The Portugal Golden Visa is one of the most popular residency-by-investment programs in the world. The scheme effectively provides a ‘golden passport’ that enables visa-free access to the Schengen Area and the opportunity to live in a safe and stable country.
However, not everything has been going as smoothly as many Golden Visa applicants would hope. Due to a wide range of factors, there have been delays in processing applications.
In this article, we’ll cover:
Portugal's Golden Visa Delays
While unforeseen circumstances such as the COVID-19 pandemic and the Ukrainian war caused some delays, the largest contributor to untimely Portugal Golden Visa applications was the disbanding of SEF and its subsequent replacement with AIMA.
It is estimated that AIMA has a backlog of over 400,000 applications, of which 350,000 were inherited from SEF, which made delays of over a year common. To address this, the newly elected government is implementing an action plan to resolve pending issues by June 2025.
In addition to hiring more workers, AIMA president Luís Goes Pinheiro confirmed that the Council of Ministers approved the validity of residency visas and documents by one year until 30 June 2025.
Increasing the validity period will hopefully relieve some strain on the agency, as applicants won’t need to scramble before their visas and documents expire. Other steps that the government has taken include modernizing computer systems and an enhanced method for scheduling appointments and expressions of interest.
Due to these delays, the analysis and pre-approval of the Golden Visa can take up to 18 months, and the biometric data collection and residence card issuance can take a further 6 to 18 months.
Recent Golden Visa Changes
Since its inception in 2012, the Portugal Golden Visa program has undergone several changes, leading many to assume that it will eventually be canceled. In 2022, an amendment to the law restricted the ‘qualifying’ areas for real estate investment within Portugal and made several investment options more expensive.
The Portuguese government explained that these changes were necessary to spread foreign investment evenly to other parts of Portugal. With the Lisbon and Porto real estate markets thriving, the government focused on developing the property market in Portugal’s interior areas.
As of October 2023, direct and indirect real estate investment and capital transfer can no longer qualify as qualifying investments. However, several attractive investments, such as venture capital fund investment and cultural and artistic donations, still qualify for the Golden Visa process.
Below are the remaining investments that are eligible for the Golden Visa in Portugal, as well as the minimum investment requirements:
- Fund subscription: Contribute to a qualified investment fund (such as private equity funds or venture capital funds) worth at least €500,000
- Investment or donation in the arts or reconstruction of national cultural heritage with a donation of at least €250,000. This is the lowest minimum investment threshold.
- Scientific research: Science or Technology research contribution of at least €500,000
- Creation of ten jobs: Creation and maintenance of ten jobs during the required period
- Share capital and job creation: Incorporation of a commercial company in the national territory or reinforcement of a company’s share capital (this company must have its head office in the national territory), in either case with an investment of €500,000, combined with the creation of five or maintaining ten jobs (five of them permanent)
Take a look at our Portugal Golden Visa Ultimate Guide by local experts
Positive News for Golden Visa Investors
Residency waiting time now counts toward nationality
In January 2024, the Portuguese parliament approved crucial changes to the nationality law, bringing relief to thousands of applicants affected by delays in residency application processing by SEF, now AIMA. This major revision addresses the waiting period required for Portuguese nationality applications.
The law was published on 5 March 2024 and came into force on 1 April 2024. Previously, individuals looking to secure Portuguese nationality through naturalization were required to hold residency in Portugal for a minimum of five years, among other requirements. The initiation of the five-year period for nationality application was contingent upon issuing the initial residency permit.
Under this new law, the time between the submission of the temporary residency permit application and its final approval will be taken into account when calculating the required legal residency period for nationality, as long as the residence permit is granted. The significant changes to Portugal’s nationality law add a layer of anticipation to the positive changes for Golden Visa applicants.
Previously, according to Article 6, Paragraph 1 of the Nationality Law, individuals seeking Portuguese nationality through naturalization had to maintain residency in Portugal for a minimum of five years, among other prerequisites. The commencement of the five-year period for nationality application was dependent on the issuance of the initial residency permit.
This means that individuals facing delays in residency approvals due to factors such as COVID-19, the Ukrainian War, and the restructuring of the Portuguese immigration department will now have their waiting period taken into account.
Consequently, they can apply for Portuguese nationality at an earlier date. For instance, individuals planning to apply for Portuguese residency in 2024 would meet the five-year residency requirement to obtain citizenship by 2029, regardless of potential delays in processing the residency application.
This is particularly positive news for those who are attracted to the Portuguese Golden Visa program because the time period for obtaining Portuguese citizenship is short in comparison to most other European countries.
Golden Visa renewals are processing very fast, but there are still delays
Golden Visas could be renewed online until December 31, 2023. While this option is no longer available, the automatic online renewal process introduced by the former SEF was reported to be efficient at that time. Some early applicants who renewed their Golden Visa this way received their new residency cards in less than two weeks. One significant advantage of online renewals was that there appeared to be no requirement to submit documents already available to SEF from the initial application.
Although the initial application still requires an in-person biometrics visit and there remains a considerable backlog, renewing existing applications was expected to help clear this backlog more quickly.
Many investors have taken legal action regarding delays in obtaining a Golden Visa to expedite the process, with reports indicating that SEF has lost hundreds of these cases. Courts have made favorable decisions for foreign investors based on legal appointment deadlines, stating that such delays in the process are not lawful.
Benefits of Having Second Residency or Citizenship
Citizenship or permanent residency by investment gives people the freedom of choice to start over in a new country and build a future for themselves and their families. It further protects one’s personal, professional, and financial interests.
People of all different non-EU nationalities can apply for the program. As of September 2023, there have been a total of 12,718 Portugal Golden Visa investors, according to our Golden Visa Statistics article, bringing billions of Euros worth of foreign investment into the Portuguese economy.
There are numerous advantages to holding a permanent residence permit or citizenship of an EU country, as well as being able to operate and reside in another country abroad. While legal residence enables visa free travel in the Schengen Area, and European citizenship (such as Portuguese citizenship), which there’s a pathway to through the Portugal Golden Visa program, enables you to live and work anywhere in this zone.
The main benefits can be summed up as follows:
Freedom of travel, with visa-free restrictions in 100+ countries
Fiscal and asset protection back-up-plan
Tax residency
privileges
Optimal social systems such as school and healthcare
As well as these benefits, Portugal Golden Visa investors put their money into a qualifying investment, which provides the opportunity for a return on investment or a sense of well-being from a philanthropic donation. The options available in 2024 include investments into local heritage projects, scientific research, job creation, or an investment fund. An investment fund is a type of financial product that collects investors’ money and invests it in certain assets to increase capital.
Why choose Global Citizen Solutions for your Immigration Visa?
GLOBAL APPROACH BY LOCAL EXPERTS
- GCS has offices located across Portugal.
- Members of the US-Portugal and UK-Portugal Chambers of Commerce in Portugal, and the Investment Migration Council (IMC).
- Our expert team can help you throughout your journey to secure your Visa.
100% APPROVAL RATE
- Our successful track record in applications provides reassurance to applicants.
- We have helped clients from more than 35 countries secure residency in Portugal.
ALL-ENCOMPASSING SOLUTION
- With a single channel of communication, our approach ensures that you have complete clarity on your application.
- Our BeGlobal® Onboarding System allows for a total flow of information.
TRANSPARENCY AND PRIVACY
- Our pricing is clear and detailed, you will not face any hidden costs.
- All data is stored within a GDPR-compliant database on a secure SSL-encrypted server.
Frequently asked questions about Portuguese Golden Visa delays
How long are the current processing times for the Portuguese Golden Visa program in 2024?
In 2024, Portuguese Golden Visa applicants can expect a processing time of at least 18 months.
How has COVID-19 impacted applications for the Portugal Golden Visa?
Despite the COVID-19 pandemic, the Portuguese government and the former SEF (which has since been replaced by AIMA) continued to run the Portugal Golden Visa program, accepting applications on a rolling basis.
What impact will AIMA have on the Portuguese Golden Visa program?
AIMA aims to be efficient in processing Golden Visa applications as it has greater strength in human resources than SEF.
What are the changes to real estate investment option for the Portuguese Golden Visa?
In October 2023, property investment was discontinued as a pathway to a Portugal Golden Visa permit, along with capital transfers. Additionally, real estate related investment funds are also ineligible.
While real estate investments no longer qualify, there are several other Golden Visa investment options available, including job creation, cultural heritage and arts investments/donations, and investment funds.
There are other Golden Visa programs that still accept real estate investments, including those in Greece and Spain.
How can I avoid Golden Visa delays?
There’s no way to avoid delays in the processing of a Golden Visa. The best course of action for all Golden Visa applicants is to ensure that you have all the required documents and make sure they’re up to date when you apply. This will reduce the risk of rejection and any associated delays in your application.
What is the new Nationality Law in Portugal?
After the Portuguese Constitutional Court’s decision, the Portuguese President approved the Portuguese Citizenship Law. The significant alteration to the Portuguese Golden Visa program had been previously disclosed approximately a month ago. Under this amendment, applicants for the Portuguese Golden Visa will now be allowed to include the ‘application waiting period’ within the 5-year citizenship period. Consequently, the 5-year timeframe will start from the submission date of the initial residency application, irrespective of its acceptance date.
What can applicants do to expedite the Golden Visa application process in Portugal?
While expediting a Portugal Golden Visa isn’t officially possible, a streamlined application can improve your chances. Prepare all documentation thoroughly and on time to avoid delays. Working with an immigration lawyer or agency ensures your application is complete and they can manage communication with Portuguese authorities throughout the process. These steps can help your application move more efficiently through AIMA.
Are there any plans to address the backlog of Golden Visa applications in Portugal?
Yes, the Portuguese government is addressing the Portugal Golden Visa backlog. The Serviço de Estrangeiros e Fronteiras (SEF) was recently replaced by the new Portuguese Agency for Integration, Migration and Asylum (AIMA). AIMA aims to improve processing efficiency, but it may take time. They estimate clearing the backlog within 18 months, by mid-2025
Which Portugal Golden Visa route has the fastest application process?
While there’s no officially “fastest” route for the Portugal Golden Visa, some options might see quicker processing due to less complexity. For example, an investment fund subscription could be a faster route. Investing in pre-approved funds managed by professionals and regulated by the Portuguese Securities Market Commission reduces the need for extensive due diligence on your part.
How should applicants plan for the uncertainties caused by the Golden Visa backlog?
While the Golden Visa delays create uncertainty, proactive planning can help. Have all documents in order for a smooth application. Finding a good immigration lawyer can be invaluable. They can help navigate potential delays and advise on recourse if wait times become excessive, such as administrative complaints or, as a last resort, judicial reviews.
