Portugal’s Minister of the Presidency, António Leitão Amaro, has accused investment migration consultants of misleading their clients about the prospect of acquiring Portuguese nationality. Speaking at a press conference following the National Council for Migration meeting on May 24, Leitão Amaro told reporters that any consultant who promised a client he was “buying a Portuguese passport” through the golden visa had deceived him.
“If a consultant promised his client that, by applying for a residence permit for investment, he had a guarantee of nationality, was buying the Portuguese passport, he was deceived,” the minister told Diário de Notícias. “And the responsibility, perhaps, lies there.”
The comments come less than a week after Lei Orgânica n.º 1/2026 entered into force on May 19, doubling the naturalization timeline from five to ten years for most foreign nationals. EU and Community of Portuguese Language Countries (CPLP) citizens now face a seven-year requirement.
Over 500 golden visa holders are preparing a collective lawsuit against the Portuguese state, and a four-firm legal consortium plans to challenge the law across multiple jurisdictions. IMI will provide further coverage of the consortium’s legal strategies in the coming days.
“The Minister Should Answer One Simple Question”
André Miranda, managing partner of Fieldfisher Portugal and one of the lawyers in the consortium, rejected the minister’s framing outright.
“No one ever promised automatic or guaranteed nationality,” Miranda told IMI. “The golden visa program was always a residence by investment (RBI) program. And the government and its agencies knew it, promoted it, and profited from it since it was introduced in October 2012. The minister is now trying to rewrite history.”
Miranda then turned the accountability argument on Leitão Amaro personally. “Before pointing fingers at consultants, the minister should answer one simple question: What happened to his promise that by 2026 all investors would have their residence cards?”
That promise dates to October 2025, when Leitão Amaro told parliament during the 2026 State Budget hearings that the Agency for Integration, Migration and Asylum (AIMA) would resolve outstanding golden visa applications in 2026, generating €85 million in revenue.
“The real misconduct here is not by advisors,” Miranda added. “It is by a state that deliberately delays, and by leaders who change the rules midway through the game. The time has come to hold politicians accountable for their promises.”
“The State’s Own Failure to Deliver”
Lawyers at Paxlegal, a third consortium firm, echoed the argument. Bárbara Pestana pointed to the years-long processing backlog as the real breach of faith.
“The real broken promise was the state’s own failure to deliver,” Pestana told IMI. “Portugal invited foreign investors to commit millions to the country, while making them wait four and five years for a residence permit.”
Her colleague Emellin Oliveira framed it more bluntly: “Trust is not destroyed by advisors; it is destroyed when the state itself fails to honour the system it created.”
“Legitimate Expectations Were Clearly Created by the State”
Raquel de Matos Esteves, founding partner of RME Legal and another member of the consortium, took a more measured but equally firm position.
“The possibility of applying for nationality as any legal resident, whether or not under the golden visa regime, continues to be provided for under Portuguese law,” Matos Esteves told IMI. “The Nationality Law may, of course, be amended; however, the real issue at stake is whether legitimate expectations were created regarding the number of years of residence required. In our view, they clearly were, by the state itself, and there is extensive documentary evidence demonstrating this.”
Matos Esteves argued that the minister’s framing misses the point entirely. “No one was ever guaranteed nationality, because Portugal does not have a citizenship by investment regime,” she said. “However, that does not justify failing to safeguard the legitimate interests of those who, in a country where nationality could be acquired through a period of lawful residence, were legitimately pursuing that path.”
Her emphasis on tutela da confiança (protection of trust) echoes the legal arguments laid out in the amicus curiae brief golden visa investors filed with the Constitutional Court in December 2025.
That brief documented how the former SEF website expressly referenced the possibility of acquiring Portuguese nationality through the golden visa residence route, and how the naturalization period had been reduced from six years to five before being doubled to ten.
A Pattern of Confrontation
Leitão Amaro’s attempt to shift blame to consultants fits a pattern. When the minister admitted in October 2025 that the government had deliberately prioritized poorer immigrants over golden visa holders in the AIMA backlog, he framed the decision as “social equity.” Lawyers called it deliberate discrimination against the investors who paid the most.
Parliament approved the nationality law changes on April 1 with a 152-64 vote, the product of a deal between the ruling Social Democratic Party (PSD) and Chega. President António José Seguro promulgated the decree on May 3.
In December 2025, the Constitutional Court struck down four of seven contested provisions but upheld the ten-year timeline. Lawmakers then reconfirmed the surviving provisions with a 157-vote supermajority.
The law contains a transitional rule under Article 7.2 protecting nationality applications filed on or before May 18, 2026. Golden visa holders who had not yet filed, however, receive no such protection.
The government has 90 days from publication to update the implementing regulation (Regulamento da Nacionalidade Portuguesa); AIMA and the Institute of Registries and Notaries (IRN) have yet to publish procedural guidance.
