When does the 2-year family reunification clock start in Portugal?

Under Law 61/2025 (effective April 22, 2026 for the 2-year rule), the two-year clock starts from the date your residence permit card was issued by AIMA — not from the date of your visa, not from your application submission, and not from your biometrics appointment. The card issuance date is the date printed on the front of your physical residence card as the 'data de emissão' or equivalent. If AIMA took 14 months to issue your card after you arrived and applied, your two-year family reunification eligibility date is 14 months later than you might have assumed. A person who arrived in April 2024, submitted their application in June 2024, and received their card in August 2025 would not be eligible to apply for family reunification until August 2027 — not April 2026.

Does the time I spent waiting for AIMA to process my application count toward the 2 years?

No. The time you spent waiting for AIMA to issue your first residence card — while your application was pending — does not count toward the two-year family reunification requirement. Only the period during which you held a valid, issued residence permit counts. This is one of the harshest practical consequences of AIMA's processing delays for people who want to bring family members to Portugal: a 16-month delay in card issuance effectively adds 16 months to the wait before family reunification can be initiated. Legal residence during the pending period is recognised for most other purposes (social security, SNS access, work rights) but not for this particular two-year prerequisite under Law 61/2025.

Are there any exceptions to the 2-year rule that could let me apply sooner?

Yes. Law 61/2025 includes several categories exempt from the two-year requirement. Minor children (under 18) of the permit holder can be included in a family reunification application regardless of how long the sponsor has held their permit. Dependent adults with disabilities that prevent independent living are similarly exempt. Spouses or civil partners are generally subject to the two-year rule, though couples who can demonstrate prior cohabitation of at least two years before the application may be treated differently in some circumstances. Refugees and beneficiaries of subsidiary protection face reduced requirements. Additionally, holders of highly qualified worker permits and certain researcher or intra-company transfer permits may have shorter waiting periods. If you believe an exception applies to your situation, a consultation with a Portuguese immigration lawyer is the surest way to confirm before you file.

I applied for family reunification but my permit had only been issued for 18 months. What happens now?

If you filed a family reunification application before reaching the two-year card issuance threshold, AIMA will likely reject the application on grounds of premature filing. The rejection will cite the failure to meet the residence duration requirement under Law 61/2025. A rejection does not create a permanent bar — you can reapply once you have held your permit for the full two years from card issuance. There is also a question of whether AIMA will simply suspend the application until the threshold is met, rather than outright rejecting it — this depends on when during the processing of your application AIMA identifies the problem. If you have received a rejection, you can appeal within 30 days under the general administrative appeal procedure (recurso contencioso), though the strongest ground for reinstatement would be if AIMA's own processing delays contributed to the premature filing. Consult a lawyer immediately if you have received a rejection notice.

My card was issued 22 months ago. How do I calculate my exact eligible date?

Your eligible date is exactly 24 months (2 full years) after the card issuance date printed on your current residence card. If your card was issued on 15 September 2024, your earliest eligible date for filing a family reunification application is 15 September 2026. If that date has already passed, you are now eligible. If it is approaching, begin gathering documents now — criminal records, marriage certificates, proof of accommodation, and income evidence — so you can file on the eligible date rather than weeks after. Note that if your card was subsequently renewed (a new card with a new issue date was issued), the two-year period under Law 61/2025 runs from the FIRST card's issuance date, not the renewal date, as long as your residence has been continuous.

Family Reunification•July 15, 2026•9 min read

Portugal Family Reunification: When Does the 2-Year Clock Start If AIMA Took Months to Issue Your Card?

Key Takeaway

Law 61/2025, which took full effect in April 2026, requires foreign residents to hold a valid residence permit for two full years before they can sponsor family members for reunification in Portugal. The critical detail that catches people out: the two-year clock starts from the date your residence card was issued — not from when you submitted your application, not from your biometrics appointment, and not from when your entry visa was stamped. For the tens of thousands of people who waited 12 to 18 months for AIMA to issue their first card, this means eligibility for family reunification is far later than they assumed. This guide explains the legal framework, works through real scenarios, and explains what to do if you filed too early.

What Law 61/2025 Actually Requires

Law 61/2025, the new Portuguese immigration framework that took effect on October 22, 2025, restructured the rules for family reunification in Portugal. The central new requirement — which became fully enforceable on April 22, 2026 — is that a foreign national holding a temporary residence permit must have held that permit for at least two full years before they can file an application for family reunification for a spouse, civil partner, or other qualifying family members living abroad.

This replaced the previous framework under which family reunification could be initiated as soon as a residence permit was in place, regardless of how recently it had been issued. The rationale stated in the legislative text is integration: requiring two years of established residence before family reunification aims to ensure that the sponsoring resident has a stable foundation in Portugal — employment, accommodation, and community ties — sufficient to support newly arriving family members. Whatever one thinks of the policy, the practical effect is that many people who thought they were approaching eligibility are now discovering they need to wait considerably longer. According to LVP Advogados, the two-year rule runs from the date the residence permit was issued — not from the date of initial visa or entry.

The Clock Starts on Card Issuance, Not Application

The single most important detail in Law 61/2025's two-year rule is the starting point of the clock. The clock does not start when you submitted your residence permit application. It does not start when you had your biometrics appointment at AIMA. It does not start when your entry visa was issued. It starts on the date AIMA issued your residence card — the date printed on the physical card itself (the 'data de emissão').

This distinction is consequential because of how long AIMA takes to issue residence cards in practice. Under the backlog conditions that have characterised AIMA since it replaced SEF in October 2023, first-time permit applicants have routinely waited between 12 and 20 months from their biometrics appointment to card issuance. A person who arrived in Portugal in March 2024, submitted their D7 application and had their biometrics in June 2024, but did not receive their card until October 2025 would have an issuance date of October 2025 — meaning they cannot file for family reunification until October 2027. Their three years of physical presence in Portugal count for nothing in this calculation; only the 24 months from the issuance date matter. This is confirmed by the SERP analysis of Law 61/2025: "The clock runs from the date the residence permit was issued, not from the date of the visa or first entry," as noted across multiple Portuguese immigration law firm analyses of the reform.

How AIMA Delays Affect Your Eligibility Date

The combination of Law 61/2025's card-issuance start date and AIMA's multi-month processing delays creates a compounding effect that has pushed family reunification eligibility far beyond what most people anticipated when they planned their move to Portugal. Someone who arrived with a D7 visa in early 2024 expecting to be eligible for family reunification within two years of arrival is now, under Law 61/2025, looking at a clock that started when AIMA finally issued the card — potentially adding 12-18 months to the original estimate.

As of mid-2026, AIMA has reduced its appointment backlog significantly — the Mission Structure that was created to clear the inherited SEF backlog processed over 525,000 cases and completed more than 771,000 appointments before winding down in December 2025. First-time biometric appointment wait times have fallen to approximately 3-6 months in most areas. However, card issuance after the biometrics appointment still adds several months in many cases. The practical implication: for applications filed in 2024 and early 2025, the accumulated delay from application submission to card receipt could total 14 to 22 months. People in this cohort are advised to check their actual card issuance date — printed on the front of the card — rather than counting from arrival or application dates when estimating family reunification eligibility.

Calculating Your Earliest Eligible Date: Real Scenarios

The formula is straightforward: your earliest date for filing a family reunification application is exactly 24 calendar months after the date printed as the issuance date on your first Portuguese residence card. If your card was issued on June 15, 2024, you can file on June 15, 2026 — but not before. If your card was issued on November 3, 2025, you cannot file until November 3, 2027.

Scenario A: Arrived Portugal October 2023. Applied for D7 permit February 2024. Biometrics March 2024. Card received August 2025 (17-month wait due to backlog). Card issuance date: August 2025. Eligible for family reunification: August 2027. Total time from arrival to family eligibility: almost 4 years.

Scenario B: Arrived Portugal January 2025. Applied for work permit February 2025. Biometrics April 2025. Card received September 2025 (7-month wait, backlog improving). Card issuance date: September 2025. Eligible for family reunification: September 2027. Total time from arrival to eligibility: 2 years and 8 months.

Scenario C: Arrived Portugal May 2025. Applied for D8 permit June 2025. Biometrics September 2025. Card received January 2026 (7-month wait). Card issuance date: January 2026. Eligible for family reunification: January 2028. Total time from arrival: 2 years and 8 months.

In all scenarios, check the physical card in your hand. If you have been through a renewal, the two-year clock for Law 61/2025 runs from the first card's issuance date, not the renewal — provided your residence has been continuous and uninterrupted. A guide to how AIMA calculates continuous residence periods is available at how AIMA counts your residence time.

Exceptions That Bypass or Shorten the Two-Year Wait

Law 61/2025 includes specific exemptions that allow family reunification before the two-year threshold. The most important exemption for most families: minor children under 18 can be included in a family reunification application from the moment the sponsoring parent holds any valid residence permit. The two-year rule applies to spouses, civil partners, and adult dependents — not to children. If your primary motivation for family reunification is bringing minor children to Portugal, the two-year wait does not apply to them.

Adult dependents who have a disability that prevents them from providing for their own basic needs are similarly exempt from the two-year prerequisite. Refugees and beneficiaries of subsidiary protection face a shorter one-year wait rather than two years. Holders of highly qualified worker permits (the Cartão Azul Europeu or equivalent) and certain intra-company transferees may also have shorter eligibility windows — check the specific permit category terms if this applies to you. For the spouse or civil partner of a Portuguese national, the family reunification framework is entirely different (spouses of Portuguese nationals follow the nationality law provisions rather than the immigration law framework) and the two-year rule does not apply.

What Happens If You Applied for Family Reunification Too Early

If you submitted a family reunification application before reaching the two-year card issuance threshold — which is easy to do if you mistakenly counted from your application or visa date rather than the card date — AIMA will identify the eligibility shortfall at the document review stage. The likely outcome is rejection of the application with a notice citing failure to meet the residence duration requirement. AIMA may alternatively suspend the application pending the eligibility date, though this is less common.

A rejection for premature filing does not create a permanent bar. You can reapply once you reach the two-year threshold from your card issuance date. However, the reapplication means new document costs: criminal record certificates, translated documents with apostilles, and updated income and accommodation proofs will all need to be fresh. If you receive a rejection notice, you have 30 days from the date of notice to file an administrative appeal (recurso hierárquico) with AIMA, or 3 months to bring a judicial appeal. An appeal on premature-filing grounds is unlikely to succeed unless you can demonstrate exceptional circumstances, but if AIMA's own delays caused your miscalculation, a lawyer may be able to argue force-majeure or legitimate expectation grounds. This is a developing area of Portuguese administrative law as Law 61/2025 is relatively new, and specialist legal advice is warranted before deciding whether to appeal or simply reapply.

For a full breakdown of Law 61/2025's requirements, exceptions, and the complete document list for a family reunification application in 2026, see the family reunification Law 61/2025 guide.

Frequently Asked Questions

See the Q&A section above for direct answers on when the two-year clock starts, whether waiting time before card issuance counts, available exceptions, what happens if you filed too early, and how to calculate your exact eligibility date.