We are pleased to inform you that the amendments to the Citizenship Law have been officially published today. As previously mentioned in our communications, these amendments bring significant changes to the citizenship application process. One crucial aspect of these changes is Article 15th which it states: "For the purposes of counting legal residence periods provided for in present law, the time elapsed since the moment in which the temporary residence permit was requested, provided that the same will be granted.” It is worth noting that there has been some ambiguity regarding what constitutes the "request" for a temporary residence permit, particularly concerning the process of acquiring a golden visa for citizenship purposes. As stated in our previous article, available here, several possibilities exist, including: i) The online submission date ii) The date of payment of the online application iii) The date of biometrics iv) The date of biometrics with no notice of further documents missing v) Other moments

Given the intention of the legislator to address the backlog affecting immigration proceedings, we anticipate that the date of online submission or payment will likely be considered as the "request" for the purpose of residency calculations.

While the law is already in force, the regulation will be implemented within the next 90 days. Once this regulation is finalized, we will have a definitive answer to the question of what moment constitutes the request for a golden visa in the context of acquiring citizenship.

Rest assured that the team at IAS is committed to providing you with full support and guidance throughout this process. We will continue to keep you informed of any further developments.