The Rule: AIMA Has 270 Days to Decide Family Reunification
Family reunification applications give AIMA a legal deadline of 270 days — nine months — to reach a decision. This period was set by Law 61/2025, the reform that amended Portugal's Foreigners Law (Lei 23/2007), and it came into force on 23 October 2025, applying to requests started after that date. It tripled the old three-month (90-day) rule. If your reagrupamento familiar has been sitting in análise for months, this is the number that matters: it is the point at which AIMA stops being merely slow and starts being in breach of a statutory obligation you can act on.
The figure is not obscure. As Agência Brasil summarised the new Foreigners Law, "the new law extends from 90 days to 270 days the period for AIMA to analyse family reunification requests". Nine months is now the default decision window for this specific procedure, and it sits apart from the general residence-permit timelines you will see quoted elsewhere. Everything in this guide flows from pinning that number to your case correctly, because counting against the wrong deadline is the single most common way applicants waste their first, best chance to escalate.
It is worth being honest about what this longer deadline means in practice. Tripling the period from 90 to 270 days was not a favour to applicants; it was the government giving an overwhelmed agency more legal room before it could be accused of breaching the law. The upside for you is clarity: the nine-month mark is a hard, enforceable line. Before this reform, a family waiting a year was simply one of many stuck in a backlog with no obvious legal threshold. Now there is a threshold, and once it passes on a complete application, the delay changes from a frustration into a breach of duty that a complaint body and, ultimately, a court can be asked to remedy.
Why 270 Days, Not 90 — The Trap in the General Deadline
Do not count your family reunification case against the 90-day deadline. A great deal of recent coverage, including our own guide to the general 90-day decision deadline under Law 62/2026, explains that AIMA must normally decide a residence application within 90 days. That rule is real, but it is the general backstop that applies "where no special period applies". Family reunification is precisely such a special case: it has its own statutory period of 270 days, and that period governs instead of the general figure.
This is not a technicality — it is the difference between an escalation that works and one that backfires. Imagine an applicant who reads the 90-day guidance, waits to day 95, and files a formal complaint or instructs a lawyer to bring an intimação, arguing AIMA has blown the legal deadline. For a family reunification file, AIMA's answer is immediate and fatal: the case is still comfortably inside its nine-month legal window, so there is no breach to remedy. The complaint is dismissed, the court action is premature, and the applicant has spent money and goodwill on a move that was always going to fail. The only thing that argument proves is that the applicant counted against the wrong number.
So the first discipline for anyone waiting on reagrupamento familiar is to hold the right figure in mind: 270 days, not 90. Mark the date your complete application was submitted, add nine months, and treat that as the earliest point at which AIMA is clearly in default on a standard case. Everything you do before that date is about building a clean record — keeping receipts, noting every status change, responding promptly to any document request — so that when day 270 arrives with no decision, your timeline speaks for itself and your escalation lands on a genuine, undeniable breach.
No More Tacit Approval: Silence Is Not a Yes
A missed 270-day deadline does not approve your family reunification automatically. Law 61/2025 removed tacit approval by silence for these cases, so AIMA's inaction can no longer be treated as an implied yes. As the same guidance on the reform puts it plainly, "silence no longer counts as approval". If you have read older advice promising that prolonged administrative silence eventually becomes a granted permit, set that expectation aside for applications governed by the new law.
This is a real shift from how many applicants understood the old deferimento tácito, under which extended silence could be argued to imply consent. The reform narrows and removes several of those routes and replaces them with an explicit obligation: AIMA must issue a decision — approve or refuse — within the legal period. The trade is deliberate. Instead of a silent, legally fragile "yes" that was routinely disputed at the counter and rarely held up when you tried to use it, you now have a concrete, enforceable right to a decision. That right is stronger in the one way that counts: a judge can order AIMA to honour it, whereas arguing that silence had already reunited your family was always an uphill fight.
The practical consequence is that crossing day 270 does not quietly legalise your relative's position or let them travel. It does something different and more useful: it unlocks your escalation options. The correct response to the deadline passing is not to keep waiting in the hope that silence helps — it will not — but to start the sequence, set out below, that forces AIMA to put a decision on paper. Even a refusal you then have to appeal is more useful than indefinite limbo, because it ends the uncertainty and starts the clock on your next steps.
When the 270-Day Clock Starts
The 270 days run from the date your family reunification application is complete and validly submitted, not from the day you first tried to book an appointment or opened the portal. This matters because AIMA enforces a strict complete-application rule: a file missing a required document can be treated as not properly submitted, which means the clock may not have started at all. Before you count nine months against AIMA, confirm your application was genuinely complete when you filed it — proof of the family relationship, the sponsor's valid residence permit, accommodation and income evidence, and any translations or apostilles the process required.
Your anchor date is the submission receipt. When you complete a reagrupamento familiar application through the AIMA family reunification online submission process, the system generates a comprovativo de entrega — keep it and note its date, because it is the document that proves when your 270 days began. If your case was filed through an older channel or at a counter, the relevant date is usually when AIMA formally accepted the file into processing. If you are unsure which date applies, it is worth confirming with an immigration lawyer, because getting the start date wrong undermines any later complaint or court action just as surely as counting against the wrong deadline does.
Keep a simple, dated chronology from day one: the submission date, every AIMA communication, each status shown on the portal, and any request for additional documents and the date you answered it. Document requests deserve particular care — respond quickly and keep proof, because AIMA can argue that a period spent waiting on you does not count against its deadline. A clean chronology that shows a complete application, prompt responses, and nine months of agency silence is exactly the record that turns an abstract complaint into a demonstrable breach of a statutory duty.
The One Extension — and the Blue Card Exception
Be realistic about the one extension AIMA can invoke before you conclude it has missed the deadline. The law permits a single further extension of the same length — another nine months — in complex cases, and AIMA must inform you if it relies on it. That means a fully extended family reunification case can legally run up to around 18 months before AIMA is in default. If you receive a reasoned notice invoking the extension, your enforceable deadline moves accordingly, and a complaint filed as if the first nine months were decisive would be premature. In the ordinary case, where no extension is notified, day 270 remains the line.
There is also an important carve-out at the other end of the scale. The exceptional extension does not apply to certain cases, and family members of EU Blue Card holders are treated far more favourably: under the relevant EU directive, their reunification decision is meant to come within 90 days, not nine months. If your sponsor holds a Portuguese EU Blue Card, your family's timeline is the faster one, and you should count against that shorter period. How consistently AIMA applies the Blue Card deadline in practice is another matter, but the legal entitlement is clearly shorter, and it is worth asserting if it is yours.
One more distinction prevents a common confusion. The 270-day period is the time AIMA has to decide your reunification request. It is not the same as the roughly 90-day window your family member then has to apply for the reunification visa at a consulate once the request is approved. These are two separate clocks at two separate stages, and conflating them leads people either to panic early or to miss a genuine consular deadline later. Keep them apart: first AIMA decides the request within its nine months; only then does the separate visa step, with its own shorter deadline, begin.
What to Do at Day 270: Complaint, Provedor, Intimação
Once the 270 days have clearly passed on a complete application, the first escalation step is a formal complaint, and the fastest route is the electronic Livro de Reclamações. Go to livroreclamacoes.pt, select Public Services (Serviços Públicos), find AIMA, and submit a complaint stating your process number, the date your complete application was submitted, and the fact that the 270-day legal deadline for family reunification under Law 61/2025 has elapsed without a decision. Be factual and specific: name the deadline, give the dates, and ask plainly for an immediate decision. A complaint that cites the exact legal obligation is far harder to deflect with a form reply than a general plea to hurry up.
If AIMA does not give an adequate response within roughly 15 to 30 working days, escalate to the Provedor de Justiça, Portugal's Ombudsman. The Provedor investigates public bodies that fail to meet their legal obligations, and a missed statutory decision deadline sits squarely within its remit. Submit online, attaching your comprovativo, the portal status, and the unanswered Livro de Reclamações complaint. The Ombudsman cannot order AIMA to decide, but it can press the agency and issue recommendations — and for many families the combination of a documented complaint and Ombudsman attention is enough to shake a stalled file loose. For the fuller menu of pressure tactics at this stage, see our AIMA "awaiting decision" limbo remedies playbook.
If the complaint route does not produce a decision, the decisive tool is an intimação para a proteção de direitos, liberdades e garantias — an urgent administrative court action that asks a judge to order AIMA to decide. Because it is built for urgency, it moves in weeks rather than the months AIMA itself takes, and courts can set a short deadline with a daily financial penalty (sanção pecuniária compulsória) for continued delay. You generally have one year from when the 270-day deadline lapsed to bring it, so do not drift toward that limit. This is a formal filing you should not improvise; our guide on when to hire an immigration lawyer in Portugal and our dedicated walk-through of forcing a decision on a delayed family reunification cover how to prepare it.
If You Are Separated From Your Family While You Wait
Many people reading this are not simply waiting on paperwork — they are living apart from a spouse or child while AIMA sits on the file. That separation is not just personal hardship; it is legally relevant, and it strengthens your hand when you escalate. Administrative courts weigh the concrete harm a delay causes when they decide whether to grant an urgent intimação and how tight a deadline to impose on AIMA. A reunification delay that keeps a parent from a minor child, or a couple apart across borders, is exactly the kind of ongoing harm that makes an urgent order more likely.
So when you escalate, document the separation concretely. Note how long your family member has been unable to join you, the practical consequences — a child's schooling in limbo, a spouse unable to work or settle, the cost of maintaining two households — and attach evidence where you can. The more clearly you show that each additional month of AIMA's silence inflicts real harm on a family the law is meant to protect, the stronger your case for the court to compel a decision quickly. Keep this record alongside your dated chronology; together they turn a missed deadline into a compelling, human application a judge can act on.
The bottom line is that family reunification runs on its own clock, and knowing the right number is half the battle. AIMA has 270 days — nine months — to decide, not 90; silence no longer approves you; and the deadline only bites once your complete application's start date is pinned down. If that nine months has passed in silence, you are no longer merely waiting in a backlog. You have an enforceable right to a decision and a clear, sequenced path — complaint, Provedor, then intimação within the one-year window — to make AIMA honour it and bring your family together.