Portugal Nationality Law 2026: New Citizenship Rules for Golden Visa Investors

In May 2026, Portugal enacted the most significant reform of its nationality law in decades. The headline change: the qualifying period of legal residence for naturalisation rose from five years to ten for most applicants, with a preferential seven-year track for EU and CPLP nationals.

For Golden Visa investors, the reform changes the length of the journey but not the destination, and not the day-to-day obligations of the visa itself. This article sets out what changed, who is affected and how to plan around it.

The new residence periods

Under the reformed law, the residence requirement for naturalisation is now:

Ten years for most non-EU nationals, including applicants from the UK, the US, Canada, the Gulf states, India, China and South Africa.
Seven years for citizens of EU member states and CPLP countries (the Community of Portuguese Language Countries, including Brazil, Angola, Mozambique and Cape Verde).

Other naturalisation requirements remain, including a clean criminal record, an A2-level Portuguese language certificate and a new civic-knowledge requirement introduced with the reform.

When the clock starts

Portugal counts the qualifying residence period for naturalisation from the point the applicant holds a residence title, not from the date the residence application was made. Article 15(1) of Lei n.º 37/81 treats as legal residence the time an individual is in Portugal with their situation regularised under any of the titles, visas or authorisations provided for in the immigration regime.

This changed on 19 May 2026. Article 15(4), inserted by Lei Orgânica n.º 1/2024 with effect from 1 April 2024, had allowed the count to include time elapsed from the moment the temporary residence authorisation was applied for, provided it was later granted. Article 5 of Lei Orgânica n.º 1/2026 expressly revoked it. So between 1 April 2024 and 18 May 2026 time spent waiting in the AIMA queue counted towards naturalisation, and since 19 May 2026 it does not.

For a Golden Visa investor this is the more expensive of the two 2026 changes. An investor who applied in 2023 and receives a residence card in 2026 now starts a ten-year clock in 2026, instead of a five-year clock that had already been running for three years.

One point is contested rather than settled. Whether a Golden Visa file already pending at AIMA counts as a procedimento administrativo pendente for the purposes of the transitional rule in article 7(2), which would preserve the previous law including the old article 15(4), is the subject of litigation and has not been decided. We would not plan on the assumption that it succeeds.

Corrected 1 September 2026: an earlier version of this section stated that applicants who had paid their Golden Visa submission fee before the law was gazetted have their residence period counted from the date of that payment. No provision of Portuguese law ties the residence count to the payment of a fee. The rule that allowed time to count from the date the residence authorisation was applied for was article 15(4) of Lei n.º 37/81, and it was revoked by article 5 of Lei Orgânica n.º 1/2026 with effect from 19 May 2026.

Who is protected by the old rules

The transitional rule is article 7(2) of Lei Orgânica n.º 1/2026: administrative procedures pending on the date the law entered into force are decided under Lei n.º 37/81 in its previous wording.

Nationality applications submitted to the registry (IRN) on or before 18 May 2026 continue to be assessed under the previous law, including the five-year residence requirement. If your application was lodged by that date, the reform does not change your position.

For everyone else, the new periods apply. There is no partial credit system: an investor three years into residence under the old expectation of a five-year track is now working towards the ten-year requirement (or seven, for EU and CPLP nationals).

What does not change for Golden Visa holders

The Golden Visa programme itself was not altered by the nationality reform. In particular:

Stay requirements are unchanged. The Portugal Golden Visa stay requirement is 7 days in the first year and 14 days in each subsequent two-year period, under article 65.º-C of Decreto Regulamentar n.º 84/2007. It is unchanged by the nationality reform.
Permanent residence after five years is still available. Many investors will find permanent residence meets their practical needs, with citizenship as a longer-term goal.
Family reunification, EU-wide Schengen travel and the investment rules all continue as before. The fund route is unchanged, as covered in our guide to Golden Visa investment funds in 2026.

Planning implications

A longer citizenship track changes the calculus in a few practical ways:

Start earlier. With the clock running from card issuance, time spent deliberating is now more expensive. Application preparation and AIMA queues sit before your start date, as we explain in our processing times guide.
Match your investment to the horizon. Fund terms, renewal cycles and exit options should be stress-tested against a ten-year plan, not a five-year one.
Consider the family position. Children’s ages, schooling plans and which family members are included at the outset all interact with the longer timeline.
Weigh alternatives honestly. For some profiles, another programme may now fit better. Our Portugal vs Greece comparison is a good place to start.

This article is for general information only and does not constitute legal or immigration advice. Transitional rules are fact-specific; always confirm how the law applies to your circumstances.