Worldway Comprehensive News: The Golden Residence Permit Program has attracted significant investment to Portugal, revitalizing the Portuguese real estate market and promoting economic development. Recently, the Portuguese Immigration and Borders Service has re-evaluated and streamlined the previous review model for the Golden Residence Permit Program, providing clearer explanations of the relevant regulations to ensure that future applications can be executed accordingly. This clarification does not constitute a change in regulations; rather, it strengthens the enforcement of existing regulations. The details apply to both initial applications and renewal applications. In this regard, Worldway's immigration experts have provided an authoritative and in-depth interpretation:
【Golden Residence Permit】
The new operational manual from the Portuguese Immigration and Borders Service aims to establish a unified process for the application of various residence permits in Portugal. The following are the main points to note:
1. Before applying for the Golden Residence Permit for investors, lawyers must assist in registering the application online in advance.
Comparison: Previously, the Immigration Service did not require prior online application registration.
Interpretation: This does not affect clients' applications for the Golden Residence Permit; lawyers will complete the relevant operations.
2. Applicants must visit Portugal at least once for their application to be approved.
Comparison: Previously, the Immigration Service did not require accompanying applicants to visit Portugal once before approval.
Interpretation: To increase the number of applicants visiting Portugal and promote local tourism, the requirement for both primary and accompanying applicants to visit Portugal has been added.
3. Clients at all stages (including initial applications and subsequent card renewals) must provide fingerprints after approval; in special circumstances, fingerprints may be taken in advance; renewal applications can only be submitted after approval.
Comparison: Previously, for initial applications, fingerprints and photographs could be scheduled during the visit, and applications could be submitted afterward; for subsequent card renewals, appointments could also be made during the 7-day immigration monitoring period. Under the new regulations, applications must be submitted first, and only after approval can appointments and other procedures be arranged with the Immigration Service.
Interpretation: This significantly impacts the procedures for clients, as the rules are gradually aligning with those of Spain. During the initial application for the Golden Residence Permit, clients will need to visit the immigration monitoring center twice, or stay in Portugal for 2-4 months while waiting for approval.
In special circumstances, to provide fingerprints before approval, the following must be submitted: flight itinerary for the primary and accompanying applicants (including a 7-day itinerary, correct client name and date of birth information, translated into Portuguese), proof of employment for the applicant, and proof of enrollment for children (translated into Portuguese). Our cooperating law firm believes that the flight itinerary is sufficient, and the more supporting documents, the better.
4. All materials submitted to the Immigration Service (notarized documents, immigration monitoring materials, etc.) must be in Portuguese; English submissions will no longer be accepted.
Comparison: Previously, it was sufficient to have Chinese materials translated into English.
Interpretation: This will increase the time required for document preparation. Document materials will be handled by a professional writing team and local law firms in Portugal, which will not significantly impact investors.(It is necessary to confirm the procedures and costs for notarization in China)
5. The validity period of the criminal record certificate is 3 months and must remain valid before all application documents are submitted to the Immigration Service. The time is based on the date of issuance of the document (embassy certification time).
Interpretation: This regulation has not changed and does not have a new impact on clients.
【Number of Golden Residence Permits Approved by the End of April】
6. The validity period of health insurance is 3 months, as per the same requirement as item 4.
Interpretation: This regulation has not changed and does not have a new impact on clients.
7. For residence card applicants (primary/accompanying) aged 18 and above, a no-debt certificate issued by tax and social security authorities must be submitted during the initial application for the residence card. This rule also applies to the renewal of residence cards, and the no-debt certificate is valid for 45 days.
Comparison: Previously, this document was not required for the initial application for the Golden Residence Permit, only for renewals.
Interpretation: Lawyers will assist in obtaining the relevant documents, and this new regulation does not affect clients.
8. After the investor's initial or renewal application is approved, they must go to Portugal to provide fingerprints (if they have not done so previously) and pay the card fee within 30 days of approval. In special circumstances, an extension may be requested for up to 60 days.
Comparison: Previously, the requirement was to provide fingerprints and pay the card fee within six months of approval. The new regulation shortens the time requirement but allows for an extension of up to 60 days.
Interpretation: This new regulation will shorten the time limit for clients to provide fingerprints after approval. For clients and their children who find it difficult to take leave to travel, early planning is necessary. The materials required for requesting an extension (in Portuguese and English) include: proof of employment for the applicant, proof of education for children, and similar documents for bank account opening.
9. Regarding family reunification rules, the 7-day residency requirement has not changed. Other changes are as follows:
a. Adult children over 18 years old, as accompanying applicants, must provide proof of admission from a Portuguese educational institution.
Comparison: Previously, children over 18 years old as accompanying applicants needed to provide proof of full-time enrollment, and non-Portuguese local universities were also accepted; now only Portuguese local educational institutions are recognized.
Interpretation: This is not a new regulation; there are relevant requirements in the "Portuguese Immigration Law." Previously, the Immigration Service was relatively lenient in approvals, allowing adult children of applicants studying at non-Portuguese universities to be approved. For adult children of primary applicants who have already been approved and are studying outside Portugal, proof of enrollment from a Portuguese institution will be required during the next renewal.
b. When applying for the Golden Residence Permit for the first time or during renewal, investors must prove that they have sufficient financial capacity to support themselves and their family living in Portugal, which requires a bank statement showing the average annual account balance per person. For example: for a family of three, with a child aged 18, they need to maintain an account balance of 12,000 euros in a Portuguese bank each year.
Comparison: Previously, this proof was not required.
Interpretation: This is not a new regulation; there are relevant requirements in the "Portuguese Immigration Law." However, the Immigration Service was previously lenient in the approval process and did not strictly require this proof. The recent reiteration of the relevant regulations by the Immigration Service means that future applicants for the Golden Residence Permit must ensure that their Portuguese bank account has sufficient balance.
Explanation regarding the requirement for investors to maintain an account balance of 12,000 euros in a Portuguese bank each year:
This is 12 times the minimum wage in Portugal [EUR 6,120.00], plus 50% of this amount as the minimum account balance for the primary applicant, while the minimum account balance for accompanying applicants is [EUR 3,060.00], plus 30% of this amount; the minimum account balance for minor children is [EUR 1,836.00]. Therefore, for a family of four (primary applicant, spouse, and two minor children), the total minimum account balance is EUR 12,852.00.
10. Accompanying parents aged 66 and above do not need to provide proof of financial dependence, but accompanying parents under 66 still need to provide proof of dependence on the primary applicant.
Interpretation: This regulation has not changed and does not have a new impact on clients.
The Portuguese government strongly supports this policy, and the Immigration Service believes that this restructuring will make the processing of individual cases more efficient. Worldway's immigration experts state that more detailed approval guidelines will better protect investors' interests and principles of fairness, and will also increase the popularity of this program, attracting more investors to immigrate to Portugal.
