on the 13th August – click here to register.
