The renewal cycle
A permit granted on the investment route runs two years and is renewed for as long as the investment is held. Renewal is a re-examination of the same conditions, not a formality, and it is the stage most often left out of the price agreed at the start.
What has to be evidenced again
The permit is valid for two years and renewable while the investment stands1. Each condition that qualified the original application is examined once more.
| Evidenced again | Where the requirement comes from |
|---|---|
| The investment is still held, under a declaration covering at least five years | AIMA, article 90-A1 |
| No part of the investment is directed at real estate, directly or indirectly | Lei 56/20233 |
| Minimum presence: 7 days in the first year, 14 days in each subsequent period | AIMA, article 90-A1 |
| Health insurance recognised in Portugal, still in force | AIMA, article 90-A1 |
| No debt to the tax authority or to Social Security, each certificate issued within 45 days | AIMA, article 90-A1 |
| No conviction for a crime punishable in Portugal by more than one year | Lei 23/20072 |
| Family ties as declared: spouse or partner, dependent children, dependent parents | Lei 23/2007, article 982 |
| The government fee for the renewal, one set per person | Portaria 307/20234 |
The published fee range for a renewal is lower than for the first application: figures put out by legal advisers during 2026 fall at roughly EUR 3,000 to EUR 3,800 a person a cycle4. Confirm the current tariff with AIMA rather than with a quotation, and count the number of people rather than the number of permits.
How a renewal is filed
Renewals have been filed online through AIMA's portal since 16 February 20261. The deadline is the expiry printed on the card, and a permit allowed to lapse is not renewed but re-argued.
The stay requirement is what most often catches a holder who has treated the permit as dormant. Seven days in the first year and fourteen in each later period is a low bar, but the days are counted at renewal and not before1. Keep boarding passes and entry stamps from the start rather than reconstructing them two years later.
What changes at five years
Five years of legal residence opens permanent residence under article 80 of the immigration law2, and a permanent permit on the investment route is issued in its own right1. The five-year holding declaration on the investment reaches its term at about the same point.
Citizenship is now much further out. Lei Orgânica 1/2026, in force since 19 May 2026, requires ten years of legal residence for most third-country nationals and seven for nationals of EU and CPLP states, counted from the grant of the permit rather than from the date of application5. Applications for naturalisation already pending on 19 May 2026 continue under the previous five-year rule5. Integration requirements include Portuguese at A2 level and a knowledge test5. The 2026 law left the investment permit itself alone5.
What to settle before the first renewal
- Whether renewals sit inside the original fee, and for how many cycles.
- Who keeps the record of days spent in Portugal, and in what form.
- Who requests the two 45-day certificates, and how far ahead of the expiry date.
- What happens at renewal if a dependent child has since reached adulthood.
- Who confirms with the fund or body that the investment still meets its route conditions.
Each of those belongs in the engagement letter rather than in an email two years later. Scope of service puts them alongside the six other clauses worth settling in writing.
Sources
- 1AIMA Autorização de Residência para Investimento, Art. 90.º-A aima.gov.pt/pt/viver/autorizacao-de-residencia-para-investimento-art-90-o-a
- 2Diário da República Lei n.º 23/2007, de 4 de julho (legal regime of entry, stay, exit and removal of foreigners), consolidated diariodarepublica.pt/dr/legislacao-consolidada/lei/2007-34513475
- 3Diário da República Lei n.º 56/2023, de 6 de outubro (Mais Habitação), amending the ARI regime diariodarepublica.pt/dr/detalhe/lei/56-2023-222674218
- 4Diário da República Portaria n.º 307/2023, de 13 de outubro (fee table for visas and residence permits) diariodarepublica.pt/dr/detalhe/portaria/307-2023-222805817
- 5Diário da República n.º 95/2026, Série I Lei Orgânica n.º 1/2026, de 18 de maio, amending and republishing the Nationality Law (Lei n.º 37/81) files.diariodarepublica.pt/1s/2026/05/09500/0000200020.pdf
Last reviewed 3 September 2026. Rules change; check each source before acting.