Since December 27, 2024, Portugal’s immigration authority (AIMA) has introduced a series of changes in how residency and citizenship applications are processed. These measures were presented as a way to reduce delays, but for many investors, the reality has been uneven progress, inconsistent communication, and ongoing uncertainty.

At IAS, we have been closely monitoring these developments and actively defending our clients’ interests, ensuring that no investor is left without guidance during this critical stage of their immigration process.

What Has Changed

One of the most visible changes has been in appointment scheduling. AIMA has begun contacting applicants directly, sometimes prioritising older cases, but often moving across timelines in an inconsistent manner. For many families, this has created renewed hope — but also confusion when more recent applications are processed ahead of long-standing ones.

Another development is the request for updated documentation. Even though no clear regulation has been issued, AIMA has required some applicants to provide fresh documents with apostilles, adding time and cost to the process without a consistent legal basis.

There is, however, a positive sign in the handling of renewals. Applicants whose biometric data was collected less than 10 years ago (for adults) or 5 years ago (for minors) have been allowed to renew their residency cards without having to provide new biometrics. In these situations, neither the investor nor their family members are required to attend a biometric appointment; instead, they are represented by their IAS lawyer, who will focus on ensuring that all supporting documentation is duly filed. This adjustment reduces unnecessary steps and eases the process for many.

Renewals without new biometrics — no need to travel to Portugal, with your lawyer handling everything on your behalf.
A welcome step that simplifies the process for many investors.

How IAS Protects Clients

Our priority has always been to safeguard investors’ applications and minimize the risks created by sudden procedural changes. To achieve this, we have:

• Monitored every application individually and responded immediately to AIMA’s requests.
• Advised clients strategically on when updated documents are truly necessary, avoiding costs and delays when possible.
• Ensured transparent communication with partners and agents to keep everyone aligned.
• Shared regular updates with investors so they can anticipate potential next steps and avoid unpleasant surprises.

This proactive approach has allowed our clients to move forward despite the lack of consistency in AIMA’s own procedures.

Our Assessment

AIMA’s recent activity demonstrates a willingness to move files and address the backlog. Yet, the system remains unpredictable. Different criteria are being applied to similar cases, and the absence of clear guidelines continues to frustrate investors.

Still, the changes also show good faith. We expect that in the coming months, AIMA will increase the number of appointments and begin applying more standardised criteria for processing. Transparency should improve, but challenges will remain, and timelines are unlikely to be fully predictable in the near term.

The system is moving — but unpredictably. At IAS, our role is to provide clarity where the process itself does not.

Looking Ahead

For investors, uncertainty is always a source of concern. The recent measures by AIMA highlight both opportunities and risks. While some clients are finally moving forward, others continue to face unexpected requests and unclear deadlines.

At IAS, we believe that the best response is vigilance and advocacy. By tracking every file, analysing each change, and working closely with both clients and institutions, we continue to provide clarity where the process itself does not. Our role is not only to navigate these obstacles but also to protect the confidence and trust that investors place in Portugal’s immigration framework.