Portugal's Foreigners Law 2026: What Changed for Vocational Course Students

Summary: a law amending Portugal's Foreigners Act (Lei 23/2007) was promulgated on 31 August 2026. It removes the provision that allowed students of vocational and professional training courses to obtain a residence permit under Article 92, and it removes in-country legalisation without a residence visa for almost every category. The route that still exists for course students is the temporary stay visa (E9) under Article 54(1)(k) — a visa that does not convert into a residence permit, does not count towards nationality and carries no right to work.

Status of the text: the law has been promulgated but has not yet been published in Diário da República. Our reading is based on Proposta de Lei 195/XXV of 7 May 2026 (PL 75/XVII in parliament) and the Texto Final approved on 17 July 2026. We will update this article once the official publication appears.

What exactly changed

• Article 92(4) was revoked. This was the paragraph that extended the Article 92 residence-permit regime to "cursos de formação ministrados por estabelecimentos de ensino ou de formação profissional" and to courses at QNQ levels 4 and 5. It was the only rule that brought DGERT-certified courses inside the residence-permit framework. It no longer exists.
• Article 92(1) has a new wording. A residence permit for study is now issued to students of ensino secundário or of courses at ISCED 2011 level 4, and only where the applicant holds a residence visa under Article 62.
• Article 92(3) is unchanged — visa-free legalisation from inside Portugal remains available only for ensino secundário. There is no equivalent for ISCED 4.
• Article 91(4) (higher education, in-country legalisation) and Article 93(3) (trainees) were also revoked.
• Article 122(1)(k) was narrowed. A residence permit without a visa is now available only to parents of minors who are simultaneously Portuguese nationals and resident in Portugal.
• Article 62 was not amended. Its paragraph 11 still obliges consulates to issue a residence visa for professional training courses — but a residence permit can no longer be granted on that basis unless the course is ISCED 4 or ensino secundário. This is a gap in the law, not a plan you can rely on.
• There are no transitional provisions in the text.

Who is affected

Students of vocational / professional courses (including DGERT-certified courses)

Most affected. The residence-permit route through Article 92 is gone. A course of this type no longer produces a residence permit, and no school — including ours — can promise one.

Higher education students

Studying at university still leads to a residence permit under Article 91, but the option of regularising from inside Portugal without a residence visa (former Article 91(4)) has been removed. The visa must be obtained at the consulate before travelling.

Trainees (estagiários)

Article 93(3) was revoked, so the same logic applies: entry with the correct visa, no in-country conversion.

Parents of minor children

Article 122(1)(k) now requires the child to be a Portuguese national and resident in Portugal. Parents of foreign minors who merely reside in Portugal no longer qualify for a visa-free permit under this provision.

Why an Article 62 visa no longer leads to a residence permit

Article 62(11) and Article 92 used to work as a pair: the consulate issued a residence visa for the course, and AIMA then issued the residence permit once the student arrived. The amendment cut the second half of that pair for vocational courses while leaving the first half in place. Formally, a consulate may still issue a residence visa for a professional training course; substantively, there is no longer a provision under which AIMA can grant the corresponding residence permit unless the course is ISCED 4 or ensino secundário.

Planning a move on the assumption that this gap will be resolved in the applicant's favour is not advisable. Until the published text and AIMA practice say otherwise, treat the vocational-course residence permit as closed.

The route that still works: temporary stay visa E9

Article 54(1)(k) of Lei 23/2007 provides a temporary stay visa for "frequência de curso em estabelecimento de ensino ou de formação profissional". This is visa type E9. Articles 54, 71 and 72 were not touched by the reform.

• Purpose: attending a course at a recognised educational or professional training establishment.
• Duration: stays of less than one year; the visa is issued for the duration of the stay, with multiple entries.
• Consular decision: up to 30 days.
• Extension in Portugal: under Article 72(1)(e), a temporary stay permit may be extended up to one year.
• Documents (Article 23-B of Decreto Regulamentar 4/2022): proof of enrolment issued by an officially recognised establishment (DGERT certification qualifies), proof of means of subsistence, proof of accommodation. No QNQ or ISCED level requirement applies.

What the E9 does not do

• It does not convert into a residence permit.
• It does not count towards the residence period for nationality.
• It carries no right to work in Portugal.

Apply for it honestly, for what it is: a legal basis to attend a course in Portugal for a limited period. Any application that hints at legalisation is both wrong on the law and risky for the applicant.

If you are already enrolled

1. Already holding a valid residence permit. Your existing permit stays valid on its own terms; check its expiry and the renewal basis with AIMA well before it runs out.
2. Holding a residence visa under Article 62 for a vocational course. Do not assume a residence permit will follow. Speak to the school and, where the sum at stake is significant, to an immigration lawyer, before travelling.
3. Preparing an application right now. Re-plan around the E9 temporary stay visa, or around a route that still leads to residence (higher education under Article 91, work, family reunification, CPLP).
4. Counting on legalisation from inside Portugal. That option no longer exists for your category unless you are in ensino secundário. Applying for the correct visa before entry is now the only sound approach.

FAQ

Can I still get a residence permit through a DGERT-certified course?

No. Article 92(4), the provision that made this possible, was revoked. No course of this type leads to a residence permit.

Does the E9 visa allow me to work?

No. The temporary stay visa carries no right to work in Portugal.

Can the E9 be converted into a residence permit later?

No. It is a temporary stay visa; it can be extended up to one year under Article 72(1)(e), but it does not convert and does not count towards nationality.

The law is not published yet — could it still change?

The text was approved on 17 July 2026 and promulgated on 31 August 2026. Publication in Diário da República is a formal step; substantive changes at this stage are unlikely. We will update this article when the official text appears.

Are there transitional rules for applications already submitted?

The text contains no transitional provisions. How pending files are treated in practice will depend on AIMA and consular guidance after publication.

Which routes still lead to residence in Portugal?

Higher education under Article 91 (with a residence visa obtained abroad), work-based routes with a work visa or job-seeker visa, the CPLP agreement, and family reunification.

Data verified as of 2026-09-02. Sources: Lei 23/2007 as amended; Proposta de Lei 195/XXV (07.05.2026); Texto Final approved 17.07.2026; Decreto Regulamentar 4/2022. This article is general information, not legal advice.