If you are waiting on a Portugal Golden Visa application in 2026, the answer on timing is a range rather than a single figure. From submission to your biometrics appointment, current sources put the wait anywhere from 6 to 24 months, depending on which AIMA office is handling your file and when you applied.
From biometrics to the issuance of your residence card, expect another 6 to 18 months. Taken together, a realistic total runs from about 12 months on the faster end to well over three years for applicants caught in the earlier backlog.
Portuguese law requires AIMA to decide within 90 working days of receiving a complete file. When that deadline passes without a decision, you have the legal option to file a lawsuit compelling the agency to act, a route a growing number of investors have already taken.
Whether litigation makes sense in your case depends on your specific circumstances and timeline, and it’s a decision to make with legal counsel rather than on your own.
Portugal Golden Visa Delays: Key Takeaways
⚠️ Portugal Nationality Law Changes 2026
In May 2026, Portugal's president, António José Seguro, approved several amendments to the Nationality Law that affect long-term residency permit holders. The most significant change requires that most nationals have 10 years of legal residency and 7 years for EU and CPLP citizens before becoming eligible for citizenship.
These changes are now in force. However, the updated Nationality Law does not affect the time required for permanent residency, which remains 5 years.
For the latest information regarding these changes, read Portugal Nationality and Citizenship Changes 2026.
Why is the Portugal Golden Visa taking so long?
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.
In 2024, it is estimated that AIMA had 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 at the time implemented 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.
However, that has only eased the pressure of the agency somewhat. As more Golden Visa and residency visa holders wait for an update on their application status, the government was forced to extend the validity of residency visas and documents to 15 October 2025. Other steps that the government took included 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 24 months, and the biometric data collection and residence card issuance can take a further 6 to 18 months.
Speeding up the process
In late October 2025, AIMA proclaimed that it will resolve all outstanding Golden Visa applications in 2026. According to Minister of the Presidency António Leitão Amaro, residency applications such as D3, D7, and D8 Visa are being prioritized, and Golden Visas are deliberately handled last. “Next year we will resolve the outstanding issues that, for reasons of social equity, we left until the end, which are those that pay the most, the ‘golden visas,'” he said.
But this isn’t the first time that AIMA or the government revealed a timeline – and not sticking to it. AIMA asked all Golden Visa applicants in early 2025 to resubmit documentation with the expectations of 30 to 90-day approvals. That was never achieved and the agency has been scheduling biometric appointment from January through March 2026.
However, to put in context just how massive a task it is for AIMA and the government to process all Golden Visa applications, Amaro said that 93 percent of pending immigration cases (all types) have been resolved, and processing 500,000 criminal records and collecting biometric data from applicants.
Current Portugal Golden Visa Processing Times
Processing times for the Portugal Golden Visa are not fixed, and no single figure captures what every applicant should expect.
Your timeline depends on which AIMA office reviews your file, how complete your documentation is, and when you originally submitted your application.
The table below breaks the process into its main stages so you can see where the time is actually going, rather than relying on one headline number that may not reflect your case.
| Stage | Typical duration | What happens |
|---|---|---|
| Investment and document preparation | Varies by applicant | You complete the qualifying investment (fund subscription or eligible donation) and assemble your document file, including proof of funds, criminal record certificates, and NIF. |
| Submission to biometrics appointment | 6 to 24 months | AIMA reviews your file and schedules you for fingerprinting. Timing varies significantly by office and by when you applied, with some 2025 applicants seeing faster scheduling than those still in the earlier backlog. |
| Biometrics appointment | Single appointment | You and any dependents attend in person to provide fingerprints. This step cannot be completed by a legal representative on your behalf. |
| Biometrics to card issuance | 6 to 18 months | AIMA finalizes your approval and a separate state body produces your physical residence card. |
| Realistic total (submission to card) | 12 months to 3+ years | Applicants who submitted more recently are generally seeing shorter timelines. Those still working through pre-2023 backlog cases have in some instances waited three to five years. |
The 90-Day Legal Decision Requirement
Under Portuguese administrative law, AIMA is required to issue a decision on a complete application within 90 working days.
This rule comes from the Código do Procedimento Administrativo (the general framework governing how public bodies must handle applications), and it applies at more than one point in the Golden Visa process: once when you are waiting for initial approval, and again when you are waiting for your residence card after biometrics.
It’s worth being precise about what this deadline does and does not guarantee.
It obligates AIMA to reach a decision, not to approve the application. If AIMA misses the 90-day window, the law treats this as “administrative silence,” and you gain the right to take legal action to compel a decision.
In June 2024, Portugal’s Supreme Administrative Court confirmed that this obligation is enforceable and that courts can penalize AIMA financially for non-compliance, though the court cannot order AIMA to approve an application outright.
There is also a time limit on your right to act. Under Article 69, you must bring a legal challenge within one year of the 90-day deadline passing. After that window closes, the right to compel a decision through this specific route lapses, regardless of how long you have actually been waiting.
However, wait times at AIMA have run far beyond 90 days for many Golden Visa applicants, which is why a growing number have turned to litigation as a way to enforce this legal deadline rather than continuing to wait indefinitely.
Recent Golden Visa Changes
Since its inception in 2012, several Portugal Golden Visa changes has led many to assume that it will eventually be canceled.
- In 2022, a law restricted the ‘qualifying’ areas for real estate investment and made several investment options more expensive.
- In 2023, the government passed the “Mais Habitação” housing bill and all real estate investment routes were abolished.
- The government introduced the New Residence Permit for Solidarity Investment in 2024.
- Also in 2024, Golden Visa applications would need be submitted digitally.
- In 2026, more than 500 Golden Visa holders filed a collective lawsuit over the 2026 Nationality Law changes and the absence of a transitional regime for applicants.
- Also in 2026, a consortium of law firms has filed a complaint with Portugal’s Ombudsman on behalf of 1,260 clients, targeting both the nationality law overhaul and the AIMA backlog.
Below are the available 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)
Litigation: Using the Courts to Address Delays
When AIMA misses the 90-day legal deadline to decide your application, Portuguese law gives you the right to bring a case against the agency for failing to act. This is not a challenge to the merits of your application. It is a claim that the state has failed to meet its own procedural obligation to decide, one way or another, within the legally required time.
If a court agrees that the deadline has been missed, it can order AIMA to issue a decision, typically within 10 to 30 business days of the ruling. The court can also impose financial penalties on the agency for continued non-compliance.
What the court cannot do is order AIMA to approve your application. The remedy addresses the delay, not the outcome.
You also have a limited window to bring this kind of case: under Article 69, the right to compel a decision expires one year after the 90-day deadline passes, so this is not an option that stays open indefinitely once the delay has occurred.
The current landscape reflects how widespread this frustration has become.
More than 500 Golden Visa holders are preparing a collective lawsuit against the Portuguese state, though this action is aimed specifically at the 2026 Nationality Law changes and the absence of a transitional regime for applicants whose permits were delayed past the May 18, 2026 cutoff, rather than at enforcing the 90-day decision deadline itself.
Separately, a consortium of law firms has filed a complaint with Portugal’s Ombudsman on behalf of 1,260 clients, targeting both the nationality law overhaul and the AIMA backlog together, on the grounds that AIMA’s own delays are what kept many applicants from qualifying under the previous framework before the cutoff.
The Ombudsman cannot issue a binding ruling, but it can refer the matter to the Constitutional Court.
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 AIMA. This major revision addresses the waiting period required for Portuguese nationality applications.
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.
⚠️ May 2026 Update on Portugal's Nationality Law Changes
Portugal's president, António José Seguro, approved amendments increasing the residency requirement for citizenship from 5 to 10 years, and from 7 to 10 years for CPLP nationals and EU citizens. This significantly impacts how visa holders and residents acquire citizenship.
For the latest information regarding these changes, read Portugal Nationality and Citizenship Changes 2026.
The proposed law will also overturn the previous revision, stating that the time to citizenship begins from the date the first residence permit is issued, not from the date of application.
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 a 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 2025, there have been over 17,000 Portugal Golden Visa investors, according to our Portugal 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 include:
- Freedom of travel, with visa-free restrictions in 100+ countries
- Fiscal and asset protection back-up-plan
- 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 2026 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 Portugal Golden Visa?
- Global approach by local experts: A team of experienced local case executives, immigration lawyers, and investment specialists based in Portugal.
- Independent service:We are not a marketing agency for any projects. You will access all eligible routes for the Golden Visa, with over 40 vetted qualifying investment options, so you can decide on the best option for you.
- 100% approval rate: We have the unique distinction of never having had a Golden Visa case rejected and have helped hundreds of clients from more than 35 countries.
- All-encompassing solution: Our dedicated onboarding and immigration teams will assist you throughout the process and beyond with a single channel of communication.
- Transparency: Our fees are clear and detailed, covering the entire process with no hidden costs.
- Privacy: Your personal data is stored within a GDPR-compliant database on a secure SSL-encrypted server.
To see the full list of reasons why to work with Global Citizen Solutions for your Portugal Golden Visa, you can find out more here: Why Work with Global Citizen Solutions for Your Golden Visa Portugal Application?
