Key figures — as of 2026-09-28: Law 62/2026, published in the Diário da República on 10 September 2026, sets a 90-day deadline for AIMA to decide residence permit applications — extendable by 30 days in "exceptional and duly justified" complex cases; AIMA issued 386,000 residence permits in 2025; historically the agency has taken two to three years to decide cases against the same 90-day standard that already existed on paper.
The Rule Now Written Into Law
Portugal's new immigration statute puts a hard number on something applicants have argued about for years: how long AIMA is allowed to sit on a residence permit file. The law states that, without prejudice to other decision deadlines set out elsewhere in the statute, an application for a residence permit must be decided within 90 days, which can be extended by 30 days in exceptional and duly justified circumstances, namely due to the complexity of the case. Consumer body DECO Proteste, summarising the practical effect for applicants, confirms AIMA has to comply with the legal 90-day deadline to decide temporary residence permit applications submitted to it, and that this deadline can be extended by 30 days in exceptional and duly justified circumstances, for example due to the complexity of the case. Crucially, the applicant must be informed of this extension — AIMA can't simply let a file go quiet.
Law firm TOF Advogados frames the change as part of a bigger EU-driven overhaul: the transposition of Directive (EU) 2024/1233 brings a 90-day decision deadline, extendable by 30, for residence permit applications, along with the possibility of changing employer without restarting the process. The same package tightens family reunification, with DECO noting the changes include restrictions to family reunification compared with the previous regime, with new integration requirements such as Portuguese language courses.
Not Actually New — But Finally Enforceable
Here's the part that gets lost in the headlines: this 90-day window isn't a brand-new invention. It already existed. Immigration analysis site IMI Daily points out that Portuguese law allows AIMA 90 days to decide a residence permit application under Article 82 of Lei 23/2007, and that in practice AIMA has taken two to three years to issue one, against a legal deadline of 90 days. What Law 62/2026 does is re-anchor that deadline inside the EU's Migration and Asylum Pact framework, spell out the extension mechanism explicitly, and tie it to a directive Portugal is legally obliged to implement — giving applicants a cleaner statutory hook if they end up in court.
That matters, because courts were already the main enforcement route. AIMA had inherited a backlog north of 400,000 files from the old SEF, and the agency's own output — 386,000 permits issued in 2025, a jump of roughly 60% year-on-year — shows real progress on volume, even if individual wait times stayed brutal for many categories, particularly family reunification and job-seeker permits.
GrowIN's Number: The Gap Between Law And Reality
Do the arithmetic and the gap is stark. The new maximum lawful wait, deadline plus extension, is 120 days — four months. AIMA's recent real-world average, per the two-to-three-year figures cited above, sits somewhere between 730 and 1,095 days. Take the midpoint, roughly 913 days, and divide by 120: applicants under the old pattern of delay were waiting close to 7.6 times longer than the new law now permits. Closing even half that gap would be a meaningful shift for the thousands of people currently in AIMA's queue.
"A 90-day deadline only means something if the agency behind it can actually hit it — Law 62/2026 gives applicants the legal footing to demand that it does," says GrowIN Portugal Editorial.
What It Means If You're Waiting
If your file is filed after the law's entry into force, you're entitled to a decision inside 90 days, or 120 with a documented, communicated extension. If AIMA blows past that without explanation, that's grounds for a formal complaint through livroreclamacoes.pt or, for older stuck cases, an administrative injunction — a route immigration lawyers have already used successfully against AIMA in cases predating this law. Keep every confirmation number, payment receipt and portal screenshot; they're your evidence trail if you need to escalate. Our visas hub walks through the current permit categories and what "complete application" actually needs to include, since an incomplete file resets the clock in AIMA's favour.
What To Watch Next
The open question is whether AIMA's internal processing capacity — staffing, digitisation, the Portal das Renovações — can actually absorb this legal pressure rather than just accumulating "complex case" extensions as a default. Watch for AIMA's own implementation guidance and for early court rulings testing what counts as sufficiently "justified" complexity under the new wording; those rulings will decide whether 120 days becomes the real ceiling or just the new, more elaborate excuse.