Portugal’s immigration framework has undergone significant transformation over the last two years. Following the end of the Expression of Interest procedure in 2024, the restructuring of renewal procedures in 2025 and the more recent changes to visa and residence routes, foreign nationals have been adapting to a legal landscape that looks markedly different from the one that existed only a few years ago.

Portugal’s Immigration Law: Stability at Last or More Change Ahead?

However, it is important to begin with one key clarification: the approved parliamentary text is not yet in force.
 
The legislative process is still ongoing. The text has been approved in general terms, but it must still go through the remaining parliamentary stages and may still be amended before final approval, presidential review and publication in the Diário da República. Until that happens, the current legal framework remains applicable.
 
One of the most significant aspects of this latest reform package is its continued movement away from the model that many immigrants came to associate with Portugal during the previous decade: entering the country first and regularising immigration status afterwards.
 
Falling in love with pastéis de nata, bacalhau com natas and Lisbon’s light while visiting Portugal as a tourist is, unfortunately, no longer enough to build an immigration strategy.
 
The overall direction of the proposed changes reinforces the principle that residence should generally be obtained through the appropriate visa process before arrival in Portugal, except in the specific cases still expressly provided for in the law.
 
The reform package also includes changes to residence routes linked to parenthood. Under the proposal, the residence route for parents of minor children would be narrowed. The child would need to be Portuguese, reside in Portugal, and the applicant would need to effectively exercise parental responsibilities and ensure the child’s maintenance and education.
 
This is a relevant change, particularly when read alongside the recent changes to the Nationality Law, which made it more difficult for children born in Portugal to acquire Portuguese nationality at birth.
 
Another noteworthy proposal concerns the effects of administrative silence in certain immigration procedures. The package seeks to limit situations in which the absence of a decision by the administration may produce effects favourable to the applicant.
 
The parliamentary package also includes measures relating to border management, screening procedures and asylum, intended to align Portugal with the European Union Pact on Migration and Asylum.
 
For current residents, one of the most practical changes concerns work based residence permits. The proposal provides that holders of a residence permit for subordinate professional activity may change employer by informing AIMA, without needing a new residence card to be issued. Similarly, holders of a residence permit for independent professional activity may change the nature of their activity by informing AIMA.
 
This may facilitate future renewal procedures and reduce the risk of complications where the applicant’s professional situation has changed since the original residence permit was granted.
 
The proposal also provides that residence permit applications may be submitted by the applicant, by a legal representative or by the employer, and that applications for the granting of a residence permit should be decided within 90 days, extendable by an additional 30 days in exceptional and duly justified circumstances.
 
The recommendation is therefore to remain attentive to future developments. Parliamentary approval in general terms does not automatically alter existing rights, invalidate current residence permits or immediately change pending procedures.
 
The final impact of these measures will depend on the completion of the legislative process and, above all, on the exact wording of the law ultimately published.
 

The coming weeks will therefore be important in determining the exact scope of these changes and the practical impact they may have on both future applicants and the thousands of foreign nationals who already call Portugal home.
 
These “amendments in instalments”, as many immigration lawyers have started calling the recurring changes to Portugal’s immigration framework, naturally create uncertainty and frustration for residents and future residents who are trying to plan their lives in Portugal.
 
We hope that this third major round of changes to Portugal’s Immigration Law will, finally, be the charm.