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

Summary: Lei n.º 62/2026, published on 10 September 2026 and in force since 11 September 2026, amends Portugal's Foreigners Act (Lei 23/2007). It revokes Article 92(4), the provision that allowed students of vocational and professional training courses to obtain a residence permit, and removes the in-country routes without a residence visa for higher-education students (Article 91(4)) and trainees (Article 93(3)). It also narrows Article 122(1)(k) for parents of minor children. 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 was published in Diário da República as Lei n.º 62/2026, of 10 September (DR n.º 176, 1.ª série), and has been in force since 11 September 2026. This article is based on the published text.

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• Article 92(4) was revoked.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 only to students of ensino secundário or of courses classified at CITE (ISCED) 2011 level 4 who hold a residence visa issued under Article 62, meet the general conditions of Article 77, are enrolled in an educational establishment and are covered by the SNS or by health insurance.
• 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. This sub-paragraph now covers only parents of minor children who hold Portuguese nationality and reside in Portugal, where the parent actually exercises parental responsibilities and provides for the child's support and education. The other sub-paragraphs of Article 122 and the exceptional-residence regime of Article 123 remain in force.
• 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 is no transitional rule for residence-permit cases. The only transitional provision of Lei 62/2026 (Article 10) keeps the previous regime for pending asylum procedures under Lei 27/2008; it does not cover applications under Article 92.

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?

Not through the former Article 92(4) route — it was revoked. The new Article 92(1) covers only ensino secundário and courses classified at CITE 2011 level 4, and only for holders of an Article 62 residence visa obtained at a consulate before travelling. Enrolment in a vocational or DGERT-certified course on its own does not lead 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.

When did the new rules take effect?

Lei n.º 62/2026 was published in Diário da República on 10 September 2026 and entered into force the next day, 11 September 2026.

Are there transitional rules for applications already submitted?

Not for residence permits. Lei 62/2026 contains one transitional provision (Article 10), and it applies only to pending asylum procedures under Lei 27/2008. If you submitted an Article 92(4) application earlier, keep your proof of submission, appointment confirmations and enrolment records, follow AIMA's practice and, where the stakes are significant, consult an immigration lawyer.

Which routes still lead to residence in Portugal?

Higher education under Article 91, with a residence visa obtained at the consulate before travelling. Work routes with a work visa; the job-seeker visa now exists only as a visa for qualified job search (visto para procura de trabalho qualificado). The CPLP route, which now requires the appropriate visa: CPLP nationals can no longer enter as tourists and apply for residence from inside Portugal. Family reunification, which now generally requires the sponsor to have held legal residence for two years. For nationality, the residence requirement is now 10 years (7 years for CPLP nationals), counted from the date the residence permit is issued.

Data verified as of 2026-09-30. Sources: Lei n.º 23/2007 as amended by Lei n.º 62/2026 (Diário da República n.º 176, 1.ª série, 10.09.2026, in force from 11.09.2026); Lei Orgânica n.º 1/2026 (Nationality Law); Decreto Regulamentar 4/2022. This article is general information, not legal advice.