A consortium of nine Portuguese law firms filed a formal complaint with the Portuguese Ombudsman, the Provedoria de Justiça, this week, acting on behalf of 1,260 golden visa clients affected by the country’s recent nationality law overhaul and the long-running processing backlog at the immigration agency AIMA.
The complaint asks the Ombudsman to intervene within its constitutional and statutory powers to protect the legitimate expectations of applicants who organized their lives around the legal framework Portugal promoted. It targets both the legislative changes and what the firms describe as “years of administrative failure” inside the Agency for Integration, Migration and Asylum (AIMA).
“Our goal is to correct a serious mistake and help restore Portugal’s credibility,” said Raquel Matos Esteves, founding partner of RME Legal, part of the consortium. She called it unacceptable to undermine the expectations of people who trusted the state and made life-changing decisions based on commitments promoted by successive governments, only to face waiting periods of three, four, or even five years in return.
Other firms that signed on are Liberty Legal, Fieldfisher Portugal, Paxlegal, LexGO Legal and Finance, Maria Margarida Torres, AVCO Legal, AGPC, and BRF Legal. The submission marks the third front in a coordinated legal campaign that began with an amicus curiae brief to the Constitutional Court in December 2025 and now runs alongside a collective lawsuit against the Portuguese state.
A Law Without a Transitional Regime
The new nationality law entered into force on May 19, doubling the naturalization timeline from five to ten years for most foreign nationals. Citizens of the European Union and the Community of Portuguese Language Countries (CPLP) now face a seven-year requirement instead.
The law’s sharpest edge for golden visa holders is the absence of a broad transitional regime. A rule under Article 7.2 protects nationality applications filed on or before May 18, 2026, but investors who had not yet reached the filing stage, often because AIMA had not issued their residence permits in time, receive no such shelter. The residency clock now starts when AIMA issues the permit, not when the application is lodged.
That sequencing is the heart of the grievance. “Our clients fulfilled every requirement, investment, compliance, fees, yet continue to be penalized by administrative dysfunction and regulatory shifts they had no part in creating,” said Sara Oliveira of LexGO.
Catarina Almeida Garret of AGPC framed the submission as a defense of people who acted in good faith. “Investors, families, and residents who made decisions in good faith under Portugal’s existing legal framework deserve fair treatment and transitional protection,” she told IMI, adding that protecting legitimate expectations is what keeps the country credible as a destination for global investment and talent.
What the Ombudsman Can and Cannot Do
The Provedor de Justiça is an independent constitutional body that defends citizens, both Portuguese and foreign, against unlawful or unfair acts of the public administration. It can investigate, request documents, and inspect public bodies without notice. It cannot, however, issue binding decisions.
Instead, the Ombudsman may issue recommendations to correct injustices, and it may ask the Constitutional Court to review the constitutionality or legality of a legal norm.
For the consortium already challenging the law on constitutional grounds, that referral power is the goal.
For Emellin Oliveira of Paxlegal, the complaint reaches beyond the investors to the architecture of the state itself. She said the submission represents “the first step in the defense and promotion of the fundamental principles of the State of democratic rule in Portugal.”
Whatever legislative choices a government makes, she argued, the rule of law still demands predictability, consistency, and respect for the legally protected rights of citizens and foreigners alike.
The firms say they now expect to meet with the Ombudsman directly. Whether that meeting produces a recommendation, a constitutional referral, or nothing at all remains to be seen.
A Widening Backlash
The Ombudsman complaint slots into a sequence of escalating moves. The consortium has already laid out a menu of options that includes state liability claims for legislative damage, constitutionality challenges in the national courts, and, once domestic remedies are exhausted, recourse to the European Court of Human Rights.
Portugal’s government has shown little appetite for retreat. Minister of the Presidency António Leitão Amaro recently accused investment migration consultants of deceiving clients into expecting nationality quickly, a framing the consortium rejected as an attempt to rewrite the history of a program the state promoted and profited from for over a decade.
Sara Oliveira put the firms’ resolve plainly: “More actions will follow. It is our duty as lawyers not to stop fighting before this injustice.”
The government has 90 days from the May 19 publication to update the implementing regulation, the Regulamento da Nacionalidade Portuguesa. AIMA and the Institute of Registries and Notaries (IRN) have yet to publish procedural guidance.
Until they do, the practical fate of thousands of pending applicants remains unsettled, which is precisely the uncertainty the firms are asking the Ombudsman to address.
