Key figures — as of 2026-08-20: Organic Law 1/2026 entered into force 19 May 2026, raising the naturalisation wait from 5 years to 7 years (EU/CPLP nationals) or 10 years (all others) — clock now starts from the date the first residence permit is issued, not the application date — only nationality applications filed at IRN on or before 18 May 2026 keep the old 5-year rule — AIMA Golden Visa processing already runs 12–36 months, so investors waiting on a first card face a compressed and uncertain timeline.
One law, three very different clocks
Foreigners who bought into Portugal's Golden Visa expecting a five-year path to a Portuguese passport are discovering that the date on a piece of paper — not the date they wired their investment — now decides which rulebook applies to them. Organic Law 1/2026, in force since 19 May 2026, was approved by Parliament on April 1, 2026, signed by the president on May 3, 2026, and entered into force on May 19, 2026, doubling the standard residency requirement so most foreign nationals now need ten years of legal residence, while EU and CPLP citizens face seven.
That alone is a headline change. What makes it messier for Golden Visa holders specifically is the transitional wording. Nationality applications already submitted to the IRN on or before May 18, 2026 continue to be processed under the previous five-year regime. Miss that cut-off — even by a day, even because AIMA hadn't yet issued your card — and a different law applies entirely.
Why the fee-payment date matters so much
The practical problem is sequencing. An investor cannot file a nationality application without a valid, issued residence permit. Many Golden Visa investors who paid their investment and application fees years ago are still waiting on AIMA to physically issue that first card — a backlog our fact sheet already flags as running 12 to 36 months. In practice, a significant number of investors have waited three to five years for their residence permits to be issued, with some applications dating back to 2021.
For this group, the new law offers no comfort. For Golden Visa and other residence-permit holders who have not yet filed a nationality application, the new 7- or 10-year requirement applies to any nationality application submitted from 19 May 2026 onward, and whether prior residency time counts toward the new clock is currently disputed and the subject of an ongoing collective legal action. That dispute is not academic — a collective legal action involving more than 500 investors, organised by Liberty Legal and Prime Legal, is forming around this question. Separately, the sequencing problem is at the heart of an Ombudsman complaint filed on investors' behalf.
The law also changes how the clock itself is measured. The law tightens how residence time is calculated by counting only periods of lawful residence supported by valid work/residence permits, starting the clock on the date the residence permit is issued rather than the date of application. Investors who assumed their years of waiting for AIMA would count toward citizenship may find those years erased entirely once the card finally arrives.
GrowIN's read on the numbers
Here's the arithmetic that should worry investors most: someone who invested in 2021 under the promise of a five-year route, but is still waiting on their first residence card in 2026 because of AIMA's backlog, could now face a full new 10-year clock starting only once that card is issued — potentially pushing eligibility to apply for citizenship into the mid-2030s, roughly fifteen years after the original investment, rather than the 2026 date the old regime implied. That is our own calculation, not an official figure, but it illustrates why so many investors are alarmed rather than merely inconvenienced.
"For Golden Visa investors, the difference between citizenship at year five and citizenship at year fifteen now hinges on a single stamped date they may not control," says GrowIN Portugal Editorial.
What's still unresolved
Not every account of the transitional rules agrees. Some commentary suggests fee-payment dates before gazetting could anchor the clock, and that constitutional arguments about state delay might force AIMA processing time to count in an applicant's favour — President Seguro made an analogous point on promulgation, expressly noting that "the counting of the legally fixed deadlines for obtaining nationality should not be affected by the slowness of the State". That principle has not yet been tested in a ruling specific to residency-stage Golden Visa holders. AIMA has not yet published guidance, and the Government has 90 days to issue the updated Regulamento da Nacionalidade. Investors should treat any confident "5, 7, or 10" answer with caution until that regulation lands.
What to do now
Check the date on your IRN comprovativo, not your investment contract. If you filed a nationality application before 18 May 2026, you're almost certainly grandfathered under the old five-year rule. If you're still waiting on your first residence card, get legal advice before assuming any prior years will count — and watch for the Regulamento da Nacionalidade, expected within 90 days of the law's publication. Our visas hub tracks Golden Visa and residency changes as AIMA guidance emerges.
This is a fast-moving area with a genuine legal dispute at its centre, and outcomes will differ investor by investor — professional advice, not forum speculation, is the only safe starting point.