Key figures — as of 2026-10-03: Old job-seeker visa suspended 23 October 2025 under Law 61/2025 — 345 days ago; replacement "visto para procura de trabalho qualificado" (Article 57-A) still cannot be requested at any consulate; implementing portaria (joint ministerial ordinance covering foreign affairs, migration, education and labour) not yet published; visa would run 120 days + 60-day extension, with estimated subsistence proof cited around €2,600–€3,280, pending final regulation.
A visa that exists only on paper
Portugal's job-seeker visa has been frozen for nearly a full year, and foreigners hoping to use it as a stepping stone into the country are left rearranging their lives around a law that technically exists but practically doesn't. The old route — which let non-EU nationals arrive for 120 days, extendable by 60, to hunt for any job — stopped taking applications on 23 October 2025, the day Law 61/2025 came into force. Law No. 61/2025, of 22 October 2025, amended Article 57-A of Law No. 23/2007, the Foreigners' Law, concerning the job-seeker visa. From 23 October 2025, Portuguese consular posts and external visa application centres could no longer accept job-seeker visa applications, since that category no longer existed under its previous terms.
In its place, the law created a narrower successor aimed squarely at skilled professionals — but it never switched on. Instead of the job-seeker visa, a qualified job-seeker visa will exist, for which applications can only be submitted once the new category has undergone the necessary regulation. That regulation is a portaria, a joint ministerial ordinance that has to come from multiple departments at once. According to the text of the law, a joint ordinance between several ministries, including Labour, will be published to define which professions fall into this category. Eleven months later, that document still hasn't appeared.
Why the hold-up matters to real people
This isn't a bureaucratic footnote. In its place comes the qualified job-seeker visa, for professionals with specialised technical skills, authorising them to carry out highly qualified professional activity until the visa expires or a residence permit is granted. To date, this new category still cannot be requested, pending publication of the regulatory ordinance that will define the professions covered. Until that regulation is published, it isn't possible to submit applications for this type of visa.
For someone who built a relocation plan around "arrive, network, interview, convert to residency," that's an indefinite hold. Law firms tracking the reform describe a visa created in statute but inoperable in practice until Lisbon decides which professions actually qualify. A specific visa is created, valid only within Portuguese territory, for candidates who demonstrate specialised technical skills, to be defined by ordinance.
GrowIN's calculation: counting from the suspension date of 23 October 2025 to today, 3 October 2026, the gap sits at 345 days — just three weeks short of a full year with a visa category legally created but administratively unusable. If the ordinance follows the same drafting pace as comparable Portuguese secondary legislation (commonly 6–18 months post-law), hopeful applicants could realistically be waiting into 2027.
"A visa that exists in the statute book but not at the consulate counter isn't a visa — it's a placeholder," says GrowIN Portugal Editorial.
What's actually still open
The practical fallout is that anyone serious about working in Portugal right now needs a job offer first, not a search-and-hope strategy. The visto de trabalho D1 is granted to someone who has an employment contract, a promise of a contract, or an individualised expression of interest from the employer, and the consulate has 60 days to decide the application. Highly qualified professionals with a confirmed role — researchers, senior IT and engineering staff, doctors — can still move through the existing D3 highly-qualified-activity route or the EU Blue Card, both of which remain fully operational and unaffected by the stalled ordinance.
What's gone is the "come first, search later" option that used to suit freelancers, career-changers and anyone without a formal degree lining up interviews in person. Estimates circulating among immigration advisers put the eventual subsistence requirement at roughly three times the national minimum wage for the visa's duration, though — as every source is careful to flag — that figure comes from reading the law's intent, not from a published rule. Nothing about eligible professions, exact financial thresholds or document lists is confirmed until the portaria lands.
What to watch next
Three things will signal movement: a formal notice on the MNE's Vistos portal, publication in Diário da República, or guidance from AIMA's own channels confirming consulates can start accepting applications. None of the three has happened yet. Until one does, our advice for anyone weighing a move is blunt — don't book flights around a visa category that isn't open, and check our visas hub for the routes that are actually functioning today, including the D1 and D3 options that don't depend on this missing regulation.
Outcomes always rest with the Portuguese authorities, and anyone planning a move on the strength of this visa should treat every number above as provisional until the ordinance is signed.