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Portugal’s AD Coalition Wants Stricter Physical Presence for Golden Visa Holders

These proposals remain only campaign positions—no draft legislation exists yet for citizenship reforms.

These proposals remain only campaign positions—no draft legislation exists yet for citizenship reforms.

The center-right AD coalition has announced its intention to propose plans to tighten naturalization requirements in its 2025 electoral program. These proposed changes could profoundly impact Golden Visa holders seeking Portuguese citizenship.

The coalition intends to “revise the requirements for granting Portuguese nationality […] by extending the minimum period of residence and effective presence in the national territory, and eliminating the possibility of illegal stay being counted toward this period.”

The AD coalition’s proposal contains two distinct changes to naturalization requirements. First, they aim to extend the overall minimum period required for citizenship eligibility. Second, their emphasis on ‘effective presence’ would require more time physically spent in Portugal during the qualification period.

This language directly addresses the residency conditions for citizenship. Current rules permit Golden Visa holders to qualify for naturalization after maintaining their status for five years while spending as little as 14 days in Portugal every two years.

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Pedro Catão Pinheiro, Partner at Next Lawyers, explains that the Aliança Democrática aims to increase residency requirements from the current five-year threshold while adding specific physical presence conditions. The coalition believes these changes would “strengthen ties to Portugal and mitigate concerns about the ‘call effect’ of the current law.”

Madalena Monteiro, founder of Liberty Legal, characterizes the initiative as “a politically motivated move” ahead of Portugal’s May 18 elections. The proposal “has not yet been officially presented” and requires parliamentary approval rather than a government decision.

The existing system offers exceptional advantages to investment visa holders. Under current regulations, Golden Visa applicants can count their processing period toward the five-year citizenship requirement—even with minimal physical presence in Portugal during this time.

As current processing times exceed 36 months for new Golden Visa applications, investors can theoretically qualify for citizenship after spending just 14 days total in Portugal. They need only maintain their status for the remainder of the five-year period while residing primarily abroad.

The electoral program criticizes previous governments for making “unilateral and even retroactive ruptures in state commitments” regarding programs like the Golden Visa. This reference appears on page 215 and hints at the coalition’s desire to restore predictability in investment-related migration programs.

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Monteiro points out this proposal contradicts “recent reforms aimed at simplifying access to Portuguese nationality to counter the country’s sharp demographic decline.” She anticipates “considerable debate” with immigrant associations likely to “strongly oppose it, particularly because residence procedures in Portugal remain complex and inconsistent.”

The proposed nationality reforms come alongside other immigration measures outlined in the program. These include eliminating “manifestação de interesse” pathways, strengthening border controls, and reforming immigration services under the Agency for Integration, Migration, and Asylum (AIMA).

Legislative Process and Electoral Outlook

Pinheiro cautions that these proposals face a complex legislative journey. Amendments to Portuguese citizenship law “require specific democratic processes” and must clear Parliament as an organic law, necessitating an absolute majority vote from more than half of all sitting members.

Monteiro adds that modifying the nationality law will “require significant parliamentary support, with at least 116 MPs voting in favour.” She views the proposal as “possibly just an electoral bluff” and finds it “especially surprising coming from the PSD, a party that has historically supported measures to attract new residents and was responsible for introducing the golden visa program.”

If the AD coalition wins the upcoming elections and maintains its objectives, the Ministry of Justice would begin the implementation process by drafting amendments to the Nationality Law.

The Council of Ministers would need to approve these changes before submitting them to the Assembly of the Republic. Parliamentary committees would review the legislation, followed by public consultations and final votes. The entire process typically spans 12 to 18 months from the ministerial draft to enforcement.

Previous governments have generally included transitional provisions for applications already in process when amending Portugal’s nationality laws. After parliamentary approval and presidential promulgation, the Diário da República publishes implementation decrees that typically establish a transition period of three to six months. The AD’s electoral program does not specify whether potential reforms would apply retroactively to current Golden Visa holders or only to new applicants.

The implementation of these proposals hinges on the outcome of Portugal’s snap legislative election scheduled for May 18, 2025. The Democratic Alliance (AD), led by Prime Minister Luís Montenegro, faces strong competition from the Socialist Party (PS) in a highly competitive race. Current polling shows the AD receiving between 27% and 34% support, while the PS polls between 27% and 31%.

Different surveys show varying leads for each party. A recent Pitagorica poll conducted for TVI and TSF placed AD at 34.4%, ahead of PS at 27.8%. An Aximage poll reported by Bloomberg showed contrasting results, as PS lead at 30.8% compared to AD’s 25.8%.

Pinheiro notes that under “the current political scenario, it is not possible to determine the outcome of the coming elections.” The AD might not win, or even if victorious, could lack the parliamentary majority needed to enact such amendments.

Neither party appears likely to secure an outright majority in the 230-seat Assembly of the Republic. The far-right Chega party consistently places third with 13% to 18% support, potentially playing a decisive role in post-election coalition negotiations. These electoral dynamics will ultimately determine whether the AD’s proposed citizenship reforms move forward.

Pinheiro believes these proposals, while worth monitoring, face “significant hurdles before becoming reality.” The AD would need not only electoral success but also “substantial political capital and cross-party support” to enact such changes. “The path from campaign promise to enacted law is long and uncertain,” he concludes. “Multiple political dominoes would need to fall perfectly for these changes to materialize in the near future.”

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