Lisbon Dec 15 — In a move that is sending ripples through Portugal’s immigrant communities, AIMA (Agência para a Integração, Migrações e Asilo) has begun converting certain residence renewal requests into new applications for residence authorization in a different article, instead of issuing outright refusals.
This procedural shift, communicated through formal emails now reaching applicants, marks a significant change in how renewal cases are handled — and, for many, a rare moment of bureaucratic flexibility in a system long criticized for rigidity and delays.
From refusal to redirection (article 88/89 to 122)
Applicants receiving the notice are told that they do not meet the legal conditions to renew their original residence typology. Under normal circumstances, this would mean a closed file and an uncertain future.
Instead, AIMA is invoking Article 122 of Law no. 23/2007, informing applicants that their original request will be “convolado” — legally transformed — into a request for the granting of a residence authorization.
In practical terms, this means:
- The original renewal request is formally refused
- The process itself remains active
- AIMA initiates a new legal pathway automatically, without requiring the applicant to start over
Automatic appointments, continued process
According to the notices, AIMA will:
- Schedule a new appointment ex officio
- Proceed with further instruction of the case
- Request that applicants submit documentation appropriate to the new residence typology at the appointed date
This approach contrasts sharply with past practice, where applicants were often required to reapply from scratch, sometimes falling into legal limbo in the process.
For the first time, AIMA appears to be acknowledging mismatches between initial residence categories and applicants’ current realities, choosing adjustment over exclusion.
Legal observers note that Article 122 is commonly associated with situations of effective integration, including employment, income, or other established ties to Portugal — even when the original permit category no longer fits.
For applicants, the message is subtle but profound: the door remains open. While the change does not guarantee approval, it reduces the risk of abrupt legal dead-ends and signals a more adaptive administrative stance.
Community advocates stress that applicants must still arrive prepared, with complete and updated documentation, when the new appointment is scheduled.
Yet for many, the tone of the message itself represents progress — a system choosing continuity over collapse, and process over punishment.
As Portugal continues to rely on migrant labor and long-term residents, this procedural evolution may mark the beginning of a quieter, more humane recalibration within the country’s migration framework.
For now, the letters are speaking — and they are saying: not yet, but not no.