As of October 2025, Portugal’s "Lei n.º 61/2025" entered into force, significantly reshaping the framework for family reunification. The reform applies to all residence permit holders, including those under the popular D7 Visa, which is designed for individuals supported by passive income.

Unlike prior versions of the law, the new regime places stronger emphasis on self-sufficiency, integration, and procedural compliance. The reforms reflect Portugal’s broader objective of promoting sustainable migration and reinforcing social cohesion.

For D7 visa holders, the changes represent a marked departure from the previously flexible and relatively streamlined reunification process.

What Has Changed?

Historically, D7 visa holders could sponsor spouses, dependent children, and in some cases parents, with moderate evidentiary requirements and without lengthy waiting periods. This flexibility contributed to the D7’s popularity among retirees, financially independent individuals, remote workers, and global investors.

Under Lei n.º 61/2025, the system has been unified and tightened. The law amends Lei n.º 23/2007 and introduces:

• Mandatory waiting periods
• Stronger proof of financial self-sufficiency
• Strict housing requirements
• Compulsory integration measures
• Expanded documentation and procedural scrutiny

Importantly, no general exemptions apply to D7 visa holders, unlike specific carve-outs granted to Golden Visa investors and D3 highly qualified professionals.

Core Restrictions Affecting D7 Visa Holders

1. Two-Year Residence Requirement

D7 visa holders must now complete two full years of legal residence in Portugal before sponsoring most family members.

Limited exemptions apply to:

• Minor or dependent children
• Golden Visa holders
• D3 visa holders (highly qualified professionals)

Couples who cohabited for at least 18 months prior to arrival may qualify for a reduced 15-month waiting period, provided they submit substantial proof of their relationship.

For most D7 holders, however, the default rule is a mandatory two-year wait.

2. Proof of Adequate Housing

Applicants must demonstrate access to adequate accommodation for at least one year.

This includes:

• A registered rental contract or proof of ownership
• Compliance with safety and health standards
• Supporting documentation such as payment receipts, deeds, or property tax records

Authorities are expected to scrutinize both the legal validity and suitability of the dwelling. Further clarification will be provided in a forthcoming ministerial ordinance.

3. Demonstration of Stable Financial Means

Financial self-sufficiency is now central to family reunification.

Applicants must provide:

• Bank statements
• Tax returns
• Income contracts
• Evidence of sustainability and continuity of income

Reliance on Portuguese social benefits is prohibited.

Although final income thresholds are pending regulatory clarification, D7 holders—who already demonstrate minimum passive income requirements (currently €870+ per month for the main applicant)—should expect deeper examination of:

• Source of income
• Long-term viability
• Ability to support additional dependents

Passive income streams such as dividends, pensions, or rental income may face heightened review.

4. Mandatory Integration Measures

Family members must now actively participate in integration programs, including:

• Portuguese language courses
• Civic values training
• School attendance for children under compulsory education laws

Failure to comply may jeopardize future residence renewals.

This adds an ongoing compliance component that did not previously exist in the D7 reunification pathway.

Processing Timelines

Applications begin with review by AIMA (Portugal’s migration agency).

• Standard processing period: up to 9 months
• Complex cases (excluding minors): up to 18 months

Upon approval:

• Family members abroad must apply for a D6 family reunification visa through the appropriate consulate
• Family members already in Portugal may coordinate appointments directly with AIMA

The former “manifestation of interest” route for regularization from within Portugal is no longer available.

Exceptions and Special Cases

The new framework distinguishes between categories as follows:

• General rule: Two-year waiting period (applies to D7 holders)
• Minor or dependent children: No waiting period
• Cohabiting partners (18+ months pre-arrival): 15-month waiting period with proof
• Golden Visa and D3 holders: Exempt from waiting period
• EU family members: Subject to separate EU freedom of movement rules

In 2025, the Constitutional Court temporarily invalidated earlier restrictions concerning spouses. Parliament subsequently enacted revised provisions, and as of 2026, the stricter framework applies without further judicial suspension.

A limited transitional 180-day window was provided for certain individuals already in Portugal, but this measure is time-bound.

Practical Implications for D7 Visa Holders

The D7 visa has long appealed to retirees, remote workers, and financially independent individuals because of its income-based eligibility and previously accessible family reunification process.

Under the new regime:

• Immediate relocation of spouses and older children may no longer be possible
• Separation periods may extend to two years
• Documentation requirements are more rigorous
• Passive income sources must withstand greater scrutiny

Applicants must maintain impeccable records of income, tax filings, and accommodation arrangements.

For families considering relocation in 2025 or later, early preparation is essential. This includes:

• Securing legally compliant housing
• Structuring passive income streams clearly
• Preparing integration planning for dependents

Those who relocated prior to October 2025 may benefit from transitional considerations, but new applicants must comply fully with the updated rules.

Planning Ahead

With further ministerial regulations expected to clarify income thresholds and housing standards, proactive legal planning is strongly recommended.

D7 visa applicants should assess:

• Timing of their move
• Financial structuring
• Family reunification strategy
• Integration readiness

Given the elimination of prior flexibility and fast-tracking advantages, careful preparation is critical to avoiding delays or prolonged family separation.

About the Advisor

Sara Rebolo is a Lisbon-based lawyer specializing in Immigration and Real Estate Law. She advises foreign investors, families, and entrepreneurs on Golden Visas, residency pathways, corporate mobility, and Portuguese citizenship. With deep expertise in evolving Portuguese immigration legislation, Sara provides tailored legal strategies to help clients navigate complex regulatory changes with confidence.