As we recently mentioned, Portugal’s Assembly of the Republic voted to approve a significant reshaping of the citizenship timeline. The bill would extend the minimum legal residence period before applying for citizenship from five years to seven years for citizens of EU and Community of Portuguese Language Countries (CPLP) and ten years for all other foreign nationals. It also changes the way time is counted: the clock would start only when a residence permit is granted, not when the application is filed. Because authorities commonly take two to three years to issue residence permits, legal experts estimate that the naturalization timeline could effectively stretch to nine to thirteen years for most foreigners, including Golden Visa investors. Article 5 of the bill shields pending citizenship applications filed before the law takes effect but does not protect current residency holders who planned to apply for citizenship after five years under the old rules.
Allow us to make this abundantly clear: the proposal is still not yet law. The new rules will only take effect when they are published in the official gazette. Until then, the current nationality law—allowing applications after five years of legal residence—remains in force.
Uncertain Outcome and Constitutional Scrutiny
Legal professionals caution that the draft is still undergoing detailed review and may change. As of the beginning of November, the bill has not yet been approved or published, and significant amendments or transitional provisions are expected. The legislative process still involves committee reports and the President’s decision; constitutional experts have criticized several measures as unconstitutional and they are likely to face judicial challenges. It is very difficult to predict when and how these changes will be implemented; the Government may establish transitional regimes or opt for immediate application.
Moreover, constitutional scholars such as Jorge Miranda and Rui Tavares Lanceiro have argued in a separate legal opinion that retroactively altering when residence time is counted violates principles of legal certainty and equality. They contend that applicants acquire legitimate expectations when they file their residency applications, and that removing the waiting‑time from the naturalization clock would be unconstitutional. While their opinion does not guarantee a court outcome, it suggests that the law may be on the applicants’ side if the draft is challenged.
Given this uncertainty, it is important to emphasize that no one can guarantee that new Golden Visa applicants will be able to rely on a five‑year path to citizenship. The proposal’s current wording would affect new residency permits issued after the law’s entry into force, and it does not automatically “grandfather” existing residents who have not yet filed citizenship applications. However, political negotiations, potential amendments, and constitutional review could still soften or overturn the harshest provisions.
Why the Golden Visa Still Makes Sense Today
Even with proposed reforms, Portugal’s Golden Visa continues to offer compelling benefits. Under the current law, Golden Visa investors can secure residence permits for themselves and eligible family members (spouse or partner, dependent children and, in some cases, dependent parents). Holders gain the right to live, work, and study in Portugal and enjoy visa‑free travel throughout the Schengen Area. The program’s minimal physical‑presence requirement—typically seven days in the first year and fourteen days per two‑year renewal period—provides flexibility for those who wish to maintain their primary residence elsewhere. Investment options include regulated investment funds, job‑creation ventures, and cultural or research donations, allowing investors to choose strategies that fit their risk profile and objectives.
The key question is whether to apply now or wait. Processing times for Golden Visa applications can exceed a year, and under the draft bill, the residence clock would only start once the residence permit is issued. Acting sooner could therefore allow investors to accrue years of legal residence under the current five‑year framework while legislators debate the changes and courts evaluate their constitutionality. Legal advisers note that applicants who already meet the current five‑year benchmark are strongly advised to submit their citizenship applications promptly. Likewise, experts recommend that those who wish to proceed should not delay.
Even if the law eventually extends the timeline, Golden Visa holders still obtain valuable benefits: a secure residency status in Portugal, access to Europe, family reunification rights and a clear path—albeit potentially longer—to citizenship. The Golden Visa remains a powerful tool for diversification and lifestyle flexibility.
Stay Informed: Join the Holborn Assets Webinar
With the legal landscape evolving rapidly, staying informed is essential. To help investors navigate these changes, Holborn Assets is hosting a live webinar titled “Portugal Golden Visa 2025: Everything You Need to Know with Live Q&A” on 12th November 2025 at 5:00 pm, Lisbon time.
During this session, Jason Swan, Senior Partner at Holborn Assets and one of Portugal’s leading Golden Visa specialists, will explain the latest legislative developments, discuss updated investment routes and AIMA processing updates, and answer participant questions. The webinar will also cover family inclusion requirements and strategies for navigating potential delays.
Registration is free. Participants will receive exclusive insights from an experienced professional and have the opportunity to ask questions during the live Q&A. Spaces are limited, so register now to secure your spot and ensure you are prepared for the forthcoming changes.
Secure your place here: Register Now
Conclusion
Portugal’s Golden Visa remains one of the most attractive residency‑by‑investment programs in the world. While the Portuguese parliament has approved a draft law that could lengthen the citizenship timeline, the proposal has not yet taken effect and may still change following presidential scrutiny and constitutional challenges. Applicants should be aware that the five‑year path to citizenship cannot be guaranteed, but legal principles and ongoing debate could protect their position. Acting now allows you to secure residency under the current rules and positions you ahead of any forthcoming changes. For tailored guidance and the latest information, we strongly encourage you to consider joining the Holborn Assets webinar on November 12, 2025.
