Where 2022-2024 Golden Visa Files Actually Stand in April 2026
The Golden Visa backlog in 2026 is no longer a monolithic problem — it is two distinct bottlenecks stacked on top of each other. The first is pre-biometrics: files lodged in 2022 and 2023 that spent 18 to 30 months waiting for AIMA to schedule biometrics. That queue has been largely cleared for main applicants in recent months, with most 2022 and early-2023 investors having attended biometrics in 2025 or early 2026, and family members following in the subsequent wave. The second bottleneck is post-biometrics: after biometrics are taken, the file moves to a final review and card-printing stage that is currently running six to fourteen months depending on the individual case. The result is a family that completed biometrics in March 2025 can reasonably still be waiting for TRC cards in April 2026 — and that is not an outlier, it is the modal experience.
This situation is documented openly by affected families. A recent r/PortugalExpats thread from a family of five who applied for the Golden Visa in 2022, had biometrics in early 2025, and still has no cards in April 2026, drew 26 comments of substantially similar experiences. Industry consultants report that AIMA has accelerated Golden Visa biometrics scheduling for H1 2026 specifically to clear the pre-biometrics backlog. What this means for a family in your position is that any planning — school enrolment, moving timelines, tax elections — must assume that TRC issuance is another six to twelve months away even after biometrics have been completed. Planning on any shorter horizon has led to the repeated misery we see in client files.
Decision One: Do You Wait, Escalate, or Restructure?
The first decision for every Golden Visa family stuck in the backlog is whether to continue waiting, to escalate through judicial channels, or to restructure the family's immigration posture by bringing other pathways online. These are not mutually exclusive — many of our clients now run a judicial escalation track alongside a continued Golden Visa file, with selected family members exploring a parallel D-type application. The right answer depends on three variables: how close to the statutory deadline you are, how operationally dependent your life is on having the TRC today, and what the true cost of continued delay is in your specific case. A retiree couple whose Portuguese home is largely symbolic until citizenship eligibility in 2027-2028 has a very different calculation than a family with two school-age children currently in Lisbon on tourist stays.
If you are less than 60 days past statutory deadlines and your life does not materially depend on the TRC today, continued waiting with active monitoring is defensible. If you are more than 60 days past deadline and either your children's schooling, your own tax residency, or the family's ability to live in Portugal is being materially compromised, escalation is warranted. Restructuring — which we discuss below — is the right call when the underlying investment vehicle's status is changing, when a family member would more quickly qualify under a different pathway, or when the family's geographic posture means that a parallel route would actually accelerate outcomes. Do not conflate these decisions: the cost and tactics for each differ substantially.
Enrolling Children in Portuguese Schools Without a TRC
The anxiety about children's schooling is often the most acute issue raised by Golden Visa families, and the good news is that Portuguese law is clearer and more protective here than most applicants realise. Compulsory education in Portugal covers every child resident in the country regardless of their parents' immigration status. Schools cannot refuse enrolment because a residence card has not issued. The documents a Portuguese state school will require are the child's NIF (tax number, which can be obtained at any Loja do Cidadão), a passport, proof of address (rental contract or property deed), the Portuguese vaccination record or an equivalent from the country of origin, and the school's own enrolment form. None of these depend on a TRC. Where a school is hesitant, producing a portal screenshot of the pending AIMA application or a letter from your Portuguese lawyer confirming the pending residence process is usually sufficient to remove the obstacle.
Private and international schools in Lisbon, Cascais, Porto, and the Algarve generally require nothing beyond the usual admissions documentation and fee payment. They do not ask about TRC status because their business model does not depend on it. If you are paying private-school fees, do so directly and do not accept any suggestion that enrolment is conditional on producing residence documents. For children entering Portuguese state schools mid-year, the Agrupamento de Escolas (school grouping) in your area is the correct point of contact, and requests for level placement should be made alongside the enrolment. A Portuguese lawyer can provide a formal letter addressed to the school if bureaucratic friction arises — this is often solved with one phone call at lawyer-rate, and should not be treated as a reason to delay enrolment.
Tax Status: NHR, IFICI, and the 183-Day Trap
Tax status is the area where families most often make unrecoverable mistakes. The Portuguese tax year is the calendar year, and Portuguese tax residency is established either by physical presence of more than 183 days in any twelve-month period, or by having your habitual home in Portugal on 31 December of a given year. Neither of those tests requires a TRC. What this means in practice is that if your family is physically present in Portugal for more than six months in 2025 or 2026, you may already be Portuguese tax-resident regardless of whether your residence card has issued, and you should be filing Portuguese tax returns on that basis. The danger is the inverse: families who assume that the lack of a TRC means they are not Portuguese tax-resident, continue filing only in their home country, and later find that the Portuguese Tax Authority considers them to have been resident all along — with penalties and interest calculated retroactively.
For IFICI (the successor to NHR for qualifying professional profiles), registration is made directly with the Portuguese Tax Authority and does not require a TRC. See the IFICI guide for the qualifying conditions. If you intended to benefit from IFICI from a particular date, and your family is actually present in Portugal as of that date, the registration should be made on time — do not wait for the TRC. For Golden Visa investors whose physical presence in Portugal is minimal (the well-known seven-days-per-year minimum for the visa), tax residency is typically not triggered and the question is moot. But for families who have actually moved here and are functioning as residents, treat tax residency as independent of the TRC status, register accordingly, and document your presence through rental contracts, NIF records, and utility bills.
Running a Parallel D7 or D8 Application
A Golden Visa applicant whose pathway has stalled can in principle pursue a second, parallel D-type visa. The most common parallel routes are the D7 (passive-income visa) and the D8 (digital nomad visa), both of which require a consular application from abroad rather than an in-Portugal AIMA filing. The advantages of doing so are real but situational. First, a D-type visa can be granted in six to nine months, which is faster than the Golden Visa card-printing queue in 2026 for most applicants. Second, a D-type visa generates a separate residence file which, once renewed twice, leads to permanent residence and citizenship eligibility on its own timetable. Third, it provides a legal basis for the applicant's presence in Portugal during any future periods where the Golden Visa status is ambiguous — for example, if an investment vehicle is restructured or wound down.
The disadvantages are coordination and cost. A parallel D-type file requires the applicant to physically apply at a Portuguese consulate abroad, which for US and UK applicants means a trip and significant fees. The application must meet the D-type category's own qualifying tests (passive-income threshold for D7, employer or contracts for D8) which are separate from the Golden Visa requirements. If both files are granted, the applicant must formally choose between them at the renewal stage — Portuguese law does not permit holding two concurrent residence titles. Where a parallel D-type makes the most sense is for one or two family members in distinctly different circumstances from the main applicant: for instance, an adult child who would qualify under D8 independently, or a retired parent who would qualify under D7 on their own means. Running a parallel D-type for a whole family while the Golden Visa file is still live is generally not cost-justified unless the Golden Visa file has a substantive problem.
The Judicial Route: When Intimação Makes Sense
The most decisive tool available to Golden Visa applicants stuck past statutory deadlines is the intimação para a prática de ato devido — a judicial order compelling AIMA to perform an administrative act it is legally required to perform. For Golden Visa applicants, this typically means compelling AIMA to issue the TRC after biometrics have been attended, or compelling AIMA to schedule biometrics after the file has passed the statutory pre-biometrics deadline. The intimação procedure sits in the administrative courts and is specifically designed for situations where a public authority has breached its statutory duty to act. It is not a general-purpose complaint mechanism; it is a targeted legal instrument with predictable outcomes.
In our experience, an intimação filed 60 days after a statutory deadline has passed produces a TRC within 60 to 120 days of the court's order. AIMA almost always complies because the alternative is daily fines and, since the 2026 legislative changes, judicial scrutiny of the agency's administrative capacity — see the Article 87-B guide for how this works. The cost is in the low four figures inclusive of court fees and legal work. The right time to file is when the file has clearly crossed the statutory deadline and when continued waiting has an identifiable cost (school enrolment, tax status, family separation). Filing earlier is possible but typically rejected by the court for lack of ripeness; filing later is often appropriate but compounds the total time you have been in the system. For families who have already waited two or three years from application, the intimação is frequently the decisive last step. See also the one-year deadline guide for how this interacts with other judicial remedies.
Frequently Asked Questions
How long are 2022-2023 Golden Visa applicants actually waiting for TRC issuance in April 2026?
The median gap between biometrics and TRC is running at 10-14 months. Early 2025 biometrics cohorts are still overwhelmingly uncarded. AIMA has accelerated pre-biometrics scheduling but post-biometrics card printing remains the bottleneck.
Can I enrol my child in a Portuguese state school without a residence card?
Yes. Portuguese compulsory education covers all resident children regardless of parents' immigration status. Schools require NIF, passport, proof of address, vaccination record — not a TRC. Private schools do not ask.
Does running a parallel D7 or D8 visa application jeopardise my pending Golden Visa case?
No. The two pathways are legally distinct. Practical constraints are cost and coordination: D-type applications must be lodged at a consulate abroad, and if both files are granted you must choose between them. Parallel filing makes sense when a family member's circumstances justify their own track.
When does an intimação para a prática de ato devido actually produce a card?
Typically 60-120 days after the court's order. File 60 days past the statutory deadline for the pending administrative act. Cost is low four figures. AIMA almost always complies because the alternative is daily fines.
Do I lose my NHR or IFICI eligibility if my TRC is delayed past my move date?
No — tax residency is established by physical presence (183-day rule) or habitual home as of 31 December, not by TRC status. Register for IFICI when you become tax-resident regardless of card status. The risk is the reverse: assuming no tax residency and later being assessed retroactively.