Tacit Approval for AIMA Renewal: The Complete 2026 Guide (Certidão de Deferimento Tácito)

If your AIMA renewal has been stuck for months with no clear decision, you may be entitled to Tacit Approval (Deferimento Tácito), a powerful legal mechanism under Portuguese law.

What is Tacit Approval in Portugal?

Tacit approval (Deferimento Tácito) is a legal concept under Portuguese administrative law.

It means:

If the government fails to issue a decision within the legally established timeframe, the request is automatically considered approved.

In the context of AIMA Renewal, this means:

• If 60 working days pass after your renewal submission (for renewals)

• And there is no express decision

• And the delay is not your fault

Your renewal may be legally considered approved.

This right is grounded in:

• Law 23/2007 (Immigration Law), Article 82(7)

• The Portuguese Administrative Procedure Code

What Is AIMA?

Agência para a Integração, Migrações e Asilo (AIMA) is Portugal’s immigration authority responsible for residence permits, renewals, and migration processes.

It replaced SEF and now handles:

• Temporary residence renewals

• Initial permits

• CPLP residency

• Golden Visa processes

• Student and work authorizations

Why would you need the Certidão de Deferimento? 

This GUIDE is primarily for people who submitted their renewal through the Mission Structure. The process (specifically the letter template) assumes that you had an in-person appointment to submit your documents.

However, you can adapt this process and the template letter for initial approval and post-July 1st, 2025, renewals. The website submittal (Step 1) works ONLY FOR RENEWALS. You CANNOT use the website to request a Tacit Approval for an initial residence card.

Please note that AIMA has 90 (not 60) days to respond to initial residency cards if you opt to request a Tacit Approval via email or registered letter. And there are some thoughts that initial cards are completely exempt from the Tacit Approval process.

If you need to calculate how many Portuguese working days have passed since you uploaded your documents to the renewal portal, you can use this calculator.

https://www.diasuteis.pt/EN/. Please note that we suggest that 60 (or 90) days start when you pay your AIMA fees. People are reporting success on the day they uploaded or submitted (in the case of initial cards) their documents as a better day from which to start counting.

The general assumption is that the “process clock” resets anytime you submit new or additional documents, so consider that when making your calculations. However, please note that tacit approval eligibility can be triggered before an audiência previa (draft rejection) if the draft rejection comes after 60 (90) business days. In other words, a draft rejection received after 60 (90) days does not reset the “process clock” because the “process clock” has already expired. Therefore, submitting for tacit approval retroactively is valid. 

Tacit Approval for AIMA Renewal: Step-by-Step Guide

Step 1 — Log in

1. Go to gov.pt and start a new request: Pedido de Certidão – Deferimento

   Tácito. This is what the website address should look like:

   https://www.gov.pt/servicos/pedir-a-certidao-de-deferimento-tacito

2. Log in with CMD (Chave Móvel Digital)

3. Don’t panic if you have to do the CMD authentication process twice. It’s a regular quirk of this system.

The CMD is just used for authentication. It does not change your AIMA account or status.

Step 2 — Applicant

1.  Fill in your name

2.  Select “Proprio” if you are submitting a request for yourself. Select “Representante” if you are submitting for a minor child. And then see Step 3.

   
   

3. Fill in email + phone

4. Use the email you want notifications sent to. It does not have to match your

5. AIMA portal email

6. Click the blue button with “Continuar.”

Step 3 — Extra step for minors (important)

When submitting as a parent/representative:

1.  Select “Representante”

2.  Select “Não” for a “Consulta código”

3.  Leave “Numero” blank, as you are not a lawyer.

4.  Choose “Não” for procuração online

5. The platform may still force a document upload.

6. Upload the birth certificate for “Procuração”.

Do NOT create or upload a fake procuração. This is a known platform quirk.

Step 4 — 2nd Screen for Personal Information 

Some of these fields will auto-populate. However, if you are applying for a minor child, you need to enter THEIR name and their NIF. The parents’ information was already captured on the previous screen.

1. Use the blue button with “Pesquisar morada” to help auto-populate the address fields.

2. Click the blue button with “Continuar.”

Step 5 (MOST IMPORTANT) — Search for the correct service & entity:

Do NOT type this manually. You must search.

1. Click on the blue button with “Pesquisar serviço.”

2. In the search box: Type “asilo.”

3. Hit enter on your keyboard. From the results: Select: AIMA

4. Choose Agência para a Integração, Migrações e Asilo . Click the blue button with “Selecionar.”

5. In the same search box: Type “renovar.”

6. Hit Enter on your keyboard

7. From the results: Select: Renovar a autorização de residência

8. Click the blue button with “Selecionar.”

When done correctly:

• Entity shows as Agência para a Integração, Migrações e Asilo

• Entity code auto-fills as CES: ORG:000026643

• If you skip this step, the form will not validate properly later.

Step 6 — Request details

Fill in:

Regime jurídico: Lei Ordinária,

• Article 77: General requirements and regime for the grant or renewal of a residence permit.

• Article 80: Permanent residence permit.

• Article 88, paragraph 1: Residence permit for employed professional activity with a prior residence visa.

• Article 88, paragraph 2: Residence permit for employed workers without a prior residence visa (often referred to as an "expression of interest" route).

• Article 89, paragraph 2: Residence permit for self-employed or Freelance professionals (without a prior residence visa).

• Article 90-A: Residence permit for investment activity (Golden Visa, largely revoked for real estate as of late 2023, but other investment options remain).

• Article 91: Residence permits for higher education students.

• Article 91-B: Residence permit for researchers.

• Article 92: Residence permits for students at secondary school or Vocational training levels.

1. Nome do pedido: “Pedido de renovação de autorização de residência”

2. Número do processo: Use the NIE identifier on the renewal receipt.

   
   

   (Some people have used their Expired Temporary Residency Card (TRC) number instead and have successfully gotten the Certificate. To be “on the safe side,” some people have chosen to submit the online request form TWICE. They submit once using the NIE and another time using their TRC number.

   
   

   AIMA, not surprisingly, provides confusing guidance on this entry. AIMA says that they want the NIE. But they are rejecting submittals with the NIE, yet issuing the certificate when the TRC number is used.) (For minors, using the NIE is often safest.)

   
   

3. For Post-July 1st renewals, use the NIPC from the upper right-hand corner of your submittal receipt.

4. Cópia do requerimento inicial submetido à entidade: Upload the renewal comprovativo (A copy of any confirmation email that you received after your appointment.)

Step 7 — Timeline questions

You’ll be asked:

• Initial submission date

• Whether documents were requested

• Whether there was an audiência previa

• Whether you responded

• Date of tacit approval formation (draft rejection).

Practical guidance: Initial submission date: renewal portal submission date (or receipt date if unsure) (Note: the date you paid your fees to AIMA is the “start date”, but that’s not what we’re recommending you use.)

 If you received an audiência prévia:

• “Foi notificado?” → Sim

• “Respondeu?” → Sim

• Response date = when you uploaded documents, Tacit approval date (common approach) 61 days after your document upload date, appointment date, or additional documents response date.

Step 8 — Declaration

1. Tick the truth declaration and GDPR consent

2. The declaration will show your name (the submitter/representative)

3. This is correct, even for minors

Step 9 – Submission

Submit and save the confirmation PDF + new process number.

It’s normal for ARTE to be on the Tacit Approval receipt.

Common mistakes to avoid

• Typing the service instead of using Pesquisar serviço

• Selecting the wrong AIMA/SGMAI entity

• Mixing parent and child timelines

• Selecting Pessoa coletiva

• Uploading unnecessary documents (except when forced).

However, these are some of the documents you should have at hand in the event they are requested.

• A copy of the registered letter that you sent to AIMA, if applicable

• A copy of your expired Título de Residência

• A copy of the email with your AIMA biometric appointment

• A copy of your receipt from paying your renewal fees

• A copy of any receipt that you received at your renewal appointment.

• A copy of any confirmation email that you received after your appointment.

After submission

You’ll receive confirmation with a new process number for the certificate request. Keep it. It’s useful for follow-ups and proof of submission. If your request is successful, you will receive a PDF copy of the Certidão de Deferimento Tácito by email.

Email to AIMA (Strongly Recommended)

Send email to:geral@aima.gov.pt

Attach:

• Expired residence card

• Renewal receipt

• Payment receipt

• Biometric appointment proof

• Tacit approval submission receipt

• Any audiência prévia and response proof

• Minor birth certificate (if applicable)

Use formal legal language referencing:Article 82(7) of Law 23/2007

Registered Letter (Optional but Powerful)

Mail to AIMA headquarters in Lisbon.

This creates documented proof of notification.

Many applicants do not need this step, but it strengthens your position.

Legal Foundation Behind Tacit Approval

Portuguese law does not allow indefinite silence from public administration.

The principle protects:

• Legal certainty

• Legitimate expectations

• Good administrative practice

Portuguese administrative courts may enforce tacit approval if AIMA fails to act even after notification.

Step 1:

You will send an email to the official AIMA address (geral@aima.gov.pt) saying you are requesting a Certidão de Deferimento Tácito. For your email, you can use the template in Appendix B. You should attach:

1. A copy of your expired Título de Residência

2. A copy of your receipt from your Step 2 online Certidão de Deferimento Tácito request, if you have one.

3. A copy of the email with your AIMA biometric appointment

4. A copy of your receipt from paying your renewal fees

5. A copy of any receipt that you received at your renewal appointment.

6. A copy of any confirmation email that you received after your appointment.

7. If applicable, a copy of your audiência previa (draft refusal) and any proof that you submitted the requested documents.

8. A copy of a minor’s birth certificate, if you are a parent submitting on behalf of your child. Apostilled is ideal, but a clear PDF usually works for this purpose.

9. A copy of the registered letter that you sent to AIMA, if you have already done that.

10. If you have already received the Certidão de Deferimento (from Step 1), you should attach a copy of that as well.

Step 2:

You are pretty much going to replicate what you did in Step 1, except you are going to do it by registered mail. Although this process is outlined, many People have not found it necessary.

You are going to send a registered letter to AIMA at this address: Avenida António Augusto de Aguiar, 20, 1069-119 Lisboa, Portugal. You will use the template in Appendix B with appropriate customization. You should include:

1. A copy of your expired Título de Residência

2. A copy of your receipt from your online Certidão de Deferimento Tácito request, if you have one.

3. A copy of the email with your AIMA biometric appointment

4. A copy of your receipt from paying your renewal fees

5. A copy of any receipt that you received at your renewal appointment.

6. A copy of any confirmation email that you received after your appointment.

7. If applicable, a copy of your audiência previa (draft refusal) and any proof that you submitted the requested documents.

8. A copy of a minor’s birth certificate, if you are a parent submitting on behalf of your child. Apostilled is ideal, but a clear PDF usually works for this purpose.

9. If you have already received the Certidão de Deferimento, you should attach a copy of that as well. 

Letter Template

NOTE: This letter is designed for pre-July 1st renewals. You’ll need to make some changes if you are a post-July 1st renewal. AIMA – Agência para a Integração, Migrações e Asilo. Agência para a Imigração e Mobilidade (AIMA, I.P.)

Requerente: [nome]

NIF: [número] Título de residência n.º: [número] Passaporte n.º: [número]

Morada: [morada completa]

Telefone: [número] E-mail: [endereço]

NIPC: [número] You should be able to find this number on the top corner of your renewal recibo for post-July renewals. NIPC is an internal number assigned by AIMA to every candidate for residency, initial or renewal.

Processo n.º: [número]

Assunto: Pedido de Emissão de Título de Residência por Deferimento Tácito Exmos. Senhores,

Venho, por este meio, solicitar a emissão do meu título de residência relativo ao processo acima identificado, com fund

amento no deferimento tácito previsto no artigo 82.º, n.º 7 da Lei n.º 23/2007, de 4 de julho, na redação dada pela Lei n.º 18/2022, de 25 de agosto.

No dia [INSERT DATE] de [INSERT MONTH] de 2025, compareci ao agendamento realizado no [INSERT LOCATION OF YOUR APPOINTMENT], no âmbito do processo de renovação da minha autorização de residência n.º [INSERT EXPIRED PERMIT NUMBER], cuja validade expirou em [INSERT DATE] de [INSERT MONTH] de 20[INSERT YEAR], tendo cumprido todas as formalidades exigidas e efetuado o pagamento integral das taxas devidas.

Nos termos do artigo 82.º, n.º 7 da Lei n.º 23/2007, “na falta de decisão no prazo de 60 dias úteis sobre o pedido de renovação da autorização de residência, por causa não

imputável ao requerente, o pedido considera-se tacitamente deferido, devendo o título de residência ser emitido de imediato”. Em conformidade com o Código do Procedimento Administrativo, esta situação configura o direito de ver o pedido considerado deferido por silêncio administrativo.

Nestes termos, e considerando o decurso do prazo legal de 60 dias úteis sem que tenha sido proferida qualquer decisão expressa relativamente ao referido pedido, e que tal atraso não se deve a conduta imputável à requerente, venho requerer a emissão imediata do meu novo título de residência com base no deferimento tácito previsto na legislação supracitada.

Agradeço a vossa atenção e solicito uma resposta célere.

Com os melhores cumprimentos, [Nome da requerente]

[INSERT YOUR CITY OF RESIDENCE] [INSERT DATE] de [INSERT MONTH] de 2026

********************************************************************************** ***

Here is an English Translation so you know what you are submitting. But you do NOT need to include the English version in your letter.

AIMA – Agency for Integration, Migration and Asylum Agency for Immigration and Mobility (AIMA, I.P.)

Applicant: [name]

Tax Identification Number (NIF): [number] Residence permit no.: [number] Passport no.: [number]

Address: [full address] Telephone: [number] Email: [address]

Legal Entity/Identification Number (NIPC): [number] Process no.: [number]

Subject: Request for Issuance of Residence Permit by Tacit Approval

Dear Sirs,

I hereby request the issuance of my residence permit relating to the process identified above, based on the tacit approval provided for in Article 82, no. 7 of Law no. 23/2007 of 4 July, as amended by Law no. 18/2022 of 25 August.

On [INSERT DATE] of [INSERT MONTH] of 2025, I attended the scheduled appointment held at the [INSERT LOCATION OF YOUR APPOINTMENT],, within the scope of the renewal process of my residence authorization no. [INSERT EXPIRED PERMNIT NUMBER], whose validity expired on [INSERT DATE] OF [INSERT MONTH] OF 20[INSERT YEAR],, having complied with all required formalities and having paid in full the applicable fees.

Under the terms of Article 82, no. 7 of Law no. 23/2007, “in the absence of a decision within the period of 60 working days regarding the request for renewal of the residence authorization, for reasons not attributable to the applicant, the request shall be deemed tacitly approved, and the residence permit must be issued immediately.” In accordance with the Administrative Procedure Code, this situation constitutes the right to have the request considered approved by administrative silence.

Accordingly, and considering that the legal period of 60 working days has elapsed without any express decision having been issued in relation to the aforementioned request, and that such delay is not due to conduct attributable to the applicant, I hereby request the immediate issuance of my new residence permit based on the tacit approval provided for in the aforementioned legislation.

Thank you for your attention, and I request a prompt response.

Yours faithfully,

[Applicant’s name]

[INSERT YOUR CITY OF RESIDENCE] [INSERT DATE] of [INSERT MONTH] of 2026 

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Frequently Asked Questions

Is Tacit Approval Automatic?

Legally yes. Practically, you must assert it.

That’s why the Certidão de Deferimento Tácito is essential.

Can I Travel With Tacit Approval?

• Help for re-entry to Portugal

• NOT valid for Schengen travel

Does Tacit Approval Guarantee My Card?

No. It establishes legal approval. Card issuance may still be delayed.

What If AIMA Ignores My Request?

If formal notification fails:

• Administrative court action is possible

• Courts can order recognition of tacit approval

Tacit Approval AIMA Renewal Strategy Summary

Step	Action	Recommended?
1	Online Certidão Request	✅ Essential
2	Email AIMA	✅ Strongly Recommended
3	Registered Letter	⚖️ Strategic
4	Court Action	⚖️ If Necessary

Final Thoughts: Should You Request Tacit Approval?

If:

• 60 working days passed

• You submitted everything

• Delay is not your fault

Then yes — Tacit Approval AIMA Renewal may be your strongest legal tool.

It is not a loophole. It is your legal right under Portuguese law.

Disclaimer

This guide is informational and not legal advice. Immigration law can change. Always verify deadlines and consult a qualified lawyer if your case is complex.