AIMA Not Answering Your Renewal? How Tacit Approval and the Deferimento Certificate Work

You paid the fee, submitted your renewal, and then nothing. Weeks turn into months, your old card expires, and AIMA stays silent. Portuguese law has an answer for this situation, called tacit approval, and many applicants are using it. Here is how it works in plain terms.

The rule

Under article 82 of the foreigners law (Lei 23/2007), when AIMA does not decide a residence permit renewal within 60 working days, for reasons that are not the applicant's fault, the request is considered approved. For a first permit, the period commonly quoted is 90 working days, although it is less clear how this applies to initial applications.

In other words, silence from the administration does not leave you in limbo forever. The law turns it into a favourable decision.

What tacit approval gives you

The practical tool is a document called the Certidão de Deferimento Tácito, a certificate stating that your renewal is tacitly approved. It is useful because it can serve as evidence that you are approved even when the new card has not arrived. Applicants use it for things like:

• unblocking or keeping a bank account,
• re-entering Portugal after a trip,
• employment situations where a valid permit is asked for.

It also often changes the status in the AIMA portal from "under review" to "approved". It is not a cure-all: it does not replace the card for travel inside the Schengen area, and getting the physical card can still take a long time.

How to request it

1. Count your working days. Use an online working-day calculator from the date you submitted your documents. The clock can restart when you send additional documents, but a refusal notice that arrives after the period has already expired does not cancel it.
2. Submit the online request. On the gov.pt portal there is a service called Pedido de Certidão de Deferimento Tácito. You log in with your Chave Móvel Digital (CMD). It works for renewals only, not for first permits.
3. Select the right entity and service. Use the search function to pick AIMA (Agência para a Integração, Migrações e Asilo) and the service "Renovar a autorização de residência". Typing it manually makes the form fail later.
4. Fill in the process details and your timeline honestly and consistently: submission date, whether documents were requested, whether you responded.
5. Keep the confirmation. If approved, you receive the certificate by email as a PDF.

The certificate is issued by a state technology agency rather than by AIMA, which can look surprising but is normal.

Other steps that strengthen your case

• Send an email to AIMA's official address asking for the certificate, with your receipts and the proof of your renewal attached.
• Send a registered letter to AIMA's headquarters stating that the legal period has expired and invoking tacit approval.
• If AIMA stays silent, the administrative courts can recognise tacit approval and order the card to be issued.

Common mistakes

• Selecting the wrong entity or typing the service by hand.
• Mixing a parent's dates with a child's when applying for a minor. A parent can use their own CMD for a child.
• Counting calendar days instead of working days.
• Uploading unrelated documents.

An honest word of caution

This area moves quickly. Portuguese immigration law was amended in 2025, AIMA's portals and forms change often, and results are not the same for everyone. We check the current position for each case before relying on it.

If your renewal is overdue, we can prepare the request and the letters.

General information, not legal advice for your situation.