Where do you apply for Portuguese citizenship — AIMA or IRN?

If you have been dealing with Portuguese immigration for a few years, you have learned to fear one agency: AIMA. Here is the good news and the confusing news at once — AIMA does not handle citizenship. Your nationality application goes to a completely different body, under a different ministry, with a different queue: the IRN (Instituto dos Registos e do Notariado), part of the Ministry of Justice, and it is decided and registered at the Conservatória dos Registos Centrais in Lisbon — the Central Registry Office.

The dividing line is worth memorising, because it decides which website, which queue and which acronym is yours. AIMA governs your right to be here — residence permits, renewals, family reunification. The IRN governs who you legally are — births, marriages, nationality. You spend years with the first one to accumulate the residence that qualifies you for the second. Then you switch. And when you switch, one of the documents you carry across is the language proof, which is a separate requirement from the new civic test — the difference between the language exam and the citizenship test is where most English-language forums go wrong. Article 16 of Law 37/81, as republished with Organic Law 1/2026, puts the nationality register squarely under the IRN and the Central Registry Office. AIMA is not in the sentence.

A quick decoder for the acronyms

• SEF — the old immigration service. It no longer exists: Decree-Law 41/2023 transferred its administrative functions and it stopped operating in late October 2023. Guides that still tell you to book at the SEF are out of date.
• AIMA — the agency that took over SEF's administrative functions. Residence, not citizenship.
• IRN — the registries institute, under the Ministry of Justice. Your citizenship application lives here.
• CRC (Conservatória dos Registos Centrais) — the single office inside the IRN that decides and registers nationality.
• Balcão da Nacionalidade — a nationality counter; an extension of the CRC where you can file in person.

So does AIMA touch the process at all?

Once, and only as a witness. Under Article 27(5) of the Nationality Regulation (Decree-Law 237-A/2006), when a naturalisation file is not summarily rejected, the Central Registry Office asks for information from the Judiciary Police, the Border and Foreigners Coordination Unit, and AIMA — because AIMA holds the record of your legal residence. Those bodies have 30 days to answer, extendable by no more than 60.

There is even an accounting trace of it: Article 19(2) of the fees regulation (Decree-Law 322-A/2001) says that in each acquisition procedure where AIMA provides information, €20 of the fee collected belongs to AIMA. Twenty euros out of your €250. That is the whole of AIMA's role — a consulted party, paid to answer a question. It does not receive your application and it cannot decide it. Nobody at AIMA can move your citizenship file, so an appointment there will not help you.

Where do you actually file?

Article 18(1) of the Regulation gives three in-person options for a naturalisation request: extensions of the Central Registry Office (the nationality counters), any civil registry office (conservatória do registo civil), and Portuguese consular services. Article 18(2) adds post — sent to the Central Registry Office — and the electronic channel. For the declaration-based routes (marriage, de facto union, children, grandchildren, birth registration) Article 32 gives the same map.

The online channel is Nacionalidade Online. One point worth being precise about, because it is often mis-sold: the official page Submeter pedido de nacionalidade states that using the online channel is mandatory for lawyers and solicitadores from 1 December 2023. Mandatory for them — Article 43-A(2) makes electronic filing optional for applicants who are not represented. You do not need a lawyer to apply. Many people use one, and for a complicated file that is money well spent, but it is a choice, not a requirement.

If you file by post or online, note Article 32(3): the application counts as made on the date it is received at the Central Registry Office, not the date you sent it. If a deadline matters to you, that difference is the deadline.

What it costs

Fixed amounts, set in Article 18(2) of the fees regulation: €250 for acquisition by declaration, adoption or naturalisation for adults; €200 where the applicant lacks legal capacity; €175 for attribution (including registering a birth that happened abroad); €150 for loss of nationality; and €50 for a nationality certificate. The table sets the amount by the type of procedure alone — it does not vary with your nationality or with where you file.

The trap is item 2.4 of the same article: if your application is summarily rejected — thrown out at the door for a missing document — the fees «são devidos na sua totalidade», due in full. You pay €250 for a file that was never examined. This is the strongest practical argument for submitting late and complete rather than early and hopeful.

Some routes are free, but which ones is currently contradictory. The new Article 6(12) of the Nationality Law makes naturalisation free for the groups in paragraphs 2, 3 and 4 — minors born in Portugal, stateless people, and children in institutional care. The Regulation's Article 44(3) still lists paragraphs «2, 3, 5 and 9», and paragraph 5 was repealed by Organic Law 1/2026. The two texts no longer agree; the pending revision of the Regulation has to fix it. If you might qualify, ask in writing and keep the answer.

How long is it supposed to take — and how long does it take?

On paper, months. For declaration routes, Article 41 gives the Central Registry Office 30 days for an initial review and the registrar 60 days to decide once the file is complete. For naturalisation, Article 27 chains 30 days of initial review, 30 (extendable to 90) for the security and AIMA checks, 45 days for a formal opinion, and then a decision by the member of government responsible for justice — a power Article 28 allows to be delegated to the head of the IRN.

In reality, years. The reason is arithmetic, and it comes from the IRN's own published figures of 5 July 2025: 367,348 applications arrived in 2022 against 199,769 registered; 274,820 against 195,946 in 2023; 277,656 against 220,496 in 2024. More comes in than goes out, every year. As of 30 June 2025 the IRN reported 515,334 pending files. Press reporting through 2026 puts the figure above half a million still — treat those numbers as journalism rather than statistics, and the IRN's own page as the citable one.

Two conclusions you can act on. First, refusals are rare: the same data show roughly 8,000 refusals a year against 200,000+ decisions. Your risk is delay, not rejection. Second, delay is legally a thing, not just a feeling. Article 61(1) of the Regulation gives you standing to challenge «atos e omissões» — acts and omissions — in the administrative courts within one year. Prolonged silence past the statutory deadlines is an omission the law names. That is a conversation for a Portuguese lawyer, and it is a real option, not a threat you make at a counter.

Checking your status without paying anyone

Use the official page Consultar estado do processo de nacionalidade. You need the consultation code that is emailed to you when the file is created at submission — save that email. Lost it? Ask at a nationality counter or call the Linha Registos on +351 211 950 500. There are four states: Submetido (submitted), Em análise (under review), Para decisão (for decision), Concluído (concluded, whether granted or refused). No official page publishes average times per state, so when a site tells you «the IRN is currently working on March 2023 files», that is crowd-sourced observation, not published fact.

Two provisions worth knowing before you file

Joining family files (Article 40-A). Where relatives file on the same day — spouses, de facto partners, adoption, or blood relatives up to the third degree — any of them can ask for the files to be joined so that common documents and steps are used once instead of three times. Even when the conditions are not met, paragraph 5 lets you point the registrar to a relative's file number. If a family is applying together, filing on the same day and asking for apensação is free and saves real work.

Documents you should not be chasing (Article 37). Paragraph 7 requires the service to obtain your Portuguese criminal record and your proof of legal residence itself, on your behalf. Paragraph 4 waives Portuguese civil registry certificates as long as you give enough detail to identify the record. Before you pay an agency to gather paperwork, check what the state is obliged to fetch for free.

Where does the new civic test fit in?

Nobody knows yet, and as of 30 July 2026 that is the accurate answer rather than a cautious one. Organic Law 1/2026 added the knowledge requirement to Article 6(1)(c) and (d) — Portuguese language and culture, history and national symbols, fundamental rights and duties, and how the state is organised. Article 4 of the same law gave the government 90 days from publication on 18 May 2026 to amend the Nationality Regulation. That window closes around mid-August 2026, and nothing has been published. There is no format, no official syllabus, no official question bank, and no way to book a sitting.

Procedurally, the open questions are specific: will the test be a certificate you attach to the file, as the language proof is today under Article 25, or a step inside the review? Who administers it, what does it cost, how do you book it? What you can do now is study the subjects the statute names — what the law already fixes about the format sets out exactly how much is known. If you want to gauge where you stand, our free quiz is built on those subjects. They are our questions, not official ones — nobody has official ones.

What to do now

If you already have the residence years, file now, at the IRN, without waiting for the regulation. Article 7(2) of Organic Law 1/2026 applies the previous version of the law to procedures already pending when it came into force — what that does and does not protect is set out in what happens to pending applications. File complete rather than fast, keep the consultation code, and set your expectations in years rather than months. Half a million people are in the same queue, and the published numbers say almost all of them reach the end of it.