# 6. The Citizenship Component ## 6.1 Purpose of the additional nationality The citizenship component has one purpose: an additional nationality, held alongside the client's existing nationality or nationalities. It is not a European instrument, not a residence permit, and not a source of European mobility (see §4.1). Subject to eligibility, due diligence and government approval, it may provide a second citizenship and passport, reduced dependence on a single country of nationality, an alternative sovereign and consular relationship, family contingency, potential intergenerational status subject to nationality law, and additional succession and personal-planning options. Each is conditional, and each is examined below. It does not provide European Union citizenship, European residence, European employment rights or visa-free access to the Schengen Area. Nationals of São Tomé and Príncipe are listed in Annex I of Regulation (EU) 2018/1806 and require a visa to cross the external borders of the Schengen member states.[^6-1] Short-stay Schengen movement within the reference structure arises from the Greek residence permit and from nothing else (see §7.10). The component's value is therefore not general. It is a function of the client's existing nationality, family composition and objectives, and for a material number of clients it is either legally unavailable or practically marginal. ## 6.2 Legal foundation of the reference programme The framework statute is Lei n.º 7/2022, the Nationality Law, published in the Diário da República, I Série, N.º 25, of 10 March 2022 and in force 90 days after publication.[^6-2] Article 10(2) supplies the naturalisation ground on which the programme is built: investment that unequivocally increases employment and contributes significantly to development, high-level activity in sport, science or culture, or the donation of direct financial or other support to the country. For those applicants the five-year residence and language requirements may be waived, but the remaining Article 10(1) conditions — majority, no final conviction carrying a prison sentence of three years or more, no terrorism or security threat, and an activity ensuring subsistence — continue to apply.[^6-2] The implementing instrument is Decreto-Lei n.º 07/2025, the Regulamentação da Nacionalidade por Investimento ou Doação (RNID), published in the Diário da República, I Série, N.º 33, of 1 August 2025 at pages 429 to 440 and in force from publication; it was approved by the Council of Ministers on 10 May 2025, promulgated on 28 July 2025, and issued under Article 111(c) of the Constitution and Article 26 of Lei n.º 7/2022.[^6-3] Article 3(h) defines the programme as a special naturalisation mechanism founded on a non-refundable contribution to the Fundo Nacional de Transformação — the National Transformation Fund — in the minimum amounts of Anexo I. The Fund is autonomous, independently audited and overseen by the Court of Auditors and the Central Bank, and contributions revert integrally to it; Article 13(1) nonetheless provides that net proceeds revert "in the defined percentages", a hook for a revenue split defined outside the decree whose terms are not public.[^6-3] Applications are processed by the Unidade de Cidadania por Investimento e Doação (UCID) under the justice minister in articulation with the investments minister; a managing entity may be designated by joint order and, where private, acts under a public-service concession contract with the UCID.[^6-3] Reported by a national news agency in August 2025: a ten-year concession signed on 21 May 2025 with a revenue split of 56% to the State and 44% to the concession holder; the concession text is not public. The decree-law was issued under the executive's own legislative competence, as the gazette records.[^6-4] Two features bear on assessment rather than marketing. The responsible ministers may alter the Anexo I fees and minimum amounts by joint order, subject to the protections at §6.4. And Article 12 of the Nationality Law has naturalisation granted by Government decree on the justice minister's favourable opinion, while Article 14(3) of the RNID has the UCID Director approving by despacho; neither text spells out the articulation, which is a question for applicant-specific São Toméan legal advice on which no reading should be asserted.[^6-2][^6-3] ## 6.3 Main applicant and family eligibility The dependant class in the gazetted texts is narrower than the class published administratively, and the divergence is material. Article 3(d) of the decree defines dependants circularly, as household members who under the law may be included in the application; the operative provision, Article 10(1)(b), admits "spouse and/or children of the principal applicant, under Article 10(4) and (5) of the Nationality Law".[^6-3] Those provisions admit minor children at the naturalisation act, the child being able to request it in his own right up to one year after majority; the spouse acquires under Article 6(1), which requires cumulatively a marriage of more than five years **and** that the marriage be under the regime of community of acquired property (*comunhão de bens adquiridos*), or under Article 6(2) a de facto union of more than three years recognised by the Civil Court.[^6-2] The property-regime condition is on the face of the statute and has no counterpart in the programme's published spouse category; how it is applied to a foreign marriage contracted under a different matrimonial regime is not addressed in either instrument and requires São Toméan advice before a spouse is priced into an application. Separation of property is the ordinary matrimonial regime in a material share of the families this report addresses, and a couple married under it does not meet the Article 6(1) limb on the face of the text. The official programme channel publishes four categories in broader terms: spouse by monogamous marriage or de facto partnership, children up to 30 years of age, and parents and grandparents aged 55 and above.[^6-5] The divergence takes two forms, and both matter to a family relying on the published version. - Neither gazetted instrument provides for children between 18 and 30, for parents, or for grandparents. The only visible statutory hook is Article 4(8) of the decree, under which the responsible ministers approve the UCID's internal procedures, and no such instrument has been located in the gazette.[^6-3][^6-2] - Neither gazetted instrument contains a decree-level de facto partner class. An unmarried partner can be admitted only through Article 6(2) of the Nationality Law, on a de facto union of more than three years recognised by the Civil Court — conditions the published category does not state; Article 6(2), unlike Article 6(1), carries no matrimonial-property-regime condition.[^6-2] The divergence here is not that the class is absent but that the published version omits the statutory conditions attaching to it, on both limbs: the published category states neither the five-year duration and the community-of-acquired-property regime required of a married spouse, nor the three-year recognised union required of a partner. A family application depending on any of those categories, on the terms as published, rests on administrative practice rather than published law, and Kestrel Private's position is that such compositions must not be priced or presented as statutory. Two further restrictions apply, neither of which appears in general programme marketing. - **The three-nationality cap.** Under Article 11(1) of the Nationality Law, nationality may not be granted to a person already holding more than two foreign nationalities; under Article 11(2), a naturalised citizen who later acquires a fourth nationality immediately loses São Toméan nationality.[^6-2] By memorandum of 10 April 2026 the UCID director placed on hold the acceptance of new applications from individuals holding three or more foreign nationalities, invoking that cap; the memorandum is not public, the statutory cap is verified.[^6-6] - **The April 2026 adult-dependant passport freeze.** By the same memorandum, passport issuance for adult dependent children aged 18 and over was placed on hold pending a revised dependency framework, the UCID being quoted that the revised law "is already underway".[^6-6][^6-7] This is a reported item: the memorandum is not public, no official announcement has been located, and no evidence has been found that the hold has been lifted as at 2 August 2026. Its status requires confirmation at the date of application. The freeze and the divergence are connected: adult dependent children were processed under a published category for which the gazetted texts provide no basis, and passport issuance to that cohort stopped. Families whose case turns on adult children, dependent parents or an unmarried partner must be advised on that footing before engagement (see §11.5 and §11.6). Two statutory disqualifiers complete the picture. Article 11(4) of the Nationality Law refuses nationality where the criminal record shows a conviction carrying a prison sentence of more than one year.[^6-2] Article 17 of the decree permits the Government, by gazetted Council of Ministers resolution, to exclude applicants of designated nationalities — those under sanctions ratified by São Tomé and Príncipe, or from states without effective judicial cooperation; no such resolution had been located as at 2 August 2026, which is a search result and not an assurance.[^6-3] ## 6.4 Published contribution and processing costs The gazetted minimum contributions and the processing fee are set out in Anexo I to the decree. | Anexo I item | Published amount | | --- | ---: | | Minimum contribution — single applicant | US$90,000 | | Minimum contribution — family application of two to four members | US$95,000 | | Each additional qualified dependant | US$5,000 | | Due-diligence and processing fee, per application | US$5,000 | | Post-approval addition — spouse of a citizen | US$10,000 | | Post-approval addition — other qualifying dependant | US$5,000 | | Post-approval addition — newborn child up to one year | US$500 | Anexo I to Decreto-Lei n.º 07/2025, as gazetted 1 August 2025; amounts as published, in US dollars, exclusive of document, legal, professional and translation costs. Anexo I also sets an annual licence fee of US$5,000 for marketing agents, which is not a client charge. The processing fee is per application, not per applicant, and is non-refundable after submission.[^6-3] The three post-approval amounts are not the whole charge for a post-approval addition. The chapeau to Anexo I item 4 requires them to be paid "in addition to the due-diligence and processing fees provided for in Anexo I" — that is, in addition to the US$5,000 per-application fee of item 2 — and the US$750 document charge applies per applicant. Stated on the report's convention as three separate lines and a total: a spouse added after approval in principle is US$10,000 + US$5,000 + US$750 = **US$15,750**; another qualifying dependant US$5,000 + US$5,000 + US$750 = **US$10,750**; a newborn child up to one year US$500 + US$750 = **US$1,250**, the programme's official channel publishing the same US$5,000 charge as a "Submission Fee (except newborns)". The gazette contains no newborn exemption, so on the gazetted text read literally a newborn addition is US$6,250; which governs requires confirmation at the date of application.[^6-3][^6-8][^6-41] Item 4 is headed "after approval in principle", while the rows beneath describe the sponsor as a citizen, and Article 14 places approval, the 90-day deposit, the oath and registration at four different moments; which of them triggers the item 4 pricing — and therefore whether a family member costs family-tier inclusion or US$15,750 later — is not resolved on the face of the decree and requires São Toméan advice.[^6-3] The contribution is payable only after approval: delivery of the approval certificate is conditional on deposit within 90 days, failing which the process lapses.[^6-3] Document charges are not in the gazette: Anexo I contains no passport, identity-card or certificate fee, a negative finding against the full text.[^6-3] The official programme channel has published an aggregate charge of US$750 per applicant for citizenship documents comprising the certificate of registration, passport and national identity card.[^6-8] That aggregate is the only official figure this report adopts; it is official-site content rather than gazetted law and requires confirmation at the date of application. Itemised splits of it circulate in commercial sources and are not used here, and the separate dobra-denominated domestic passport schedule published by the Serviço de Migração e Fronteiras is not the programme charge.[^6-9] On those figures the identifiable government-side cost of a single applicant is US$90,000 plus US$5,000 plus US$750, or US$95,750; a family application of four within the statutory dependant class is US$95,000 plus US$5,000 plus US$3,000, or US$103,000. Both exclude legal, professional, translation, apostille, courier and agent costs and any Kestrel Private engagement, apply no currency conversion, and rely on the US$750 aggregate that requires confirmation at the date of application. Family compositions and the full cost model are built in Chapter 11 and at §10.2 and §10.3. The fee-change power requires precise reading. Article 22(1) permits the responsible ministers, by joint order, to alter the Anexo I fees and minimum amounts, but "without prejudice to commitments assumed by the State in specific instruments"; Article 22(2) provides that an update "does not affect processes already admitted".[^6-3] Article 22(2) is expressed to protect an already-admitted process against an Anexo I increase made by joint order after admission. It does not do four things: - Its trigger is defined, but the identity of the two terms is not confirmed. Article 10(6) provides that the UCID admits an application only when all forms are complete and accompanied by the required documents and fees, which on its face places admission at completed filing with the Anexo I fees paid rather than at approval — before, not after, the UCID's preliminary appreciation within 15 days, the Public Prosecutor's prior consideration, the Director's decision, deposit and the oath.[^6-3] Article 22(2) protects "processes already admitted". Whether the two provisions use "admitted" in the same sense is not stated, and a client should not be told the shield has attached without São Toméan advice on that point. - It does not protect against refusal, against a refused prior consideration, or against lapse where the contribution is not deposited within 90 days. - It does not reach beyond Anexo I: it fixes no legal, professional, translation, document or agent cost, and does not bind amendment of the Nationality Law or replacement of the decree. - Its edges cannot be assessed, because Article 22(1) subordinates the power to commitments in instruments that are not public. Fee and threshold increases are treated as a risk in their own right at §14.2. ## 6.5 Application and due-diligence process Applications are submitted electronically through the UCID platform on an official form in Portuguese or English, with full payment of the Anexo I fees, a medical certificate, a criminal-record certificate issued within the preceding three months, certified translations, and a declaration of support for each dependant other than the spouse.[^6-3] Foreign documents must be legalised by Hague Apostille or, in its absence, authenticated by the competent consular authority; São Tomé and Príncipe acceded to the Apostille Convention on 19 December 2007, with entry into force on 13 September 2008.[^6-3][^6-10] Due diligence is performed by independent qualified external entities engaged by the UCID, and interviews may be required in person or by video. A consultative Review Committee chaired by a representative of the Public Prosecutor, with members from the Migration and Frontiers Service, Finance, the Registries and the Financial Intelligence Unit, verifies AML/CFT compliance and may trigger precautionary suspension of a file; the UCID makes a preliminary appreciation of each application within 15 days.[^6-3] The programme channel publishes that applications must be initiated through licensed marketing agents.[^6-11] The gazetted texts license and sanction agents (Article 6) but do not state that requirement, and this report does not treat it as established law; it requires confirmation at the date of application.[^6-3] The same channel publishes indicative timelines of approximately 1.5 to three months to decision — its homepage states 1.5 to two months and its FAQ approximately two to three months — and, as at 4 August 2026, states that issuance of the passport after approval "currently takes about 4 months".[^6-11][^6-41] Those are statements of that channel, not audited figures; the channel's own qualifier "currently" indicates the figure is unstable, and no processing time is guaranteed. After deposit, the applicant swears an oath of fidelity before a public official in São Tomé and Príncipe or, where abroad, before the competent diplomatic or consular agent; the decree imposes no travel, visit or residence requirement.[^6-3] It is separately reported that, from 9 April 2026, national identity-card issuance may be completed remotely by video verification with the Civil Registry and Notary Office; that requires confirmation at the date of application.[^6-6] ## 6.6 Source-of-funds requirements Source-of-funds preparation is the part of the process most likely to determine the outcome, and it is treated as a discipline in its own right in Chapter 15 (see §15.1). Within this component, Anexo III sets the mandatory schedule: certified passport copies, criminal-record certificates from the countries of nationality and of residence over the last five years, proof of residence, a declaration of the lawful origin of funds with supporting bank documentation, proof of payment of the base fee, and a due-diligence report issued by a UCID-recognised entity rather than by the applicant's own advisers.[^6-3] The statutory disqualifiers of Articles 10(1) and 11(4) of the Nationality Law operate independently of the quality of the file.[^6-2] The evidential burden is therefore assembled before submission, not in response to queries after it. Where source of wealth cannot be explained and evidenced, or the specific investment funds cannot be traced, the application is not one Kestrel Private takes forward. ## 6.7 Approval, refusal and review The completed file must be submitted to the Ministério Público for a prior visto, which the Nationality Law requires to be given within 30 days; if the visto is refused, the process lapses.[^6-3][^6-2] Following the visto, or the Public Prosecutor's silence, the UCID Director decides within 15 days by reasoned decision.[^6-3] The Public Prosecutor's prior consideration is a substantive stage, not a formality; a refusal terminates the process by operation of the decree. The refund position must be assembled strictly from the text, because the decree contains no general refund clause. The contribution is non-refundable but payable only after approval; the US$5,000 processing fee is non-refundable after submission; and no express refund provision exists for any other scenario, including lapse after deposit or a successful judicial opposition after acquisition.[^6-3] Nothing should be represented to a client about recovery of sums paid beyond what those provisions state. The articulation between the Nationality Law's grant by Government decree and the decree-law's approval by despacho (§6.2), and the avenues of review against a refusal, require applicant-specific São Toméan legal advice; no reading of either is asserted here. ## 6.8 Revocation and post-naturalisation risk The exposure does not end at the grant, and this is the part of the chapter that most requires an applicant-specific legal explanation before engagement rather than a summary. The Public Prosecutor may institute judicial opposition before the administrative court within six months counted from the declaration of the acquisition of nationality, and the opposition has no suspensive effect on the acquisition.[^6-3][^6-2] A client granted citizenship and issued a passport therefore remains within a statutory window during which the acquisition may be challenged by the State's own prosecuting authority. The decree's administrative sanctions are a warning; a fine of up to 20% of the total investment; suspension or cancellation of a licence; revocation of nationality; and rescission of contract, with a prior hearing always guaranteed.[^6-3] The Nationality Law separately provides defined loss grounds for naturalised citizens — acts against state security, repeated acts against public health, or acquisition by fraud — decreed after a final court conviction and with no possibility of reacquisition; the fourth-nationality rule of Article 11(2) operates automatically and independently of all of them.[^6-2] These provisions interact with the dependant divergence at §6.3: where a family application includes categories published administratively but with no visible basis in the gazetted texts, or an unmarried partner admitted otherwise than on Article 6 terms, the six-month window and the revocation sanction make the legal-certainty exposure live rather than theoretical. Revocation and post-approval risk are carried into the risk register at §14.15. ## 6.9 Passport and travel-access limitations Nationals of São Tomé and Príncipe are listed in Annex I of Regulation (EU) 2018/1806 and absent from Annex II; they require a visa to cross the external borders of the Schengen member states.[^6-1] The citizenship component is therefore never the source of European mobility and must not be presented as improving Schengen access; within the reference structure that function belongs to the Greek residence permit alone (see §7.10). Beyond the Schengen states, the report uses only the formulation supported by destination-government sources: travelling solely on the São Toméan passport, the holder has visa-free or equivalent access to a limited number of states — verified examples are South Africa (90 days on ordinary passports, schedule issued 9 December 2025), Singapore and Hong Kong (14 days) — while the Schengen states, the United Kingdom and the United States all require visas.[^6-12][^6-13][^6-14] São Tomé and Príncipe is item 85 in the United Kingdom's visa national list at Appendix Visitor, VN 1.1(a), version updated 30 July 2026, and is not a designated United States Visa Waiver Program country.[^6-15][^6-16] Brazil's own official table codes ordinary São Toméan passports as visa-required as at its date of 30 September 2022, the most recent officially published table located; any later change requires confirmation at the date of application.[^6-17] No official list of the passport's total travel access is published, and aggregate counts circulated commercially cannot be verified and are not used here. Two document facts complete the picture. Passports are issued by the Serviço de Migração e Fronteiras, which states that it has begun issuing a passport that is electronic and confers greater security, and publishes the country signing certificate authority artefacts of an electronic-passport public-key infrastructure; whether every booklet issued to programme citizens is that booklet, and participation in the ICAO Public Key Directory, could not be verified.[^6-9] No official source states the validity period; industry sources conflict, no figure is printed here, and validity requires confirmation at the date of application. ### The CPLP Mobility Agreement One multilateral instrument attaches structured legal consequences to São Toméan nationality abroad, and both what it provides and what it does not provide belong in this section. The Acordo sobre a Mobilidade entre os Estados-Membros da CPLP was signed at Luanda on 17 July 2021 and has been in force for São Tomé and Príncipe and for Portugal since 1 January 2022.[^6-42][^6-43] Portugal implemented it by Lei n.º 18/2022 de 25 de agosto, which inserted Articles 52.º-A and 87.º-A into Lei n.º 23/2007 de 4 de julho and gave a CPLP residence permit a named place in Portuguese immigration law.[^6-44] Article 87.º-A refers to "os cidadãos nacionais de Estados abrangidos pelo Acordo CPLP" — nationals of states covered by the CPLP Agreement — which is a condition expressed about the state, not about the manner in which an individual acquired that state's nationality.[^6-45] None of this is travel access, and none of it qualifies the position stated above. The Agreement's mandatory floor exempts from visa requirements only the holders of diplomatic, official, special and service passports, for stays of up to 90 days; an ordinary passport, which is what a naturalised citizen holds, obtains nothing automatically under it.[^6-42] Portugal has declared that it applies the temporary-stay, residence-visa and residence-permit modalities and expressly does not apply the short-stay modality, being bound by the European Union's common legislation on short-stay Schengen visas.[^6-43] The Schengen visa requirement set out at the opening of this section is untouched by the Agreement, and the citizenship component remains what §6.1 and §6.9 state it to be: not a source of European mobility. What the Agreement provides between any two Parties is a separate question from what its text provides in the abstract, and on that question this report reaches a limit. Article 38(1) makes the application of each modality depend in every case on consent expressed through diplomatic channels, and Article 38(2) requires each Party to notify the depositary — the CPLP Executive Secretariat — which modalities, which categories of person and which further terms it accepts, and which Party or Parties it binds itself to in the partnership.[^6-42] No Article 38(2) notification could be obtained for any Party, including Portugal: no publicly accessible notification has been located confirming the modalities and categories accepted specifically between Portugal and São Tomé and Príncipe, and Portugal's public declaration names the modalities it applies but not the Parties it has bound itself to.[^6-43] The Agreement's provision for registration with the United Nations does not make those bilateral notifications publicly accessible, so the absence of a public record is evidence in neither direction.[^6-42] Confirmation has been requested from the CPLP Executive Secretariat in its capacity as depositary. **Whether Portugal has named São Tomé and Príncipe is unestablished, and the route cannot be relied upon until it is confirmed in writing with the Portuguese authorities or the CPLP Executive Secretariat.** Subject to that confirmation, the instruments provide as follows. Article 25 of the Agreement gives the holder of a CPLP residence permit the same rights, freedoms and guarantees as nationals of the host Party, and equality of treatment in economic, social and cultural rights, save for the rights that the host Party's internal law reserves to its own citizens; the permit has an initial duration of one year and is renewable for successive two-year periods.[^6-42] Since Lei n.º 61/2025 de 22 de outubro an applicant must already hold a residence visa in order to apply in Portuguese territory, and AIMA states that grant of the permit "pressupõe, no momento atual, a obtenção prévia de um visto consular obtido expressamente para esse efeito" — presupposes, at the present time, the prior obtaining of a consular visa expressly for that purpose.[^6-45][^6-46] Those are the rights of a permit holder. They confer nothing on a São Toméan national who has not obtained and does not hold such a permit. Two qualifications complete the account. No origin condition, no minimum period since naturalisation and no anti-abuse rule directed at investment-acquired citizenship was found in the instruments read for this report — the Agreement in full, Lei n.º 18/2022 including its republication of Lei n.º 23/2007, Lei n.º 61/2025 and the AIMA guidance — which is a search result across those texts and not an assurance; Portuguese consular practice is unpublished and was not examined.[^6-42][^6-44][^6-45][^6-46] The Agreement itself permits a Party to draw exactly that distinction: Article 19(3), read with Article 7(2), allows ordinary-passport holders to be subdivided into groups by reference to the activities they carry on, the situation they are in, or any other relevant criterion, so the absence of such a condition is a policy position rather than a protected one.[^6-42] The CPLP route forms no part of the reference structure and is not assessed here as an alternative to the residence component; it is set out so that the claim, which a client will encounter, can be measured against the instruments. ## 6.10 Intergenerational and succession considerations The formulation used in Chapter 1 — potential intergenerational status, subject to nationality law — is precise, and the mechanics sit in the Nationality Law rather than the decree. A child born abroad after the parent's naturalisation falls within Article 5(c): children of a São Toméan father or mother, born abroad, "who declare that they wish to be São Toméan" are São Toméans of origin.[^6-2] Attribution takes effect from birth under Article 2, but the operative condition is a declaration: transmission is by declaration and registration, not automatic. Every attribution is transcribed against the birth record at the Conservatória dos Registos Centrais under Article 21, and declarations may be made before consular agents under Article 22(1) — only naturalisation is excluded from that route, by Article 22(3).[^6-2] Three conditions attach. Only filiation established during the child's minority produces nationality effects (Article 4). The naturalised parent must still hold São Toméan nationality at the child's birth, which brings the fourth-nationality rule of Article 11(2) back into view. And while Article 5(c) draws no distinction on its face between parents who are nationals of origin and parents who are naturalised, no São Toméan court or registry authority interpreting it for programme-naturalised parents has been located; the programme is one year old and no published practice can yet exist.[^6-2] Grandchildren of a São Toméan national born abroad appear in Article 5(d), which contains no express declaration condition; that limb is drafted more loosely and its registry treatment is untested. Children alive at the date of application do not use these provisions: they participate as included dependants under §6.3, or, as minors, by declaration under Article 7 — the route by which minor children of a person who acquires nationality may themselves acquire it.[^6-2] Succession planning should not be built on this component without São Toméan advice. São Toméan succession law was not verified for this report and the Portuguese legítima tradition may import its own forced-heirship rules, which must be established locally before any conclusion is drawn about the client's wider estate planning (see §13.3). ## 6.11 Banking and institutional acceptance A second passport changes what a client can present. It does not change what a bank is required to establish, and it conceals nothing. The passport does not displace the client's existing nationality, birthplace, tax residence or beneficial-ownership position in a bank's records; what the São Toméan booklet's data page itself records requires confirmation at the date of application. Financial institutions apply customer due diligence to the whole profile, not to the strongest document presented, and account opening cannot be guaranteed (see §9.5). Where the component is presented as a way of changing how a client appears to a financial institution, it has been mis-sold. The country's list status as at 2 August 2026 is stated here as status, not endorsement. - It is not on the FATF list of jurisdictions under increased monitoring of 19 June 2026, which comprises 22 jurisdictions, nor on the FATF call-for-action list of the same date (countermeasures: the Democratic People's Republic of Korea and Iran; enhanced due diligence: Myanmar).[^6-18][^6-19] - It appears nowhere in the Annex to Commission Delegated Regulation (EU) 2016/1675, the EU high-risk third-country list, in the consolidated version of 29 January 2026.[^6-20] - It is on neither Annex I nor Annex II of the EU list of non-cooperative jurisdictions for tax purposes in the revision of 17 February 2026, and does not appear within the screening scope; the next revision is due in October 2026.[^6-21] - It appears nowhere in the OECD Global Forum's status-of-commitments list for the automatic exchange of financial account information of 27 July 2026, and has made no CRS commitment.[^6-22] The last of those is frequently presented in the market as an advantage. It is not one, and is not offered as one here: non-participation in CRS reduces neither the client's reporting obligations in the client's own jurisdictions of tax residence and nationality nor the disclosure a bank will require. FATF and the OECD have identified real risks in citizenship- and residence-by-investment arrangements while acknowledging that many applicants have legitimate wealth and objectives; both propositions are carried in this report. ## 6.12 Programme maturity and operating-history risk The programme has existed in law for approximately one year at the date of this report. It does not have the long public operating history of older citizenship programmes, and assessment must extend beyond the published price to the matters Chapter 1 lists — operational status at the date of application, the authority and standing of the appointed application channel, current processing and issuance experience, due-diligence standards, government and institutional capacity, passport issuance procedures (§17.15), grounds for refusal, refund provisions, post-approval legal risk, and international acceptance and banking treatment (§6.11). The available activity data are programme-supplied and reported rather than audited. Industry reporting of 20 January 2026 records 98 applications from 27 nationalities between September 2025 and mid-January 2026, 27 approvals with no refusals among processed files, average processing of 2.5 months, and the first programme passport issued in January 2026.[^6-23] The programme channel separately claims more than 220 applications submitted and 50 or more licensed marketing agents.[^6-11] An approvals record with no refusals among a small number of files is not evidence of due-diligence rigour in either direction. The decree's quarterly reporting obligation to the justice minister, the Public Prosecutor and the National Assembly is a transparency mechanism whose output has not been located in public.[^6-3] The country context bears on continuity rather than legality. An attempted coup was suppressed in November 2022, and in January 2025 the President dismissed the Prime Minister by decree.[^6-24][^6-25] The presidential election was held on 19 July 2026 and President Vila Nova was re-elected in the first round with 55.94% on preliminary results; parliamentary elections remain scheduled for 27 September 2026, and the principal opposition party is on record as wanting the nationality law revised.[^6-26][^6-27] Programme continuity is a live political question and cannot be assumed. External risk should be attributed correctly. The European Commission has recorded that it is closely scrutinising investor citizenship schemes of third countries capable of being used to circumvent the EU short-stay visa procedure, and the revised visa-suspension mechanism now provides an express ground of that kind.[^6-28][^6-29] The executed precedent is Vanuatu: the EU visa waiver was partially suspended from 4 May 2022, fully suspended for all Vanuatu nationals from 4 February 2023, and Vanuatu was permanently transferred to Annex I by Regulation (EU) 2025/11 — visa-free to visa-required in three steps, on citizenship-by-investment grounds.[^6-30][^6-31][^6-32] That mechanism cannot be applied to São Tomé and Príncipe, which is already in Annex I and has no visa exemption to suspend.[^6-1] No EU institution statement, visa-policy measure or suspension move concerning this programme had been located as at 2 August 2026, which is a dated search result and not an assurance.[^6-33] The Vanuatu precedent matters to the reference structure for a different reason: the analogous failure mode attaches to the continuity of the Greek permit, not to the São Tomé passport (see §14.1). The programme's stated statutory purpose is a matter of record, and is set out here as such rather than adopted. Contributions are directed to a single destination, the National Transformation Fund, which the decree gives administrative and financial autonomy, a dedicated bank account, a mandatory annual independent audit and oversight by the Court of Auditors and the Central Bank, and to which contributions revert integrally (see §6.2).[^6-3] The purposes a mechanism of that design is intended to serve in a small state are fiscal rather than document-issuing: non-debt public revenue, diversification of a narrow revenue base, and funding for public investment. That is the purpose the instrument's architecture expresses. It is not a statement of what the programme has delivered, and it is not offered as one. Revenue is not evidence of development, and this report applies to that proposition the scepticism it applies to every other. Whether such a mechanism produces public benefit turns on matters the drafting of an instrument cannot settle: identity, sanctions, politically-exposed-person and source-of-funds screening applied rigorously rather than nominally; refusal and revocation powers genuinely exercised; proceeds integrated into the national budget rather than held beside it; transparent procurement of whatever they fund; independent audit performed and its findings acted upon; parliamentary reporting; published programme statistics; project-level outcomes visible to citizens; and the integrity of São Toméan nationality protected throughout. None of those is established by the decree that provides for them. What this report can verify is narrow. As at 2 August 2026 no outcome data has been published: the quarterly reporting obligation described above has produced nothing located in public, the activity figures are programme-supplied rather than audited, and the destination of proceeds is itself qualified, Article 13(1) providing that net proceeds revert "in the defined percentages" — a split defined outside the decree whose terms are not public (see §6.2).[^6-3] The programme is approximately one year old, and no assessment of delivered benefit is available to be made. This report makes none. The programme can create meaningful value for São Tomé and Príncipe only where carefully screened contributions are transparently converted into visible national benefit without compromising the integrity of São Toméan nationality, national security or international trust. ## 6.13 Who benefits from this citizenship The component may be worth having where the objective is nationality diversification rather than travel, and where the client's own nationality law permits the acquisition. That describes, in particular: - Clients holding a single nationality on the Schengen visa-required list who want a second sovereign and consular relationship as contingency, and who accept that neither passport removes the Schengen visa requirement. South African clients are the clearest case in Kestrel Private's primary market: since the Constitutional Court's judgment of 6 May 2025, which declared section 6(1)(a) of the South African Citizenship Act 88 of 1995 invalid from its promulgation, a South African citizen may acquire a second citizenship without losing South African citizenship and without prior ministerial permission.[^6-34] South Africa is itself in Annex I, so the mobility gain is negligible; the case rests on contingency and diversification (see §13.2). - Clients whose objective is intergenerational optionality, on the declaration-based terms at §6.10, and who understand that no registry practice yet exists. - Clients holding two nationalities or fewer, unaffected by the three-nationality cap and the April 2026 hold, and whose family composition falls inside the statutory dependant class. In each case the component is worth having only if the client can carry the risks in §6.8 and §6.12, and only where the total cost is proportionate to the objective (see §13.11). ## 6.14 Who may obtain little practical value For a substantial group of clients the component fails Kestrel Private's own assessment, and the decline criterion set out in Chapter 1 — that a second nationality would not provide a meaningful benefit — is applied without softening. The criteria are these. - **Indian nationals cannot take this component at all.** Under section 9(1) of the Citizenship Act 1955, an Indian citizen who by naturalisation, registration or otherwise voluntarily acquires the citizenship of another country ceases upon such acquisition to be a citizen of India.[^6-35] The Indian passport must be surrendered immediately, and misuse is an offence under section 12(1A) of the Passports Act 1967.[^6-36] Overseas Citizen of India status is a lifelong visa and residence status, not citizenship, excluding public employment, electoral rights and constitutional offices.[^6-37] The residence component remains open to Indian clients; this one does not. - **Mainland Chinese nationals are in a different but equally restrictive position.** Article 3 of the PRC Nationality Law provides that the People's Republic of China does not recognise dual nationality for any Chinese national, and Article 9 that a Chinese national settled abroad who is naturalised as a foreign national or acquires foreign nationality of his own free will automatically loses Chinese nationality.[^6-38] Article 9's automatic-loss trigger is drafted to require both settlement abroad and voluntary acquisition, so the position of a mainland-resident national is not settled by the text alone and requires PRC advice. Kestrel Private therefore treats mainland Chinese nationals as generally unsuitable for this component absent specific facts (see §13.2). - **United Kingdom and United States nationals may hold it, but gain little.** UK law permits dual citizenship without application or permission, and a US citizen who naturalises abroad does not automatically lose US citizenship, intent to retain being presumed.[^6-39][^6-40] Both are already visa-exempt for the Schengen Area, so the mobility gain is nil, and a US client adds reporting surface rather than removing any. The value case is contingency, diversification and intergenerational optionality, or it is nothing. - **Kestrel Private declines the component where the objective is a stronger travel passport alone**: on the verified position at §6.9, the passport does not improve access to Europe, the United Kingdom or the United States. - **Where a family's composition depends on adult children or dependent parents, the component is deferred** pending confirmation of the published categories, which rest on administrative practice; passport issuance to adult dependent children was reportedly on hold as at the last located information (see §6.3 and §11.5). The same treatment applies to a spouse whose marriage does not meet both limbs of Article 6(1) — more than five years and the regime of community of acquired property (*comunhão de bens adquiridos*) — and to an unmarried partner who cannot evidence a de facto union of more than three years recognised by the Civil Court, the only basis on which the published de facto partnership category has statutory support (see §6.3). - **Clients holding three or more foreign nationalities** fall outside the statutory limit of two foreign nationalities and are therefore ineligible; on the reported April 2026 position they are also outside acceptance (see §6.3). - **Kestrel Private does not proceed where source of wealth cannot be evidenced and the investment funds cannot be traced**, here or in the structure as a whole (see §15.1 and §13.14). The component is assessed on its own legal terms; where it fails that assessment, the residence component is not a consolation prize for it, and neither is a substitute for the other (see §5.7). ### Notes [^6-1]: Regulation (EU) 2018/1806 of the European Parliament and of the Council listing the third countries whose nationals must be in possession of visas when crossing the external borders and those whose nationals are exempt from that requirement, Annex I (São Tomé and Príncipe listed; absent from Annex II), consolidated version of 30 December 2025; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^6-2]: São Tomé and Príncipe, Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República, I Série, N.º 25, 10 March 2022, Articles 2, 4, 5, 6, 7, 10, 11, 12, 15, 16, 19–22, 26 (original Portuguese; gazette facsimile read in full); https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^6-3]: São Tomé and Príncipe, Decreto-Lei n.º 07/2025 (Regulamentação da Nacionalidade por Investimento ou Doação), Diário da República, I Série, N.º 33, 1 August 2025, pp. 429–440, Articles 3, 4, 6–14, 16–18, 21, 22 and Anexos I and III (original Portuguese; gazette facsimile read in full); https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^6-4]: Lusa, "São Tomé permite obtenção de nacionalidade com investimento ou doação a partir de 90 mil dólares", 15 August 2025 (reporting the ten-year concession contract of 21 May 2025 and the 56/44 revenue split; the concession text is not public); https://www.rtp.pt/noticias/mundo/sao-tome-permite-obtencao-de-nacionalidade-com-investimento-ou-doacao-a-partir-de-90-mil-dolares_n1676574 (accessed 2 August 2026). [^6-5]: São Tomé and Príncipe Citizenship by Investment Unit, "Become a Citizen" (published dependant categories), archived capture of 17 July 2026; https://web.archive.org/web/20260717032201/https://cip.gov.st/become-a-citizen (accessed 2 August 2026). [^6-6]: IMI Daily, "São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule", 11 April 2026 (reporting the UCID director's memorandum of 10 April 2026: three-or-more-nationality hold; adult-dependant passport hold; remote identity-card issuance from 9 April 2026; the memorandum is not public); https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/ (accessed 2 August 2026). [^6-7]: NTL International, "São Tomé and Príncipe CBI 2026 legislative updates", 14 April 2026 (corroborating the adult-dependant passport hold); https://ntlinternational.com/press/sao-tome-and-principe-cbi-2026-legislative-updates (accessed 2 August 2026). [^6-8]: São Tomé and Príncipe Citizenship by Investment Unit, "Financial Layout" (aggregate charge of US$750 per applicant for certificate of registration, passport and national identity card), official programme site on the government domain, https://cip.gov.st/donation-to-the-national-transformation-fund (accessed 4 August 2026). [^6-9]: São Tomé and Príncipe, Serviço de Migração e Fronteiras — official site: home page (electronic passport), ePassport CSCA public-key certificates page, and passport fee schedule, read live 2 August 2026; https://www.smf.st/ ; https://www.smf.st/epassport/index.html ; https://www.smf.st/taxas.php (accessed 2 August 2026). [^6-10]: Hague Conference on Private International Law, Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents, status table, São Tomé and Príncipe entry (accession 19 December 2007; entry into force 13 September 2008); https://www.hcch.net/en/instruments/conventions/status-table/?cid=41 (accessed 2 August 2026). [^6-11]: São Tomé and Príncipe Citizenship by Investment Unit, cip.gov.st home page (licensed marketing agents as the stated application channel; indicative processing times; nationalities served; applications-submitted milestone), archived capture of 10 July 2026; https://web.archive.org/web/20260710224801/https://cip.gov.st/ (accessed 2 August 2026). [^6-12]: South Africa, Department of Home Affairs, schedule of visa-exempt countries (São Tomé and Príncipe, ordinary passports, 90 days, no fee), issued 9 December 2025; http://www.dha.gov.za/index.php/immigration-services/exempt-countries (accessed 2 August 2026). [^6-13]: Singapore, Immigration & Checkpoints Authority, visa requirements (São Tomé and Príncipe absent from the visa-required assessment-level lists); https://www.ica.gov.sg/enter-transit-depart/entering-singapore/visa_requirements (accessed 2 August 2026). [^6-14]: Hong Kong Special Administrative Region, Immigration Department, visit visa / entry permit requirements ("Sao Tome and Principe — 14 Days"); https://www.immd.gov.hk/eng/services/visas/visit-transit/visit-visa-entry-permit.html (accessed 2 August 2026). [^6-15]: United Kingdom, Immigration Rules, Appendix Visitor: Visa national list, VN 1.1(a), item 85 (São Tomé and Príncipe), version updated 30 July 2026; https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-visitor-visa-national-list (accessed 2 August 2026). [^6-16]: United States Department of State, Visa Waiver Program designated-country list (São Tomé and Príncipe absent), archived capture of 6 July 2026; https://web.archive.org/web/20260706071940/https://travel.state.gov/content/travel/en/us-visas/tourism-visit/visa-waiver-program.html (accessed 2 August 2026). [^6-17]: Brazil, Ministério das Relações Exteriores, Quadro Geral de Regime de Vistos, São Tomé e Príncipe row (ordinary passports: "Visto exigido"), table dated 30 September 2022 (most recent officially published table located; later change requires confirmation); https://web.archive.org/web/20250508180030/https://www.gov.br/mre/pt-br/assuntos/portal-consular/arquivos/arquivos-qgrv/qgrv-simples-port-30set22.pdf (accessed 2 August 2026). [^6-18]: Financial Action Task Force, "Jurisdictions under Increased Monitoring — 19 June 2026" (22 jurisdictions; São Tomé and Príncipe absent), archived copy of the official statement page; https://web.archive.org/web/20260727100641/https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html (accessed 2 August 2026). [^6-19]: Financial Action Task Force, "High-Risk Jurisdictions subject to a Call for Action — 19 June 2026" (countermeasures: Democratic People's Republic of Korea, Iran; enhanced due diligence: Myanmar; São Tomé and Príncipe absent), archived copy of the official statement page; https://web.archive.org/web/20260801093014/https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html (accessed 2 August 2026). [^6-20]: Commission Delegated Regulation (EU) 2016/1675 supplementing Directive (EU) 2015/849 by identifying high-risk third countries with strategic deficiencies, Annex, consolidated version of 29 January 2026 (São Tomé and Príncipe absent); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02016R1675-20260129 (accessed 2 August 2026). [^6-21]: Council of the European Union, EU list of non-cooperative jurisdictions for tax purposes, Annex I as revised 17 February 2026 (São Tomé and Príncipe absent from Annexes I and II and from the screening scope; next revision due October 2026), archived copy of the official Council page; https://web.archive.org/web/20260728182757/https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/ (accessed 2 August 2026). [^6-22]: OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, "Status of commitments for the automatic exchange of financial account information (AEOI)", update of 27 July 2026 (São Tomé and Príncipe absent from all categories); https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/aeoi-commitments.pdf (accessed 2 August 2026). [^6-23]: IMI Daily, "São Tomé Citizenship Program Garners 98 Applications in First 4.5 Months", 20 January 2026 (programme-supplied statistics; sponsored feature); https://www.imidaily.com/intelligence/sao-tome-citizenship-program-garners-98-applications-in-first-4-5-months/ (accessed 2 August 2026). [^6-24]: Voice of America, report of the attempted coup in São Tomé and Príncipe of 24–25 November 2022, November 2022; https://www.voanews.com/a/sao-tome-failed-coup/6852268.html (accessed 2 August 2026). [^6-25]: Africanews, "São Tomé and Príncipe: president dismisses government by decree", 6 January 2025; https://www.africanews.com/2025/01/06/sao-tome-and-principe-president-dismisses-government-by-decree/ (accessed 2 August 2026). [^6-26]: Associated Press, report of the São Tomé and Príncipe presidential election of 19 July 2026 (Carlos Vila Nova re-elected in the first round with 55.94%, preliminary results), 20 July 2026, carried by US News, usnews.com; corroborated by Ecofin Agency, July 2026, ecofinagency.com (accessed 2 August 2026). [^6-27]: IFES ElectionGuide, São Tomé and Príncipe country entry (parliamentary elections scheduled for 27 September 2026), electionguide.org (accessed 2 August 2026). [^6-28]: European Commission, Recommendation C(2022) 2028 final, 28 March 2022, recital 6 (scrutiny of third-country investor citizenship schemes capable of circumventing the EU short-stay visa procedure); https://investmentmigration.org/wp-content/uploads/2022/07/recommendation-limit-access-individuals-connected-Russian-Belarusian-government-citizenship-residence-EU-through-investor-schemes_en.pdf (accessed 2 August 2026). [^6-29]: Regulation (EU) 2025/2441 revising the visa-suspension mechanism (inserting Article 8a(1)(e) into Regulation (EU) 2018/1806), OJ L, 10 December 2025; https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R2441 (accessed 2 August 2026). [^6-30]: Council Decision (EU) 2022/366 of 3 March 2022 on the partial suspension of the application of the EU–Vanuatu visa-waiver agreement, applicable from 4 May 2022, OJ L 69, 4 March 2022, p. 105; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D0366 (accessed 2 August 2026). [^6-31]: Council Decision (EU) 2022/2198 of 8 November 2022 on the full suspension of the application of the EU–Vanuatu visa-waiver agreement for all Vanuatu nationals from 4 February 2023, OJ L 292, 11 November 2022, p. 47; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D2198 (accessed 2 August 2026). [^6-32]: Regulation (EU) 2025/11 of 19 December 2024 transferring Vanuatu from Annex II to Annex I of Regulation (EU) 2018/1806, OJ L, 14 January 2025, in force on the twentieth day following publication; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0011 (accessed 2 August 2026). [^6-33]: European Commission, Investor Citizenship Schemes policy page, checked 2 August 2026 for any measure concerning the São Tomé and Príncipe programme (dated statement of absence); https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/democracy-eu-citizenship-anti-corruption/eu-citizenship/investor-citizenship-schemes_en (accessed 2 August 2026). [^6-34]: Constitutional Court of South Africa, *Democratic Alliance v Minister of Home Affairs and Another* [2025] ZACC 8 (CCT 184/23), judgment of 6 May 2025, confirming [2023] ZASCA 97 (section 6(1)(a) of the South African Citizenship Act 88 of 1995 declared invalid from promulgation on 6 October 1995); https://collections.concourt.org.za/handle/20.500.12144/38508 (accessed 2 August 2026). [^6-35]: India, The Citizenship Act, 1955 (as amended), section 9(1), Ministry of Home Affairs consolidated text of 10 September 2024; https://www.mha.gov.in/sites/default/files/2024-09/TheCitizenshipAct1955_10092024.pdf (accessed 2 August 2026). [^6-36]: Embassy of India, "Surrender of Indian Passport" (section 12(1A), Passports Act 1967; graduated penalties); https://eoikinshasa.gov.in/pages/MzY (accessed 2 August 2026). [^6-37]: India, Ministry of External Affairs, extracts of the Citizenship Act 1955, sections 7A–7D (Overseas Citizen of India; section 7B(2) exclusions); https://mea.gov.in/images/pdf/extracts-of-citizenship-act1955.pdf (accessed 2 August 2026). [^6-38]: People's Republic of China, Nationality Law (1980), Articles 3 and 9, official National Immigration Administration English text; https://en.nia.gov.cn/n147418/n147458/c155976/content.html (accessed 2 August 2026). [^6-39]: United Kingdom Government, "Dual citizenship"; https://www.gov.uk/dual-citizenship (accessed 2 August 2026). [^6-40]: United States Department of State, Foreign Affairs Manual, 7 FAM 080/083 (dual nationality; presumption of intent to retain US nationality); https://fam.state.gov/fam/07fam/07fam0080.html (accessed 2 August 2026). [^6-41]: São Tomé and Príncipe Citizenship by Investment Unit, official programme channel, read live 4 August 2026: home page statistics band ("1.5 - 2 Months average time to decision"; "*Post-Approval to passport currently takes about 4 months"), https://cip.gov.st/ ; and "Post-Approval Inclusion Fees" ("Submission Fee (except newborns) $5,000"; spouse $10,000; each additional dependent $5,000; newborn child up to 1 year $500), https://cip.gov.st/post-approval-inclusion-fees (both accessed 4 August 2026). [^6-42]: Acordo sobre a Mobilidade entre os Estados-Membros da CPLP, signed at Luanda 17 July 2021, Articles 4(2)(a), 6, 7(2), 19(3), 22(1), 25, 27, 37 and 38(1)–(2) (original Portuguese; authenticated text read in full, Articles 1 to 39), annexed to Resolução da Assembleia da República n.º 313/2021, Diário da República, 1.ª série, n.º 237, 9 December 2021, pp. 4–14; https://files.dre.pt/1s/2021/12/23700/0000400014.pdf (accessed 4 August 2026). [^6-43]: Embaixada de Portugal na Cidade da Praia (Ministério dos Negócios Estrangeiros), "Nota sobre a aplicação do Acordo sobre a Mobilidade na CPLP", 31 December 2021 (entry into force 1 January 2022 for Cabo Verde, São Tomé e Príncipe, Portugal and Guiné-Bissau; Portugal applies the temporary-stay, residence-visa and residence-permit provisions and does not apply the short-stay provisions, being bound by the European Union's common legislation on short-stay Schengen visas; the note states the modalities and does not identify the partner Parties); https://praia.embaixadaportugal.mne.gov.pt/pt/a-embaixada/noticias/nota-sobre-a-aplicacao-do-acordo-sobre-a-mobilidade-na-cplp ; deposit of Portugal's instrument of ratification with the CPLP Executive Secretariat on 9 December 2021, Secretariado Executivo da CPLP, https://secretariadoexecutivo.cplp.org/informacoes/noticias/noticias-detalhe/?id=15664 (both accessed 4 August 2026). [^6-44]: Portugal, Lei n.º 18/2022, de 25 de agosto, Diário da República, 1.ª série, n.º 164, Articles 1, 4 and 5 (ninth amendment to Lei n.º 23/2007, de 4 de julho, inserting Articles 52.º-A and 87.º-A; the same publication carries the official republication of Lei n.º 23/2007); https://files.diariodarepublica.pt/1s/2022/08/16400/0000200137.pdf (accessed 4 August 2026). The 2022 text has been amended since and is not quoted here as current. [^6-45]: Portugal, Lei n.º 61/2025, de 22 de outubro, Diário da República, 1.ª série, n.º 204, Articles 2 and 7 (amending Article 87.º-A of Lei n.º 23/2007 so that a CPLP national holding a residence visa may apply to AIMA, I.P. in national territory, and revoking Article 52.º-A(1)(c)); https://data.dre.pt/eli/lei/61/2025/10/22/p/dre/pt/pdf (accessed 4 August 2026). Whether the consolidated text has been further amended since 22 October 2025 was not established; the DRE consolidated database does not serve its text to automated retrieval. [^6-46]: AIMA, I.P., "Concessão de Autorização de Residência CPLP — Resposta às Questões mais Frequentes" (administrative guidance; file metadata indicates a February 2025 revision, predating Lei n.º 61/2025); https://aima.gov.pt/media/pages/documents/2fefff63bb-1740070504/concessao-ar-cplp-19.02.pdf , linked from https://aima.gov.pt/pt/a-aima/perguntas-frequentes-faqs/concessao-de-autorizacao-de-residencia-cplp (accessed 4 August 2026).