The Short Answer: Your Case Is Not Automatically Dead
If you filed a manifestação de interesse before the route closed and have heard nothing since, your case is not automatically cancelled simply because the programme ended. The decisive question is whether your expression of interest was carried forward into a formal residence permit application by the 31 December 2025 deadline set under Law 61/2025. If it was, you are one of roughly 130,000 people whose file is still a pending decision sitting in AIMA's queue — a case AIMA is legally obliged to decide, even though no new manifestações are accepted. If your case was never completed by that deadline, it is at risk of forfeiture, and your path forward is different.
This distinction is everything, and it is the reason so many people in this situation feel paralysed: the headlines said the route was "ended," and applicants understandably assumed that meant their own pending case was dead. It does not. As reporting on the reform confirmed, the regularisation pathway was "permanently discontinued as of December 31, 2025, with all pending applications facing an absolute submission deadline on that date" (AccessPortugal) — an absolute deadline to submit, not an instruction that already-submitted cases disappear. The rest of this guide is about finding out which side of that line your case falls on, and what to do next.
What Article 88/89 Manifestação de Interesse Was
The manifestação de interesse was the "expression of interest" mechanism under Articles 88(2) and 89(2) of Portugal's old Foreigners Law (Lei 23/2007). It let a non-EU national who was already physically in Portugal and paying into Portuguese social security regularise their situation and apply for a residence permit for work without first obtaining a work visa from a consulate abroad. For years it was the practical route by which large numbers of people who arrived on other grounds — or without a long-stay visa — converted into legal work residents once they had a job and were contributing. That is why a quarter of stalled cases involve people who would describe their route as "other" rather than a named D-visa: the manifestação sat outside the tidy visa categories.
The volume of applications this route generated is exactly why it was closed and why the backlog is so large. New expressions of interest stopped being accepted in June 2024, part of the wider tightening that reduced the flow of foreign nationals entering Portugal to seek a residence permit. But closure to new entrants said nothing about the enormous stock of cases already in the system. Those pending files — people who had already expressed interest, often already working and contributing for months or years — are the ones now stuck in limbo, and they are the audience this guide is written for. The broader story of the programme's closure is covered in our explainer on the end of the manifestation of interest.
The December 2025 Deadline and What It Meant for You
Law 61/2025, published in the Diário da República on 22 October 2025, set 31 December 2025 as the absolute final deadline for pending manifestação cases to be submitted as residence permit applications, under penalty of forfeiture. In the words of the law's own framing, applications had to be "submitted, mandatorily, by December 31, 2025, under penalty of forfeiture" (AccessPortugal). That deadline has now passed, which means the relevant question for anyone reading this in 2026 is no longer "will I make the deadline" but "did my case make it, and where is it now."
There are two outcomes, and you need to know which is yours. In the first, your expression of interest was properly carried forward — the residence permit application was submitted with its documents before the deadline — and your case is now a pending decision, alive in the AIMA queue and entitled to a decision. In the second, the case was never completed: the application was not lodged by 31 December 2025, and it is therefore exposed to caducidade, the forfeiture the law prescribes. Because the consequences diverge so sharply, do not guess. The next section is about confirming, from the AIMA system itself, which outcome applies to you — and until you have done that, treat your case as potentially still alive rather than writing it off.
Where the ~130,000 Pending Cases Actually Sit Now
The roughly 130,000 manifestação-derived cases reported pending in late 2025 did not vanish into an ordinary queue — many were routed to AIMA's dedicated backlog-clearing operation. Throughout 2025 and 2026, AIMA has run a task-force effort (the mission structure) specifically to work through the pending stock, issuing appointment and biometric convocations by email to applicants who had been waiting. If you receive an unexpected email from AIMA offering an appointment or requesting documents, that is very likely your old case surfacing in this process — treat it as urgent and genuine rather than assuming it is spam, but verify the sender carefully before acting.
The complicating development for 2026 is that this dedicated mission structure has been winding down, with responsibility for the remaining complex cases being reorganised — a transition we cover in our guide to the AIMA mission structure closing in August 2026. On top of that, the new immigration and asylum framework under Law 62/2026 came into force on 11 September 2026, changing decision procedures going forward. None of this cancels a validly pending application, but it does mean cases are moving between structures, which is exactly the kind of institutional churn in which files go quiet. The lesson is not to panic at silence but to make your case visible and documented so it does not get lost in the reorganisation.
How to Check and Force a Decision on Your Case
Start by confirming your case is alive. Log into the AIMA portal with the credentials tied to your original submission and locate your process reference. If the case appears as an active residence permit application awaiting decision, it is in the queue and your job is to monitor it and hold AIMA to the legal decision period. If you cannot access the account, or the case is not visible, submit a dated request through the AIMA contact form (contactenos) citing your process number and asking for written confirmation that the case is registered and pending. Save the ticket number and every screenshot with its date — this paper trail is the evidence that anchors any later escalation.
When a validly filed application has been pending far beyond the legal decision period, silence is no longer something you simply endure — it is an unlawful administrative omission, and an administrative court can order AIMA to decide. The instrument is an acção de intimação, an action to compel a decision, and it has a strong record against AIMA precisely because the obligation to decide is statutory rather than discretionary. Crucially, the fact that the manifestação programme itself closed does not extinguish your right to a decision on a case you lodged in time — the closure governs new entries, not your pending file. The general playbook for this, including the pre-litigation demand that often produces movement on its own, is set out in our guide to AIMA decision-limbo remedies. If your case is genuinely stuck and validly filed, this is the lever.
If Your Case Lapsed: The Realistic Options
If confirmation shows your case was never completed by 31 December 2025 and has lapsed by forfeiture, be honest with yourself about the position: you generally cannot re-open the old expression of interest, because the route no longer accepts entrants and the deadline to convert has passed. Clinging to the lapsed case wastes time you should spend on a route that still exists. The productive move is a clear-eyed assessment of your eligibility under a current legal pathway — a work or other residence visa applied for through the normal channels, or a specific regularisation basis if one genuinely applies to your circumstances.
This is the point where a case-by-case legal assessment earns its cost, because the right answer depends entirely on your exact facts: how long you have been in Portugal, whether you have an employment contract and social security contributions, your nationality, and your family situation all change what is available. Some people in this position have viable routes they were not aware of; others face a harder path and need realistic advice rather than false hope. What you should not do is nothing — an expired case does not improve with time, and an irregular stay carries its own risks. Whether your file is a live pending decision or a lapsed one, the single most valuable step is to establish the truth of its status now and act on the route that actually remains open to you.
Frequently Asked Questions
Is my pending manifestação de interesse still valid in 2026?
It depends on whether your case was converted into a formal residence permit application by the 31 December 2025 deadline under Law 61/2025. Cases properly carried forward by that date remain pending decisions with AIMA and are not automatically cancelled because the route closed. A manifestação never converted or completed by the deadline is at risk of forfeiture. The status of your file on the AIMA system is what decides it — not the fact that the programme ended.
What happened to the manifestação de interesse route?
The expression-of-interest route under Articles 88(2) and 89(2) of the old Foreigners Law — which let people already in Portugal and paying social security regularise without a prior work visa — stopped accepting new expressions in June 2024. Law 61/2025 then set 31 December 2025 as the absolute final deadline for pending cases to be submitted as residence permit applications, under penalty of forfeiture. Around 130,000 cases were reported pending in late 2025.
How do I check the status of my old manifestação de interesse?
Log into the AIMA portal with the credentials tied to your original submission and locate the case reference. If it shows as an active residence permit application awaiting decision, it is live and in the queue. If you cannot access the account or the case is not visible, submit a dated contact-form (contactenos) request citing your process number and asking for confirmation the case is registered and pending. Keep the ticket number — that timestamped record is what you rely on for any escalation.
Can I force AIMA to decide my pending manifestação de interesse case?
Yes. Where a residence permit application derived from a manifestação has been pending well beyond the legal decision period, the delay is an unlawful omission and an administrative court can order AIMA to decide through an acção de intimação. Because the underlying application was validly filed in time, the closure of the programme does not extinguish your right to a decision. A documented trail of your filing date and follow-ups is the foundation of that action.
I filed a manifestação de interesse but never completed it before December 2025 — what now?
If your case was not carried forward into a residence permit application by 31 December 2025, it is at serious risk of having lapsed by forfeiture, and you generally cannot re-open the old expression of interest because the route no longer accepts entrants. The realistic path is to assess eligibility under a current legal route — a work or other residence visa through the normal channels, or a specific regularisation basis if one applies. A case-by-case legal assessment is essential because the answer turns on your exact facts.