Portugal’s new foreigners law: the vocational course route closes and late renewals lose their safety net

Portugal changed its foreigners law overnight. Lei n.º 62/2026 was published in the Diário da República on Thursday 10 September and, under its Article 11, entered into force the following day. It was approved by parliament on 17 July, promulgated by President António José Seguro on 31 August and countersigned by Prime Minister Luís Montenegro on 1 September. The law rewrites parts of three statutes at once: the 1994 law on temporary reception centres, the 2007 law governing entry, stay, exit and removal of foreign nationals, and the 2008 asylum law. Most of its 52 pages concern asylum and removal procedure. But three changes buried in the amendments to the 2007 law will decide how a lot of ordinary moves to Portugal now work, and one of them is a quiet loss of a protection applicants have relied on for years.

Background

This is the third tightening in roughly two years. In 2024 Portugal closed the manifestação de interesse, the mechanism that let people who had entered without a residence visa regularise themselves after the fact once they had been working and paying social security. In October 2025, Lei n.º 61/2025 reshaped family reunification, introducing a general requirement that the sponsor hold a valid residence permit for two years before applying, with shorter waits for couples who had already lived together and none for dependent children. Lei n.º 62/2026 is a different kind of instrument. Its stated purpose is to implement the EU Pact on Migration and Asylum: it gives effect to seven EU regulations, (EU) 2024/1349, 2024/1356, 2024/1347, 2024/1348, 2024/1350, 2024/1351 and 2024/1359, and transposes two directives, 2024/1346 on reception conditions and 2024/1233, the recast single permit directive covering combined residence and work authorisation. The changes that matter most to a GoMate reader come from that second directive, not from the asylum package.

The student route: narrowed, not abolished

Article 92 of Law 23/2007 governs residence permits for students in secondary education and in level 4 vocational courses under the international ISCED classification. As amended, its paragraph 1 grants the permit only to someone who already holds a residence visa issued under Article 62, provided they also meet the general conditions of Article 77, are enrolled at an educational establishment and are covered either by the Serviço Nacional de Saúde or by health insurance. Paragraph 4 was repealed outright. The practical result is that a level 4 vocational course no longer works as a way into residence from inside the country: you obtain the visa at a Portuguese consulate before you travel, and the permit follows from it. One important qualification, which most coverage of this law has missed: paragraph 3 was not amended and remains in force. It still allows a residence permit to be granted to a secondary education student who does not hold an Article 62 residence visa, provided they entered and have remained legally in Portuguese territory. So the door is closed for vocational students and still ajar for secondary school students who are in the country lawfully.

The change nobody announced: overdue renewals no longer approve themselves

Several reports have described this law as putting a 90-day deadline on residence permit decisions for the first time. That is not what happened. The 90-day deadline for deciding a first residence permit application has been in Article 82 since Decreto-Lei n.º 41/2023, and the 60-day deadline for renewals is unchanged. Two things did change, and both favour the administration. First, the 90 days can now be extended by a further 30 in exceptional and duly justified circumstances, in particular where the file is complex, with the applicant to be informed. The realistic worst case is therefore 120 days, not 90. Second, and more consequential, the law repeals paragraph 7 of Article 82. Until 10 September that paragraph provided that if AIMA missed the renewal deadline for reasons not attributable to the applicant, the application was deemed granted and the residence document had to be issued immediately. That safety net is gone. The 60-day renewal deadline survives, but missing it now produces no automatic consequence at all.

A genuine improvement for people already working in Portugal

The same law adds a new paragraph 8 to Article 88: the holder of a residence permit for employment may change employer by notifying AIMA, with no need for a new permit to be issued. A parallel new paragraph 6 in Article 89 lets the holder of a self-employment residence permit change the nature of the activity the same way. Both come from the recast single permit directive, and both remove a step that used to mean waiting on AIMA to issue a replacement document. There is a limit worth knowing before you rely on it. Article 88 paragraph 5 was not amended and still provides that an employee who wants to take up self-employed activity does so through replacement of the residence document. Changing jobs as an employee is now a notification; moving from employment into self-employment is not.

Who it affects

The clearest losers are people who were counting on arriving first and sorting out status afterwards through a vocational course, in practice often Brazilian and other CPLP nationals who can enter Portugal for a short stay without a visa. If you are in Portugal on a short stay holding a level 4 course offer and planning to file in the coming weeks, that plan no longer works. The repeal of the deemed-approval rule affects a much larger and quieter group: anyone whose renewal is already sitting with AIMA past its deadline. Until 10 September an overdue renewal eventually converted into an entitlement; from 11 September it converts into nothing, and the remedy is administrative or judicial rather than automatic. If you are moving on a D7, D8 digital nomad, work or family route, your eligibility is unchanged. You were already required to obtain the correct residence visa at a consulate before travelling, and you still are.

What this means in practice

The safe assumption for anyone planning a move is the one Portugal has been converging on since 2024: get the right residence visa before you fly, from the Portuguese consulate with jurisdiction over where you live. If you have an application or a renewal with AIMA, write down the date you filed and keep the receipt, because the deadlines still exist even though missing them no longer grants you anything by default. If your renewal is already overdue, the question of whether a deemed approval had crystallised before 11 September is a real legal question and worth putting to a lawyer rather than guessing at. And if you are employed in Portugal and changing jobs, the new notification route is the one to use, but confirm with AIMA what form that notification takes before you rely on it. Our <a href="/country-guides/portugal">Portugal country guide</a> covers the visa categories and the permit sequence, and the <a href="/field-guide/visas-status">visas and status</a> section of the field guide explains the difference between a visa, which lets you enter, and a residence permit, which lets you stay, a distinction this law leans on heavily.