AIMA deadline counter

What this counter does

You choose the type of application — a first residence permit or a renewal — and the date you submitted it. The counter shows the last day AIMA has to decide, how many working days have passed until today and how many are left. If AIMA has told you that it extended the deadline, tick the box and 30 working days are added. Once the deadline has passed, it writes a short letter in Portuguese asking AIMA to decide, with your case number and the dates already filled in.

The legal deadlines since 11 September 2026

The deadlines are in article 82 of the Foreigners Act (Lei 23/2007), as amended by Lei 62/2026, published on 10 September 2026 and in force since 11 September 2026:

• First residence permit: 90 days. AIMA may extend this by 30 days, but only in exceptional and duly justified circumstances — the law gives a complex case as the example — and it has to inform you of the extension.
• Renewal: 60 days. The article provides no extension for renewals.

The 90-day rule applies “without prejudice to other decision deadlines” in the same Act, so a few categories have their own deadline. The counter uses the two general ones.

How the days are counted

The Foreigners Act gives the number of days; the counting rules come from article 87 of the Administrative Procedure Code (Código do Procedimento Administrativo, CPA):

1. The day of the event — here, the day you submitted — does not count. Counting starts the next day.
2. The deadline is suspended on Saturdays, Sundays and public holidays. In practice 90 days means 90 working days: a little over four months on the calendar.
3. If the last day falls on a day the office is closed to the public, the deadline moves to the next working day. A day on which the government gives civil servants time off (tolerância de ponto) counts as closed.

The counter skips the national public holidays, including Good Friday and Corpus Christi, which move with Easter each year. It does not include municipal holidays, which differ from town to town. If one falls inside your window, allow a day of margin before you act.

A missed deadline no longer means approval

Until 10 September 2026, article 82 n.º 7 said that a request not decided within the deadline of the previous number — the 60 days for renewals — for reasons not attributable to the applicant was deemed approved (deferimento tácito). It covered renewals only, never first permits. Article 9 b) of Lei 62/2026 revoked it.

What remains is AIMA’s duty to decide. Under article 129 of the CPA, failing to decide within the legal deadline is a breach of that duty and lets you use the “appropriate administrative and judicial means”.

Lei 62/2026 has no transitional rule for residence applications — its transitional article covers asylum procedures only. If a renewal’s 60 days had already run out before 11 September 2026, whether a tacit approval had formed is a question for a lawyer; in our reading it is arguable, not automatic.

When the deadline has passed

1. Send the letter. Registered post with acknowledgement of receipt (carta registada com aviso de receção) to AIMA’s head office. Keep the receipt: it is dated proof that you asked for a decision.
2. Complain. The Livro de Reclamações and the Provedor de Justiça (Ombudsman) are free. They cannot decide your case, but they put your file on record — our guide explains what actually works.
3. Go to court, with a lawyer. An administrative court can order AIMA to issue the decision it owes — the ação de condenação à prática de ato devido (Administrative Courts Procedure Code, CPTA, articles 66 and 67). In cases of inaction it must be filed within one year of the end of the legal deadline (CPTA article 69 n.º 1). Where a quick decision is indispensable to exercise a right in time, lawyers use the urgent intimação para proteção de direitos, liberdades e garantias (CPTA article 109).

A court makes AIMA decide; it does not guarantee a yes. More on the stuck states in what to do when AIMA is silent.

What the letter says

The letter is always in Portuguese, whatever language you read this page in. It states your case number, the type of application and the date you submitted it, cites article 82 of Lei 23/2007 as amended by Lei 62/2026, says that the legal deadline ended on the date shown without any decision being notified, and asks for a decision as soon as possible. Before sending, fill in your full name, your passport or document number and your address.

Renewals: when to apply and the receipt

Ask for renewal up to 30 days before your card expires (article 78 n.º 1). The receipt of a renewal request has the same effect as the residence card for 60 days, renewable (article 78 n.º 7) — keep it with your card. See AIMA appointments, renewals and your rights and when to start a renewal.

Practical tips

• Enter the date the application was actually submitted and keep the proof, together with the payment reference (DUC) and every confirmation email.
• If AIMA asked you for documents, answer inside its window. Whether that request moves the start of the count is not settled (our reading) — a lawyer will count from the dates in your file.
• Before writing, check your status online — a decision may already be there. Deferimento means approved.