Understanding the "Transition Period" for old SEF appointments in 2026

Understanding the “Transition Period” for old SEF appointments in 2026

Maybe you booked a renewal with SEF years ago. The agency then dissolved, the appointment never happened, and your residence card has been expired so long that the photo looks like someone else. You are not alone. This guide explains what the old transition period was, how it ended, and which document now proves you are in Portugal legally.

What the Transition Period Actually Was

I remember the feeling well. You have a printed SEF confirmation in a folder, a card with a date long gone, and a vague memory of a news headline saying “expired documents remain valid.” For years that was enough to get through a bank visit or a new job. Then the rules shifted beneath everyone’s feet. To understand where you stand, you need to know how the safety net was built and exactly when it was taken away.

From SEF to AIMA and the Chain of Extensions

When SEF was replaced by AIMA, the new agency inherited an enormous backlog of renewals, old bookings and half-finished files. For background on how the agencies differ, see AIMA vs SEF: What Changed for Foreigners in Portugal After the Transition. The government did not process everyone at once. It passed a series of decree-laws that kept expired documents usable while the system caught up.

That chain began with Decreto-Lei 10-A/2020, during the pandemic. It was later extended several times. Decreto-Lei 41-A/2024 pushed acceptance of expired residence permits to 30 June 2025. Then Decreto-Lei 85-B/2025, published on 30 June 2025 and in force from 1 July 2025, added one final window. Under its article 2(1), residence permits whose validity ended between 22 February 2020 and 30 June 2025 were accepted, on the same terms, until 15 October 2025.

This whole period of rolling extensions is what expats usually mean by the “transition period.” It was never a single law. It was a series of temporary patches, each one bought a few more months, and each one had an end date.

The 15 October 2025 Cut-Off

The last patch ended on 15 October 2025. Article 2(2) of Decreto-Lei 85-B/2025 sets the rule for what happens next. After that date, residence-permit documents are accepted on presentation of the holder’s AIMA-issued proof of payment of the renewal application.

AIMA’s own notice of 15 October 2025 spelled out the consequence. After that date, expired residence permits stop being valid if the holder has not yet started the renewal process. When the renewal is registered and paid, AIMA issues the renewal receipt.

The meaning is simple, even if it stings. The date on your card no longer carries you by itself. What carries you is having registered and paid your renewal with AIMA, and holding the receipt that proves it. If you are worried about what an expired card means for you personally, see My Portugal residence permit expired: Am I considered an illegal immigrant?.

Where an Old SEF Appointment Leaves You Now

This is the part that hurts most for long-term residents. Many of us did everything right. We booked, we waited, we kept the email. Then the institution we booked with ceased to exist.

Old Bookings, References and Confirmations

An old SEF appointment confirmation, SEF reference number or SEF submission proof belongs to your personal history. Keep it. It shows when you first tried to renew, and that can matter if you ever end up talking to a lawyer about delays. For that kind of route, see Using a lawyer for AIMA delays: Does filing a lawsuit (intimação) actually work?.

These papers are no longer the documents an employer, bank or official will act on, though. As of October 2026, the document with legal effect is the AIMA renewal receipt. If you have not yet registered your renewal with AIMA, the old SEF booking does not hold your place.

Also note where renewals are handled. From 1 August 2025, the registry offices, the IRN, no longer handle residence-permit renewal appointments. Renewals sit with AIMA. A friend of mine kept trying the Loja do Cidadão counter in Lisbon out of habit and was sent home each time. The door has simply moved.

The Renewal Receipt Is the Document That Counts

Lei 23/2007, the Foreigners’ Law, article 78(7), says the receipt of the renewal application has the same effects as the residence card for 60 days, renewable. That one sentence is the backbone of your legal life while you wait.

In practice, renewals are made on AIMA’s online renewals portal. The receipt is issued after payment. For permits that expired between 22 February 2020 and 30 June 2025, AIMA issues it within 10 working days after payment is confirmed, in your personal area on the portal. The full walkthrough is in How to Renew Your Portuguese Residence Permit Online via the AIMA Portal.

Because the receipt’s effect lasts 60 days and is renewable, check its date regularly. Look in your personal area for an updated version before the current one runs out. Do not let it lapse quietly in your downloads folder.

Timing Rules You Should Know

The Foreigners’ Law and its regulation set clear timing rules, and I wish someone had explained them to me on day one:

  • Article 78(1) of Lei 23/2007: renewal must be requested up to 30 days before the permit expires.
  • Article 63(16) of Decreto Regulamentar 84/2007: the request is made between 90 and 30 days before expiry.
  • Article 63(14) of the same regulation: the right of residence does not lapse until six months after the expiry of the permit being renewed.

There is one more change worth knowing. Lei 62/2026, in force from 11 September 2026, revoked article 82(7) of Lei 23/2007. Since then, the passage of time on its own does not turn a pending renewal into an approved one. Your renewal is decided when AIMA decides it, and the receipt is what covers you in the meantime.

Step-by-Step: Moving From an Old SEF Booking to an AIMA Receipt

If you are sitting on an old SEF confirmation and an expired card, here is the order I would follow:

  1. Gather your file. That means your passport, expired residence card, NIF, NISS if you work, proof of address and proof of your means or employment. Keep old SEF emails in the same folder as history, not as proof.
  2. Check that your details are consistent. If your address at Finanças still shows somewhere you left years ago, fix it first. Services like Bordr can help with tax-number admin if you are dealing with it from a distance.
  3. Prepare translations. If any supporting document is in a language other than Portuguese, get a certified translation. A service such as RushTranslate can produce certified translations, but check what Portuguese authorities accept for your document type. The broader rules are in Translating and Certifying Documents for Portuguese Immigration.
  4. Go to AIMA’s online renewals portal and register the renewal under your own credentials.
  5. Pay the renewal using the method the portal gives you. For paying a payment reference at an ATM, see How to pay the AIMA residence permit issuance fee (DUC) at a Multibanco ATM.
  6. Wait for payment confirmation, then watch your personal area. For permits that expired between 22 February 2020 and 30 June 2025, the receipt should appear within 10 working days after payment is confirmed.
  7. Download the receipt and print several copies. Save a PDF to your phone and to cloud storage.
  8. Note the 60-day effect on your calendar, and look for the renewed receipt before each period ends.
  9. Keep a contact log of every portal message, email, phone call and in-person visit, with the date, time and a short note of what was said.
  10. If nothing moves for a long time, escalate. The tools are a formal complaint, covered in How to file a formal complaint against AIMA on the Livro de Reclamações, and legal advice.

When I did this myself, I was paralysed by the fear of doing it “wrong.” Once the receipt appeared, my shoulders dropped about three centimetres. It is the single most calming piece of paper in Portuguese immigration life.

Living Day to Day With a Renewal Receipt

Getting the receipt is half the battle. The other half is using it confidently with people who may never have seen one.

Work and Self-Employment

Article 83(1)(b) to (c) of Lei 23/2007 says a residence-permit holder may work as an employee or as self-employed without special authorisation. Read with article 78(7), a valid renewal receipt carries the same effects as the card. When an HR department asks for proof of your right to work, give them your expired card together with your current AIMA renewal receipt.

Some HR teams panic at anything unfamiliar. Bring a printed copy and point calmly to article 78(7). Offer to send the PDF so their compliance team can file it. For more on handling those conversations, see AIMA appointment delayed: How to prove legal status to Portuguese employers.

If you freelance on recibos verdes, the same logic applies. Your activity at Finanças carries on, but keep the receipt current in case a client or your accountant asks.

Banks, Landlords and Other Paperwork

Banks are where most of us feel the friction. Article 78(7) gives the receipt the same effects as the card for 60 days, renewable. Even so, no rule found obliges a bank to accept an expired card with a renewal receipt. Banks run their own compliance checks and may ask for more, such as updated proof of address or a newer receipt.

A neighbour of mine in Porto had her account restricted until she brought the receipt in person and a branch manager scanned it into her file. If you hit that wall, see What to do if your bank freezes your account because your residence card expired.

Landlords, utility companies and the health centre can also be cautious. Healthcare access through the SNS depends on your registration, and staff at a Centro de Saúde may ask questions when they see an expired card. Some expats keep private international cover, such as Cigna Global, running as a bridge while their status paperwork catches up. Whether that makes sense depends on your budget and health needs, so check the provider’s own page for current plan details.

Travel is a separate question. Before you leave Portugal while waiting, get specific advice. Border and transit checks are not the same as a bank counter. See Can I fly through Frankfurt if my Portuguese residence permit is currently expired? before booking anything.

Keeping Your Paper Trail Organised

The table below shows which documents to bring in the situations you are most likely to face.

Situation Document that carries legal effect What else to bring Practical tip
Starting or keeping a job Current AIMA renewal receipt Expired card, passport Point HR to Lei 23/2007 articles 78(7) and 83
Bank account review Current AIMA renewal receipt Expired card, passport, proof of address The bank may ask for more documents
Renting a flat Current AIMA renewal receipt Passport, NIF, proof of income Offer the landlord a PDF copy for the file
Health centre visit Current AIMA renewal receipt Utente number, passport Keep any private cover documents on hand
Speaking to a lawyer about delays Current AIMA renewal receipt Old SEF confirmations, contact log Old SEF papers show your history
Permit expired, renewal not yet registered None until you register and pay Everything in your file Register and pay on the AIMA portal first

My personal habits, learned the hard way:

  • Keep one physical folder and one cloud folder with identical contents.
  • Name each receipt file with its issue date so you can see the newest at a glance.
  • Set calendar reminders well before each 60-day effect ends.
  • Keep the contact log going even when nothing seems to be happening. Gaps are exactly what you will need to show later.
  • Keep old SEF emails and confirmations as historical records, filed apart from the documents you hand over.

For the wider picture of living with delays, see Dealing with AIMA Backlogs: What to Do If Your Card Expires.

The emotional side matters too. Living on a receipt can feel like renting your own life. But the law gives that receipt real weight. Once you know which document counts, you can stop rummaging through old SEF emails before every appointment and walk in holding the one paper that matters.

Disclaimer

This article is for general informational purposes only and does not constitute professional advice. Laws, prices and regulations vary by location and change over time. Consult a qualified professional for guidance on your specific situation.

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