Key figures — as of 2026-09-12: Law 62/2026 published 10 September 2026 (Diário da República n.º 176/2026), in force since 11 September — closing the tourist-to-student-course route that had become Portugal's de facto replacement for the old "manifestação de interesse"; new EU-driven 90-day decision deadline (extendable by 30 days) for residence permit applications; the 2024–2025 predecessor reform already cleared roughly 500,000 pending cases, rejecting about half, with a hard cutoff of 31 December 2025 for the last transitional applicants.
What actually changed on 11 September
Portugal's immigration law has been rewritten piece by piece since mid-2024, and Law 62/2026 is the latest — and by most legal readings, one of the final — nails in the coffin of "arrive first, regularise later." Law 62/2026 is dated 10 September and was published that same day in Diário da República n.º 176/2026, with the diploma establishing that it enters into force the day after publication — meaning Friday, 11 September was the first day of application.
The specific mechanism it closes is narrower than the original 2024 reform but arguably just as consequential. The new regime now requires, in situations covered by article 92, that applicants hold a residence visa for a residence permit to be granted to secondary-school or level-4 course students, in addition to the other legal conditions. That clause had quietly become the main workaround people relied on after the government shut the original loophole. This change comes after Portugal had already closed, in 2024, the manifestações de interesse regime that let certain foreign nationals try to regularise their situation in Portugal without having first obtained the corresponding residence visa.
Once that door closed, another opened — and lawmakers have now shut that one too. The mechanism of entering Portugal as a tourist and requesting, once already in national territory, a visa for professional study became a workaround, and the decision was taken because this regularisation mechanism, despite being provided for in law, was being used as a kind of expression of interest. Many immigrants, particularly Brazilians, had been coming to Portugal without a consular visa and, once on national territory, enrolling in professional schools as a route into legal residency. That path is now formally shut.
The 90-day clock and what it really means
The other headline element of Law 62/2026 comes from Brussels rather than São Bento. The law transposes the European Pact on Migration and Asylum, approved on 14 May 2024, into Portuguese law. Among its technical provisions: the transposition of Directive (EU) 2024/1233 introduces a 90-day decision deadline, extendable by 30 days, for residence permit applications, along with the possibility of changing employer or activity.
On paper that sounds like good news for applicants stuck in AIMA's backlog. In practice, it cuts both ways. GrowIN Portugal's analysis: a maximum 90+30-day window is a dramatic improvement against the multi-year waits many applicants have faced — but it only helps people who already qualify to apply through a recognised channel. For the much larger pool who previously counted on entering as tourists and regularising later, the relevant number isn't 120 days; it's zero, because the application itself is no longer possible without a visa issued abroad. Tightening the clock at the back end while closing the door at the front end is not the same as making the system faster for the people currently in the country undocumented.
Why this hits harder than earlier reforms
This is now the third distinct closure in roughly two years. First came the end of manifestação de interesse itself in June 2024. Then, the mechanism that allowed undocumented migrants to regularise their status based on proof of employment and social security contributions was definitively eliminated, with a transitional deadline requiring those registered with social security and working as of 3 June 2024 to apply by 31 December 2025, after which the regime lapsed. That original 2024 abolition saw the government clear approximately 500,000 pending cases, rejecting roughly half. Now the professional-course workaround that filled the gap is gone too.
"Every route back into the system that didn't start at a Portuguese consulate has now been closed, one law at a time," is a fair summary of where policy stands — GrowIN Portugal Editorial.
Practical implications
Anyone currently in Portugal without a residence visa — including those who entered as tourists hoping to enrol in a course and convert their status later — no longer has that option under article 92. Existing residence permit applications lodged before 11 September should still be assessed, but new applications built around the tourist-to-student route will be refused. Family members, CPLP nationals and others affected by adjacent 2025–2026 reforms should check their specific category directly with AIMA (https://aima.gov.pt) rather than assume older guidance still applies — the rules have shifted at least three times since 2024 alone.
For genuine long-term routes into Portugal, the D7, D8 Digital Nomad, Startup Visa and Golden Visa fund route remain open and unaffected by this specific law; see our visas hub for the current requirements on each.
What to watch next
Regulations implementing some of Law 62/2026's asylum-reception provisions are still pending, and legal challenges to related 2026 reforms — including the nationality law amendments — remain active before the Constitutional Court. Anyone with a pending case, or considering a move to Portugal without a pre-approved visa, should treat this as a moving target and get current, case-specific advice before making any decisions based on older information.