Key figures — as of 2026-08-02: 90 days — the maximum legal deadline for a decision on a combined residence-and-work permit under Directive (EU) 2024/1233 (down from four months) — transposition deadline was 21/22 May 2026, which Portugal missed — the European Commission opened infringement proceedings against Portugal in July 2026, giving it two months to respond — over 133,000 cases against AIMA were already pending at the Lisbon administrative court as of October 2025.
The number that matters: 90 days
The headline figure is 90. That's how many days an EU member state now legally has to decide on a combined residence-and-work application once it's complete, under Directive (EU) 2024/1233 of the European Parliament and of the Council of 24 April 2024 on a single application procedure for a single permit for third-country nationals to reside and work in the territory of a Member State. It replaces the old four-month window set by the 2011 single permit rules, and it also lets holders of a valid residence permit apply directly from the EU without having to go back to their country of origin.
For anyone who has sat through an AIMA appointment wait, that's the part worth reading twice: this is now a binding EU obligation, not a national aspiration.
Portugal is late — and Brussels has noticed
Here's the twist. Most coverage of this directive has framed 22 May 2026 as the day the new rules "kick in." In Portugal's case, they haven't — at least not in national law. The day passed, the deadline for transposing Directive (EU) 2024/1233 into national law, and it didn't happen, according to Público's legal commentary published in late May.
Brussels responded in July. The European Commission is pursuing Portugal over the failure to notify transposition of the Single Permit Directive, which cuts the decision deadline for residence-and-work applications to 90 days and lets non-EU citizens apply from abroad or, for existing residence permit holders, from inside the member state; Portugal now has two months to report on the progress made. In practice, that clock runs out around September 2026.
This lands against a backdrop of an agency already drowning in its own backlog. In October 2025, more than 133,000 cases against AIMA were pending at the Lisbon Administrative Circuit Court alone — the vast majority filed by people who'd simply had enough of waiting for a decision that never came.
GrowIN's calculation: if Portugal wanted to clear that 133,000-case backlog within a single year — before even starting to process new applications inside the future 90-day window — AIMA and the courts would need to resolve roughly 364 cases every single day, including weekends. That arithmetic is the honest measure of the gap between what Directive (EU) 2024/1233 promises on paper and what's achievable on the ground right now.
What it does — and very clearly does not — change
The confusion online has mostly been about scope. Some social posts have implied the directive lets a residence permit holder in one EU country simply relocate and work in another. It doesn't. The directive does not affect the right of Member States to determine the volumes of admission of third-country nationals, under Article 79(5) TFEU — each country still decides, independently, who gets to live and work there. A Portuguese single permit remains a Portuguese permit.
What genuinely changes, once transposed, is procedural: a maximum response time of up to 90 days after a complete application is submitted; the right to the same pay and working conditions as nationals, including holidays, hours and safety; the ability to change employer after a minimum period set by each Member State; and legal permanence while awaiting renewal, even with an expired document. It also creates a formal complaints and redress route and requires monitoring and inspections against exploitative employers, per the Commission's summary.
The practical takeaway for foreigners in Portugal
Right now, nothing has changed at AIMA counters. Portugal is operating in a legal grey zone: bound by an EU directive whose deadline has passed, without the domestic legislation that would actually give applicants an enforceable 90-day right. Until a transposition law is published in Diário da República, current AIMA timelines, appointment backlogs and the Portal das Renovações process remain what they are. Anyone applying for a work-and-residence permit should keep assembling paperwork exactly as advised on the visas hub and shouldn't expect faster decisions this year on the strength of an EU deadline alone.
As GrowIN Portugal Editorial put it: the mobility this directive delivers is procedural, not geographic — it's about waiting less at AIMA, not about waking up with the right to move to Berlin.
What to watch next
Three things worth tracking over the coming months: whether Portugal publishes transposition legislation before the Commission's September response deadline; whether the European Court of Justice becomes involved if Portugal still hasn't acted; and whether AIMA publishes any operational guidance translating the 90-day rule into actual processing targets. None of that will open a path to freely relocating within the EU — that decision still sits with each member state, Portugal included.
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