grant, renewal, CPLP, AIMA delays and permanent residence

Residence Permit in Portugal

A residence permit is what allows a Brazilian national to live legally in Portugal after the visa.

Who this is for

Brazilians who live or intend to live in Portugal with a residence visa, a CPLP permit or a residence card to be renewed.

What we review

Type of permit, renewal deadlines, the status of expired residence cards, the CPLP permit, AIMA delays and the requirements for permanent residence.

How we work

Applications and renewals with AIMA, administrative complaints and actions in the Portuguese administrative courts, with lawyers in Brazil and in Portugal.

On this page we explain how it is granted and renewed, what has changed for the CPLP permit and for expired residence cards, what to do when AIMA does not decide within the deadline, and how to obtain permanent residence.

Types of residence permit and how it is granted

The Foreigners Act (Lei de Estrangeiros) (Law 23/2007) provides for two types of residence permit (autorização de residência): temporary and permanent (Article 74). Anyone authorized to reside is issued a residence card (título de residência), which replaces the identity document for all legal purposes, without prejudice to the regime of the Treaty of Porto Seguro for Brazilians (Articles 74(2) and 84).

The temporary permit

As a rule, the temporary permit is valid for two years from the issuance of the card and is renewable for successive periods of three years (Article 75(1)). There are special regimes with their own periods, such as the residence permit for investment.

To be granted the permit, the applicant must meet, among others, the following cumulative requirements (Article 77(1)):

  • a valid residence visa, granted for one of the purposes provided for by law, or a job-seeker visa;
  • presence in Portugal, means of subsistence and accommodation;
  • registration with social security, where applicable;
  • no conviction for a crime punishable in Portugal by imprisonment of more than one year and no alert in the Schengen Information System.

In practice, anyone who enters with a residence visa later applies, in Portugal, for the permit corresponding to the purpose of the visa: employment (D1), independent or entrepreneurial activity (D2), highly qualified activity (D3), study (D4 and D5), family reunification (D6) or own income (D7). Investment follows the regime of the residence permit for investment (Golden Visa).

Where and within what deadline

The application is filed with AIMA (Agency for Integration, Migration and Asylum — Agência para a Integração, Migrações e Asilo) by the applicant, their legal representative or the employer (Article 81(1), as worded by Law 62/2026, in force since September 11, 2026). An application for a grant must be decided within 90 days, extendable by 30 days in exceptional and justified circumstances, with notice to the applicant (Article 82(5)). A denial is notified with the grounds and with an indication of the right to challenge it in court and of the respective deadline (Article 82(8)).

Renewal: deadlines and how to apply

  • Advance notice: renewal of the temporary permit must be requested up to 30 days before the end of its validity (Article 78(1) of Law 23/2007).
  • Requirements: means of subsistence, accommodation, tax and social security obligations met, and no convictions that, individually or cumulatively, exceed one year of imprisonment (Article 78(2)). The onset of illness after the first card does not, by itself, justify refusal (Article 78(4)).
  • Receipt: the receipt for the renewal application has the same effects as the card for 60 days, a period that is renewable (Article 78(7)).
  • Decision: a renewal application must be decided within 60 days (Article 82(6)).
  • Who applies: the applicant or their legal representative, with AIMA's services (Article 81-A, as worded by Law 62/2026).

The Renewals Portal

According to AIMA, the Renewals Portal (Portal de Renovações) currently receives renewal applications for permits expiring between July 1, 2025 and December 31, 2026, and those for residence permits for investment that expired between February 22, 2020 and December 31, 2026. Anyone with a permit (other than an ARI) that expired between February 22, 2020 and June 30, 2025 must use the services.aima.gov.pt platform. For cards expiring later, AIMA indicates that it is necessary to wait for the portal to open to the following months.

According to AIMA's information, the applicant must have their social security contributions and tax situation in order, pay the fee in advance and submit the required documents; the collection of biometric data is scheduled only when necessary.

Absences from the country

The temporary permit may be canceled if the holder, without valid reasons, is absent for six consecutive months or eight non-consecutive months within the total period of validity (Article 85(2)(a)). Absence beyond these limits must be justified to AIMA, as a rule before departure (Article 85(3)).

CPLP residence permit: what exists today

Nationals of States covered by the CPLP (Community of Portuguese Language Countries) Mobility Agreement, such as Brazil, may apply in Portugal, with AIMA, for the CPLP residence permit (Article 87-A of Law 23/2007).

Who can apply after Law 61/2025

As worded by Law 61/2025, in force since October 23, 2025, the application requires the applicant to hold a residence visa (Articles 75(2) and 87-A(1)). The previous wording, introduced by Law 9/2025, allowed applications by those with a short-stay visa or legal entry. The new rules apply to procedures started after Law 61/2025 entered into force (Article 8). The grant depends on the conditions of the residence visa and of the CPLP permit, and AIMA checks the Portuguese criminal record on its own initiative (Article 87-A(2) and (3)).

The card after Law 9/2025

  • Law 9/2025, in force since February 14, 2025, gave CPLP permits the same validity as those granted to nationals of other countries (Article 1(2)).
  • According to AIMA, the CPLP permit is now issued in the uniform format residence card used in the European Union, and no longer as a paper certificate, with an in-person appointment to collect biometric data. For a new grant, the card is valid for two years.
  • For those who held the paper certificate, AIMA stated in its frequently asked questions on renewal that renewal or replacement would take place upon being summoned by email, with payment of a fee and an appointment, and that the new card would be valid for three or two years, depending on whether or not the current card had run its full term.

AIMA also indicated that the grant of the CPLP permit requires a consular visa obtained for that purpose at Portuguese consular posts.

The end of the expression of interest

Until June 2024, anyone who entered Portugal without a residence visa could, under certain conditions, apply for a residence permit for work based on an expression of interest (manifestação de interesse). Decree-Law 37-A/2024 (Decreto-Lei), in force since June 4, 2024, revoked that route, eliminating paragraphs 2 and 6 of Article 88 and paragraphs 2, 4 and 5 of Article 89 of the Foreigners Act (Article 2).

Transitional regime

As worded by Law 40/2024, the decree-law does not apply (Article 3(2)):

  • to residence permit procedures started on or before June 3, 2024;
  • to those who prove that, before that date, whether or not they had filed an expression of interest, they were already registered with social security and making contributions as an employee or self-employed worker, with a view to completing the 12 months required under the old rule.

These cases continue to be governed by the previous wording of the law (Article 3(3)). AIMA's clarification on the transitional regime describes the same two situations. Outside them, the rule is to obtain the residence visa at the consulate before traveling.

Expired residence cards and the extension of validity

Since 2020, the validity of expired residence documents has been extended several times, based on Article 16 of Decree-Law 10-A/2020. The last instrument in that series was Decree-Law 85-B/2025, which provides (Article 2):

  • permits whose validity ended between February 22, 2020 and June 30, 2025 were accepted, on the same terms, until October 15, 2025;
  • after October 15, 2025, these documents are accepted upon presentation of the proof of payment for the renewal application, issued by AIMA, valid for 180 days from issuance.

The preamble of the decree-law itself acknowledges that the extensions were due to the services' inability to respond and announces the end of that cycle.

Travel

AIMA clarified, regarding the earlier extensions, that they were valid only before the Portuguese authorities and that entry into and movement within other Schengen countries are governed by the Schengen Borders Code (AIMA FAQ on residence cards). The receipt for an application for a grant is not a travel document either.

What to do with an expired residence card

  • check which renewal channel the case falls under, according to the expiration date (see the section on renewal);
  • keep the proof of payment and the application receipt;
  • avoid traveling outside Portugal without a document valid for travel;
  • if the application has stalled, consider the remedies described in the next section.

AIMA delays: what to do

When AIMA does not decide within the legal deadline (90 days for a grant, with a possible 30-day extension, and 60 days for renewal), there are administrative and judicial remedies. The choice depends on the stage of the application, the concrete harm and the evidence available.

Administrative complaint

Failure to decide within the legal deadline constitutes a breach of the duty to decide and allows the applicant to use the appropriate administrative and judicial remedies (Article 129 of the Code of Administrative Procedure (Código do Procedimento Administrativo)). The applicant may respond to the omission by requesting that the act be issued (Article 184(1)(b)), by means of a complaint addressed to the body responsible for the omission (Article 191(1)). The deadline for deciding the complaint is 30 days (Article 192(2)). The complaint puts the delay and the request for a decision on record, but does not remove the need to watch the deadline for a lawsuit.

Complaints Book

Public Administration services must visibly publicize the existence of the Complaints Book (Livro de Reclamações) and of the electronic complaints platform. The service complained about must respond, with reasons and the measures taken, within a maximum of 15 days (Article 38 of Decree-Law 135/99, as worded by Decree-Law 74/2017). It is a means of complaining about the service; it does not, by itself, compel a decision on the application.

Administrative action

The typical lawsuit is the administrative action to compel a decision (ação administrativa de condenação à prática de ato devido), in which the court is asked to order AIMA to decide within a set period (Articles 66 and 67(1)(a) of the CPTA). In case of inaction, the right of action lapses one year after the end of the legal deadline for a decision (Article 69(1)). It may be accompanied by an interim (precautionary) measure (providência cautelar) when there is a risk of harm that is difficult to repair (Articles 112 and 120). In the administrative courts, representation by a lawyer is mandatory (Article 11(1)).

The injunction (intimação) and the limits of Law 61/2025

Law 61/2025 added Article 87-B to the Foreigners Act, applicable to AIMA's decisions and omissions in residence matters:

  • actions follow, as a rule, the form of an administrative action, without prejudice to interim relief (paragraph 1);
  • the summary injunction to protect rights, freedoms and guarantees (intimação para proteção de direitos, liberdades e garantias) is admissible only when, in addition to the requirements of Article 109 of the CPTA, AIMA's action or omission compromises, in a demonstrably serious and direct manner, the timely exercise of personal rights whose protection cannot be ensured by interim measures (paragraph 2);
  • if requested, the judge must weigh the number of procedures pending at AIMA, any abnormal pressure of applications, the resources available and the equitable treatment of other applicants (paragraph 3).

These rules apply to court proceedings started on or after October 23, 2025 (Article 8 of Law 61/2025). In an injunction, the judge decides within the time needed to ensure its practical effect, up to five days after the necessary steps have been taken (Article 111(1) of the CPTA).

See also the page on administrative action against AIMA and the IRN.

Permanent residence

Foreign nationals are entitled to a permanent residence permit if they cumulatively (Article 80(1) of Law 23/2007):

  • have held a temporary residence permit for at least five years;
  • have not, in the last five years, been sentenced to a penalty or penalties exceeding one year of imprisonment;
  • have means of subsistence and accommodation;
  • demonstrate knowledge of basic Portuguese.

The permanent permit has no validity limit, but the card must be renewed every five years or whenever the identification data change (Article 76). It may be canceled if the holder, without valid reasons, is absent for 24 consecutive months or, within a period of three years, for 30 non-consecutive months (Article 85(2)(b)); there is no cancellation when it is proven that, during the absence, the person carried on a professional, business, cultural or social activity (Article 85(4)).

The law also provides, in parallel, for EU long-term resident status, which requires legal and uninterrupted residence in the five years preceding the application (Articles 125 and 126). Holders of an investment permit follow their own rules, described on the Golden Visa page.

Residence and citizenship

Permanent residence is not a requirement for naturalization. Since Organic Law 1/2026 (Lei Orgânica), a Brazilian national needs seven years of legal residence, and, for new applications, the time elapsed since the application for a temporary residence permit no longer counts (repeal of paragraph 4 of Article 15 of the Nationality Act). See the page on citizenship by length of residence.

How the firm handles the case

With lawyers in São Paulo and in Albufeira, Sene & Araújo assists Brazilians in obtaining and maintaining residence in Portugal.

  1. Initial review: purpose of the stay, appropriate visa, Brazilian and Portuguese documents, and history of residence cards, where they already exist.
  2. Application and renewal: preparation of the application for a grant or renewal with AIMA, monitoring of advance-notice deadlines and of the limits on absence from the country.
  3. Expired cards and CPLP: checking the applicable renewal channel and the situation of those with a paper or pending CPLP permit.
  4. Delay or denial: administrative complaint and, where appropriate, administrative action, interim measure or injunction (intimação) in the Portuguese administrative courts, with an assessment of the requirements of Article 87-B.
  5. Next steps: permanent residence, family reunification and planning of the citizenship application.

The decision on each application always rests with AIMA or the court. Our role is to organize the case, meet the deadlines and present the appropriate grounds.

Legal basis and official sources

Frequently asked questions

Common questions

Didn't find your question? Talk to our team on WhatsApp.

How long does AIMA have to decide a residence permit application?

An application for a grant must be decided within 90 days, extendable by 30 days in exceptional and justified circumstances, with notice to the applicant. A renewal application must be decided within 60 days (Article 82(5) and (6) of Law 23/2007). Other regimes, such as family reunification, have their own deadlines.

How far in advance should I apply for renewal?

Up to 30 days before the card expires (Article 78(1)). The receipt for the renewal application has the same effects as the card for 60 days, a period that is renewable (Article 78(7)). According to AIMA, applications are made on the Renewals Portal, according to the card's expiration date.

My residence card has expired. Is it still valid?

It depends on the date. Permits that expired between February 22, 2020 and June 30, 2025 were accepted until October 15, 2025. After that, they are accepted upon presentation of the proof of payment for the renewal application issued by AIMA, valid for 180 days (Article 2 of Decree-Law 85-B/2025). Outside these cases, the renewal must be dealt with as soon as possible.

Can I enter Portugal as a tourist and apply for the CPLP residence permit?

For procedures started since October 23, 2025, no. With Law 61/2025, the CPLP permit now requires a residence visa (Articles 75(2) and 87-A(1) of Law 23/2007), obtained at Portuguese consular posts.

Can I work while I wait for AIMA's decision?

While the residence permit application is pending, for reasons not attributable to the applicant, the holder of a residence visa may carry on a professional activity under the terms of the law (Article 81(4) of Law 23/2007). On renewal, the application receipt has the effects of the card for 60 days, renewable (Article 78(7)).

When is a summary injunction to protect rights (intimação) available against AIMA?

Since Law 61/2025, only when AIMA's omission or action compromises, in a demonstrably serious and direct manner, the timely exercise of personal rights that cannot be protected by an interim measure (Article 87-B(2)). In other cases, the remedy is an administrative action, possibly with an interim measure. The analysis depends on the evidence of concrete harm.

Contact

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