Key figures — as of 2026-09-07: Naturalisation residency requirement raised from 5 years to 10 years for most foreign nationals (7 years for EU/CPLP nationals) — law in force since 19 May 2026 — residency clock now starts from the date the first residence card is issued, not the application date — AIMA card-issuance delays currently run 12–36 months for Golden Visa (ARI) applicants.
What changed, and why it matters now
Golden Visa investors planning around a five-year route to a Portuguese passport need to redo the maths. Portugal's revised Nationality Law — Organic Law No. 1/2026 — took effect on 19 May 2026, and the residency period rose to ten years for most applicants, seven for EU and CPLP nationals, with the clock now starting from the issuance of the first residence permit. For the thousands of non-EU investors who bought into the ARI programme expecting citizenship inside half a decade, that's not a tweak — it's a different plan entirely.
The change was signed into law by President António José Seguro, who promulgated Portugal's revised Nationality Law on May 3, 2026, before it entered into force in mid-May. The scale of the shift is being described bluntly by immigration lawyers: for thousands of foreign residents and Golden Visa investors, the previous five-year path to citizenship has been replaced by a much longer and more uncertain process.
The clock now starts later than most people assumed
The headline number — five to ten years — is only half the story. The more consequential detail is when that clock begins. Previously, residency time could be counted from the date an application was submitted. Under the new framework, administrative practice generally counted residency from the date the first residence application or manifestation of interest was submitted, but under the new law the clock now starts from the date your first residence permit is actually issued, not from submission.
That matters enormously for Golden Visa applicants specifically, because AIMA's processing backlog means the gap between filing and actually holding a card can itself run into years. As one legal analysis puts it: due to delays at AIMA, many residents wait 18 to 24 months for their first residence card, and when this delay is added to the new 10-year requirement, the actual period from arrival in Portugal to citizenship eligibility may now exceed 12 or 13 years.
The government has said the change isn't meant to punish people for state delays, but it hasn't retroactively fixed the gap between application and card issuance either. The relevant official position, cited in legal press, stated that the residency clock will run from the date the residence title is obtained, reversing the 2024 provision that counted time from the moment a residence permit was requested.
GrowIN's read on the numbers
Here's the calculation that matters for anyone weighing up an ARI investment today. Current Golden Visa processing at AIMA runs approximately 12–36 months before a first residence card is even issued. Take the midpoint — roughly 18–24 months — add it to the new 10-year requirement for non-EU/CPLP nationals, and an investor filing their ARI application in September 2026 is realistically looking at citizenship eligibility somewhere around 2037 to 2039, not 2031 as the old five-year rule would have suggested. That's an additional six to eight years of holding an investment, filing tax returns, and renewing permits before a passport application can even be lodged — a materially different commitment than what was marketed to investors as recently as last year.
"The Golden Visa hasn't closed, but the finish line for citizenship has moved a decade further down the track for most investors," says GrowIN Portugal Editorial.
Who's protected, and who isn't
Not everyone is affected equally. Applications already filed before the cut-off keep the old rules: applications formally submitted to the IRN on or before 18 May 2026 are assessed under the previous five-year framework. But there's no soft landing for people who were close to the finish line without having actually filed. As one relocation adviser notes, if you had gathered your documents, passed your language test, or been intending to apply but had not yet submitted, you are unlikely to benefit from the old rule, and no general grandfathering provision was included.
EU and CPLP nationals fare better under the new tiers, though the gap between the two tracks isn't a simple EU/non-EU split. The dividing line is nationals of EU member states and Portuguese-speaking countries — a Brazilian and a German are on the same seven-year track. Americans, Britons, Canadians, Australians and most other nationalities fall into the ten-year bracket.
What hasn't changed
Crucially, the Golden Visa residence programme itself is untouched. Investment routes, minimum stay requirements and permanent residency timelines remain as they were — the law took effect on May 19, 2026, extending the standard naturalisation period from 5 to 10 years while leaving the Golden Visa residence programme itself unchanged. Permanent residency after five years of investment is still on the table for those who want it without pursuing a passport.
What to watch next
Applicants currently mid-process should confirm the exact issuance date on their first residence card with AIMA, since that date — not the investment date or application date — now anchors the entire naturalisation timeline. Anyone weighing a Golden Visa purely as a fast route to an EU passport should treat the ten-year (or seven-year) figure as the realistic planning horizon, not the investment or renewal cycle. For a full breakdown of current Golden Visa routes and eligibility, see our visas hub, and speak to a qualified immigration lawyer before filing — outcomes depend on AIMA's processing pace and individual circumstances, which no article can guarantee.
The direction of travel is clear even if the exact administrative mechanics are still being tested in practice: Portugal's citizenship-by-investment pathway is now a long-haul commitment, not a five-year exit strategy.