If you have an AIMA Portugal residence permit renewal pending, 10 September 2026 was the last day the law stopped waiting for AIMA on your behalf. Until then, if sixty working days passed with no decision, and the delay was AIMA’s fault rather than yours, your renewal was treated as approved. No official signed it and no judge ordered it — the law did it automatically.
On 11 September, that changed. A new immigration law entered into force, and under the text approved by Parliament, that automatic approval no longer exists.
This article breaks down, in plain language, what the new law does to AIMA’s decision deadlines and what it means when AIMA stays silent on your file. There is a great deal more in the law, and we touch on it briefly — but the change that will affect the largest number of people reading this page is the one about time.
The New Law in One Paragraph
The law is Lei n.º 62/2026, published 10 September 2026 and effective from the following day. Most coverage has focused on its border and asylum chapters — a new screening procedure, faster returns for people refused entry, longer detention periods, and revised asylum timelines, all bringing Portugal in line with the EU’s Pact on Migration and Asylum. The same law also closed the route into residency through vocational courses, narrowed the rule for parents of Portuguese children, and — almost unnoticed — rewrote the article that sets AIMA’s decision deadlines.
How AIMA’s Residence Permit Renewal Deadlines Worked Before 11 September
Lei n.º 23/2007, Portugal’s main immigration law, has always set a deadline for AIMA (formerly SEF) to decide: ninety days for a first residence permit, sixty days for a renewal. Missing a deadline like this usually has a modest consequence — the administration is in breach of its duty to decide, and you can complain or go to court to compel a decision.
Renewals had something stronger. If the sixty-day deadline passed through no fault of yours, the renewal was deemed granted — so-called tacit approval. In practice, AIMA rarely issued cards automatically once the clock ran out, and many applicants still needed to go to the administrative courts to get the card released. But enforcing an approval you already hold is a much stronger legal position than asking a court for a decision you don’t yet have.
What Changes for Your AIMA Portugal Residence Permit Renewal
The deadline for a first residence permit decision is now ninety days, extendable by a further thirty days in exceptional, duly justified cases — provided AIMA notifies the applicant. That puts the outer limit at 120 days. This comes from an EU directive on the single permit, which Portugal transposed late, partly in response to a European Commission warning letter issued in July.
The directive requires the 90-day deadline — it leaves the consequence of missing it to each member state. Portugal’s choice: the government’s text, presented in June and confirmed through to promulgation, removed tacit approval for renewals. The Constitutional Court only reviewed the provisions the President had queried (all on detention, removal, and children); the deadline changes were never before it.
One caveat worth flagging honestly: we have not yet checked the final Diário da República wording of Article 82 word-for-word. If the tacit approval clause somehow survived, we will correct this article — as of writing, everything above reflects the government’s text and the reporting through promulgation.
What This Means If Your AIMA Renewal Is Pending
If your first application is pending, the practical change is simply a longer clock — 90, possibly 120 days, with AIMA required to notify you of any extension.
If your AIMA Portugal residence permit renewal is pending, the change is structural. Under the old rule, sixty days of AIMA silence turned into an approval. Now, once the deadline expires, you’re in the same position as any applicant facing bureaucratic delay: AIMA is in breach of its duty to decide, and your remedy is to ask a court to order a decision through the intimação — the urgent procedure the Supreme Administrative Court confirmed as the correct tool in 2024. It works, and the courts have moved quickly on it — but it’s now a court filing, with a lawyer and a fee, to obtain what the law previously gave for free on day sixty-one.
There’s a fairness dimension too. Tacit approval put the cost of AIMA’s own delay on AIMA. A system where the only consequence is the right to sue shifts that cost back onto the applicant who did everything correctly — a domestic policy choice, not something the EU required.
If Your Renewal Was Already Overdue on 11 September
Many renewals were already past the old sixty-day deadline when the law changed. Portuguese law generally holds that a new law governs the future and doesn’t undo a right that already existed under the old one — but we have seen no transitional rule published for pending residence files (only for pending asylum cases). How AIMA and the courts treat these files will be one of the first real tests of the new law. If this applies to you, the date your sixty days expired is now a critical fact — keep every document that proves it.
What You Can Do Now for Your Portugal Residence Permit Renewal
- Submit a complete application — missing documents restart delays that count against you.
- Keep your payment receipt, which since October 2025 serves as your residence document for 180 days while you wait.
- Keep your address updated with AIMA — all notifications go there.
- Respond to every document request within its deadline — any delay on your side weakens your position later.
- Note the exact date AIMA’s legal deadline expires — under the new law, that date is when you can act, not when the law acts for you.
The new immigration law will be judged mainly on its border and asylum chapters. But for families and investors renewing a residence permit, the part that matters is quieter: how long the state has to answer, and what happens when it doesn’t. Until last week, the law answered for you. Now, in most cases, you’ll need to ask.
If your AIMA Portugal residence permit renewal has passed its legal deadline, Liberty’s team can review your file and explain your options under the law as it now stands. Speak to a Portugal immigration lawyer at Liberty →