On 23 June 2025, the Portuguese Government publicly announced a set of legislative proposals that may reshape the existing immigration and nationality legal framework. Naturally, these announcements have generated interest among our clients and partners worldwide, particularly among Golden Visa applicants and other foreign investors participating in structured immigration programs.

At IAS - International Atlantic Services, we understand that moments of regulatory change can bring questions and concerns. Our commitment is to provide clear, factual guidance on what has been proposed, what it may mean in practice, and why there is no cause for alarm or rushed decisions at this stage. This communication also outlines the proactive measures we are taking to safeguard our clients’ interests.

Part I: Context And What Was Announced

On 23 June, following the Council of Ministers meeting, the Government presented a draft package of legal amendments. These proposals are part of a broader policy review and have not yet become law.

Before any measures can take effect, they must proceed through several formal legislative steps:

• Debate and review by parliamentary committees
• Negotiation and coordination among the main political parties
• A general vote in Parliament, which the Government cannot pass alone due to the absence of a majority
• Final promulgation and signature by the President of the Republic
• Publication in the official national gazette.

During the announcement, the Minister for the Presidency stated that the proposed rules are expected to apply solely to new applications submitted after the law enters into force, providing important reassurance for those with processes already underway.

This aligns with Portugal’s longstanding commitment to legal certainty and protection of acquired rights.

It is also relevant to note that Parliament will recess in mid-July for the summer holiday period. Accordingly, the legislative process is not expected to advance swiftly. A realistic timeframe for debate, revision, and potential approval is estimated between three to six months.

Part II: Overview of the Proposal

The proposed amendments address both nationality eligibility and immigration pathways. The most relevant elements include:

1. Citizenship by Origin (Children Born in Portugal)

• At least one parent must have held legal residence in Portugal for three years at the time of the child’s birth.

2. Citizenship by Naturalization

Updated the minimum residence periods:

• Four years for stateless individuals
• Seven years for citizens of CPLP countries (Community of Portuguese Language Countries)
• Ten years for all other foreign nationals.

Additional requirements:

• Demonstrated knowledge of Portuguese language, culture, and civic responsibilities
• Clean criminal record
• Discontinuation of the Sephardic Jewish naturalization route
• Possibility of revocation of citizenship within ten years in cases of serious criminal conviction

3. Changes to Immigration Rules

• Job-seeker visas limited to highly qualified professionals
• Family reunification available after two years of residence, subject to additional requirements
• Revised criteria for CPLP nationals entering via tourism
• Elimination of tacit approvals of residency applications resulting from administrative delays.

4. Renewals and Enforcement

• Automatic extensions of residence permits will remain valid until 15 October 2025
• From 1 July, AIMA will begin processing renewal applications on a case-by-case basis via a dedicated online platform
• A new national unit will support border control and immigration enforcement

Part III: Stability, Legal Continuity, and Staying Informed

Portugal has a long-standing tradition of protecting acquired rights and consistently applying transitional measures when laws change. In every previous reform, applicants in process were able to proceed under the legal framework in place at the time of submission. While no measures have been approved, this consistent record reinforces the expectation that current applications will remain protected. For those considering applying, this period may be an opportunity to move forward confidently under the existing rules, with professional guidance.

In line with this legal tradition, we expect that any new rules will not be applied retroactively. For example:

• The 2022 Golden Visa reforms were introduced with transitional rules protecting prior applicants
• The 2018 amendments to nationality law also included grandfathering provisions for applicants already in process.

Furthermore, several reputable media outlets have reported that the Government is considering tailored provisions for structured immigration programs such as the Golden Visa, given their regulated nature and economic importance. These discussions reinforce the expectation that existing applications will not be adversely impacted.

While no measures have yet been approved, clients who are currently considering an application may wish to move forward under the current legal framework. We encourage you

to explore your options confidently, while ensuring that any decision is taken in close consultation with your legal advisor to safeguard your interests.

Timeline of the Legislative Process

For clarity, the standard legislative process includes:

1. Government approves and announces the draft proposal
2. Parliamentary specialty committees review the draft
3. Negotiation among political parties to secure majority support
4. General vote in Parliament
5. Signature by the President of the Republic
6. Publication in the official national gazette
7. Entry into force on the date set in the law

With the upcoming summer recess, the legislative process is expected to progress gradually, likely extending over three to six months or longer into the autumn.

Our Commitment

IAS and the Mercan Group have consistently provided clients with transparent guidance and dedicated support throughout previous regulatory developments. We are actively monitoring this situation and remain in close contact with relevant legal and institutional stakeholders.

At this time, there is no legal or political precedent for the retroactive application of reforms of this nature in Portugal, and we believe the country will continue to uphold its legal values of predictability, stability, and fairness.

We encourage our clients to rely on the guidance of your dedicated legal team at IAS and to refrain from acting based on unofficial information or speculation. We will continue to keep you informed with timely, factual updates as new information becomes available.

If you have any questions or would like to discuss your specific case, please don’t hesitate to contact us. We are here to support you every step of the way.

Thank you,

IAS – International Atlantic Services