Portugal golden visa processing time is the single biggest unknown for families applying in 2026. Submit an application this week and AIMA is likely to schedule your biometrics for May 2027, with the residence card being issued around eight months later. Yet the legal deadline for a decision is 90 working days. This guide explains the gap between what the law promises and what AIMA is actually delivering, and what a new rule in force since 11 September means for delays between the two. Understanding both timelines is essential for investor families planning their move, their children’s schooling and their path to citizenship.
The Short Answer on Portugal Golden Visa Processing Time
The law gives AIMA 90 working days, extendable by 30, to decide a first residence permit application, and 60 working days to decide a renewal. In practice, a new application submitted today should expect its first card in early 2028. Paper applications submitted before 2025 face even longer delays, while renewals are taking more than a year. Since 11 September 2026, a renewal that AIMA fails to decide on time is no longer deemed approved. The waiting time is the same; its legal effect has changed.
Portugal Golden Visa Processing Time: What the Law Describes
The Golden Visa, or ARI (autorização de residência para atividade de investimento), lives in article 90.º-A of Lei n.º 23/2007. The qualifying investments are in article 3.º, n.º 1, d): at least €500,000 into a qualifying non-real-estate investment fund, at least €250,000 to artistic production or cultural heritage, or €500,000 into a Portuguese company creating five permanent jobs, each held for five years. Property has been out since Lei n.º 56/2023.
Once the application is submitted through the ARI portal, article 82.º governs the clock. In the wording given by Lei n.º 62/2026 of 10 September, n.º 5 gives AIMA 90 working days to decide a first application, extendable by 30 working days “in exceptional and duly justified circumstances.” N.º 6 keeps the renewal deadline at 60 working days. The article itself says “dias”; they are working days because article 87.º, c) of the Código do Procedimento Administrativo suspends procedural deadlines on Saturdays, Sundays and public holidays, and Lei n.º 23/2007 sets no different rule. In calendar terms, 90 working days is a little over four months and 60 working days close to three. The permit is issued for two years and renewed for two-year periods under article 90.º-A, n.º 2, on proof that the investment is maintained. Minimum physical presence, under Decreto Regulamentar n.º 84/2007, is seven days in the first year and fourteen in each subsequent two-year period.
The Real Portugal Golden Visa Processing Time: What AIMA Is Delivering
In October 2025 the Minister of the Presidency told Parliament that pending Golden Visa files had been “left for the end,” for reasons of social equity, and would be resolved in 2026, a statement tied to €85 million of expected AIMA fee revenue. In December 2025, when we filed an amicus curiae brief with the Constitutional Court, the files it described had been waiting since 2021. Executive Digest reported in April 2026 a renewal that had taken 25 months, in a universe of 12,178 Golden Visa holders, with around 4,000 complaints against AIMA reaching the Ombudsman in 2025.
What our own files show, as of this week, is a queue running at two speeds.
Applications submitted through the ARI portal since 2025 move on one track. An investor who submits now is being given a biometrics appointment for May 2027, roughly eight months out. The residence cards arriving in our office this month belong to biometrics taken in January 2026, so the step from fingerprints to card is currently running at about eight months as well. Put together, a complete file submitted today can reasonably expect its first card in early 2028.
Applications submitted before 2025, still on paper, move on a slower track, and their pace depends almost entirely on the AIMA office where the file sits. Lisboa 1, the office with the largest ARI caseload, is at the time of writing analysing files submitted in November 2024. For these investors the relevant question is which counter holds the file, and the answer moves the estimate by many months.
Anyone who promises a number of months without asking when and how the file was submitted is guessing.
What Changed on 11 September for Portugal Golden Visa Processing Time
Lei n.º 62/2026 did two things to article 82.º that matter to every Golden Visa holder. It lengthened the first-decision deadline from a flat 90 working days to 90 plus 30. And it repealed n.º 7, under which a renewal not decided within 60 working days, for reasons not attributable to the applicant, was deemed granted, with immediate issue of the card.
Until 10 September, the 60-working-day deadline had practical legal consequences: cross it and the law itself did the deciding. Since 11 September, crossing it produces nothing automatic. Under Articles 128.º to 130.º of the Portuguese Administrative Procedure Code (CPA), in the event of administrative silence, the applicant is entitled to resort to the appropriate judicial remedies. Although the statutory deadline remains unchanged, its expiry no longer produces the same legal consequences as before.
One issue remains unclear: whether renewal applications for which the 60-working-day deadline had already expired before 11 September, and which were therefore deemed approved under the previous wording of Article 82.º, n.º 7, retain that status. Based on the principle of non-retroactivity, our position would be that they do. However, this will need to be confirmed in light of the transitional provisions set out in Article 10.º.
Article 90.º-A, which specifically governs Golden Visas, was not amended. Therefore, the rules applicable to the Golden Visa itself remain unchanged; what has changed are the legal consequences of AIMA’s failure to issue a decision within the applicable deadline.
Why the Wait Now Costs More Than It Looks
A separate timeline must also be considered in relation to Portuguese citizenship. Lei Orgânica n.º 1/2026, in force since 19 May 2026, increased the residence requirement for naturalisation to ten years, or seven years for CPLP and EU nationals. It also repealed Article 15.º, n.º 4 of the Lei da Nacionalidade, under which the period between the application for the first residence permit and its approval was counted towards the residence requirement for citizenship once the permit was granted. Acórdão n.º 1133/2025 of the Constitutional Court did not prevent that repeal from taking effect.
For Golden Visa applicants and their family members, the practical consequence is significant: the period spent waiting for AIMA to issue the first residence permit no longer counts towards the residence period required for citizenship. Therefore, if an application is submitted today but the first residence permit is only issued in early 2028, the applicable residence period for citizenship purposes will only start to count from 2028. The Golden Visa remains a valid route to Portuguese residence; however, delays in the issuance of the first residence permit now have a direct impact on the timeline for eligibility for citizenship. Read our full breakdown of Portugal’s nationality law changes (link da verificare).
The Court Route
Since Acórdão n.º 11/2024 of the Supremo Tribunal Administrativo, the intimação under articles 109.º to 111.º of the CPTA has been the recognised instrument against AIMA’s inaction, now framed by article 87.º-B of Lei n.º 23/2007, whose n.º 2 requires the delay to compromise, seriously and directly, the timely exercise of a personal right.
For an investor whose card has expired or whose children’s residence depends on it, that threshold is usually met, and the courts have been deciding: the 28-judge task force created in April 2026 closed 22,436 cases in three months.
On 18 September, Parliament approved, in general terms only, a legislative authorisation to let these intimações be filed in the court of the applicant’s residence; the operative decree-law does not yet exist.
The Mistakes We See Most Often
Four main mistakes should be avoided: submitting an incomplete application, which may legitimately delay AIMA’s decision; allowing a residence card to expire without requesting renewal, thereby losing the protection provided by Article 78.º, n.º 7; treating the statutory deadline as a guaranteed decision date rather than the point from which legal remedies become available; and, since 11 September, assuming that a renewal is automatically approved after 60 working days of AIMA’s silence.
What You Can Do in General Terms
Keep the file complete and the address current. Record the submission date, the office handling the file and the date each legal deadline expires. Ask AIMA in writing once the 90 or the 60 working days have run. Treat the intimação as the ordinary instrument it is, and decide its timing with your adviser. Plan citizenship from the date on the card.
If you want a clear read on your own Portugal golden visa processing time, our team at Liberty can review your file against the rules currently in force — see our Golden Visa services (link da verificare).
Why We Expect These Figures to Improve
Two things deserve to be said in AIMA’s favour, because fairness cuts both ways. The Government has committed publicly to clearing the pending ARI files by the end of 2026, and that commitment is now on the record with a budget attached to it. And in our own office the files are moving faster than they did a year ago: appointments are being issued, cards are arriving, and the paper backlog in the older offices is being worked through, unevenly but visibly. Our estimate, for what an estimate is worth, is that the eight-month gaps described above will shorten over the coming months. We will update this article as our files show it. What we will not do is plan a client’s life on a promise before it has been kept.
The Golden Visa remains, in our view, a sound residence programme with a lawful investment at its core, however, a State that lengthens its own deadlines and removes the consequence of missing them owes applicants a clear account of how long they will wait.
If you are planning a Golden Visa application or renewal and want your timeline assessed on the rules currently in force, you can reach our Lisbon team through our contact page.