Published by Aliança Portuguesa para a Migração por Investimento.
Updated Editorial standards
The investment applicant and each family member must satisfy the conditions that apply to their own residence application. Family eligibility depends on the legal relationship, dependency and supporting evidence.
Key considerations
- ARI families are exempt from the general two-year family reunification waiting period introduced in 2025.
- An investment does not remove the personal and documentary requirements for the applicant or family.
- Adult children, dependent parents and unmarried partners require particular attention to evidence.
The principal applicant
Article 90.º-A combines the qualifying investment with the relevant general conditions in Article 77 of Law No. 23/2007. Assess the applicant’s identity, nationality, travel and immigration history, criminal records, health cover and financial documentation before treating the investment as a complete application.
Bank acceptance, a fund subscription or a cultural project declaration establishes only part of the file. None replaces AIMA’s assessment of the person. Any previous immigration refusal, conviction, entry restriction or uncertainty over the source of funds should be disclosed to the professional assessing the application.
Family relationships covered by the law
Articles 99 and 100 identify the relationships that may support reunification. The conditions differ by category; neither family membership nor financial support alone is sufficient in every case.
- A spouse, or a partner whose qualifying relationship is established under Portuguese law.
- Minor or incapacitated dependent children, and qualifying adopted children.
- Unmarried dependent adult children who are studying. Article 99(1)(e) contains the ARI-specific category.
- Dependent first-degree ascendants of the resident or spouse.
- Minor siblings under legally recognised guardianship, where the statutory conditions are met.
The ARI exception to the waiting period
Law No. 61/2025 introduced a general residence period before family reunification. Article 98(3)(c) expressly excludes family members of an Article 90.º-A residence holder from the general two-year period. This exception does not dispense with relationship, accommodation, means of subsistence or other applicable conditions.
The same amendment requires a valid and recognised marriage or partnership and a minimum age of 18 for both partners at the time of the request. Its rules on integration and renewal must be read together with their implementing provisions and the law’s application in time. Avoid applying a general headline about waiting periods to every ARI file.
Dependency and adult children
Dependency should be supported by a coherent history rather than a single unexplained transfer. Useful material for professional assessment may include regular support, living arrangements, education records and the family member’s own income or resources.
AIMA’s published ARI family checklist refers to dependent children over 18 and up to 25. Article 99(1)(e) itself describes unmarried dependent adult children who are studying, without stating that age ceiling. A case outside the published administrative checklist requires a specific legal assessment. Do not assume either automatic exclusion or automatic acceptance.
Prepare a file for each person
Prepare civil-status certificates, passports and the relevant criminal-record and other documents for each family member. Adoption, guardianship, divorce, custody and consent documents may need additional examination. Foreign documents can require an apostille or consular legalisation, and translation where required, according to their origin and the applicable rules.
Check that names, dates of birth and marital status are consistent across the file. For a child approaching adulthood, record age and study status at each procedural stage. Keep family applications linked through their official process references rather than assuming they will always progress together.
A household file in practice
Consider a hypothetical household consisting of an investor, a spouse, a 14-year-old child, a 20-year-old student and a parent who receives financial support. This example organises the questions to ask; it does not establish eligibility for any real family. Each person needs an individual document checklist and a record of the legal category relied on.
| Person | Issue to resolve | Material for assessment |
|---|---|---|
| Investor | Personal eligibility and qualifying investment | Identity, background and investment evidence |
| Spouse | Recognised marriage and individual conditions | Marriage record and personal documents |
| Minor child | Parentage and any relevant consent or custody issues | Birth record and relevant parental documents |
| Adult student | Unmarried status, study and dependency | Current study records and a history of financial support |
| Parent | Relationship and actual dependency | Civil records, support evidence and financial circumstances |
Review the family’s position at renewal
A family residence card has its own validity and renewal requirements. Changes in dependency, study, marriage or custody can affect the legal basis. The principal applicant’s investment obligations and a family member’s possible autonomous residence rights should be assessed separately.
Before submission, ask which legal category is relied on for each person, what evidence establishes it, which documents expire and how a foreseeable family change would be handled. A written person-by-person checklist is more useful than a single family eligibility assurance.
Practical questions
Does one qualifying investment cover every family member automatically?
The principal investment and family eligibility are different questions. The investor must establish the ARI basis, while each family member must establish their own qualifying relationship and other applicable conditions. Prepare separate document and fee records, even where the applications are coordinated.
What if a child becomes an adult while the file is pending?
Record the date of birth, application dates and any change in study or dependency. Ask which conditions will be examined at the relevant decision or renewal stage and which evidence should be updated. Do not assume that the original submission permanently fixes the child’s category.
Is a parent’s age enough to demonstrate dependency?
Do not treat age alone as a complete assessment of the statutory dependency condition. Assemble the relationship evidence and a clear account of the parent’s resources and support. Ask the professional handling the case which documents and any applicable administrative presumptions are relevant to that particular file.
Source references
Sources and further reading
Personal eligibility and family reunification framework.
diariodarepublica.ptARI waiting-period exception, age conditions and temporal application.
diariodarepublica.ptApplicant requirements.
aima.gov.ptAdministrative documentary guidance, including its adult-child age band.
aima.gov.ptForeign document recognition and authentication.
aima.gov.ptFamily procedure and renewal guidance.
aima.gov.ptGeneral information. The applicable law, your circumstances and the competent authority’s decision determine your position. Editorial Standards and Corrections
