The expression of interest is over: what replaced it in 2026

• Repealed on 4 June 2024: Decreto-Lei n.º 37-A/2024 removed the "expression of interest" (arts 88.º n.º 2 and 89.º n.º 2 of the Foreigners Act) — the route by which someone who entered as a tourist could apply for a residence permit after contributing to Social Security
• Pending files were protected: applications started before the repeal follow the old law; Lei n.º 61/2025 then set a hard deadline — 31 December 2025 — after which unfiled regularisations lapsed
• The replacement is a visa applied for abroad: work visa with a contract, CPLP residence visa, temporary-stay visas, and, since October 2025, the visa for qualified job-seekers (art. 57.º-A)
• The former job-seeker visa is gone — no applications since 23 October 2025

For a decade the manifestação de interesse was the back door of Portuguese immigration: enter on a tourist stamp, find work, pay twelve months of Social Security, and ask AIMA (before it, SEF) to regularise you from inside the country. It produced, in the Government’s own words, “hundreds of thousands of files pending analysis”. It is closed. This article says what the repeal did, what happened to the files already lodged, and what the legal routes are in 2026 for someone who would have used it.

What the expression of interest was

Two paragraphs of Lei n.º 23/2007 carried it. Article 88.º, n.º 2, allowed a residence permit for employed work without a residence visa when the foreigner had a work contract or an employment relationship proven by a union, an employers’ association or a labour inspectorate, had entered and stayed legally, and was registered with Social Security. Article 89.º, n.º 2, did the same for self-employment. The “expression of interest” was the online form that opened the file. Paragraphs 6 and 7 of article 81.º and n.º 6 of article 88.º and n.º 4–5 of article 89.º added presumptions of legal entry that made the route work in practice.

The repeal: Decreto-Lei n.º 37-A/2024

Approved on 3 June 2024 and in force the day after publication, the decree-law repealed those provisions outright (art. 2.º: “n.os 6 e 7 do artigo 81.º, os n.os 2 e 6 do artigo 88.º e os n.os 2, 4 e 5 do artigo 89.º”). Its preamble is unusually blunt about why: the mechanism had become the main way of entering Portugal, a registration and a mere promise of a contract were enough to start it, it fed exploitation of people in “manifest vulnerability”, and it left the services unable to answer hundreds of thousands of files.

Article 3.º, n.º 2, protected acquired positions: “the present decree-law does not apply to residence-permit procedures started before its entry into force, which continue to be governed by Lei n.º 23/2007 in its previous wording”. A file opened by 3 June 2024 was therefore still processed under the old rules — by the Estrutura de Missão created to clear the backlog.

The 2025 deadline for pending files

Lei n.º 61/2025 of 22 October rewrote that transitional article. Its new n.º 3 states that, for the purposes of the protected cases, “residence-permit applications must be submitted, without fail, by 31 December 2025, on pain of lapse” (sob pena de caducidade). Someone who had registered an expression of interest but never converted it into an actual application by that date lost the benefit of the old law. Files properly lodged before the deadline continue; their holders renew the permit they obtain like anyone else — see renewing a residence permit.

What replaces it, route by route

Every route in the table is described in our guide to Portuguese visas, with the documents, the means of subsistence (100 % of the 920 € minimum wage for the applicant, 50 % per adult family member, 30 % per child) and the 110 € consular fee.

If you are in Portugal without a permit today

Three honest observations, from files we see every week:

1. No file lodged before 31 December 2025 means no protected position. Registering an expression of interest in 2023 and waiting is not an application; the lapse is in the law.
2. A tourist entry does not convert into residence. The way back is a residence visa at the consulate of your country of residence — which may require leaving Portugal and proving the entry-and-stay conditions from abroad.
3. Family ties are the one door that opens from inside: a spouse, partner or parent with a residence permit can apply for reunification at AIMA for relatives who entered legally.

Whatever your case, get it assessed before acting: an application filed on the wrong basis is refused, and a refusal is on record for the next one.