Urgency and Delay in the Portuguese Citizenship Process

The Portuguese Nationality Regulation (Decree-Law 237-A/2006) sets time limits for each stage of the process, but not an overall time limit for the decision.

Applications by declaration (children, grandchildren, marriage or de facto union)

• Within 30 days of receipt, the Central Registry Office carries out a summary review and, if documents are missing, notifies the applicant to remedy the deficiencies within 30 days (Art. 41(1)).
• Once the file is complete, the registrar decides within 60 days (Art. 41(2)). If the intention is to reject the application, the applicant is first heard, within 30 days (Art. 41(3)).

Naturalization (length of residence)

• Preliminary review within 30 days of receipt (Art. 27(2)).
• Request for information from the Criminal Police (Polícia Judiciária), the Border and Foreigners Coordination Unit and AIMA, which respond within 30 days, extendable to 60 (Art. 27(5) and (6)).
• Opinion within 45 days after the inquiries, followed by the decision of the member of the Government responsible for justice (Art. 27(10)).

The process may also be suspended, for example, when there are well-founded doubts about the authenticity of foreign documents or pending inquiries (Art. 42(3)).

The current reality

In practice, the time limits under the Regulation have been widely exceeded. In August 2026, the Government announced a plan to clear the IRN's backlog, with teams dedicated to citizenship at the Central Registry Office in Lisbon and the Central Archive in Porto and additional registrars and registry officers. The IRN does not publish an official average decision time, and each process must be monitored individually.

The Portuguese Nationality Regulation does not provide for an urgent or priority processing regime. The possibility arises from resolutions of the IRN's Executive Board. The current one is the resolution of May 20, 2026, which standardized the criteria and revoked the resolution of October 27, 2022, republished on January 18, 2023.

The general rule

Urgency requests in processes for the attribution, acquisition or loss of citizenship are of a highly exceptional nature. Urgency is granted only when the applicant alleges and proves that the lack of a priority decision will cause them serious, irreparable and imminent harm. Without a demonstrated concrete risk, there is no urgent treatment (point 1).

Accepted grounds, provided they are proven (point 2)

• age of 75 or over, taking into account the impact of age and average life expectancy on the effectiveness of the right;
• inability to access urgent, life-saving medical treatment provided in Portugal or in another Member State only to citizens of the European Union, proven by a statement from the healthcare facility;
• inevitable loss of employment due to expiry of a visa and the need to leave the country to renew it, with an employment contract and a statement from the employer;
• statelessness;
• imminent risk of deportation to a country where the applicant may be persecuted;
• serious humanitarian situations, such as a risk to physical integrity or extreme vulnerability;
• a minor who remains undocumented, when regularization depends on the citizenship process;
• other objectively reasonable grounds, arising from very sensitive circumstances or capable of causing serious, irreparable and imminent harm.

Illness, on its own, is not on the list. It falls under the ground of urgent medical treatment, as described, or may be invoked as another reasonable ground, if it demonstrates serious and imminent harm.

Regardless of any request, the IRN must give priority to processes for the attribution of citizenship to minors born abroad, children of a Portuguese citizen, who have no other citizenship and remain undocumented (point 7).

• Who can apply: only the applicant, their legal representative or an attorney-in-fact with specific powers for that purpose (IRN resolution of May 20, 2026, point 3). A general power of attorney for the process may not be enough.
• Burden of proof: it is for the applicant to demonstrate the serious harm resulting from the lack of a timely decision (point 4). The request must be accompanied by the documents proving the ground invoked: an identity document, in the case of age; a statement from the healthcare facility; an employment contract and a statement from the employer, among others.
• Who decides: the registrar responsible for the process, in the exercise of their functional autonomy (point 5).
• Effects: the assessment of urgency neither conditions nor anticipates the outcome of the final decision on citizenship (point 6). Urgency speeds up the review; it does not change the requirements.

A well-grounded request identifies the process, indicates the specific ground in the resolution, explains the harm caused by the delay and attaches the evidence. Generic requests, without proof of risk, tend to be refused, because the resolution requires the harm to be demonstrated.

Anyone who has applied for Portuguese citizenship can check the status of the process free of charge with the access code, sent by email when the process is created. When a lawyer has been appointed, the IRN may have sent the code directly to the lawyer (justica.gov.pt — Check the status of a citizenship process).

The four statuses

• Submitted (Submetido): the application has been received and registered in the system.
• Under review (Em análise): verification of the requirements, the documents and their authenticity, or consultation of external bodies.
• For decision (Para decisão): the order containing the decision has been issued.
• Completed (Concluído): citizenship granted and registered in the civil registry, or application refused and closed.

The online check is not available in some cases, such as attribution by registration of the birth in the Portuguese civil registry, including at consulates. If you have lost the code, you can request it at a Citizenship Desk (Balcão da Nacionalidade) or through the Linha Registos helpline.

What is worth monitoring

• notifications by registered letter, which are presumed to have been made on the third business day after postal registration (Art. 41(7) and Art. 27(15) of the Regulation);
• requests for missing documents, with a 30-day period to remedy them (Art. 41(1));
• the prior hearing before a rejection, also with 30 days to respond (Arts. 27(11) and 41(3));
• the date on which the process moved to each status, which helps demonstrate the delay, if it becomes necessary to take action.

See also our guide Portuguese citizenship step by step.

The lack of a decision within the legal time limit constitutes a breach of the duty to decide and allows the interested party to use the appropriate administrative and judicial remedies (Art. 129 of the Code of Administrative Procedure).

• Complaint against failure to act: the interested party may respond to the failure to act by requesting that the act be issued (Art. 184(1)(b)), through a complaint addressed to the body responsible for the omission (Art. 191(1)). The time limit for deciding the complaint is 30 days (Art. 192(2)).
• Urgency request: when one of the grounds in the IRN resolution applies, it is the most direct way to obtain priority within the process itself.
• Complaints Book (Livro de Reclamações): public services must publicize the existence of the complaints book and the electronic platform, and respond within 15 days (Art. 38 of Decree-Law 135/99 (Decreto-Lei), as amended by Decree-Law 74/2017). It serves to record a complaint about the service, but does not, in itself, require the process to be decided.

The Regulation provides for the Code of Administrative Procedure to apply, on a subsidiary basis, to the calculation of time limits and to the hierarchical appeal against a decision refusing registration (Art. 41(9)).

Citizenship litigation is governed by the Statute of Administrative and Tax Courts and the Code of Procedure in Administrative Courts (Art. 26 of the Nationality Act, republished by Organic Law 1/2026 (Lei Orgânica)). Anyone with a direct and personal interest may take legal action against acts and omissions in citizenship procedures, within one year (Art. 61(1) of the Regulation).

Administrative action to compel a decision

This is the appropriate remedy to ask the court to order the IRN, or the member of the Government with authority over naturalization, to decide within a set period, when no decision was made within the legal time limit (Arts. 66 and 67(1)(a) of the CPTA). In the event of inaction, the right of action lapses one year after the end of the legal time limit for the decision (Art. 69(1)). It may be accompanied by an interim measure (Arts. 112 and 120).

Summary injunction to protect rights, freedoms and guarantees

It is available when a swift decision is indispensable to ensure the timely exercise of one of the rights, freedoms and guarantees, and an interim measure is not possible or sufficient (Art. 109(1) of the CPTA). The judge decides within the time needed to ensure a useful effect, up to five days after the inquiries (Art. 111(1)). The restrictions in Art. 87-B of the Foreigners Act (Lei de Estrangeiros), introduced by Law 61/2025 (Lei), concern actions against AIMA in residence matters, not citizenship processes at the IRN.

In the administrative courts, representation by a lawyer is mandatory (Art. 11(1) of the CPTA). See also the page on administrative actions against AIMA and the IRN.

Organic Law 1/2026 (Lei Orgânica) was published on May 18, 2026 and entered into force the following day, May 19, 2026 (Art. 8). The transitional rule is in Art. 7:

• the law takes effect from its entry into force (para. 1);
• administrative procedures pending on that date are governed by the Nationality Act as previously worded (para. 2).

Thus, an application that was already pending continues to be assessed under the old rules, for example as regards the five-year residence period for naturalization, the new knowledge requirements or the route through ascendants. Delay by the IRN after May 19, 2026 does not cause the process to fall under the new law.

The date that counts for online applications

On May 7, 2026, in view of the large volume of applications, the IRN announced that, for the purposes of applying the amendments to the Nationality Act, what counts is the date the application was submitted on the online platform (IRN notice).

The Regulation yet to be adapted

The law gave the Government 90 days from publication to amend the Portuguese Nationality Regulation (Art. 4). In the consolidated version of the Regulation in the Diário da República, consulted on September 30, 2026, the last recorded amendment still predates the new law.

To understand what has changed, see the article New Nationality Act: what changed for Brazilians.

With lawyers in São Paulo and Albufeira, Sene & Araújo assists Brazilians with Portuguese citizenship processes from the application to registration.

1. Process assessment: type of application, submission date, applicable law and current status in the online check.
2. Urgency request: analysis of the fit with the grounds in the IRN resolution, gathering of evidence and filing of the request, with a power of attorney granting specific powers.
3. Monitoring: tracking notifications, responding to requests for documents and to the prior hearing.
4. Excessive delay: administrative complaint and, where appropriate, an administrative action to compel a decision or an injunction (intimação) before the Portuguese administrative courts, with attention to the one-year time limit.

The decision on urgency rests with the responsible registrar, and the decision on citizenship with the Portuguese authorities. Our role is to substantiate the request, meet the deadlines and follow each stage.