Key figures — as of 2026-08-29: AMIGOS Act signed into law 23 December 2022, fully implemented 23 April 2024 — Portuguese nationals now eligible for US E-1/E-2 visas — a 3-year continuous domicile requirement applies to anyone who naturalised via financial investment before applying for E-2 — Portugal's own naturalisation clock, under the new 2026 nationality law, now runs 10 years for non-EU/CPLP applicants, up from 5.
The headline figure
The number that actually matters right now is three — as in three years. That's the continuous domicile period the AMIGOS Act requires of anyone who acquired a treaty-country passport "by making a financial investment," before that passport can unlock a US E-2 treaty investor visa. The rule states that if an alien who has never received an E visa became the national of an E visa-eligible foreign country by making a financial investment in that foreign country, that alien must have been domiciled in that foreign country for a continuous period of at least three years at any point before applying for an E visa. For Americans who came to Portugal on a Golden Visa and are eyeing eventual Portuguese citizenship, that clause — not some fresh Washington drama — is the part worth understanding.
What the AMIGOS Act actually did
Contrary to how it sometimes gets described, this isn't a bill still working its way through Congress. The U.S. Embassy in Lisbon announced the full implementation of the Advancing Mutual Interests and Growing our Success (AMIGOS) Act, signed by President Joseph Biden in December 2022. It created a new non-immigrant category for Portuguese nationals — the E-1 and E-2 trade and investment visas. The bill made Portuguese nationals eligible for E-1 and E-2 nonimmigrant visas if the government of Portugal provides similar nonimmigrant status to U.S. nationals. Portugal already met that reciprocity bar, so eligible Portuguese citizens were able to apply for these visas online starting April 23, 2024. That's the plumbing: it lets Portuguese entrepreneurs and traders move into the US market with fewer hurdles. House Judiciary Chairman Jerrold Nadler put the trade rationale plainly in his floor remarks, calling it a way to let "citizens of Portugal... participate in the E-1 and E-2 visa programs for traders and investors."
The part that touches Golden Visa Americans
The AMIGOS Act's real relevance for GrowIN's American readers sits in its fine print, not its headline. Because Portugal's own Golden Visa leads to citizenship, US lawmakers worried the E-2 route could become a backdoor for investors who buy their way into a passport with no genuine ties to the country. E2 country nationals who are not "domiciled" can no longer get E2 visas if they got citizenship by "financial investment." That domicile clause was written into the AMIGOS text itself and has stayed in force since 2022 — it isn't a new 2026 amendment, but a companion measure, the Senate's E Visa Integrity Act, has kept the issue alive in Washington. Senators Chuck Grassley and Mike Lee introduced S. 2863, the E Visa Integrity Act, which would restrict "investment aliens" from using their newly purchased citizenship to apply for American E visas unless they had lived continuously for three years in their new country. That bill hasn't cleared the Senate, but its existence signals Congress isn't done tightening these rules.
GrowIN's read: the timeline just got longer
Here's the calculation that matters for an American who takes the Golden Visa fund route today. Under Portugal's new nationality law, naturalisation for non-EU, non-CPLP applicants — which covers Americans — now requires 10 years of residence rather than five, with the clock starting from the date the residence permit is issued. Add the AMIGOS Act's 3-year domicile requirement on top, and an American who wants to leverage a Golden Visa-derived Portuguese passport for a US E-2 visa is looking at a 13-year runway in the most literal reading of the rules stacked together — versus roughly 8 years under the old 5-year nationality timeline. That's a meaningful shift for anyone treating citizenship-by-investment as a stepping stone rather than an end goal.
"For Americans using Portugal's Golden Visa as a bridge back into a US investor visa, two unrelated laws just quietly doubled the wait," says GrowIN Portugal Editorial.
Tax ties: a separate, live conversation
Nothing in the AMIGOS Act touches US tax obligations — Americans remain subject to citizenship-based taxation regardless of where they live, filing status unchanged by this treaty. The genuinely live legislative story on that front is the Residence-Based Taxation for Americans Abroad Act (H.R. 10468), introduced in December 2024, which would let qualifying US citizens abroad elect non-resident tax treatment. That bill remains in committee, with the Joint Committee on Taxation still scoring its revenue impact — a separate process worth tracking on our tax & NIF hub for Americans balancing US filing duties against IFICI or NHR-transition planning in Portugal.
What to watch
The Golden Visa's fund-only route still runs a €500,000 minimum through CMVM-regulated vehicles, with AIMA processing typically taking 12–36 months — plenty of time for the rules around both citizenship and E-2 eligibility to keep shifting before any American investor reaches the naturalisation stage. Anyone weighing a Golden Visa application specifically for eventual US mobility should treat AMIGOS Act's domicile clause, the Senate's still-pending E Visa Integrity Act, and Portugal's new 10-year nationality timeline as three separate clocks that all need to run out — and should get tailored advice from an immigration attorney qualified in both jurisdictions before assuming either passport delivers what they expect.
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