We have been residents in Portugal on a D7 visa for the past two years, but are considering transitioning to the Golden Visa program for greater flexibility. If we make this switch, will the time we have already spent in Portugal under the D7 be counted toward the time required for Portuguese citizenship, given the recent changes introduced to nationality in Congress?
Answers
Under Portuguese nationality law, naturalization depends on legal residence rather than the type of permit. Time under D7, work visas, or the Golden Visa counts equally, provided residence is lawful and continuous. Legal residence is measured by the uninterrupted holding of valid residence permits that are properly renewed, with no gaps. If you move from a D7 permit to the Golden Visa, your accumulated time continues to count. The reference point is the first residence permit issued, not the visa category. So, two years under a D7 permit will still count toward citizenship if residence remains continuous. Recent 2026 amendments propose extending the required period to 7 years (EU/CPLP) and 10 years (others), measured from the date of the first permit issued. However, as of 7 April 2026, these changes are still awaiting presidential approval and are not yet in force. In any case, counting D7 residence toward citizenship is not in question and is unaffected by these changes.
Regarding your situation, we confirm that Portuguese nationality law currently requires 5 years of legal residence in Portugal for naturalization purposes. In this context, the time you have already spent in Portugal under a D7 residence permit will be taken into account towards this requirement, even if you decide to transition to the Golden Visa (GV) regime, provided that your legal residence status remains uninterrupted. As to the recent developments you mention, it is correct that legislative changes have been discussed and even approved at the parliamentary level, including proposals to increase the required period of residence. However, such changes have not entered into force to date, and the current legal framework, including the 5-year requirement, remains applicable. Accordingly, under the law currently in force, your existing period of legal residence should remain relevant for citizenship purposes, provided it is continuous and you comply with all other legal requirements.
Under the current Citizenship law, the residency periods over the last 15 years count toward the citizenship application, even if they are not continuous. This rule may soon be amended under the current legislative process to amend citizenship law.
