Portugal’s nationality law sets naturalization at ten years for most foreign nationals. The count does not begin until the Agency for Integration, Migration and Asylum (AIMA) issues a residence permit.
AIMA has taken two to three years to issue one, against a legal deadline of 90 days. Those years land on top of the ten before an applicant can apply.
Every route to citizenship has a number written into its nationality law and a second number that law does not set. The second one measures how many files an agency, a court, or a head of state can decide in a year.
That second number is where almost all the surprise in a citizenship timeline lives, and it puts two applicants with identical entitlements years apart. This article maps where the time hides across eight routes.
Portugal Moved the Date the Clock Starts
Portugal’s parliament first approved the revised Nationality Law on October 28, 2025, by 157 votes to 64. The Constitutional Court then struck down four of the seven contested clauses in December.
Parliament re-approved a revised text on April 1, 2026, by 152 votes to 64. President António José Seguro promulgated it on May 3, and Lei Orgânica n.º 1/2026 took effect on May 19.
Foreign nationals can now naturalize after ten years of legal residence. Citizens of European Union member states and nationals of countries where Portuguese is an official language qualify at seven.
The residency count begins on the day AIMA issues a residence permit. A 2024 amendment had started the count at filing, to shelter applicants from administrative delay, and the new law reverses it.
Portuguese law allows AIMA 90 days to decide a residence permit application under Article 82 of Lei 23/2007. The agency has taken two to three years.
Seguro flagged the problem as he signed. The Presidency’s promulgation note, written in the third person, records him pointing to the slowness of the state as something that should not affect the timelines the law fixes for acquiring nationality.
The note has no binding force, and the law it accompanies left the counting rule it complains about in place.
One protection survived. The new requirements do not apply to administrative procedures already pending when the law entered into force.
Anyone who filed before May 19, 2026 therefore remains under the previous five-year rule. How far that reaches is the live question.
Article 7(2) refers to pending administrative procedures without saying which ones. Madalena Monteiro of Liberty Legal argues that applicants with pending residency files retain the benefit of the existing counting method.
That ambiguity decides whether the more than 20,000 investors awaiting AIMA appointments as of April 2026, some of them since 2021, fall under the five-year rule or the ten-year one.
The legal campaign against the Portuguese state has three fronts. Investors filed an amicus curiae brief with the Constitutional Court in December 2025.
More than 500 investors organized a collective action in May 2026. A consortium of nine law firms then filed an Ombudsman complaint on behalf of 1,260 clients on June 26, 2026.
The United States Makes You Wait Before the Clock Can Start
US law requires that applicants have lawful permanent residence for five years before naturalizing, or three when married to a citizen. Almost the whole wait comes before the green card.
EB-5 investors born in high-demand countries queue for an immigrant visa number. As of the September 2026 Visa Bulletin, the final action date for Chinese nationals in the unreserved EB-5 category stood at December 1, 2016.
A Chinese investor whose petition has a 2017 priority date is waiting for a number nearly a decade later. The five-year residence clock has not begun.
For Indian nationals, the State Department marked unreserved EB-5 unavailable for the rest of fiscal year 2026 after India used its prorated limit. The same bulletin warns that the unreserved category could retrogress or become unavailable for every country before September 30.
The reserved set-aside categories tell the other half of the story. Rural, high-unemployment, and infrastructure allocations remained current for every country in that bulletin, China and India included.
This wait has a different cause from the others in this article. Congress wrote the per-country limits into the Immigration and Nationality Act, so the queue is an allocation rule rather than an agency’s throughput.
The effect on an applicant is the same. Two investors committing identical capital in the same month can be a decade apart on the path to a US passport.
Country of birth and investment category decide that gap, and neither appears anywhere in the naturalization statute.
Paraguay and Panama Wait on a Signature
Paraguay’s Constitution requires under Article 148 that applicants complete a minimum of three years of residence in the national territory. It says nothing about permanent residence.
The rule that those three years begin only when a foreigner obtains radicación permanente comes from Article 42 of Acordada 464/07, an internal regulation of the Supreme Court of Justice.
That same regulation sets its own deadlines. Article 47 gives the public prosecutor five days to deliver an opinion, and Article 48 gives the full Court 30 days to grant or refuse the petition.
Paraguay has never passed a law implementing Article 148. A naturalization bill now before the Chamber of Deputies puts the consequences plainly in its explanatory memorandum: Legal uncertainty, administrative and judicial discretion, requirements with no constitutional basis, and proceedings of three to five years against a constitutional requirement of three years of residence.
The counting rule in Article 42 is one of the requirements with no constitutional basis that the memorandum means.
The bill would also move the decision away from the Supreme Court. Article 10 of the draft assigns it to the Juez de Primera Instancia en lo Civil y Comercial of the applicant’s domicile, and leaves the Court compiling a register of everyone naturalized since 1992.
It would give the public prosecutor nine days to respond and the judge 20 days to rule. The bill remained in committee as of May 2026 and had not moved by September.
After a ruling comes an oath at the Palace of Justice, the Carta de Naturalización, registration with the identification authority, a new cédula, and only then a passport application.
Three years is the published figure. The legislature’s own estimate puts the procedure at three to five years, and applicants who enter through temporary residency rather than the investor route add up to two more years before the qualifying clock opens.
Article 10 of Panama’s Constitution requires that applicants complete five consecutive years of residence before seeking naturalization. It cuts that to three for applicants married to a Panamanian citizen, or with a child born in Panama to a Panamanian parent.
The grant arrives by presidential decree. Eduardo Arango, then Vice Minister, told IMI in December 2025 that the President signs each one personally, and that José Raúl Mulino had made clearing the naturalization backlog a priority.
Arango left the post on June 1, 2026. Panama has published no figure since for how many decrees await signature.
Five years is the statutory figure for a Friendly Nations or qualified investor applicant. The signature queue is outside the statute.
Argentina shows what happens when the identity of the signer is itself contested. Two federal courts struck down President Javier Milei’s transfer of naturalization from federal judges to the migration directorate in June 2026, and the government has appealed to the Supreme Court.
In Spain, Filing Suit Is Often Faster Than Waiting
Spain and Portugal both write ten years into their nationality laws for most applicants. Spain cuts that to two years for nationals of Ibero-American countries and a short list of others.
The delivered figures diverge because of what happens around the ten years.
Royal Decree 1004/2015 gives the responsible directorate, since renamed the Directorate General for Legal Security and Public Faith, a maximum of one year to resolve and notify a nationality-by-residence application. The year begins on the date the application enters that directorate.
When that year passes with no decision, Spanish law treats the application as denied by administrative silence. That deemed denial opens a contentious-administrative appeal to the Audiencia Nacional.
Practitioners report resolution times of one to three years, and many file the appeal to force movement. A well-documented file frequently resolves through satisfacción extraprocesal, where the ministry decides the case instead of defending it in court.
Two Routes With No Residence Requirement at All
Polish citizenship by descent is a confirmation rather than a grant. Poland treats a qualifying descendant as having been a citizen since birth, and the procedure recognizes a status that already exists.
There is no residence period, no language test, and no investment. The whole timeline is administrative.
Article 55 of the Act on Polish Citizenship assigns the decision to the voivode for the applicant’s place or last place of residence in Poland. Where no such place exists it goes to the Mazowiecki Voivode in Warsaw, which routes the whole diaspora through one office.
Article 10(3a) of the 2009 Act gives the authority six months from the day the application reaches it. The Code of Administrative Procedure governs that count, applied through Article 10(3).
Article 35(5) of the Code then excludes periods for specified acts, suspension, mediation, and any delay attributable to the applicant or to causes beyond the authority’s control.
Law firms handling these cases report waits measured in years.
Confirmation does not end the process. Transcribing foreign civil records into the Polish registry, obtaining a PESEL number, and applying for the passport all follow it.
Italy shows what happens when a consular queue starts deciding who has a legal right. Law 74/2025 restricted citizenship by descent for people born abroad who already have another nationality.
The statute preserves recognition where a parent or grandparent was exclusively an Italian citizen. It also preserves recognition where a parent lived in Italy for at least two continuous years after acquiring Italian citizenship and before the birth.
A grandparent born in Italy who also had Argentine or Brazilian nationality no longer supports a claim under that test. Consulates verify the point through negative citizenship certificates, renunciation attestations, and certificates of non-registration on foreign electoral rolls.
The Constitutional Court upheld the restriction in Judgment 63/2026, decided on March 11, 2026 and deposited on April 30. The statute itself, and not the judgment, protects those who had filed a complete application, secured a communicated appointment, or started court proceedings before the cutoff of March 27, 2025.
At paragraph 9.1 the Court declined to address applicants who had sought an appointment and never received one.
Consular calendars across South America and the United States had been saturated for years. The record in one Cassation case included a 2022 notice from the Bogotá embassy acknowledging that it could not process new descent applications, with no resumption date set.
Two people with identical ancestry ended up on opposite sides of a legal line, separated by whether a booking portal had capacity.
The Court of Cassation opened one door on May 12, 2026, ruling in order 13818/2026 that an applicant blocked from filing at all may go straight to court.
Article 3-bis is now before the Court of Justice of the European Union. Ordinanza 147/2026, heard on June 9, 2026 and deposited on July 23, referred its compatibility with EU law to Luxembourg and suspended the proceedings before the Constitutional Court.
Article 3-bis remains in force while Luxembourg considers the question.
A separate ruling settled a different question. The Court of Cassation, in its United Sections, ruled in judgment 24045/2026 of July 26, 2026 that Article 3-bis does not apply to judicial claims filed before March 27, 2025.
The Shortest Routes Show the Widest Proportional Gap
Citizenship by Investment (CBI) once removed the residence requirement altogether. That is no longer accurate for any of the five Caribbean programs.
Antigua and Barbuda presented a bill in Parliament in July 2026 raising its post-citizenship requirement from five days to 30. In Grenada a 30-day rule reached the statute book and was then deferred on August 21, days before it was due to commence.
Saint Kitts and Nevis announced an overhaul in January 2026 that would replace donation-only routes with physical presence requirements, without fixing a day count. Saint Lucia’s draft 30-day regulations are not in force.
Dominica ended its no-visit model on June 10, 2026, when Prime Minister Roosevelt Skerrit said new citizens must collect their passports in person.
The regional layer is not in force either. The 2025 ECCIRA agreement sets the obligation at an aggregate of at least 30 days during the first five calendar years after the grant of citizenship, and it takes effect once the regional regulator begins work.
Brochures across the five programs advertise three to six months. The IMI Processing Times Tool, which surveys approval timelines reported by working agents each quarter, recorded a spread of roughly five to 18 months on Q4 2025 data.
Saint Lucia had the longest wait, averaging 18 months with reported cases from 12 to 26 months. Half the programs IMI tracks got faster in Q1 2026, with Dominica among them.
Italy led that same quarterly survey, which covers residence programs alongside citizenship ones. Italy’s investor visa grants a residence permit, and naturalization there requires ten years of residence.
No legislature set any of those numbers. Application volume, the due diligence layers added since 2023, and each unit’s processing capacity produced the spread.
Four Questions That Produce the Delivered Number
Any provider will quote you the statutory figure. Four questions move the conversation to the delivered one.
Which event starts the clock?
Filing, permit issuance, and permanent residence status are three different dates. Portugal moved between two of them in one legislative session, adding years to the timeline of every investor awaiting a permit without touching the ten-year headline.
Who signs the final decision?
A registrar, a ministry, a full supreme court, and a president have different throughput. The difference compounds over a five-year or ten-year horizon.
What is that authority’s current queue?
Ask for a number with a date attached to it. Quarterly processing data and each government’s own published statistics beat a brochure range.
What happens when the legal deadline passes?
Spain converts silence into a denial you can litigate, which is a usable tool. Poland excludes most of the delay from the deadline itself, which leaves an applicant waiting with nothing to appeal against.
The statutory period is the one figure in a citizenship timeline that does not change while you wait. Everything on either side of it is capacity, and capacity is what belongs in the decision.
