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Portugal Golden Visa Citizenship Timeline 2026: What the New Nationality Law Means

DF

Written by

Dean Fankhauser

Founder and CEO

Published: March 25, 2026 Updated: April 9, 2026
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David Simões Fitas — Portugal Golden Visa lawyer

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Updated 9 April 2026: On 1 April 2026, the Portuguese Parliament re-approved the revised nationality law by a 152–64 vote, extending the citizenship residency requirement from five years to ten for most non-EU nationals (seven years for EU and CPLP nationals). The bill now awaits presidential signature. The residence clock starts from the date the first residence card is issued, not from when the application was submitted.

For fund investors, this means the planning horizon has effectively shifted. While the law is not yet formally in force — it requires presidential promulgation and implementing regulations — the parliamentary supermajority makes a veto unlikely. Investors should now plan conservatively around a ten-year citizenship timeline and treat anything shorter as upside.

This article explains exactly where things stand, what the new timeline means in practice, and how fund investors should think about maturity timelines, fund selection, and citizenship planning under the revised legal landscape.

Key Takeaways

  1. On 1 April 2026, Parliament re-approved the revised nationality law by a 152–64 vote. The ten-year citizenship timeline is now awaiting presidential signature.

  2. The original bill was blocked by the Constitutional Court in December 2025 on four specific provisions (retroactivity, criminal record bars, vague fraud language, nationality cancellation). Parliament amended those provisions and re-approved.

  3. The ten-year residency requirement applies to most non-EU nationals. EU and CPLP nationals face a seven-year timeline.

  4. The residence clock now starts from the date the first residence card is issued, not from when the application was submitted.

  5. Permanent residency after five years is not affected. Even under the ten-year citizenship rule, you can still obtain permanent residency at the five-year mark.

  6. Fund investors should plan around a ten-year horizon. Open-ended funds or closed-ended funds with eight- to ten-year maturities are now strongly preferred.

What Is the Current Law on Citizenship for Golden Visa Holders?

Under current Portuguese law (Law No. 37/81, as amended), foreign nationals can apply for citizenship after five years of legal residency. The five-year clock generally starts from the date the residency application is submitted, provided the application is ultimately approved — though the precise counting method has been the subject of evolving interpretation and is one of the points at issue in the proposed reform.

To qualify, applicants must have maintained legal residency for five years, demonstrate sufficient knowledge of the Portuguese language at the A2 level, hold a clean criminal record, and not have been convicted of a crime carrying a sentence of three or more years under Portuguese law.

For Golden Visa holders specifically, "maintaining legal residency" means keeping the qualifying investment in place (the €500,000 fund subscription), meeting the minimum stay requirements (7 days in Year 1, then 14 days in each subsequent two-year period), and renewing the residence permit at the Year 2 and Year 4 marks.

Portuguese citizenship grants an EU passport with visa-free or visa-on-arrival access to over 180 destinations, the right to live, work, and study anywhere in the European Union, voting rights in Portugal, and the ability to pass citizenship to future generations. Portugal allows dual citizenship, so you do not need to renounce your existing nationality.

What Did Parliament Propose to Change?

In October 2025, Portugal's Parliament approved a reform that would have doubled the citizenship residency requirement from five years to ten years for most non-EU nationals. The vote passed with 157 votes in favour and 64 against, supported by the centre-right AD ruling coalition, the far-right Chega party, and the liberal IL party.

The key changes in the approved bill were as follows. The naturalization period would increase from five to ten years for most non-EU, non-CPLP nationals. For citizens of CPLP (Community of Portuguese Language Countries) and EU member states, the timeline would increase to seven years. The residency clock would start from the date the first residence card is issued, rather than from the date of application, which could add one to three additional years in practice due to AIMA processing backlogs. New criteria around proving a "genuine connection" to Portugal would be introduced. And provisions around loss of nationality for criminal convictions and fraud would be added.

Prime Minister Luis Montenegro framed the reform as aligning Portugal with other European countries where longer naturalization periods are the norm.

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What Did the Constitutional Court Decide?

On 15 December 2025, Portugal's Constitutional Court ruled that four provisions of the nationality law reform were unconstitutional. As a result, the law cannot proceed in its current form and must return to Parliament for revision.

The four provisions struck down were: the automatic denial of citizenship for people convicted of crimes with sentences of two years or more, which the Court found to be a disproportionate restriction on access to citizenship; vague "fraud" language that could prevent nationality consolidation for good-faith applicants, because the rule did not clearly define when it applied; provisions allowing cancellation of nationality for undefined conduct "against the national community," because the law did not explain what behaviour this meant; and a related change to the Penal Code allowing loss of nationality as an accessory criminal penalty.

Critically, the Constitutional Court did not strike down the ten-year citizenship timeline itself. The extended residency requirement remains in the reform package as approved by Parliament. However, because the Court found specific provisions unconstitutional, the entire bill must return to Parliament for amendment before it can be promulgated.

The Court also found it unconstitutional to retroactively apply the new, longer timelines to people with pending citizenship applications. This provides a degree of protection for applicants who filed under the existing five-year rule.

Where Does the Law Stand Right Now?

As of April 2026, the revised nationality law has been re-approved by Parliament and is awaiting presidential signature. Here is the full legislative timeline:

October 28, 2025: Parliament approves the nationality law reform with 157 votes in favour.

November 13, 2025: The Socialist Party (PS) bypasses the President and requests a preventive constitutional review by the Constitutional Court.

December 15, 2025: The Constitutional Court declares four provisions unconstitutional and sends the bill back to Parliament.

January 2026: The Constitutional Court's written decision is published. No further parliamentary debate can occur until the new President, Antonio Jose Seguro (who took office on 9 March 2026), is formally in post and three new Constitutional Court judges are appointed.

March 2026: The Nationality Law is placed on the parliamentary agenda for reconsideration in April 2026.

April 1, 2026: Parliament re-approves the amended nationality law by a 152–64 vote, removing the provisions the Constitutional Court struck down. The ten-year timeline for non-EU nationals and seven-year timeline for EU/CPLP nationals are confirmed.

What happens next: the bill goes to President Antonio Jose Seguro for signature. Given the two-thirds parliamentary supermajority, a presidential veto would be overridden on return. Once signed, implementing regulations will follow. The law is expected to enter into force within months, though the exact date will depend on the regulatory timeline.

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What Does This Mean for Golden Visa Fund Investors?

For investors considering the Golden Visa today, the current five-year citizenship path is still available — but the window may not be open indefinitely. The government has repeatedly signalled its intention to extend the timeline, and the 10-year requirement itself was not found unconstitutional.

This creates a strategic calculus: investors who apply now begin their five-year clock under the current rules. If the amended law is eventually enacted without transitional protections for new applicants, those who waited may face a 10-year timeline instead. Many immigration lawyers are advising clients to begin the process now to secure the most favourable position.

The Permanent Residency Safety Net

Even if citizenship timelines are extended, the right to apply for permanent residency after five years is not affected by the proposed changes. Permanent residency allows you to live and work in Portugal indefinitely without renewing temporary permits, and provides visa-free travel within the 29-country Schengen area for up to 90 days in any 180-day period. It does not grant an EU passport or voting rights, but it provides a stable residency status while you wait for citizenship eligibility.

In a 10-year scenario, the practical path would be: Years 1-5 on the Golden Visa (temporary residence permit, renewed at Year 2 and Year 4), then apply for permanent residency at Year 5, then wait an additional five years before applying for citizenship at Year 10.

Fund Maturity Implications

This is where the nationality law uncertainty directly affects fund selection. Under the current five-year rule, a fund with a six- to eight-year maturity aligns well — your investment is maintained through the citizenship eligibility window with some buffer.

Under a potential 10-year rule, the calculus changes. A closed-ended fund with a seven-year maturity would liquidate three years before you reach citizenship eligibility, potentially requiring you to reinvest in another fund to maintain your residency status during the gap. Investors planning for a possible 10-year scenario should consider open-ended funds (which allow indefinite holding), funds with longer maturity timelines (eight to ten years), or funds with extension provisions that could bridge the gap.

David Simões Fitas — Portugal Golden Visa lawyer

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Work with licensed Portuguese lawyers on your Golden Visa application.

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How Should Fund Investors Plan for Both Scenarios?

Factor5-Year Citizenship (Current Law)10-Year Citizenship (If Enacted)
Minimum investment hold5 years5 years (for permanent residency); 10 years total for citizenship
Ideal fund maturity6-8 years8-10+ years, or open-ended
Closed-ended fund riskLow — maturity aligns with timelineHigher — fund may liquidate before citizenship eligibility
Open-ended fund advantageModerate — flexibility after 5 yearsHigh — can hold indefinitely until citizenship
Reinvestment riskMinimalSignificant if fund matures before Year 10
Permanent residencyAvailable at Year 5Available at Year 5 (unchanged)
Citizenship applicationYear 5Year 10
Total estimated cost~€570,000-€645,000 over 5 years~€700,000-€800,000+ over 10 years (additional renewals, fees, travel)

The most prudent approach is to select a fund structure that works under both the current five-year rule and a potential 10-year rule. Here is how the two scenarios compare for fund selection:

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The Open-Ended Fund Advantage

In an uncertain legislative environment, open-ended funds provide a structural advantage. Because they do not have a fixed maturity date, you can hold your participation units for as long as needed — whether that is five years, seven years, or ten years. You are not forced to reinvest if the citizenship timeline is extended.

The trade-off is that open-ended funds typically invest in liquid assets (listed Portuguese equities and bonds) rather than private equity or venture capital, which may limit return potential compared to closed-ended alternatives. However, for investors who prioritise flexibility and immigration certainty over maximum returns, this trade-off may be worthwhile.

The Closed-Ended Fund Approach

If you prefer the potentially higher returns of private equity or venture capital funds, look for vehicles with maturity timelines of at least eight years, ideally with one- to three-year extension provisions. This provides coverage under both the current five-year rule and a potential 10-year scenario, with the extension clauses adding further buffer.

Also confirm whether the fund allows participation unit transfers on a secondary market. If you need to exit before the fund's maturity (for example, because you have already obtained citizenship), the ability to sell your units to another investor provides an exit mechanism.

Frequently Asked Questions

The five-year rule under Law No. 37/81 is technically still in effect until the revised law is signed by the President and enters into force. However, Parliament re-approved the ten-year timeline on 1 April 2026 by a supermajority, so the change is now highly likely to take effect. Investors should plan around the ten-year horizon.
No. The Constitutional Court struck down four specific provisions of the nationality law reform — related to criminal record bars, vague fraud language, nationality cancellation criteria, and retroactive application to pending cases. The 10-year residency requirement itself was not among the provisions found unconstitutional. It remains in the reform package and could be enacted once Parliament amends the unconstitutional provisions.
Parliament re-approved the amended bill on 1 April 2026. It now goes to President Antonio Jose Seguro for signature. Once signed, implementing regulations will follow. Given the two-thirds parliamentary majority, a presidential veto would be overridden on return. Most observers expect the law to enter into force in mid-to-late 2026.
The Constitutional Court specifically ruled that it is unconstitutional to require people with pending citizenship applications to meet the new, longer timelines. This provides protection for applicants who have already filed under the five-year rule. However, the treatment of current residency holders who have not yet filed for citizenship remains an open question that will depend on the final transitional provisions adopted by Parliament.
No. The proposed changes affect only the citizenship timeline — how long you must hold residency before applying for Portuguese nationality. The Golden Visa programme itself, including the €500,000 fund investment route, minimum stay requirements, family inclusion, Schengen travel rights, and the ability to live and work in Portugal, is entirely unaffected.
Yes. The five-year threshold for permanent residency is not affected by the proposed nationality law changes. You can apply for permanent residency after five years of legal residency, provided you meet the requirements (A2 Portuguese language proficiency, clean criminal record, sufficient financial means, proof of accommodation). Permanent residency provides indefinite residency rights but does not grant an EU passport.
This is ultimately a personal decision, but the strategic logic favours acting sooner. Investors who begin the process now start their five-year clock under the current rules. If the amended law is enacted without transitional protections for new applicants, those who waited will face the longer timeline. Many immigration lawyers are advising clients to apply now to secure the most favourable position. The downside of acting now is limited — even in a 10-year scenario, you still obtain residency, Schengen access, and permanent residency at Year 5.
If the 10-year rule is enacted, your fund investment may need to be maintained for up to 10 years to support ongoing residency renewals before citizenship eligibility. This means closed-ended funds with six- to seven-year maturities could liquidate before you reach eligibility, requiring reinvestment. Consider open-ended funds (no fixed maturity), closed-ended funds with eight- to ten-year timelines, or funds with extension provisions. For a full comparison, see our article on open-ended vs. closed-ended Golden Visa funds.
If you are approaching the five-year mark under the current law, consult your immigration lawyer about filing your citizenship application as soon as you are eligible. Applications submitted under the current five-year rule are protected — the Constitutional Court ruled that pending applications cannot be retroactively reassessed under new, longer timelines.

Timeline: Key Dates for Fund Investors

2023, October: Real estate removed from Golden Visa; fund route becomes primary pathway.

2025, June: Portuguese government proposes nationality law changes.

2025, October 28: Parliament approves 10-year citizenship timeline (157-64 vote).

2025, November 13: Socialist Party requests Constitutional Court review.

2025, December 15: Constitutional Court strikes down four provisions; law sent back to Parliament.

2026, January: Written decision published. New President (Antonio Jose Seguro, inaugurated 9 March) and Constitutional Court judges pending.

2026, March: Nationality Law placed on parliamentary agenda for April 2026 reconsideration.

2026, April 1: Parliament re-approves the amended nationality law by a 152–64 vote. Ten-year timeline for non-EU nationals and seven-year timeline for EU/CPLP nationals confirmed.

Next: Presidential signature, implementing regulations, and entry into force (expected mid-to-late 2026).

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Have questions about the fund route, fees, or your application? Speak directly with a licensed Portuguese lawyer — no commitment required.

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How MovingTo Can Help

Portugal Golden VisaCitizenship TimelineNationality LawConstitutional CourtFund InvestorsPermanent ResidencyEU CitizenshipGolden Visa 2026

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David Simões Fitas — Portugal Golden Visa lawyer

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About the Author

Dean Fankhauser photo
Dean Fankhauser

Founder and CEO of Movingto. Has overseen 2,500+ Golden Visa applications with a 100% approval rate and 10+ years in cross-border investment advisory.

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