Submit a Portugal Golden Visa application this week, and AIMA will schedule your biometrics for May 2027, with the card arriving roughly eight months after that. The law says the decision is due in 90 working days. A Portugal golden visa lawyer who tracks both numbers, and the reasons behind them, is what lets an investor plan the move, the schooling, and the citizenship route with real confidence, not a brochure estimate.
This guide sets out what the law promises and what AIMA is actually delivering in 2026. For the rule change on tacit approval specifically, we cover that in full detail in our article on the new renewal deadlines (libertylex.com/insights/aima-portugal-residence-permit-renewal-2026/). Here, we look at the whole picture: submission to card, and card to citizenship.
The Short Answer From Your Portugal Golden Visa Lawyer
The law gives AIMA 90 working days, extendable by 30, to decide a first Golden Visa application, and 60 working days for a renewal. In practice, a complete application filed today should expect its first card in early 2028. Paper files submitted before 2025 sit further back in the queue.
What the Portugal Golden Visa Law Promises
The Golden Visa, known formally as the ARI (autorização de residência para atividade de investimento), sits in article 90.º-A of Lei n.º 23/2007. Investors qualify through one of three routes: €500,000 into a qualifying investment fund, €250,000 into cultural heritage or artistic production, or €500,000 into a Portuguese company that creates and holds five permanent jobs for five years. Real estate stopped qualifying back in 2023.
Under Lei n.º 62/2026 of 10 September, AIMA has 90 working days to decide a first application, with a possible 30-day extension in exceptional cases. Once granted, the permit runs for two years and renews for two-year periods, with a minimum physical presence requirement of seven days in year one and fourteen in each following two-year cycle. For the agency’s own procedures, see AIMA’s official site (aima.gov.pt).
What AIMA is actually delivering in 2026
The Portuguese government told Parliament in October 2025 that pending Golden Visa files would be cleared by the end of 2026. The numbers behind that promise are worth knowing. A renewal reported by Executive Digest took 25 months to process, out of a pool of 12,178 Golden Visa holders. Around 4,000 complaints against AIMA reached the Ombudsman in 2025 alone.
There are two queues moving at different speeds right now. Applications filed through the ARI portal since 2025 are getting biometrics appointments roughly eight months out, landing in May 2027 for new submissions. Cards for investors whose biometrics were taken in January 2026 are arriving this month, another eight-month gap. Put the two together, and a complete file submitted today lands its first card in early 2028.
Paper applications filed before 2025 move on a slower, uneven track. Lisboa 1, the AIMA office with the largest ARI caseload, is currently working through files submitted in November 2024. Which office holds your file matters as much as the date on your submission. Our Portugal Golden Visa page (libertylex.com/portugal/#golden) walks through the current investment routes and requirements.
The Clock That Costs Most: Citizenship
A second deadline runs alongside the residency one, and it’s the one investors planning long-term often miss. Since 19 May 2026, the residence requirement for Portuguese naturalization rose to ten years, seven for EU and CPLP nationals. The change also repealed the rule that let time spent waiting for a first permit count once granted.
The effect is direct. Every month AIMA takes to issue a first card no longer counts toward citizenship. A file submitted today and carded in early 2028 starts its ten-year clock in 2028, not on the day of application. See our Portuguese Citizenship page (libertylex.com/portugal/#portciti) for how the pathway works today.
When the Courts Step In
Since a 2024 ruling from the Supremo Tribunal Administrativo, the intimação, a formal court petition against administrative inaction, has been the recognized remedy against AIMA delays. It applies when the delay seriously and directly compromises a personal right, a threshold most investors with an expired card or a child’s residency at stake will meet. A dedicated 28-judge task force closed 22,436 such cases in three months during 2026.
Four Mistakes Investors Make
An incomplete file gives AIMA a lawful reason to delay. Letting a card expire without requesting renewal forfeits the receipt that keeps it valid. Treating the legal deadline as a promise, rather than as the date a remedy becomes available, costs time. And assuming a late renewal has been approved by silence is no longer safe under the rule that took effect this September, which we break down here (libertylex.com/insights/aima-portugal-residence-permit-renewal-2026/).
Work With a Portugal Golden Visa Lawyer Who Tracks the Real Numbers
The Golden Visa remains a sound residency route built on a real investment. But a state that extends its own deadlines owes applicants a clear answer on how long the wait actually is. Until AIMA gives one, the honest estimate from your Portugal golden visa lawyer is: longer than the law states, shorter for investors who use the law actively, and never as short as the brochure promises.
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