Portugal Golden Visa Delays 2024: All You Need to Know

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.

It has welcomed 10,636 investors (and 17,614 family members) to Portugal, since its inception in 2012. However, in recent times there have been some Portugal Golden Visa delays, due to a wide range of factors.

In this article, we cover the following:

• Program operating status of the Portugal Golden Visa
• Portugal’s Golden Visa Program 2023 changes and 2024 updates
• Benefits of having a second residency or citizenship through this investment program
• Portugal Golden Visa delays and the current situation
• Positive changes to the Portugal Golden Visa timeline
• Portugal Golden Visa waiting time estimations for 2024
• How we can help you today

Portuguese Golden Visa Delays - Program Operation Status

• Portugal’s Golden Visa program is operating as usual. 
• The application, including NIF (Portuguese tax number) issuance, the initial AIMA application, the opening of a Portuguese bank account, and notary services, are open as usual.
• Face-to-face interviews for biometrics are running as usual, but you must book an appointment beforehand. However, you should expect some delays, which we shall cover in more detail below. 
• All documents related to the Portugal Golden Visa application are now submitted online. After the request is approved, you must appear in person for a biometric interview.

With regards to the Golden Visa Portugal, it is business as usual, and biometrics operations have been up and running again since July 2020.

Portugal Golden Visa Delays and the Current Situation

As previously mentioned, there have been some Golden Visa delays with the processing of visas. This is due to an unfortunate series of events, including the COVID-19 pandemic, general elections, and a restructuring of the SEF (Serviço de Estrangeiros e Fronteiras) department – the department that was responsible for processing Golden Visas – and, most recently, the Ukrainian war. In October 2023, SEF was eliminated and replaced by AIMA, which is expected to make the processing of visas more efficient in the long term.

Portugal Golden Visa applications have considerably stalled in the last year or so. This has created a considerable backlog and long waiting time. In October 2023, Investment Migration Insider reported that Portugal’s €4bn Golden Visa backlog would take until 2030 to finish processing.

Recent Golden Visa changes

There have also been recent changes to the Golden Visa program. As of October 2023, direct and indirect real estate investment and capital transfer can no longer be qualifying investments as part of the program.

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: Make a contribution 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)

Positive News for Golden Visa Investors

SEF was replaced by AIMA

The Foreigners and Borders Service (SEF) was extinguished on October 29th. SEF, the agency responsible for managing foreign documents, was replaced by the Agency for Integration, Migration, and Asylum (AIMA).

This change aims to streamline immigration services in Portugal, address longstanding backlogs, and create a more efficient system for both residents and foreign nationals seeking services.

AIMA is tasked with managing all matters concerning foreign documents, residence permits, and visa renewals in Portugal.

This move is expected to make the Golden Visa process more efficient for foreign investors from now on.

The new Nationality Law: Positive news for Golden Visa holders in 2024

In January 2024, the Portuguese parliament approved crucial amendments to the nationality law, providing relief to numerous Golden Visa applicants affected by delays in the processing of residency applications by SEF, now AIMA. This significant revision focuses on the waiting period necessary for Portuguese nationality applications.

The law, published on March 5, 2024, took effect on April 1, 2024.

What are the alterations to the Nationality Law?

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.

With this recent legislative development, the revised Article 15, now encompassing Paragraph 1 of the nationality law, explicitly states that the time between the submission of the temporary residency permit application and its final approval will be considered in calculating the necessary legal residency period for nationality, provided the residency permit is granted.

Positive impact on Portugal Golden Visa applicants

The substantial adjustments to Portugal’s nationality law create a sense of anticipation regarding positive changes for Portuguese Golden Visa applicants.

Previously, applicants were subject to the stringent requirement of a minimum five-year residency period starting from the issuance of the initial residency permit. This often led to prolonged waiting times for Portuguese citizenship, with candidates experiencing delays due to processing backlogs at the former SEF.

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.

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:

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. See our full guide here for more information.

How We Can Help You Today

Whether the Portuguese Golden Visa, the Spain Golden Visa program, or another scheme, we understand that it can be a time-consuming affair as well as a stressful experience to reach a big decision like applying for residency in a foreign country.

As consultants in investment migration, we can help you apply for several residency-by-investment programs. Our step-by-step strategy, tailor-made to each unique client, means we are there for you every step of the way.

For further information or to discuss your personal circumstances in a private consultation, please book a call with a Global Citizen Solutions expert or get in touch with us by filling out the form below.

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 other visas are available for moving to Portugal?

There are numerous other pathways in Portugal for those who live outside the European Union countries looking to relocate, outside of the Portugal Golden Visa program.

• The D8 Digital Nomad Visa is the visa choice for those doing remote work and want to set their movable desk up in Portugal.
• The D7 Passive Income Visa is ideal for those planning to stay for up to two years. However, you must provide proof of passive income and are not actively working to earn a living.
• The D2 Entrepreneur visa caters to individuals intending to establish or acquire a business in Portugal.

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 Portugal 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.