When Portugal’s Parliament approved the Nationality Law reform on 28 October 2025, it did more than extend waiting periods — it rewrote the clock itself. The new law changes both when the countdown to citizenship begins and how time is measured.
For many long-term residents and immigrants waiting on AIMA’s endless queues, these two questions — from when does my residence count? and which rule applies to me? — are not academic. They decide whether one may apply this year or must wait several more.
The Moment of Change
According to the new law’s transitional provision (Article 5.º), the reform will take effect the day after it is published in the Diário da República.
Applications submitted before that date will remain under the old five-year rule. Everything filed afterward will follow the seven- or ten-year residency requirement.
This distinction is vital: it means there is still a narrow window — a final breath before the new regime — for those who have already reached five years of legal residence to apply.
In short:
- If your application for nationality is submitted before publication, it will be decided under the old law.
- If you submit after publication, the new waiting periods (7 years for CPLP/EU nationals, 10 years for others) apply.
The law does not apply retroactively, protecting those who already entered the system. But from its effective date forward, Portugal’s path to citizenship becomes longer.
Counting Time: The Subtle but Crucial Shift
Article 15.º (3) brings a quiet reform that could benefit some applicants — especially those whose residence history has been interrupted.
The new rule states that all legal residence periods — even if non-consecutive — may be counted, provided they fall within a total frame of:
- 6 years for stateless persons and refugees,
- 9 years for citizens of CPLP and EU countries, and
- 12 years for all others.
This provision recognises that migration is rarely linear. Many residents experience temporary gaps — waiting for renewals, changing permits, or returning briefly to their home countries. Time can now be aggregated, as long as it remains within the overall period.
Waiting Time vs. Residence Time
One debate remains unsettled: whether the time between submitting the first residence-permit request and the issuance of the card counts as legal residence for nationality purposes.
Earlier drafts and ministerial guidance suggested that this time would count — recognising the backlog reality in AIMA’s system. However, the final text is silent on this point, and we must wait for the regulatory update (within 90 days) to confirm whether that inclusion survives.
If maintained, it could be the only piece of generosity left in an otherwise tightening law.
Practical Impact
For residents and lawyers, the message is clear:
- File your nationality applications immediately if you already meet five years of residence.
- Once the law is published, the clock resets, and the new seven- or ten-year countdown begins.
- For those with interrupted residence, the ability to combine separate periods may soften the blow of longer total requirements.
In a system burdened by bureaucracy, time has become both the barrier and the battleground.
Portuguese Legal Reference
Artigo 5.º – Regime transitório
1 – A presente lei entra em vigor no dia seguinte ao da sua publicação.
2 – Os pedidos pendentes na data da entrada em vigor são apreciados ao abrigo da legislação anterior.Artigo 15.º, n.º 3
“Para efeitos do cômputo do tempo de residência legal, são considerados todos os períodos de residência legal, consecutivos ou interpolados, desde que ocorram no prazo máximo de seis, nove ou doze anos, consoante se trate, respetivamente, de apátridas e refugiados, de cidadãos nacionais de Estados membros da CPLP ou da União Europeia, ou de outros cidadãos estrangeiros.”
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