Portugal 2026: A Timeline of the Changes in Citizenship, Visas and the Golden Visa

Between 2023 and 2026, Portugal changed almost every rule that matters to people thinking about living in the country, investing or applying for citizenship: the Golden Visa stopped accepting real estate, the expression of interest (manifestação de interesse) ended, the CPLP route began to require a visa, the residence period for naturalization increased and the Non-Habitual Resident (NHR) tax regime was replaced. Each change came through a different law, with its own entry-into-force dates and transitional rules, and that is what usually causes confusion.

This article organizes these changes in chronological order, with the rule behind each one, and explains what applies today to each profile. It will be updated whenever a new law or regulation is published. Last reviewed: October 1, 2026.

Summary: what applies on October 1, 2026

• Golden Visa: it still exists, but without the purchase of real estate, urban rehabilitation or a simple capital transfer since October 7, 2023.
• Living in Portugal: the rule is to obtain a residence visa at the consulate before traveling. The expression of interest ended in 2024, and the CPLP residence permit began to depend on a residence visa in 2025.
• Citizenship by residence: since May 19, 2026, 7 years of legal residence are required for Brazilians and European Union citizens and 10 years for everyone else, with new knowledge requirements.
• Citizenship applications pending on May 19, 2026: they are still decided under the previous law.
• Tax: the NHR was replaced by IFICI, a narrower regime aimed at qualified activities.

The timeline, date by date

October 7, 2023: Golden Visa without real estate (Law 56/2023)

Law 56/2023 (Lei), known as Mais Habitação (More Housing), was published on October 6, 2023 and came into force the next day. Since then, no new applications for a Residence Permit for Investment Activity (ARI) are accepted on the basis of a capital transfer, the purchase of real estate or urban rehabilitation (Art. 42(1)). The remaining options cannot be used, directly or indirectly, for real estate investment.

Those who already held an ARI, including one based on real estate, did not lose it: permits granted earlier can still be renewed, the rule also applies to reunited family members, and applications pending on October 7, 2023 remained valid (Arts. 42 and 43). The options in force and the minimum amounts are in our article on the Golden Visa in 2026.

January 1, 2024: IFICI replaces the NHR (Law 82/2023)

The 2024 State Budget Law (Law 82/2023, of December 29) added Art. 58-A to the Tax Benefits Statute (Estatuto dos Benefícios Fiscais, EBF), which created the tax incentive for scientific research and innovation (IFICI). It applies to people who become tax residents in Portugal, were not residents in any of the previous five years and carry out one of the listed activities, such as higher education teaching and research, highly qualified professions in certain companies or positions in certified startups. The benefit is a special 20% rate on net Category A and B income earned in these activities, for 10 consecutive years (paragraphs 1 and 2).

The former Non-Habitual Resident (NHR) regime was repealed, with a transitional regime. In practice, IFICI does not cover pensions or passive income and does not come from the Golden Visa or any visa. See the page on Brazil–Portugal tax residence.

April 1, 2024: Organic Law 1/2024 (citizenship)

Organic Law 1/2024 (Lei Orgânica), published on March 5, 2024, came into force on the first day of the following month. Two changes had a practical impact:

• for citizenship purposes, the time elapsed since the application for a temporary residence permit began to count, provided the permit was granted (Art. 15(4) of the Nationality Act (Lei da Nacionalidade));
• descendants of Sephardic Jews began to need three years of legal residence in Portugal (Art. 6(7)).

Both rules were repealed in 2026, as explained below.

June 4, 2024: end of the expression of interest (Decree-Law 37-A/2024)

Decree-Law 37-A/2024 (Decreto-Lei), published on June 3, 2024 and in force the next day, repealed the residence permit procedures based on an expression of interest (manifestação de interesse). Until then, people who entered without a residence visa could, under certain conditions, regularize their status in Portugal on the basis of work. Procedures already started continued to be governed by the previous law (Art. 3). Law 40/2024, of November 7, extended this transitional regime to people who were already registered with social security and paying contributions before the change. The details are on the page about the residence permit.

December 23, 2024: IFICI regulations (Ministerial Order 352/2024/1)

Ministerial Order 352/2024/1 (Portaria) set out the rules for IFICI. A practical point: registration must be made by January 15 of the year after the year in which the person became a resident; after this deadline, the regime only takes effect from the year of registration, for the remaining period (Art. 58-A(7) of the EBF).

February 14, 2025: CPLP card in the uniform format (Law 9/2025)

Law 9/2025, published on February 13, 2025, gave CPLP residence permits the same validity as those granted to nationals of other countries. According to AIMA, the card began to be issued in the uniform format used in the European Union.

October 23, 2025: Law 61/2025 (foreigners)

Law 61/2025, published on October 22, 2025 and in force the next day, amended the Foreigners Act (Lei de Estrangeiros) on key points for Brazilians:

• CPLP route: the CPLP residence permit is now requested at AIMA by holders of a residence visa (Art. 87-A(1)). It is no longer possible to enter as a tourist and apply for the CPLP permit in Portugal.
• Family reunification: as a rule, the resident needs a residence permit that has been valid for at least two years, with exceptions, including minor children and family members of ARI holders (Art. 98).
• Job seeking: the visa became a visa to seek qualified work, limited to people with the technical skills to be defined in a ministerial order (Art. 57-A).
• Actions against AIMA: the new Art. 87-B limited the summary injunction to protect rights (intimação) against AIMA.

The new rules apply to administrative procedures and court cases started after the entry into force (Art. 8).

May 19, 2026: Organic Law 1/2026 (citizenship)

Organic Law 1/2026, published on May 18, 2026 and in force the next day, was the deepest change of the period:

• Residence period: 7 years for nationals of Portuguese-speaking countries, such as Brazil, and for European Union citizens; 10 years for everyone else (Art. 6(1)(b)).
• Counting: periods of legal residence are added up within a maximum window of 9 years (Brazilians and EU citizens) or 12 years (other foreign nationals), and the waiting time for a residence permit application no longer counts (Art. 15(3), and repeal of Art. 15(4)).
• Knowledge: knowledge of the national culture, history and symbols, of fundamental rights and duties and of the political organization of the State is now required, as well as a solemn declaration of adherence to the principles of the democratic rule of law. For Brazilians, only knowledge of the language is presumed (Art. 6(10)).
• Routes closed: naturalization of descendants of Sephardic Jews and of ascendants of Portuguese nationals by origin is no longer available for new applications.
• New route: great-grandchildren of Portuguese nationals by origin with five years of legal residence can be naturalized without the general residence period (Art. 6(8)).

The previous law applies to procedures pending on May 19, 2026 (Art. 7(2)), as confirmed by the Ministry of Justice. The details are in the article on the new Nationality Act and in the guide on how to count the 7 years.

September 11, 2026: Law 62/2026 (asylum, migration and residence)

Law 62/2026, published on September 10, 2026 and in force the next day, implements the EU Pact on Migration and Asylum and transposes the Single Permit Directive for residence and work. For Brazilians, the most visible points are:

• higher education students and interns who entered without a residence visa can no longer apply for the permit directly in Portugal;
• the residence permit application can be filed by the applicant, the legal representative or the employer, and the renewal application by the applicant or the legal representative (Arts. 81 and 81-A of the Foreigners Act);
• the law kept the decision periods of 90 days for the grant, extendable by 30, and 60 days for renewal (Art. 82).

Law 62/2026 did not change the Golden Visa investment options.

What is still to come

Some changes already approved depend on implementing regulations. Points to watch:

• Nationality Regulation: Organic Law 1/2026 gave the Government 90 days from publication to adapt the regulation (Art. 4). When we checked on October 1, 2026, the consolidated version of the Portuguese Nationality Regulation (Regulamento da Nacionalidade Portuguesa) in the Diário da República (Portugal's official gazette) did not yet show this amendment. The format of the tests on culture, history and the organization of the State and the certificates accepted depend on it.
• Visa to seek qualified work: it depends on the ministerial order that defines the required skills. In September 2026, the Ministry of Foreign Affairs (MNE) stated that the visa was not yet available at consulates.
• Integration measures in family reunification: provided for by Law 61/2025, they depend on implementing regulations.

What this means for you

If you want to live in Portugal

Plan the visa while you are still in Brazil. Entering as a tourist is not residence and no longer serves as a bridge to the CPLP permit, to work or, since September 2026, to higher education. Start by comparing the visas for Portugal and choose the one that matches your real reason for moving.

If you already live in Portugal and are thinking about citizenship

Gather the full history of your residence cards and check for any gaps without regular status. With the rule of 7 years within a 9-year window, a card that expired without renewal may delay the application. See citizenship by length of residence and, if your card has expired, what to do with an expired residence card.

If you are thinking about investing: the Golden Visa

The Golden Visa remains the main exception to the consular visa rule: the ARI is requested directly from AIMA after entering Portugal, and it requires a reduced minimum stay of 7 days in the first year and 14 days in each subsequent two-year period. The options in force include non-real-estate investment funds, job creation, scientific research, culture and setting up a company that creates jobs. Time as an ARI holder counts as legal residence for citizenship, now with the 7-year period for Brazilians. Since the investment must be maintained and documented over several years, the structure chosen at the start makes a difference. See our page on the Golden Visa.

If you have a pending application

A citizenship application filed by May 18, 2026 follows the previous law, including the five-year period. A residence permit application generally follows the law in force when the procedure began. Before withdrawing an application or filing another one, confirm which regime applies: a new application may fall under the stricter rules. If delay is the problem, see urgency and delays in the citizenship process.

If you are going to change your tax residence

A visa and tax residence are different things. Portuguese tax residence depends on staying more than 183 days or having a home with the intention of making it your habitual residence (Art. 16 of the IRS Code), and IFICI only covers specific activities. Plan the date of the move and register on time.

Common mistakes

• Following guidance from before 2024, such as entering as a tourist and regularizing later. These routes were closed one by one.
• Thinking that the Golden Visa still accepts real estate, including through funds or companies that work as vehicles for buying property.
• Counting AIMA's waiting time toward citizenship, a rule that applied between 2024 and 2026 and was repealed for new applications.
• Assuming that the language presumption waives all tests: for Brazilians, it covers only the Portuguese language.
• Expecting IFICI for any profession or for retirees: the regime is limited to the activities in the law and has a registration deadline.
• Deciding based on news about bills: what counts is the date of publication and of entry into force in the Diário da República.

How Sene & Araújo can help

Sene & Araújo has lawyers admitted to the OAB and to the Portuguese Bar Association, with offices in São Paulo and Albufeira, and acts directly before AIMA, the IRN, the consulates and the Portuguese administrative courts. We review your situation in light of the date of each application and the applicable transitional rule, organize the path to the visa or the Golden Visa and plan citizenship from the first residence card. Decisions rest with the Portuguese authorities; our role is to prepare and follow each step. Talk to our team.

• Law 56/2023, of October 6 (Mais Habitação) — Arts. 42, 43 and 44
• Tax Benefits Statute (Estatuto dos Benefícios Fiscais), Art. 58-A (IFICI), added by Law 82/2023 — Portal das Finanças
• Ministerial Order 352/2024/1, of December 23 — IFICI regulations
• Organic Law 1/2024, of March 5 (Arts. 2 and 9)
• Decree-Law 37-A/2024, of June 3 (end of the expression of interest; Art. 3)
• Law 40/2024 of November 7 (transitional regime)
• Law 9/2025, of February 13 (CPLP permit)
• Law 61/2025, of October 22 (Arts. 2, 8 and 9)
• Organic Law 1/2026, of May 18 (Arts. 2, 4, 5, 7 and 8) — DR 95/2026
• Law 37/81 — Nationality Act, consolidated version (Arts. 6 and 15)
• Ministry of Justice — Nationality Act: new rules come into force on May 19
• Law 62/2026, of September 10 (Arts. 1, 4, 9 and 11) — DR 176/2026
• Portuguese Nationality Regulation — Decree-Law 237-A/2006, consolidated version (checked on October 1, 2026)
• IRS Code (Código do IRS), Art. 16 (tax residence) — Portal das Finanças

Sene & Araújo Sociedade de Advogados team. Content prepared and reviewed by the firm's lawyers, admitted to the Brazilian Bar Association (OAB) and the Portuguese Bar Association (Ordem dos Advogados), with offices in São Paulo and Albufeira. The provisions cited were checked against the official sources listed above. Meet the team.