Reviewed by Jane Katkova, Founder & Licensed CICC ConsultantOn 26 June 2026 a consortium of nine Portuguese law firms filed a formal complaint with Portugal's Ombudsman, the Provedoria de Justiça, on behalf of 1,260 golden visa investors. The complaint concerns two connected matters: the Nationality Law revision that took effect on 19 May 2026 (Lei Orgânica n.º 1/2026), and the processing delays at AIMA that left many investors without a residence card when the law changed.
Grounds of the complaint
The new law raised the residence period for naturalisation from five to ten years for most nationalities and counts that period from the issue of the residence permit, not from the date the application was submitted. Investors who filed under the Portugal golden visa and then waited three to five years for AIMA to issue a card argue that they have lost that time through no fault of their own, and that those without a card at the cut-off fall outside the law's transitional protection.
The firms ask the Ombudsman, Luísa Neto, to:
- refer the Nationality Law to the Constitutional Court for review;
- press the Government to adopt a transitional regime for applicants already in the process;
- have the residence period counted from the date of the original application.
The consortium had already submitted an amicus curiae brief to the Constitutional Court in December 2025, when an earlier version of the law was under review.
Next steps and timetable
Reports in late July 2026 said the group expected a meeting with the Ombudsman within about two weeks and was prepared to start court proceedings against the State in September 2026 if no solution was offered, with the number of investors taking part potentially rising to 2,000. The lawyers have also said they would take the matter to the European Court of Human Rights if domestic remedies fail.
The Government has not announced a transitional regime. A minister's remark that investors had been led to expect nationality drew a public reply from Fieldfisher Portugal's André Miranda, who asked what had become of the commitment that all investors would have their residence cards by 2026. As at the date of this update we have not seen a ruling or a legislative amendment resulting from the complaint.
What this means for applicants
For US and Canadian citizens, and for US and Canadian residents on other passports, who already hold or have applied for a Portuguese golden visa, the complaint is the main route by which the lost processing time might be restored. It is a request, not a result. We advise planning on the law as it stands: ten years of legal residence counted from the issue of the first card, as set out on our Portugal citizenship timeline page.
Existing investors should keep a complete record of the application date, every AIMA fee payment, biometrics date and card issue date, because any transitional rule is likely to turn on those dates. Whether to join a collective action is a decision to take with your Portuguese lawyer.
New applicants should enter Portugal for what the programme reliably delivers today, which is EU residence with a light stay requirement, and treat citizenship as a long-term prospect. To compare Portugal with the other options on our European residence pages, book a consultation.