Portugal's Citizenship Timeline Extended To 10 Years (May 2026) – What Practitioners Need To Know About Application Timing And Grandfathering

THE MAY 2026 REFORM: LEGAL FRAMEWORK AND TIMING

On May 19^th, 2026, a new set of amendments to the Portuguese Law no. 37/81 of October 03^rd, known as Portuguese Nationality Law, entered into force after a long legislative process that included a Constitutional review and a veto from the Portuguese President.

Th final draft was approved by Parliament on April 01^st, 2026 and later on promulgated by the President of the Republic on May 03^rd, entering into force on May 19^th, 2026 after its official publication on the country’s Official Gazette.

There were various changes introduced with these amendments to the Nationality Law, including to rules on the so-called Citizenship by Ancestry (in Portugal, the technical term translates closer to “Nationality by origin”¹), rules for newborn children in Portugal of foreign parents, stricter requirements regarding criminal backgrounds and the end of the special regime for citizenship by descent for Sephardic Jews.

What investors are most likely to be concerned about are, however, the changes to the rules to acquire nationality by naturalization:

• Citizenship eligibility for foreign residents extended from 5 years to 10 years of continuous legal residency, or 7 years for other EU and CPLP nationals.
• The clock for citizenship now only starts ticking once final approval has been granted, not from the date of submission of the application.

GRANDFATHERING: PRE-MAY 19 vs. POST-MAY 19 APPLICANTS

It is important to establish that nationality law and immigration law in Portugal are viewed and ruled as separate, independent laws. The Golden Visa program, as a residency program is, in its entirety, ruled by Immigration Law. 

The path for citizenship, however, is ruled by Nationality Law, that does not differentiate between the type of legal residents when it comes to the rules to acquire citizenship by naturalization. In other words, these amendments apply to all legal residents in Portugal, such as work-permit holders, students, digital nomads, etc., not only Golden Visa holders.

With that in mind, in practical terms, it is not unequivocal to argue that the constitutional principle of retroactivity, popularly called “grandfathering” should apply to all those who had applied or even obtained a residence permit before the law entered into force.

Retroactivity in the context of nationality law clearly applies to citizenship applications that met all its requirements and had been filed before the amendments entered into force. These applications are guaranteed to be processed under the “old” rules.

When it comes to those who had residence permits or ongoing residence applications in Portugal before May 19^th but did not meet all the requirements for citizenship applications and had not yet filed it, the situation is not at all legally clear.

The Portuguese legal community has different understandings on these situations and there have been several lawsuits and complaints filed to argue against it, as well as against the lack of a transitional regime, but the results of these legal actions may take several months/years to be settled.

Aside from this, the regulations that will implement the practical effects of these amendments have still not been drafted and approved, and we do not have a clear timeline as to when it will take place (although legally, it should be done in the subsequent 90-day period, delays can happen).

Practitioners should manage client’s expectations realistically, and not provide false guarantees that the situation will be reversed or that there were clear violations of this or that constitutional principle. Time and the evolution of the legal actions and implementation of the regulations will tell the best course of action for each case and, at this stage, prudence is recommended.

3. RESIDENCY vs. CITIZENSHIP: THESE ARE DIFFERENT CLOCKS

As the Golden Visa and Citizenship by naturalization are ruled by separate Laws, requirements and timelines are also somewhat independent.

The residency requirements under the Golden Visa remain unchanged. Investors and their families must be physically present in Portugal for a minimum of 7 days in the first year after receiving final approval, and a total of 14 days every two subsequent years-periods.

After five years of holding the Golden Visa, should they chose to, they may apply for Permanent Residence in the country, that also has minimum stay requirements and is valid for 5-year periods.

For an USA or Chinese investor, for example, after 10 years of continuous legal residency – for example, 10 years of holding the Golden Visa, or 5 years of holding the Golden Visa plus 5 years of holding permanent residence – investors are allowed to request for Portuguese Citizenship, provided all other requirements are met. This timeline can be reduced from 10 to 7 years if the investor is from a CPLP country.

The practical implication is that investors must now wait longer to be able to apply for Citizenship, but still do not need to physically relocate to Portugal in order to acquire it.

Regarding the investment conducted, Permanent Residency generally allows investors to exit their investments and maintain their Residence status – depending on each circumstance and private investment agreements.

4. EU/CPLP ADVANTAGE: 7-YEAR TIMELINE

Other EU or CPLP (Portuguese-speaking countries) nationals have a right to a 7-year citizenship timeline instead of 10. As Golden Visa investors cannot have EU citizenship to qualify for the residence program, we will focus only on CPLP nationals for this article.

CPLP countries have shared historical heritage and since the 80s and 90s have developed bonds of international cooperation in political, social, cultural and economical fields. Citizens from Angola, Brazil, Cape Verde, East Timor, Equatorial Guinea, Guinea-Bissau, Mozambique, São Tomé and Príncipe are allowed to apply for citizenship after 7 years of holding legal residence in Portugal.

In practical terms under the new rules, a Brazilian who received their final approval for a Portuguese Golden Visa in August 2026 will be eligible for Portuguese citizenship, if all other requirements are met and keeps renewing their residency, in August 3033.

A USA investor who receives the approval on the same date will have to wait until August 2036. 

In practical terms, the new citizenship rule increased the timeline for citizenship by only 2 years for CPLP nationals, which is not as dramatic as the five year increase for other nationals, thus remaining highly attractive and competitive.

5. REALISTIC CLIENT CONVERSATIONS: TIMEFRAME AND STRATEGY

Realistically, the Portuguese Golden Visa is no longer a fast path to EU citizenship for most investors; however, it is still one of the only EU countries that has a residency program that can lead to citizenship with minimum physical presence.

Choosing which immigration program is more suitable for an investor will depend entirely on their backgrounds, personal circumstances, short and long-time goals and expectations regarding timelines and costs.

If they are simply looking for an immediate second citizenship for better mobility, other non-EU programs could be more interesting, or even EU citizenship by ancestry programs, if they qualify – that can also be complex and time-consuming.

On another hand, if they are looking for an EU country as a base to access other countries in the Schengen space from time to time, Portugal Golden Visa becomes highly attractive, and acquiring citizenship from an EU country comes as a bonus after 7-10 years.

For other investors, combining two or more immigration programs could be highly advantageous as well, for example a Caribbean citizenship by investment program alongside the Portuguese Golden Visa.

It is also important to consider the costs and timeline involved. The Portuguese Golden Visa requires a minimum EUR 200,000 (for the so-called donation path) investment, and is more popular for its EUR 500,000 investment fund path, aside from administrative costs, government fees and professional fees. The initial residence permit can take 2 years or more to be granted, although there have been improvements on the timeline by AIMA, and the path to citizenship can now take to 7-10 years.

7. CLOSING: NAVIGATING THE NEW REALITY

In conclusion, Portugal’s citizenship timeline has been extended, but a few practical and operational guidelines are still to be drafted and approved by the Government, which will be relevant to assess old Golden Visa applicant’s circumstances.

For new applicants, the scope of those who look for Portugal’s immigration programs is likely to shift from investors looking for quick access to EU citizenship, to those looking for easy Schengen access with minimum physical presence requirements, and a long-term plan B.

Practitioners should adapt to each client’s specific circumstances, needs and expectations, and a multi-jurisdiction strategy can be the key to help them achieving their goals.

As regulations continue to evolve, maintain updated information on IRN channels (Portuguese entity responsible for nationality process), legislative developments and official communications from the government.

Footnote

^{1. Please note that the Portuguese law does not differentiate between “citizenship” and “nationality”. For the purposes of this article, these expressions are used as synonyms.}

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.