Portuguese Citizenship Law: Proposed Changes and What They May Mean for Golden Visa Holders

The Portuguese Government has proposed changes to the Nationality Law, including a longer residency requirement for citizenship. In this article, we outline what has been proposed, what it may mean for Golden Visa holders, and what you should know if you’ve already applied or plan to apply in the future.

Note: These are proposals — not yet law. The final outcome will depend on the legislative process in the coming weeks or, more likely, the coming months.

Sections

1. What Has Been Proposed?
2. Is This Law Already in Effect?
3. How Does It Affect Golden Visa Holders?
4. What Happens if You Already Applied for Citizenship?
5. What About Future Applications?
6. Can You Still Get Permanent Residency After 5 Years?
7. What Should You Expect Next?
8. Final Notes

What Has Been Proposed?

On June 23, 2025, the Portuguese Government presented a draft law that includes changes to the Nationality Law. The proposal includes:

• Increasing the minimum legal residency requirement to apply for citizenship:
  • 10 years for most applicants
  • 7 years for nationals of Portuguese-speaking countries (CPLP)

• The period starts from the date of issuance of the first residence permit, not the date of application
• New requirements for naturalization:
  • A2-level Portuguese language proficiency
  • Civic knowledge test (Portuguese culture, rights, and duties)
  • No criminal record for crimes punishable by imprisonment
• Ending the Sephardic Jewish ancestry nationality route
• Creating a new public security unit (UNEF) and revising related immigration rules

Is This Law Already in Effect?

No, the law is not in effect. The proposed changes have been presented to Parliament but are not yet approved. The legislative process will likely involve:

• Debates in Parliament
• Potential amendments
• Negotiations with other political parties

At this stage, these are proposals, not law.

How Does It Affect Golden Visa Holders?

The Golden Visa (ARI) is a residency program. The Government has not proposed any changes to the residency rights under this program.

• Your right to residency remains protected once your GV application is submitted
• There was no reference to changes to the Golden Visa itself in this announcement
• However, access to citizenship through the GV route may be impacted by the proposed law, depending on timing

What Happens if You Already Applied for Citizenship?

According to the Government’s own statement:

• The new citizenship rules will not apply to naturalization applications submitted before June 19, 2025
• However, applications submitted with incomplete documentation (e.g., “tick-the-box” filings) may not be accepted

This means:

• If you applied before June 19, 2025, and your file is complete, the current (5-year) rule should apply
• If your application was submitted after June 19th, or is incomplete, the new rules may apply once enacted

Important to Note: A similar stance was taken during the 2023 “Mais Habitação” legislative process. However, retroactive application of a law before it is enacted is widely considered unconstitutional. Therefore, there is a strong legal basis to believe that these proposed changes, which are still not law, would only apply after the law formally comes into effect.

What About Future Applications?

If the proposal becomes law as is:

• New applicants will have to wait 10 years from the date of their first residence card issuance
• They must meet the new language, civic, and clean criminal record requirements
• The Government suggested a need for “real ties” and “belonging to the community” for citizenship eligibility

Can You Still Get Permanent Residency After 5 Years?

Yes, the option for permanent residency (PR) remains.

Key points:

• PR may be granted after 5 years of residence under the Golden Visa
• A2-level Portuguese is typically required

Note: Golden Visa-specific PR rules may differ from regular PR. Please consult your lawyer for case-specific guidance.

What Should You Expect Next?

• The draft law is still under review. Changes may occur during the parliamentary process.
• Industry stakeholders, including lawyers and fund managers, are actively monitoring the situation.
• If passed, the law will only apply to new applications submitted after the law enters into force, except where noted.

Final Notes

This article reflects the current public information available as of June 24, 2025, based on:

• Official statements by the Portuguese Council of Ministers
• Public summaries and legal commentary
• Draft legislative proposals

We encourage all applicants and investors to consult their legal advisors for guidance on their specific situations. This article does not constitute legal advice.

We will continue to monitor developments and update this page as the situation evolves.