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After completing her higher education, Brenda joined AnchorLess in 2023. She is an expert on relocation issues in Europe.

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Table of contents

What was Portugal's Expression of Interest?
How did the Expression of Interest work in Portugal?
Could you really move to Portugal as a tourist and legalize later?
What was life like while an Expression of Interest was pending?
How did the backlog build up?
Is today's AIMA backlog a legacy of the Expression of Interest?
How big did the Expression of Interest become?
How did the Expression of Interest touch Portuguese citizenship?
Why did Portugal end the Expression of Interest?
When did Portugal end the Expression of Interest?
What happened after the Expression of Interest ended?
What was Portugal's "Expression of Interest 2.0"?
Can you still arrive as a tourist and get residency later?
What replaced Portugal's Expression of Interest?
Why do people still think moving to Portugal is easy?
How can AnchorLess help you move to Portugal the right way?
Portugal's "arrive first, regularize later" era is over

Portugal

Immigration

22/09/2026

Portugal Expression of Interest: How It Worked and Ended

Portugal's Expression of Interest, or 'Manifestação de Interesse', was an immigration route that let certain foreign nationals already in Portugal apply for a residence permit through work, even without the residence visa that this kind of stay would normally require. It sat inside Portuguese immigration law as a residency process, not a visa you obtained abroad. Portugal closed the Expression of Interest to new applicants in June 2024, by government decree, so for anyone moving to Portugal today it is no longer a legal way to get a residence permit.

For years it was one of Europe's most accessible immigration routes, and we watched it up close. Foreign citizens could enter Portugal legally as a visitor, sort out their documents, tax, and Social Security, find work or open an activity, and then apply for a residence permit from inside the country. In short, you could move first and regularize later.

That route shaped Portugal's immigration boom, left hundreds of thousands of residence cases waiting, reached into nationality law, and built the reputation Portugal still carries: that you can just show up and "fix the papers later." If you are weighing a move now, the short answer is at the end, where we cover the requirements for residency, the residence permits foreign citizens actually use today, and your real options for living in Portugal.

First it helps to understand what the Expression of Interest actually was, because most of the advice still circulating describes a Portugal that no longer exists.

What was Portugal's Expression of Interest?

The Expression of Interest was a way for certain foreign nationals to ask for a Portuguese residence permit through work, without first holding the residence visa that this kind of stay would normally require.

The two main versions lived in the former Article 88(2) of Portugal's Foreigners Law, for employees, and Article 89(2), for the self-employed. When the government scrapped the mechanism, the repeal decree described it in unusually blunt terms: it had let people regularize their stay through employed or independent work without a valid visa for that purpose.

That is what made it exceptional, and it is worth holding onto as you read the rest.

Who could use the Expression of Interest?

Article 88(2) covered people seeking residence on the basis of a job in Portugal, shown through an employment contract or another qualifying employment relationship, alongside the other residence requirements in force at the time.

Article 89(2) did the same for independent activity: people working through service contracts or as independent professionals, rather than as employees.

Was the Expression of Interest a visa?

No. A residence visa is normally obtained before you move, through the Portuguese consulate, and it authorizes you to enter for the purpose of getting residence.

The Expression of Interest ran the other way around. You could already be living in Portugal before you built the work situation that supported the application.

It was also not the same as a residence permit. Someone could have submitted a 'Manifestação de Interesse' and still be waiting for the appointment, the biometrics, and the decision. Once the waiting stretched into years, that gap between "I applied" and "I have a card" became the whole experience.

How did the Expression of Interest work in Portugal?

The exact documents changed over the years, but the path most people took looked recognizable from start to finish.

1. Enter Portugal legally

Many applicants first arrived as visitors, either visa-free or on a short-stay visa depending on nationality. This is where the shorthand "come as a tourist and legalize later" comes from.

It should not be read as "any tourist automatically became a resident." The applicant still had to meet the requirements and build a real basis for residence. What the law removed was the need to arrange everything through a consulate before arriving.

By late 2023, people in immigration forums were openly planning entire relocations around this, treating the trip to Portugal as step one of a move rather than a holiday.

2. Register for tax and Social Security

Once in Portugal, most people set up the basics they needed to work: a NIF (tax number) and a NISS (Social Security number), plus their tax registration.

These often came before the job that would ultimately support the application. People arrived, dealt with the bureaucracy, and then entered the labor market.

3. Find work or start an activity

Next came the actual basis for residence. For an employee, that meant finding an employer and the right employment paperwork. For an independent worker, it meant opening activity and starting to provide services.

This was the real difference from a normal work visa: the job search happened after the move. That lowered the barrier enormously for anyone who would have struggled to get hired by a Portuguese employer while still living abroad.

The flexibility cut both ways. People also arrived expecting work that then fell through, and community threads from that period carry plenty of warnings that living without a residence card made renting, banking, and daily admin harder while you waited.

4. Build the contribution record

Social Security mattered here. A contribution history was relevant in some cases, and the transitional rules created later specifically protected people who were already registered and contributing before the June 2024 cutoff.

This is why older discussions talk so much about 'descontos', the Social Security contributions. For many applicants, Portugal was already collecting from their pay while their status was still waiting to become a residence card.

5. Submit the Expression of Interest online

Once the pieces were in place, the applicant filed the 'Manifestação de Interesse' electronically, with the supporting documents.

Older threads mention SAPA, short for 'Sistema Automático de Pré-Agendamento'. It was the online platform used to register and submit the Expression of Interest, upload documents, track the case, and receive notifications.

For a lot of people, "submitting on SAPA" felt like a milestone. It was really only the start.

Filing on SAPA did not produce a residence permit. The case still had to be assessed, the applicant called or allowed to schedule an in-person appointment, documents checked, biometrics taken, and a decision issued before any card existed.

By early 2024, people were blunt about this in expat groups: someone trying to work out which process applied would be told that if they meant the Expression of Interest, they were looking at a wait measured in years. That was community shorthand, not an official timeline, but it captured how normal the long wait had become.

6. Wait for SEF or AIMA to process the case

This is where the rule on paper and the real experience drifted apart. The law created a path to residence. It did not create an administration able to process unlimited applications quickly.

So people spent months, sometimes years, in the space between living in Portugal and holding a Portuguese residence card. The move from SEF to AIMA in late 2023 added its own uncertainty, and applicants with open cases spent that period unsure what would happen to their files.

7. Attend the appointment and get residence

Eventually, when the case moved forward, the applicant completed the formal residence step, and the gap between "I have an Expression of Interest" and "I have residence" finally closed. For some, that gap had lasted years.

Could you really move to Portugal as a tourist and legalize later?

For many workers under the old Articles 88(2) and 89(2), that is effectively what the law allowed, as long as the requirements were eventually met. It is why old advice about Portugal sounds so different from anything accurate today.

The traditional path is: choose a route, apply abroad, get the visa, then move and complete residence. The Expression of Interest let it run as: move, get your registrations, find work, file, and get residence later. For someone without a job lined up before departure, that was a very different world.

The catch was on the other end. Getting into the system was unusually easy; getting through it was not. That single tension explains both why the route became so popular and why it eventually became impossible to sustain.

What was life like while an Expression of Interest was pending?

People often describe that period as a legal limbo. The word captures the feeling, but it is not a precise legal status.

Many applicants were already fully part of Portugal's economy: working, paying tax, contributing to Social Security, renting, raising families. They just did not yet hold the residence card that usually comes with all of that.

Working and waiting at the same time

The defining contradiction of the era was that you could be woven into the system before you held your first card. That is exactly why the later citizenship debates got so heated: if the state took years to process a case, should those years simply vanish when it came time to count residence for nationality?

Could applicants travel while waiting?

Travel was one of the biggest worries, because a pending Expression of Interest was not itself a residence card or a travel document.

In early 2024, a common question in expat groups was whether someone with a pending case could leave the Schengen area and come back without jeopardizing years of waiting.

The honest answer was that it depended on the person's own nationality, visa status, and Schengen rules, not on the pending case. A 'Manifestação de Interesse' on its own did not guarantee re-entry, which is worth remembering for anyone still holding an old, unresolved file today.

How did the backlog build up?

The clearest way to see the Expression of Interest is as a timeline, because the same route felt completely different from one year to the next.

2022. Long processing times were already visible, but the system was still expanding, and the trade-off (move without a consular visa, then wait) still looked worth it to most people.

2023. By late in the year, people were comparing two strategies out loud: get a visa before moving, or enter and use the Expression of Interest. Some were already pointing newcomers toward the then-general job seeker visa as a more structured option, a sign the ground was starting to shift.

Early 2024. Waits of a year or more were routine in community discussions, and reaching AIMA had become its own challenge. The route's strength and its weakness were now inseparable.

June 2024. Portugal published Decree-Law 37-A/2024 on 3 June 2024, in force from 4 June 2024. It revoked the procedures under Articles 88(2) and 89(2), ending the main route for new applicants. Cases already started up to 3 June were saved. New files stopped; the pile of old ones did not.

Late 2024. Some people reported losing track of their case entirely after the old portal began redirecting elsewhere. The route had closed for newcomers, and the people already inside it were still waiting.

2025. Others reported finally completing an appointment and then waiting for the physical card to arrive. "Portugal ended the Expression of Interest in June 2024" never meant everyone stopped dealing with one that month. It meant no new cases were created through that general route.

2026. Even now, some applicants describe having waited years between filing and a decision, and then trying to work out which of those years count toward permanent residence or citizenship. The timeline the old route created still stretches across many lives.

Is today's AIMA backlog a legacy of the Expression of Interest?

Largely, yes. A big share of the historic backlog AIMA inherited came straight from it.

When the special mission to clear pending cases began its work (it started on 9 September 2024), its opening task was roughly 450,000 pending Expressions of Interest. That is an extraordinary number for a single procedure. The operation later expanded to CPLP cases, transitional Expression of Interest cases, renewals, and family reunification, so not every AIMA delay in 2026 is an Expression of Interest case.

But the two are not separable. By 18 December 2025, the government reported that 97% of that original Expression of Interest stock had been treated. The route is finished as a strategy; its administrative shadow is not entirely gone.

How big did the Expression of Interest become?

Big enough to change the shape of Portuguese immigration.

Portugal's foreign-resident population grew from 421,802 in 2017 to 1,543,697 in 2024. The Expression of Interest was not the only cause. Labor demand, CPLP migration, residence visas, and family routes all played a part. But a procedure sitting at around 450,000 pending files at the point of intervention was not a footnote, and about 120,157 Expressions of Interest were automatically converted into CPLP residence permits across 2023 and 2024.

The clearest signal came after the route closed. AIMA measures a flow of people entering "with residence in view," which it defines as Expressions of Interest plus job-seeker visas, plus residence visas of all kinds. That combined flow fell from 156,951 in the first half of 2024 to 64,848 in the second, a 59% drop. It does not prove the route alone "caused the boom," but removing it clearly changed the scale of the inflow.

How did the Expression of Interest touch Portuguese citizenship?

This is one of the least obvious parts of the story, and one of the most consequential.

The long wait before a first card raised a basic fairness question: if the state took years to process residence, should those years disappear when counting time for nationality?

Did waiting time count toward naturalization?

For a while, yes, within limits. A 2024 change to the Nationality Law let qualifying time from the request for temporary residence count toward the residence period for nationality, provided the residence application was later approved. For people whose cards had been delayed for years, that mattered a great deal.

It did not mean that simply filing an Expression of Interest turned every later day into legal residence for all purposes. It meant the date printed on the first card was no longer necessarily the only date that counted.

That rule did not last. The Nationality Law was reformed again through Lei Orgânica 1/2026, in force from 19 May 2026. It set the general residence period at 7 years for nationals of Portuguese-speaking countries and EU citizens, and 10 years for others, and it repealed the rule that counted time from the residence request. Nationality applications that were administrative procedures already pending on 19 May 2026 stay under the previous law.

The timing tells its own story. During the years of long delays, the law bent to recognize some of that waiting; two years later, it moved firmly the other way for new applicants.

Could children born in Portugal become Portuguese?

The rules in force during much of this era also gave real weight to residence "regardless of title."

Before the 2026 reform, a child born in Portugal to foreign parents could be Portuguese by origin when, at birth, one parent was legally resident, with no specific minimum period stated for that route.

The old rule also reached a parent who had simply been living in Portugal for at least a year, regardless of title. During the Expression of Interest years, that mattered: a parent could be present and building a life while still waiting for a first card, and that residence in fact could count for the child.

The reform changed this sharply. The current law requires that one parent have been legally resident for at least five years at the time of birth.

Could parents of Portuguese children naturalize?

The earlier framework also let an ascendant of a Portuguese citizen by origin apply for naturalization after living in Portugal for at least five years, regardless of title, provided the other conditions were met and parentage was established at the child's birth. It is one more place where residence in fact, not the card, carried legal weight.

Why did Portugal end the Expression of Interest?

The government that ended it argued the route had drifted far from its original, exceptional purpose. Decree-Law 37-A/2024 said plainly that a mechanism meant for narrow cases had become a general path to residence without the proper visa.

Behind that was the sheer scale. Hundreds of thousands of cases were waiting, the foreign population had grown fast, and AIMA had just replaced SEF. The old model also placed most of the screening and admin after the person had already arrived, and the policy that followed moved that work to the other side of the journey.

None of this required a verdict on whether the route was "too easy." It was easy to enter and hard to finish, and that combination was the real problem.

When did Portugal end the Expression of Interest?

The main route ended in June 2024, but the cleanup ran for years.

Decree-Law 37-A/2024 was published on 3 June 2024 and took effect on 4 June 2024, revoking Articles 88(2) and 89(2). Cases already started up to 3 June were preserved, so the old pipeline stayed alive even as new filings stopped.

The transitional protection was then widened. Lei 40/2024, of 7 November 2024, extended it to people who could show that, before 4 June 2024, they were already registered and contributing to Social Security toward the old 12-month requirement, even without having filed. Lei 61/2025, of 22 October 2025 (in force 23 October), later set a hard deadline of 31 December 2025 for that specific transitional group to apply. That deadline was never a general cutoff for all old cases; it applied to that group.

This is why people kept discussing "Manifestação de Interesse cases" well after June 2024. The route was closed to newcomers, but its old files were still moving through the system.

What happened after the Expression of Interest ended?

Portugal did not flip to a visa-first system overnight, and this is where most coverage stops too early.

The main employment route was gone, but other parts of the Foreigners Law still let specific groups ask for residence from inside Portugal without the usual consular visa. That is why migrants, lawyers, and social-media creators started hunting for the routes that could produce a similar result. Some of those routes picked up the informal name "Manifestação de Interesse 2.0."

How the Job Seeker Visa bridged the two systems

Portugal had introduced a general job seeker visa in 2022. It already differed from the Expression of Interest, because you had to get the visa before traveling. But it kept one familiar feature: you did not need a Portuguese job before moving. You applied abroad, traveled, looked for work, and requested residence after starting a job.

That made it a halfway model, with the authorization moved before arrival but the job search still allowed after it. By late 2023, people were already recommending it over the Expression of Interest as the more structured way in.

How the Job Seeker Visa was narrowed, and why you cannot use it yet

That flexibility then shrank. Lei 61/2025 replaced the general job seeker visa with a Qualified Job Seeker Visa under Article 57-A, aimed at people with specialized technical skills, and tied to highly qualified activity.

Here is the part almost no one reports, and it matters for anyone reading this to plan a move: As of mid 2026, you still cannot actually apply for it. The law created the route, but left one piece to later regulation. The government still has to publish a 'portaria' defining which "specialized technical skills" qualify, and it has not appeared since the law took effect in October 2025. Until it does, the route does not open. Portuguese visa centers continue to say they cannot accept applications for the new visa until that regulation exists, and in mid-2026 people in expat forums were describing the old job seeker route as suspended with no clear return date.

So there is no 'portaria', no official notice that the route is active, and no first-hand report of anyone applying under it. It exists in the law and nowhere else yet.

Two things worth getting right, because they circulate wrongly. This visa does not require you to already have a job; the gate is being a qualified professional under a definition that does not exist yet, after which you would enter, find highly qualified work, and only then request residence. And it is not the D3, which is a separate route for someone who is already going to perform highly qualified work.

If Portugal ever loosens the idea of arriving without a visa again, this qualified route is the likeliest place for it. It would be a defined, gated way for a specialized professional to enter and look for work, not a reopening of the old Expression of Interest. For now, though, there is no sign of that either. The government's attention has been elsewhere, mostly on making the whole immigration process clearly defined, step by step, with routes people can actually follow.

What was Portugal's "Expression of Interest 2.0"?

"Expression of Interest 2.0" was never an official category. It was an informal label for the narrower routes that, after the main one closed, still let some people enter legally first and build a basis for residence from inside Portugal.

Education became the clearest example. Parts of the Foreigners Law had long let some students already lawfully in Portugal get residence without first holding the matching residence visa. These were genuine legal routes, not loopholes. But after the big route vanished, a narrow student rule could produce a result migrants recognized: arrive legally, meet a condition in Portugal, apply for residence without having entered on that visa.

By mid-2026, professional and vocational study routes were being promoted openly as a way to enter and later obtain residence. Portuguese reporting called it a "Manifestação de Interesse 2.0," and the government moved to close it. Lei 62/2026, of 10 September 2026 (in force 11 September), rewrote Article 92 so that residence for secondary-school students and certain vocational courses now depends on holding the residence visa issued under Article 62, and it revoked the provision that had allowed the earlier exception.

That gives the whole period a clear shape. The broad employment route ended in June 2024; attention shifted to narrower in-country routes through 2024 and 2025; and in 2026 Portugal closed one of the routes that had started to reproduce the old logic. The change was progressive, not a single switch.

Can you still arrive as a tourist and get residency later?

For the old, general, work-based route: no. Someone arriving today cannot count on entering as a visitor, taking an ordinary job, and regularizing through an Article 88(2) Expression of Interest. Articles 88(2) and 89(2) have been revoked for new cases since June 2024.

Specific legal exceptions still exist. Article 122 of the Foreigners Law still allows residence with a visa waiver in defined situations, and it survived the 2026 changes. Those are narrow statutory categories, though, assessed on their own terms, not a general successor to the Expression of Interest.

This is why old forum posts, videos, and relocation advice can now point you wrong. A post from a couple of years ago saying "just come, get your NIF and NISS, find a job, and file an Expression of Interest" may describe what people really did at the time. It does not describe Portugal's system today.

Is the Expression of Interest coming back?

Probably not within any timeframe worth planning around, though we would stop short of calling it impossible. A bill to bring it back was proposed in 2024 and lapsed without passing. Looking at the effects the route left behind and where things stand now, we do not expect it to return as a real option any time soon.

Portugal can also move quickly when it wants to. It is a small country with a small parliament, and changing a law here does not take the long, heavy process it might elsewhere, as the recent immigration and nationality reforms showed. So no one can promise it will never reappear in some form.

If you are planning your move for the next five or ten years, though, do not count on it. AIMA and the services around it are still working through the backlog the old system created. The past two years have been mostly about clearing that up and tightening the rules. A return to the old, wide-open version cuts against the whole direction Portugal has taken.

And if some version does come back sooner than expected, it will almost certainly arrive with a much firmer gate than before, precisely to avoid repeating what just happened.

What replaced Portugal's Expression of Interest?

For most people, the honest answer is simpler than the long list of visa names suggests: you arrive with a visa.

Nothing directly replaced the Expression of Interest. Portugal changed where the preparation happens. The old logic was: come to Portugal, get set up, find the basis for residence, regularize. The current logic is: work out your route, prepare your documents where you live, get the right visa, then move and complete residence. For most non-EU nationals planning a move, that preparation now starts before you leave.

What are your options for living in Portugal now?

The options for living in Portugal are still real; they just run in the opposite order from the old route, and you pick one before you move. Most foreign citizens now match a residence visa to their situation, whether that is remote work, passive income, business, or study, and then complete their residence permit after arriving. Nationals of the Portuguese-speaking community, the CPLP countries, have their own dedicated route. This is one reason people from that community of Portuguese-speaking nations often see a smoother path than other foreign citizens. What all of these residence permits share is that they are set up before the move, not improvised after it.

The requirements for residency depend on the specific route, but they follow the same shape: proof that you meet that route's conditions (income, work, enrollment, or a family or CPLP link), a clean record, and the documents filed in advance. That is the real change from the Expression of Interest years. The residency requirements have not become impossible; they simply have to be met up front rather than assembled once you are already living in Portugal.

If you do not have a Portuguese job lined up, the Qualified Job Seeker Visa is the closest thing on paper, but as covered above, it is not usable yet. People whose residence rights come from a relationship with an EU citizen follow a different framework entirely, under EU free-movement law, which is not a continuation of the old route either.

For a typical non-EU national planning an ordinary move, "I'll go as a tourist and figure out residence there" is no longer a strategy.

Why do people still think moving to Portugal is easy?

Because the reputation was earned. For years, Portugal genuinely let large numbers of non-EU workers move first and build the basis for residence afterward, and by 2023 people were planning around that openly.

Then the system changed fast, and the internet did not keep up. In roughly four years Portugal went from a broad post-arrival route, through its abolition in June 2024, into a stricter job seeker regime in October 2025, a tougher Nationality Law in May 2026, and a narrowing of study routes in September 2026. Each change has its own legal basis. Together they mark a clear move away from the model the Expression of Interest represented.

So someone researching Portugal today can still find advice that was perfectly normal in 2022 and is simply wrong for a new arrival now. Portugal changed the whole philosophy that old form stood for, not only the portal it lived on.

How can AnchorLess help you move to Portugal the right way?

The single biggest change since the Expression of Interest era is that the preparation now happens before you travel, not after you arrive. That is exactly the part that used to be easy to underestimate, and it is where getting it wrong is most expensive.

That is the part we handle. We help you work out which route actually fits your situation, get the documents ready in your home country, and prepare the visa application before you move, so that you arrive on the right basis instead of hoping to fix it later. If you have an old, unresolved case from the Expression of Interest years, we can help you understand where it stands and what your realistic options are now.

Key Takeaways

Portugal's "arrive first, regularize later" era is over

The Expression of Interest was more than a form. It stood for a model in which people could enter under one basis, build a life and a contribution record, and only afterward complete the move to residence. That flexibility made Portugal reachable for workers who could never have qualified from abroad, and it left a mark that is still being cleared: the recovery effort began with around 450,000 of these cases, and 97% of that original stock had been treated by the end of 2025.

What replaced it is a different order of operations. Today, for most people, the legal basis comes first and the move follows it, and the routes that once let you arrive first have been narrowed one by one.

If you are planning a move now, that is the real takeaway, and the good news inside it: the uncertainty of the old system is gone, but so is the improvisation. Getting the route and the visa right before you leave is what makes the rest of your relocation to Portugal calm instead of a gamble.

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