Portugal’s New Citizenship Rules, Stuck Applications and Learning Portuguese: Your Questions Answered
By Dra. Sandra Gomes Pinto, Founding Partner, SGP – Sandra Gomes Pinto & Associados, Lisbon · Published 7 November 2026 · Last reviewed November 2026
In short: This guide answers the questions our audience asked most about Portugal’s new citizenship rules and life after the move. It covers the regulation of the new Nationality Law approved on 29 October 2026, what can be done about citizenship applications pending for years, D7 visas and permanent residency, learning European Portuguese and the CIPLE exam, wills and inheritance, and how a 401(k) is taxed in Portugal. The answers come from a live Q&A webinar co-hosted with Sandra Carapinha, founder of Learn European Portuguese Online (LEPO), in which Dra. Sandra Gomes Pinto answered audience questions. She is a Lisbon lawyer whose firm has helped more than 500 Americans and other international clients relocate to Portugal.
Portugal’s new citizenship rules at a glance
Topic | Rule or figure (November 2026) |
Regulation of the new Nationality Law | Approved by the Council of Ministers on 29 October 2026; awaiting promulgation and publication |
Pending citizenship applications | Not affected; decided under the previous rules |
Citizenship by residence (most applicants) | 10 years of legal residence, counted from the first residence card |
Citizenship (Portuguese-speaking countries and EU citizens) | 7 years of legal residence |
New requirements announced | Declaration of honour, basic knowledge of civic rights, culture and history, proof of means of subsistence |
Permanent residency | After 5 years of legal residence, plus A2 Portuguese |
Language level | A2 (CIPLE); B1 and B2 certificates are also accepted |
CIPLE exam in the US | May and November; enrolment opens in January |
CIPLE exam in Portugal | Most months, except January, August and December |
Absence limit (temporary permit) | 6 consecutive months or 8 months in total |
Inheritance without a will | Portuguese law and forced heirship generally apply to habitual residents |
401(k) withdrawals | Taxed in Portugal as a private pension, at progressive rates |
Portugal’s new nationality rules: the 29 October regulation
What did the Council of Ministers approve on 29 October 2026?
The Council of Ministers approved the decree-law that regulates the new Nationality Law, setting out how its new requirements will work in practice. At the time of the webinar, the full text was not yet public. It still has to be promulgated by the President and published in the Diário da República, which typically happens within four to six weeks unless the President uses a political or constitutional veto, which is not expected.
What new requirements will apply to citizenship by residence?
Based on what has been announced, applicants for citizenship by residence (naturalisation) will face four main changes:
A declaration of honour: a statement that you will respect Portugal’s democratic principles and legal order. A standard form is expected, so this should be a simple step.
Basic knowledge of civic rights, the legal system, Portuguese culture and history, in addition to the A2 Portuguese language level.
Proof of means of subsistence: SGP expects the threshold to be in line with the D7 visa, based on the Portuguese minimum wage (€920 per month in 2026), possibly with savings of around one year of minimum wage. This is SGP’s expectation, not yet confirmed.
More digitalisation: public services are expected to share information, so documents you have already given to AIMA or other services should not have to be submitted again.
Will the new law affect my pending citizenship application?
No. Applications that were already pending when the new law came into force are not affected and continue under the previous rules.
Are citizenship by ancestry and by marriage affected?
Not by these changes. The main novelties affect naturalisation, that is, citizenship through residence. However, SGP believes the ancestry and marriage routes may change in the future, so if you are considering either of them, move forward early rather than wait.
How long do I now need to live in Portugal to apply for citizenship?
Ten years of legal residence for most applicants; seven years for nationals of Portuguese-speaking countries and EU citizens. The clock starts when your first residence card is issued. Nationals of Portuguese-speaking countries are typically also exempt from the A2 language test. For more detail, read Portugal’s New Nationality Law 2026: Your Questions Answered.
My first residence card was issued in 2025. Does the 10-year rule apply to me?
Yes. If you have not yet submitted a citizenship application, the new rules apply to you, even if you applied for your Golden Visa years earlier.
Will the lawsuits against the new rules succeed?
SGP does not expect them to. Every country has the right to change its laws. The Golden Visa is a residence-by-investment programme, not citizenship by investment, and the law never gave investors an automatic right to Portuguese citizenship. What Portugal does offer is a clear path to living here permanently, which is not the case in many other countries.
Will waiting ten years for citizenship affect my daily life in Portugal?
No. Your rights in daily life are not affected. After five years you can apply for permanent residency, the right to live in Portugal indefinitely, or for EU long-term resident status, which makes it much easier to move to another European country without starting a visa process from scratch. Both require A2 Portuguese.
When will we know more about the culture and history test?
Once the decree-law is published. SGP expects the details within four to six weeks, after the President’s approval and publication in the Diário da República. The test is not expected to be academic: it should require a basic level of knowledge, not university level.
Stuck citizenship applications
My citizenship application has been pending for years with no update. Can anything be done?
In many cases, yes. Some applications have been pending for four years without any progress. This summer, SGP’s research team studied the case law and developed several strategies to move these cases forward, including an injunction before the administrative court and referrals to other public entities. There is no one-size-fits-all solution: SGP needs to understand your story, your reasons and your specific situation. With this approach, SGP has already been able to expedite many processes.
Connections to Portugal can also strengthen your case, for example owning or inheriting property here, investing here, family ties, or a long relationship with the language and the Portuguese community.
My ancestry application seems stuck. Should I switch to the residency route?
Probably not. Citizenship through ancestry, especially through a parent, typically follows an easier and quicker path than citizenship through residence. If you want to live in Portugal in the meantime, you can apply for a visa while your citizenship application is decided.
Is citizenship through grandparents different from citizenship through parents?
Yes. Through a parent, the process usually takes less time, you do not need the A2 test, and one Portuguese parent is enough. Through a grandparent, it generally takes longer: you must prove A2 Portuguese and an effective connection to the Portuguese community. Under the new law, you will also need to show basic knowledge of Portuguese history, culture and civic rights, and sign the declaration of respect for the democratic and legal order.
Visas, permanent residency and travel
How long can I spend outside Portugal on a D7 visa?
The law says you should not be absent for more than six consecutive months, or eight months in total, within the two-year period of your residence permit. In practice, the Portuguese authorities have been tolerant: serious reasons to spend more time abroad, such as caring for a family member or health, have been accepted. This is only checked when you renew, and the main question is whether Portugal is really your home, where your family life is centred, and not just an address. For more, read Renewing Your Residence Card in Portugal: What to Expect in 2026.
Why is it so hard to get a VFS appointment?
It depends on your consulate. San Francisco and New York have not been very difficult, while Washington, Houston and Miami have been more challenging. You must apply through the consulate that covers where you live: if you live in California, you must go to San Francisco. SGP developed its own booking tool and other strategies to help clients in the harder jurisdictions get appointments.
My D7 is approved but my AIMA appointment is months away. When should I move?
As soon as you can. Arriving early is what the Portuguese authorities like to see. In some cases SGP has managed to bring AIMA appointments forward, but this is difficult and never guaranteed.
When can I apply for permanent residency in Portugal?
After five years of legal residence, counted from when your first residence card was issued, and with A2 Portuguese. Until your permanent residency card is issued, keep renewing your temporary residence as usual.
Can I use the EU passport line at the airport?
Yes, once you have your residence card. Many SGP clients use the EU residents’ line, which usually has a much shorter queue, including when entering through another EU country. With only the D7 visa stamp in your passport it is more difficult, because you do not yet have the residence card.
I did not meet the Golden Visa minimum stay in my first year. Is my renewal at risk?
Usually not, if you make up for it. You should spend seven days in Portugal in the first year, but in SGP’s experience, applicants who spend 14 days here in the second year have generally not had problems with AIMA at renewal.
Learning European Portuguese, with Sandra Carapinha
Is A2 Portuguese also required for permanent residency?
Yes. A2 is required for permanent residency as well as for citizenship, which is one more reason to start learning early.
When should I start learning Portuguese?
Before you move. According to Sandra Carapinha, a common mistake is leaving the language until the end, after the house and the paperwork, when it is the part that takes longest. You do not need intensive courses: around 90% of her students have one hour of class a week, plus time to review. Consistency matters more than intensity, and arriving with some notions of the language makes immersion much easier.
Should I learn Brazilian or European Portuguese? Are apps a good idea?
If you are moving to Portugal, focus on European Portuguese first. Many apps, including Duolingo, focus on Brazilian Portuguese, which can confuse beginners, although there are now newer apps and resources in European Portuguese. You will hear Brazilian Portuguese in Portugal too, so later on it is useful to learn the differences, ideally with a few sessions with a teacher.
How long does it take to reach A2 Portuguese?
Traditionally, around 150 hours of study, but with one-to-one classes many of Sandra Carapinha’s students get there in less than half that time. It depends on the student: knowing Spanish helps, for example. What matters is setting time aside to study and review, and having a plan with a target exam date.
When and where can I take the CIPLE (A2) exam?
In the United States, the CIPLE is held in May and November in Berkeley, Washington, Boston and New Jersey; enrolment opens in January and places can go within an hour. In Portugal, you can take it in most major cities and on the islands, almost every month except January, August and December. Results take about two months, and the certificate another month. The CIPLE is valid for life and can be retaken, so take it as soon as you are ready. The B1 and B2 certificates are also accepted for citizenship.
I have a hearing impairment. Can I get special accommodations for the CIPLE?
Yes. Enrol in the CIPLE as normal, then email the exam centre with documentation from your doctor. Depending on your situation, they may waive the listening component, or provide a computer with a headset and let you listen to the audio more times than usual.
What if I truly cannot learn Portuguese?
In some situations, such as an impairment that makes learning impossible, there may be alternatives, and some courses allow the exam to be waived. But SGP strongly encourages everyone to learn: the language is the foundation for truly becoming part of the culture and the country.
Are one-to-one classes better than group classes?
One-to-one classes are usually the best way to start. You learn at your own pace without comparing yourself with others, and missed classes can be rescheduled. Group classes work better from A2+ or B1 level, with students matched by level. Couples or adult family members can also learn together.
Can my children learn Portuguese too?
Yes. LEPO teaches children from age five, usually separately from their parents, with shorter classes adapted to their age, and helps children transitioning into Portuguese public schools. Teenagers turning 18 can also prepare for the CIPLE if they want to apply for citizenship with their parents.
Wills and inheritance in Portugal
What happens if I die in Portugal without a will?
If you are habitually resident in Portugal, Portuguese law will generally apply to your estate under EU rules, even if you are not a European citizen. Portuguese law has forced heirship, which is usually not what American clients want: most couples prefer the surviving spouse to inherit first, and the children only after both have passed away. To achieve this, you need a will that chooses the law that applies to your estate. This can simplify the inheritance process a great deal.
If my spouse and I own our home, does it pass automatically to the survivor?
No, not automatically. Typically, each spouse already owns half. If Portuguese law applies, the deceased spouse’s half passes to the surviving spouse and the children in equal parts, unless you have a will or another document stating that a different law applies and that your spouse is your universal heir.
I already have a will in another country. Can that country’s law govern my estate?
Yes, if your life has a connection with that country. SGP needs to look at your specific situation to confirm the best approach.
Do executors in Portugal work the same way as in the US or the UK?
No. Executors in Portugal have much more limited powers, mainly urgent and administrative tasks in the inheritance process. A Portuguese executor may still be helpful, as they will be more familiar with Portuguese bureaucracy.
Is a long-term unmarried partner treated like a spouse in Portugal?
No, not for inheritance. A partner in a de facto union may have some rights, such as staying in the home for a period or receiving part of a pension, but proving it can be very difficult. If you want the legal consequences of marriage, SGP’s advice is to get married.
Does a prenuptial agreement from my home country carry over to Portugal?
It may. It depends on which law applies to your property regime under private international law, so it needs to be checked case by case.
Taxes and the bigger financial picture
How is a 401(k) taxed in Portugal?
A 401(k) is generally treated as a private pension and, under the double taxation treaty between Portugal and the US, withdrawals are taxed in Portugal at progressive rates. If you registered under the former NHR regime, a 10% rate applies to withdrawals. If you do not withdraw, you are not taxed. As US citizens are also taxed by the US, it is important to coordinate both sides.
Planning makes a real difference: for example, you can withdraw some money before you become a tax resident in Portugal, or size your withdrawals with the progressive rates in mind. If you may qualify for Portugal’s new tax incentive regime (often called NHR 2.0), for an innovative project or a high-value activity, talk to SGP about how it applies to your income.
Are taxes in Portugal worth it?
Never look at taxes in isolation; look at your whole financial picture. High-quality healthcare costs a fraction of what it does in the United States, and a top-ranked university can cost around €800 a year. When SGP’s clients compare, they say they spend between half and one third of what they spent in the US.
The SGP Membership
How is the SGP Membership different from simply being a client?
It is ongoing support, not just help at the big moments. Members receive exclusive webinars and newsletters on topics such as taxes, social security for remote workers, capital gains on US home sales and practical matters like public transport passes for over-65s. They also get priority support, for example with lease problems or a property purchase, and discounts on residence renewals, citizenship applications, wills and property purchases. Enrolment opens for a limited period each year.
🎧 Listen to the full session: this Q&A is also Episode XII of the SGP podcast, Thinking about moving to Portugal?, on Spotify and Apple Podcasts.
🇵🇹 Want to start learning European Portuguese? Sandra Carapinha offers a free consultation call through Learn European Portuguese Online (LEPO).
About the author
Dra. Sandra Gomes Pinto is the Founding Partner of SGP – Sandra Gomes Pinto & Associados, a Lisbon law firm advising international clients on Portuguese immigration and citizenship, property transactions, tax, and wills and estate planning. SGP was a pioneer in helping Americans move to Portugal and has assisted more than 500 Americans and other international clients with their relocation. The firm accompanies clients to their AIMA appointments.
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📩 Have a question about your own situation? Contact SGP at sgp@sandragomespinto.com or visit sandragomespinto.com. If you attended the webinar or listened to the podcast, mention the code SGP your partner to moving to Portugal: the first 20 people to get in touch receive a free consultation.
This article summarises general information shared in a webinar and reflects Portuguese law and practice as of November 2026. It is not legal advice for your specific situation.
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