What Parliament Voted On June 11
On Thursday June 11 2026, Portugal's parliament took to a vote a package of additional amendments to the Foreigners Law (Lei de Estrangeiros, Lei 23/2007 as already amended by Lei 61/2025). The government of Prime Minister Luís Montenegro brought the package forward with the votes of the right-wing Chega party secured, which on paper guarantees passage. As the Portuguese daily PÚBLICO reported, the government "conta com o apoio do Chega, partido da ultradireita, para aprovar nesta quinta-feira, 11 de junho, o pacote de medidas adicionais da Lei de Estrangeiros que fecha ainda mais as portas aos imigrantes" (source, translated: the government is counting on the support of Chega, the far-right party, to approve this Thursday, June 11, the package of additional Foreigners Law measures that closes the doors to immigrants even further). The vote was scheduled to begin at 2pm in the Assembleia da República.
A point worth being precise about: a parliamentary vote is not the same as a law in force. Once a decree is approved by parliament it must be sent to the President of the Republic for promulgation, and then published in the Diário da República before its provisions take effect. At the time of writing, the package had been brought to the June 11 vote with the governing bloc holding the numbers, but the final consolidated text and entry-into-force date should be confirmed in the official gazette before anyone treats a specific provision as already binding. This article focuses on the substance and the practical consequence for applicants, because the direction of travel — the removal of tacit approval — is what changes the calculus for people currently stuck in AIMA's queue. This is a separate piece of legislation from the 2026 Nationality Law (Lei Orgânica 1/2026), which deals with citizenship timelines rather than residence permits.
What "Tacit Approval" Actually Meant for Stuck Applicants
Deferimento tácito — tacit, or implied, approval — is a principle of Portuguese administrative law under which a request can be treated as granted when the public authority allows the legal deadline for a decision to elapse without ruling. In the immigration setting, the argument ran like this: AIMA is bound by statutory time limits to decide residence permit applications and renewals; when it blows those deadlines by months or years, the applicant should be able to treat the application as deemed approved rather than be left in indefinite limbo. The newspaper Diário de Notícias summarised the proposal precisely: the government proposes "o fim do chamado 'deferimento tácito', ou seja quando há um atraso na emissão do título de residência renovado entende-se que está aprovado" (source, translated: the end of the so-called 'tacit approval', that is, when there is a delay in issuing the renewed residence permit it is understood to be approved).
In practice, deferimento tácito was less a guaranteed automatic stamp and more a contested legal lever. Immigration lawyers raised it in court actions against AIMA's chronic delays — sometimes to argue that a long-overdue application had already crystallised into an approval, sometimes as part of the broader case that the agency was acting unlawfully by sitting on files. AIMA's backlog made the argument potent: with delays documented at up to four years on some processes, the gap between the legal deadline and the actual decision date was enormous, and that gap was exactly the space in which the tacit-approval theory operated. The June 11 package is designed to close that space. By extinguishing deferimento tácito for residence requests, the legislation aims to ensure that an AIMA delay — however long — can no longer be converted into an approval by operation of law. The delay becomes purely a failure to decide, remediable only by compelling a decision, not by deeming one to have happened.
Why This Hits People Already Waiting on AIMA Hardest
The irony of this measure is that it removes a remedy whose entire existence was a response to the state's own failure. Tacit approval mattered precisely because AIMA could not decide cases on time. Applicants did not invent the four-year waits; the agency's backlog created them, and the law's deadline-plus-tacit-approval structure was the safety valve. Removing the safety valve while the backlog persists shifts the full cost of the delay back onto the applicant. If your renewal has been pending for two years past its legal deadline, you no longer have the argument that the silence itself worked in your favour — you are simply waiting, with a court order as your only forcing mechanism.
For the wealthy, consular-visa cohort — D7 retirees, D8 remote workers, Golden Visa investors — the in-country regularisation restrictions in the package are largely irrelevant, because these applicants enter Portugal on a visa issued by a consulate abroad and never relied on the from-inside-the-territory pathways being closed. But the tacit-approval change is squarely relevant, because the one thing this group shares with every other immigrant is exposure to AIMA's processing delays. A Golden Visa applicant waiting 18 to 24 months for a biometric appointment, or a D7 holder whose renewal has sat undecided past the deadline, was a potential beneficiary of the tacit-approval argument. That potential benefit is what the legislation removes. The structural problem — AIMA being unable to meet its own deadlines — is untouched; only the applicant's leverage over that failure is reduced.
The Other Two Measures: Student Permits and Family Reunification
The tacit-approval change travelled inside a package with two other restrictions, both aimed at in-country regularisation. The first ends the ability to obtain a residence permit from within Portugal on the basis of enrolment in a vocational or professional course, requiring instead a prior consular study visa issued in the applicant's country of origin. As PÚBLICO reported, the bill "altera ainda o regime de acesso à autorização de residência para estudo, exigindo-se a emissão de um visto consular prévio para esse efeito" (source, translated: also alters the regime for access to a study residence permit, requiring the issuance of a prior consular visa for that purpose). The government frames the existing route as a mechanism prone to abuse. This change principally affects nationals — predominantly Brazilians — who used technical-course enrolment as a regularisation path; it is covered in more depth in our analysis of AIMA's shift on student and education-sector migration.
The second measure tightens the route that allowed a parent of a minor child resident in Portugal to regularise from inside the country, which the government has characterised as a form of disguised family reunification running contrary to the tightening already enacted in the 2025 family reunification rules. Like the student measure, this is an in-country regularisation pathway rather than a consular one, so it has limited bearing on the consular-visa audience. The common thread across all three measures is the government's stated objective of closing pathways that allow a person already physically present in Portugal — without a prior entry visa for the relevant purpose — to convert that presence into legal residence. The tacit-approval change is the outlier in this group, because it does not target a specific entry route at all; it targets the consequence of administrative delay, and therefore reaches every applicant regardless of how they arrived.
What Changes for Your Litigation Options
If you have been following the litigation strategies that immigration firms have deployed against AIMA, the removal of tacit approval reshapes the menu rather than emptying it. The core judicial remedy against agency inaction has always been the intimação para a prática de ato legalmente devido — a court action that compels AIMA to perform an act it is legally obliged to perform, on a deadline set by the court. That remedy does not depend on deferimento tácito; it depends on showing that AIMA has a legal duty to decide and has failed to do so within the lawful period. Ending tacit approval does not weaken the intimação route. What it removes is the parallel and more aggressive argument that the delay had already produced an approval, which a court could in some readings recognise. After this change, the realistic outcome of a successful action is a court-ordered decision, not a court-declared approval.
The distinction matters for how applicants should set expectations. A court-ordered decision forces AIMA to rule but does not guarantee the ruling is positive — although, where the file is complete and the substantive requirements are met, a compelled decision is in practice very likely to be favourable, because AIMA has no lawful basis to refuse a qualifying applicant. The practical playbook therefore becomes: keep your file complete and current so that a forced decision can only go one way, document the delay precisely (dates of submission, the legal deadline, the elapsed time), and pursue an intimação if the wait has exceeded the lawful period with no movement. Our step-by-step guide to filing a lawsuit against AIMA and our breakdown of the three-track litigation strategy set out how these actions are structured. The key adjustment after June 11 is to anchor the strategy on compelling a decision, not on claiming an automatic one.
What To Do Now
The first action is to confirm the legal status of the change rather than act on a headline. A parliamentary vote took place on June 11, but the binding text is the version promulgated and published in the Diário da República. If a current strategy in your case rests on a tacit-approval argument, your lawyer needs to check whether the new provision has been promulgated and is in force, what its precise wording is, and whether it contains transitional rules affecting applications already pending. Legislation of this kind frequently includes transition provisions that treat in-flight cases differently from new ones, and that detail can determine whether a pending tacit-approval argument survives. Do not assume the rule is already extinguished, and do not assume your old leverage still exists — verify against the gazette.
The second action is to make your file litigation-ready regardless of how this specific provision lands. That means ensuring your application or renewal is substantively complete, that you hold valid interim coverage where applicable (an active permit or a valid renewal comprovativo), and that you have a clean documentary record of when you submitted, what the legal deadline was, and how far past it AIMA has gone. If your wait has materially exceeded the lawful decision period, take advice on an intimação now rather than waiting, because the value of that remedy is unaffected by the end of tacit approval. The broader point for the audience this blog serves is that the structural problem has not changed: AIMA still cannot meet its own deadlines, and the legislative response has been to reduce applicants' leverage over that failure rather than to fix it. The defensive posture — complete file, documented delay, readiness to compel a decision in court — is now more important, not less.
Frequently Asked Questions
What is "deferimento tácito" (tacit approval) in Portuguese immigration law?
Deferimento tácito is the administrative-law principle that a request is deemed granted once the authority lets the legal decision deadline pass without ruling. In immigration, applicants argued that when AIMA failed to decide a residence application or renewal within the statutory period, it should be treated as approved by default, and used this as a litigation argument to force action on stuck cases. The June 11 2026 Foreigners Law package moves to extinguish this principle for residence requests, so an AIMA delay can no longer be argued to produce an automatic approval.
Was the end of tacit approval already approved and is it law yet?
It was put to a vote in parliament on June 11 2026 as part of a wider Foreigners Law package, with the government holding a guaranteed majority through Chega's support. A bill does not become binding law on the day of the vote: the approved decree must be promulgated by the President and published in the Diário da República before it takes effect. Until then, the final text and entry-into-force date should be confirmed against the official gazette, and anyone relying on a tacit-approval argument should get current legal advice.
Does ending tacit approval mean my pending AIMA application is now worthless?
No. Removing deferimento tácito does not cancel or reject pending applications — it removes one specific argument (that an AIMA delay equals automatic approval). Your application stays in the queue and AIMA still has a legal duty to decide it. The remedy for delay shifts to an intimação, a court order compelling AIMA to issue a decision within a set deadline. If your file is complete and meets the requirements, a court-ordered decision is still very likely to be favourable.
I am a D7, D8 or Golden Visa applicant stuck at AIMA — should I be worried?
The in-country regularisation restrictions in the package do not target consular-visa holders such as D7, D8 and Golden Visa applicants. The change that matters to you is the removal of tacit approval, because it narrows the toolkit for forcing a decision on a delayed file. The intimação route becomes the primary judicial remedy rather than any argument that delay produces automatic approval. Keep your file complete and current, document the delay, and take legal advice on an intimação if your wait has exceeded the legal deadline.
How is this different from the 2026 Nationality Law?
They are two separate pieces of legislation. The Nationality Law (Lei Orgânica 1/2026) deals with how long you must hold legal residence before you can naturalise as a Portuguese citizen, and was promulgated earlier in 2026. The June 11 Foreigners Law package deals with residence permits — how you obtain and keep the right to live in Portugal — including the end of tacit approval, the consular-visa requirement for study permits, and family-reunification tightening. A change to one does not automatically change the other.