Should You Apply for the Portugal Golden Visa Before the Citizenship Timeline Decision?

Portugal's parliament is reviewing legislation that would extend citizenship eligibility from 5 years to 10 years. This will potentially double the wait for the EU passport that makes the Golden Visa attractive to many Americans.

The answer isn't "apply immediately." Understanding what's changing, how Portugal's processing reality affects your timeline, and whether rushing compromises your application quality is essential to making the right decision.

What's Happening with Portugal Golden Visa Citizenship Timeline

On June 23, 2025, Portuguese lawmakers proposed significant changes to the Golden Visa program's path to citizenship. The legislation is currently under parliamentary review, with a decision expected in October 2025.

This is a proposal, not yet law. While it has advanced through committee review, parliamentary approval is not guaranteed. Portuguese authorities cite concerns about integration and language proficiency among Golden Visa holders who spend only 7 days per year in the country.

The outcome is uncertain. Portugal recognizes the economic value of the program, particularly the surge in American applicants who now represent the top nationality, but also faces pressure to tighten citizenship requirements.

The Proposed Change: From 5 Years to 10 Years

If the legislation passes, here's what would change:

Current citizenship eligibility requirements:

• 5 years from application date

• Average 7 days/year physical presence

• A2 Portuguese language proficiency

• Clean criminal record and tax compliance

  
  

Proposed new requirements:

• 10 years from permit issuance (not application)

• Same physical presence (7 days/year)

• A2 Portuguese language proficiency

• New cultural and civic knowledge test

• Clean criminal record and tax compliance

  
  

The critical difference: The timeline would start from permit issuance (when you receive your residence card), not application submission. With current 18-30 month processing delays, Americans could face up to 11-12+ years from application to citizenship eligibility.

Grandfathering Provisions

The proposed legislation includes grandfathering for applications submitted before June 19, 2025 with complete documentation. Those applications would remain eligible under the 5-year rule even if the extension passes.

That deadline has passed. However, depending on final legislative language, applications submitted before the law's effective date might still qualify. Portuguese legal tradition generally protects applicants who submitted under previous rules but only with complete, properly documented applications.

How the April 2024 Change Helps Your Timeline

Before considering the proposed extension, understand a critical change that already occurred: Portugal now starts the 5-year citizenship clock on your application submission date, not when your residence card is issued.

Why this matters: With 18-30 month processing times a real possibility, this change effectively reduces your total wait by 1.5-2.5 years. If you apply in October 2025 and receive approval in March 2027, your citizenship eligibility countdown started in October 2025.

This change was designed to offset processing delays and reduce the penalty for applicants caught in Portugal's backlog of approximately 50,000 pending cases.

Timeline Comparison: 5 Years vs. 10 Years

Under current 5-year rule:

• October 2025: Submit application

• March 2027: Receive residence card (18-month processing)

• October 2030: Eligible to apply for citizenship (5 years from application)

• October 2032: Receive citizenship (estimated 2-year processing)

• Total: ~7 years from application to passport

  
  

Under proposed 10-year rule:

• October 2025: Submit application

• March 2027: Receive residence card (18-month processing)

• March 2037: Eligible to apply for citizenship (10 years from permit issuance)

• March 2039: Receive citizenship (estimated 2-year processing)

• Total: ~13.5 years from application to passport

  
  

The difference: 6+ additional years.

The Reality of Applying Now: 18-30 Month Processing

Here's what's important to remember: Applying in October 2025 doesn't mean approval in October 2025.

Current processing timeline:

• Preparation: 2-6 weeks (NIF, bank account, fund subscription)

• Application to pre-approval: 9-18 months

• Biometrics appointment: 3-12 months after pre-approval

• Card issuance: 1-4 months after biometrics

• Total: 18-30 months from submission to residence card

  
  

Portugal's immigration authority (AIMA) is working through approximately 50,000 pending cases. Despite administrative reforms, the backlog persists.

What this means: If you want to submit in October 2025, you need to start preparation now. Opening a Portuguese bank account takes 4-8 weeks for Americans. FBI background checks take 2-4 weeks. Fund selection requires due diligence time.

The real question isn't "should I apply in October?" instead, it's "can I submit a complete, high-quality application in October?"

What This Means for Your Decision

The proposed citizenship extension adds complexity, but it shouldn't drive panic or poor decision-making.

Remember why you would pursue the Golden Visa: "Plan B" residency without immediate relocation, portfolio diversification through European investment, EU travel rights (90 days visa-free in 29 Schengen countries), multi-generational planning for children, and quality of life considerations around safety and stability.

Even on a 10-year timeline, you receive immediate benefits: You can live in Portugal full-time if you choose, travel freely in Schengen, and establish your European base. Citizenship is the endpoint, not the only benefit.

For families with young children, a 10-year timeline may actually align better with college and career planning in Europe.

For families motivated by immediate relocation, the timeline change matters less since you'll be living in Portugal regardless.

For wealth diversification strategy, citizenship timeline is one factor among many including fund performance, tax implications, and program stability matter equally.

The decision depends on your documentation readiness, fund selection progress, and why you're pursuing this path. Every family's situation is different.

Key Takeaways

The proposed change is real but not yet law. Portugal's parliament is reviewing legislation to extend citizenship eligibility from 5 to 10 years. A decision is expected in October 2025, but passage is not guaranteed.

Grandfathering provisions may protect earlier applicants. Applications submitted before June 19, 2025 with complete documentation may remain eligible under the 5-year rule. The specifics depend on final legislative language.

The April 2024 change helps everyone. Your citizenship clock now starts from application date, not approval date. This reduces effective wait time by 1.5-2.5 years given current processing delays.

Processing could take 18-30 months regardless. Applying in October 2025 means approval in 2027. The urgency is about application submission, not immediate residency.

Quality matters more than speed. An incomplete or poorly prepared application can be rejected, offers no grandfathering protection, and may jeopardize your entire Golden Visa path. Proper fund selection, tax planning, and documentation are essential.

The 10-year timeline doesn't invalidate the program. Even on a longer citizenship timeline, the Golden Visa provides immediate residency benefits, EU travel rights, portfolio diversification, and family optionality that many Americans value.

This is a complex decision requiring professional guidance. Every family's situation is different ranging from timeline urgency, financial readiness to motivation factors, and risk tolerance all influence whether to accelerate or maintain proper preparation pace.

Disclaimer: This article provides general information about the Portugal Golden Visa program and proposed policy changes. It is not legal advice, immigration advice, tax advice, or investment advice. Portuguese immigration law is complex and subject to change. Consult a qualified Portuguese immigration lawyer, US expat tax specialist, and financial advisor for guidance specific to your situation.

Ready to Discuss Your Timeline?

Uncertain about whether you should accelerate your application or focus on proper preparation? The decision depends on your specific documentation readiness, fund selection progress, and family circumstances.

Schedule a consultation with our team to discuss your situation and understand the realistic timeline for your Golden Visa application. We'll help you evaluate whether you can submit a complete, high-quality application in the near term.