The "One Printing Machine" Problem
In April 2026, a resident of Portugal whose pre-July renewal had been approved by AIMA in December 2025 posted on r/PortugalExpats that he had received no card, that the 60-day statutory deadline had long passed, and that he had gone to AIMA in person to ask why. The answer, which has been repeated in multiple variations across that forum in the past month, was that everything on AIMA's side was normal, that the delay was due to there being only one working printing machine, and that the applicant should sue if he wanted the card to issue. The thread has attracted 34 comments, most of them from applicants in the same position. A second thread from a different applicant reported that a counter worker confirmed the printing bottleneck in front of witnesses.
This is not a parody of Portuguese bureaucracy; it is an accurate description of the current state of the card-issuance pipeline. The formal position of AIMA is that card production is centralised at the Imprensa Nacional-Casa da Moeda and that production delays are a function of supply-chain factors. In practice, the effect on applicants is the same: an approved file sits in a production queue for months beyond the statutory deadline, during which the applicant has no residence card, limited ability to travel in Schengen, friction with banks and landlords, and — since the April 2026 nationality law — an additional month added to their citizenship countdown for every month of delay. The advice to "just sue" is, in context, a frank admission by counter staff that they cannot resolve the issue from their position, and that the applicant's only practical leverage is judicial.
What the 60-Day Statutory Deadline Actually Requires
The Portuguese Código do Procedimento Administrativo (CPA) sets a general 90-day deadline for the completion of administrative procedures. The immigration-specific regulations — the regulamento of the Law of Foreigners — reduce this to 60 days for the specific act of issuing a residence card once the underlying application has been approved. The trigger for the 60-day clock is the date the applicant is formally notified of the approval, whether by email, portal message, or postal notification. Once that clock runs out without a card being issued, AIMA is in breach of its statutory duty. This is a specific legal state that opens specific legal remedies — it is not a matter of administrative inconvenience or delay in the colloquial sense, but a breach of law that an administrative court has the power to remedy.
The 60-day deadline applies irrespective of the visa category. Whether the approval is for a D7, D8, Golden Visa, family reunification, article 15, or the residence-permit track, the 60-day clock for the physical card issuance runs from the approval notification. Applicants sometimes misidentify the start of the clock — it is the approval notification, not the biometrics date, and not the date of any prior administrative milestone. If you do not have clear documentation of when your approval was communicated, your first step is to request it in writing from AIMA, which is often answered faster than the substantive request because it is purely ministerial. For detailed guidance on what counts as an approval notification, see the AIMA notification system guide.
The Intimação Playbook for Post-Approval Delays
The intimação para a prática de ato devido is a specific judicial procedure within the administrative courts, designed for precisely this situation: a public authority has a legal duty to perform an administrative act, the statutory deadline has passed, and the authority has not acted. The applicant files a short judicial petition — typically 10 to 15 pages — identifying the administrative act that is overdue, citing the statutory deadline that has been breached, attaching the approval notification and any correspondence showing non-compliance, and asking the court to set a deadline for AIMA to perform the act. The court's procedure is compressed: the petition is filed, AIMA is served and given a short window to respond, and the court then issues its order. From filing to court order is typically four to eight weeks.
The court's order will specify a deadline — usually 30 to 60 days — for AIMA to issue the card. AIMA almost always complies, because the alternative is daily fines and, since the April 2026 legislative reforms, judicial scrutiny of the agency's administrative capacity. The physical card is typically delivered within 60 to 120 days of the court's order. The total timeline from filing the intimação to having the card in hand is therefore three to six months. The cost in a straightforward case is between €1,500 and €3,000 inclusive of court fees and lawyer's work. In our firm's files over the past 18 months, the compliance rate is very high: of approximately 140 intimações filed for post-approval card delays, we have seen compliance in over 95 percent of cases within the court's deadline, with the remaining cases resolved within a further 60 days after follow-up motions. See the one-year deadline guide for how this interacts with broader judicial remedies.
Non-Judicial Escalation That Sometimes Works
Before filing an intimação, many applicants try non-judicial escalation routes. Some of these are worth attempting; others are mostly ritual. The escalations that occasionally produce movement are: a formal written complaint to AIMA through the portal, with citation of the 60-day deadline and the approval notification; a complaint to the Ouvidoria (AIMA's ombuds office) which occasionally surfaces stuck files to more senior staff; and, for cases with particularly strong humanitarian factors, a complaint to the Provedor de Justiça (the national ombudsman). The Provedor cannot compel AIMA but can and does write formal letters that sometimes unstick files. None of these routes carries the reliability of the judicial remedy, but they are cheap and can produce a result without the cost of court proceedings.
The escalations that almost never work, despite being frequently recommended online, are: showing up in person at AIMA to complain; contacting the Ministry of Internal Administration directly; and emailing the AIMA contact centre. The first typically produces an apology and a suggestion to sue. The second is ignored at the ministerial level because the issue is operational rather than political. The third generates an automated acknowledgement and no substantive response. Our general advice to clients is to spend 30 to 60 days on non-judicial routes if the cost of waiting is bearable, and to proceed to the intimação if it is not. See the AIMA contact centre guide for realistic expectations on the non-judicial channels.
Living Without a Physical TRC — The Evidence Portfolio
Between approval and card issuance, applicants need to live as residents without having the primary residence document. This is workable for domestic purposes and problematic for cross-border purposes, and the difference is worth understanding clearly. For domestic purposes — opening or maintaining Portuguese bank accounts, signing leases, registering utilities, enrolling children in schools, accessing the SNS health system, dealing with the Tax Authority — the approval notification combined with NIF, NISS, passport, and proof of address is almost always sufficient. Occasional bureaucratic friction arises but is resolvable through persistence or a lawyer's letter. The informal convention in Portuguese institutions is that an approved but uncarded applicant is treated as a resident.
For cross-border purposes — travel within Schengen, flights that might involve document inspection on re-entry, or any interaction with consular authorities — the lack of a physical card is a real operational problem. Schengen border guards are not well-trained on Portuguese administrative documents and the approval notification is not a travel document in the formal sense. For essential travel, a lawyer can apply to AIMA for an urgent travel document or for a letter to a specific consulate, though both are increasingly rarely granted. For any applicant who needs to travel outside Portugal during this period, the pragmatic advice is to avoid non-essential trips and, if travel is unavoidable, to carry the approval notification, a lawyer letter, and to coordinate in advance with the border posts you expect to use.
What Changes Under the April 2026 Nationality Law
The nationality law approved by the Portuguese Parliament on 1 April 2026 — see our full coverage of the parliamentary vote — changes two things that matter directly for applicants stuck in the post-approval card queue. First, the qualifying residency period for citizenship has been extended from 5 to 10 years for non-EU, non-CPLP nationals (7 years for CPLP). Second, and more consequentially for affected applicants, the start of the qualifying period has been moved to the date of issuance of the first residence card rather than the date of the underlying application. What this means in practical terms is that every month your card is delayed is a month added to your citizenship countdown. An applicant whose approval issued in December 2025 and whose card finally issues in December 2026 has, under the new regime, a citizenship clock that starts in December 2026 rather than at some earlier point.
This change has materially increased the strategic value of the intimação for applicants whose citizenship timeline is relevant — which includes, by our estimate, a majority of our long-standing client base. A €2,000 intimação that compresses a card-issuance delay from 12 months to 4 months effectively buys 8 months of earlier citizenship eligibility at the end of the residence clock. For investors, retirees, and long-term remote workers whose overall tax and estate planning is pegged to Portuguese citizenship, this is a straightforward positive-expected-value decision. See also the Article 87-B judicial oversight guide for how the same reforms empower courts to scrutinise AIMA's administrative capacity in a more searching way going forward.
Frequently Asked Questions
What is the statutory deadline for AIMA to issue a residence card after approval?
Sixty days from the approval notification. Set by the CPA's general 90-day rule as specified in the immigration regulations. After 60 days, AIMA is in breach of its statutory duty and the intimação route is available.
Is it true that AIMA only has one working card-printing machine?
This is what counter staff have been telling applicants in Lisbon in April 2026. The formal position is that production sits with INCM, not AIMA. Practically, card production is the current bottleneck, and the "sue us" advice from staff is a frank admission that they lack authority to unstick files.
How much does an intimação for an overdue card cost and how long does it take?
€1,500 to €3,000 including court fees. Four to eight weeks from filing to court order. 60-120 days from order to physical card. Compliance rate exceeds 95% in our files.
Can I travel in Schengen with just the approval notification and no physical card?
Technically yes, but Schengen border guards are inconsistent on Portuguese administrative documents. Avoid non-essential travel. For unavoidable trips, carry the approval notification plus a lawyer letter and pre-coordinate where possible.
Does the April 2026 nationality law change anything about card-printing delays?
Yes. The citizenship clock now starts at first card issuance, not at application. Every month of card delay adds a month to the citizenship countdown — materially increasing the return on an intimação.