by Maria Gabriela Bragança
Over the past months, anyone with an eye on Portugal’s future has felt the tension building. First came the announcements, then the debates, then the late-night discussions in Parliament. Headlines were dominated by one idea: Portugal was about to turn the page on its relatively open path to citizenship.
Parliament has now done its part. A new, stricter version of the Nationality Law has been approved, reshaping the rules on who can become Portuguese and when. For many foreign residents, and especially for families investing here through the Golden Visa, the first reaction was simple: “What does this mean for us?”
The answer, at the end of November 2025, is more nuanced than many initial reactions suggested.
The parliamentary vote was decisive and the message of the reform is clear: Portugal wants a longer, deeper path to citizenship, tied more closely to integration in the country. The approved text doubles the general residence requirement for naturalisation from five to ten years, and introduces a seven-year track for residents from EU and Portuguese-speaking countries. It tightens rules around language, cultural knowledge, financial self-sufficiency and criminal background. It raises the bar for children to acquire nationality through being born in Portugal, and it even opens the door to loss of nationality in certain serious criminal cases.
On paper, it is a significant shift away from the “five-year path to a passport” that made Portugal stand out for so long.
Yet the story is not finished. After Parliament voted, the law did not simply slide into the statute books. It hit an important constitutional checkpoint.
A formal request was submitted for preventive review by the Constitutional Court, challenging key elements of the reform. This mechanism, rarely used in the Court’s history, immediately suspended the law before it could be promulgated. The judges now have a limited window to decide whether the new rules respect the Constitution, particularly in areas such as proportionality, legal certainty and equality.
Until that decision is handed down – and until the President chooses to promulgate, veto or send the text back to Parliament – the old Nationality Law remains in force. For now, citizenship can still be requested after five years of legal residence, under the existing framework.
This “in-between” moment is confusing, especially for those who are close to the five-year mark or who are planning long-term moves. Official statements and expert commentary increasingly describe the approved law and its consequences, while at the same time stressing that it is not yet binding. It is a transitional situation: everyone can see the likely direction of travel, but the legal road has not fully shifted.
Amid this uncertainty, one piece of the puzzle has remained remarkably stable: the rules on Permanent Residency – including for Golden Visa investors.
Permanent Residency in Portugal continues to be accessible after five years of legal stay. That has not been altered by the Nationality Law reform process. The foreigners’ law, which governs the general regime of entry, stay and removal of foreign nationals, has been amended this year on other fronts – for example, to end the old “Manifestação de Interesse” route and to adjust rules on family reunification – but the core five-year path to permanent residence remains in place.
For those holding, or considering, a residence permit for investment (the ARI, widely known as the Golden Visa), this distinction is crucial. The Golden Visa was never a direct citizenship-for-investment programme; it was a residency-by-investment route that could eventually lead to citizenship under the general naturalisation rules.
That logic has not changed. What the parliamentary reform is trying to do is lengthen the citizenship horizon, not the residency one.
Golden Visa holders still:
– Invest and obtain their initial residence permit.
– Maintain their investment and comply with the minimal physical stay requirements.
– Reach the five-year mark and become eligible to apply for Permanent Residency under the foreigners’ law.
Legal analyses published in recent weeks have been consistent on one point: even if the new Nationality Law eventually comes into force in the form approved by Parliament, the investment lock-up period for Golden Visa funds remains tied to the five-year residency requirement for Permanent Residency, not to any extended citizenship timeline. Once an investor secures permanent residence, they are no longer legally obliged to retain the qualifying investment, even if they intend to wait longer before applying for nationality under stricter rules. In practical terms, this means that for Golden Visa investors:
– Today, the law in force still allows a citizenship application after five years of residence.
– If and when the reform is confirmed, new applicants will likely face a ten-year path to citizenship (or seven years for certain nationalities), but
– The five-year investment horizon and the five-year route to Permanent Residency remain the anchor.
This is why so many advisors are now telling clients to mentally decouple two things that were often blended together in marketing narratives: the investment period and the citizenship timeline. The first remains relatively short and clearly defined; the second is becoming longer, more demanding and, for the moment, is still in a state of legal flux.
For families already in the process, or about to start, the most sensible approach is to plan on the basis of what is stable: Permanent Residency. That is the status that guarantees long-term living, working and study rights in Portugal and preserves Schengen mobility, regardless of how long the journey to a passport ultimately becomes.
Against this backdrop, Golden Visa investors are understandably looking for structures that are not only legally compliant today, but also resilient to future changes and carefully aligned with the residency rules rather than optimistic assumptions about citizenship.
This is where the design and governance of a fund truly matter.
At Ventures.eu, we have been following each procedural step of the reform and each new opinion published by leading immigration and nationality lawyers. Our fund was structured from the outset around the five-year Permanent Residency requirement and an eight-year fund horizon, which means that even under the stricter, proposed nationality rules, our model remains aligned with the legal obligations that actually govern investment lock-up.
We combine that legal alignment with something investors increasingly value in this environment: a clear, transparent focus on real European innovation, professional management, and close collaboration with specialised Golden Visa legal teams. That allows our investors to concentrate on two things that remain fully within reach – securing long-term residency in Portugal and participating in the growth of high-potential European companies – while the broader debate on nationality continues to unfold.
The Nationality Law is changing; the final shape of the reform now rests with the Constitutional Court and, ultimately, the President. But for Golden Visa investors, the foundation remains solid. Residency, and the five-year path to Permanent Residency, is still where stability lies – and it is precisely around that anchor that we continue to build and manage our fund.
