Background on the nationality law amendments
In October 2025 Portugal’s parliament approved a significant reform of the nationality law. The draft legislation would extend the minimum period of legal residence required for naturalisation from five years to ten years for most non‑EU nationals and to seven years for citizens of other EU member states and the Community of Portuguese Language Countries. Another important change would reset the start of the naturalisation clock: under the proposal, time would only begin counting once a residence permit is issued rather than when the application is submitted. Because residence permits can take two to three years to obtain, this adjustment would lengthen the effective wait for citizenship to as long as twelve or thirteen years in some cases. The bill was sent to the president after the final vote on 28 October 2025.
Immediately after approval, one‑fifth of deputies in the Assembly of the Republic, led by the Socialist Party, petitioned the Constitutional Court to undertake a preventive review. This mechanism, used only a handful of times since the Court was created, automatically freezes a law before it is promulgated. Consequently, the bill cannot be signed or published and none of its provisions can take effect until the Court issues its opinion. The judges have a strict deadline of 25 days from the date the referral is filed to deliver their decision. Until then, the current nationality law remains fully in force.
For readers looking to understand how these developments could affect future applications, Holborn Assets will be holding a webinar on 4 December that breaks down the Court review, the potential scenarios and the Golden Visa process under the rules in force today, with a Q&A session at the end. Register for the webinar here
Implications for current and prospective applicants
Current applicants
For those who are already on the path to citizenship under the Golden Visa or another residency scheme, the most important point is continuity. The existing five‑year rule continues to apply. Applications already filed with the Agency for Integration, Migration and Asylum (AIMA) remain governed by the current legal framework, and there is no requirement to wait longer while the Court deliberates. Applicants should continue to gather documentation – proof of residence, tax compliance, language certificates and integration evidence – and be prepared to submit complete files once they reach the five‑year mark.
Prospective applicants
For people looking to secure a foothold in Europe, the current pause offers a window of opportunity rather than a reason to delay. Although it is not yet clear whether the Court will uphold, amend or strike down parts of the legislation, the Golden Visa continues to operate under the familiar five‑year naturalisation timeline. An investment of €500 000 in qualifying funds, real estate, cultural projects or job‑creation ventures still unlocks a renewable residence permit that extends to family members. Permit holders may live and work in Portugal, access healthcare and education, and enjoy visa‑free travel across the Schengen Area.
Portugal’s appeal goes beyond the legal text. A mild climate, competitive cost of living, safe communities and access to world‑class beaches and cuisine make the country an attractive destination for individuals and families. The Golden Visa further allows investors to pursue a European lifestyle while retaining their original nationality, as Portugal recognises dual citizenship. For entrepreneurs, the country offers a strategic base within the European single market, an emerging tech scene and favourable tax regimes for non‑habitual residents.
Acting now may provide an important safeguard against future changes. Because the nationality law has been suspended pending judicial review, applications filed under the current framework are expected to be “grandfathered” if longer residency requirements are adopted later. Prospective applicants who value certainty should consider their investment and residency process sooner rather than later, ensuring that they benefit from the existing five‑year route to citizenship while positioning themselves to take advantage of Portugal’s many lifestyle and economic benefits.
Why the amendments are controversial
The proposal to extend residency requirements and retroactively change when the naturalisation clock starts has drawn criticism from constitutional scholars, lawyers and advocacy groups. Opponents argue that treating different nationalities differently — seven years for EU and CPLP citizens and ten years for everyone else — may violate principles of equality. They also contend that starting the count only when the residence card is issued penalises applicants for administrative delays outside their control. There is concern that such retroactive changes undermine legal certainty and legitimate expectations of people who have already structured their lives and investments around the existing rules.
Supporters of the reform respond that Portugal’s popularity has surged in recent years. Between 2019 and 2024, the foreign population nearly tripled to around 1.6 million. Over 50,000 foreigners were granted nationality in 2024, but only about 15,000 actually live in the country. Proponents say longer timelines would encourage deeper integration and discourage “passport shopping,” and they note that Spain and many other EU countries require ten years of residence for naturalisation. The preventive review will allow the Constitutional Court to weigh these competing perspectives and assess whether parts of the bill are constitutionally sound.
The broader context of Portugal’s migration policies
Portugal’s Golden Visa programme, launched in 2012, has generated nearly €9 billion in investment and created tens of thousands of jobs. It remains one of the few residency‑by‑investment schemes still operating in Europe. Applicants can invest in private equity or venture capital funds, acquire real estate, support cultural projects or create jobs. Successful investors receive residence permits renewable every two years, with relatively modest physical‑presence requirements (an average of seven days per year). After five years of legal residence, participants can apply for permanent residence or citizenship, provided they demonstrate basic Portuguese language proficiency and integration. Portugal recognises dual citizenship, which is an added advantage over countries that require renunciation of the original passport.
Beyond the Golden Visa, Portugal offers other visas attractive to different profiles. The D7 visa is designed for retirees and people with passive income, requiring a modest monthly income threshold. The digital nomad visa allows remote workers to live in Portugal while working for foreign employers. These options underscore that Portugal is committed to attracting talent and investment while balancing social integration and economic sustainability.
Guidance for navigating the pause
- Maintain documentation: All residents on the citizenship track should ensure that residence permits, tax filings and proof of physical presence are up to date. Robust documentation will be crucial when submitting applications, regardless of future changes.
- Plan ahead: Those nearing the five‑year mark should begin preparing citizenship applications. It is advisable to consult immigration professionals to verify eligibility and prepare language and integration certificates.
- Assess investment timelines: Prospective investors should evaluate how long they plan to maintain ties to Portugal. Even if the residency requirement lengthens, the broader benefits of EU residency – family security, access to world‑class healthcare and education, business opportunities and mobility – still justifies participation. Submitting an application under the current rules may secure a faster path to citizenship for those prepared to invest now and could protect against future extensions.
- Monitor official announcements: The Constitutional Court’s decision, expected by mid‑December 2025, will clarify whether the new law stands as is, is amended or is struck down. Only official publications should be relied upon for accurate information.
Upcoming webinar
To help applicants and prospective applicants understand the evolving landscape, Holborn Assets is organising a webinar titled “Portugal Golden Visa: Everything You Need to Know” on 4th December 2025 at 5:00pm Lisbon time. Jason Swan, Senior Partner, will discuss the Constitutional Court’s review, outline possible outcomes and provide a complete overview of the program. The session will address common questions from prospective investors and explain how to navigate the process under the existing legislation. Interested participants can register below.
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