Support measures to startups

The outbreak of COVID-19, and the restrictive measures imposed by the government, affected all economic areas. Startups are no exception and in general have had a strong break in their performance.

To minimize the mortality of startups, by their nature highly vulnerable to risk, especially those with innovative business models, several support measures have been created:


Innovative and Specific Measures for Startups:

StartupRH Covid19

This measure aims to support early stage startups (founded less than 5 years ago), with an incentive equivalent to a minimum wage per employee, up to 10 employees, and aims to mitigate the immediate lack of liquidity, particularly with respect to operating expenses with Human Resources.

For Startups to be able to resort to this support, they must guarantee the maintenance of jobs in 2020, and they may not have already used the lay-off regime.


Startup Voucher Extension

Targeted to entities with active Startup Vouchers, which are extended for three months, in the amount of 2075 euros per entrepreneur. To resort to this support measure, it is sufficient that the startup already has a Startup voucher assigned.

The Startup Voucher is a measure that drives projects of young entrepreneurs, and is embodied in various support instruments, during the process in which the projects pass from idea to reality.

This measure arises as a way of making up for the immediate lack of liquidity on the part of start-ups, particularly regarding operational expenses and the fulfilment of long-term responsibilities.


Incubation ticket COVID19

Supports startups under 5 years old, providing a simplified incentive of EUR 1,500 in incubation services (which include rents, telecommunications, and other aspects). This support takes the form of a 100% non-refundable incentive.

These services will be provided by accredited incubators belonging to the National Network of Incubators.

In order to access this support, in addition to the proper records of all entities concerned, it is also necessary that no workers are made redundant in 2020.



“Mezzanine” funding for Startups Covid19

It is aimed at high-potential start-ups that have benefited from investments by Business Angels, venture capital investors or other partners, or have benefited from incentive schemes and have undergone technology transfer processes.

This measure intends to inject liquidity into these companies, through debt instruments (loans) convertible into share capital after 12 months and applying a discount rate that avoids the dilution of promoters.

This line aims to mitigate the effects of the Covid-19 pandemic by supporting start-ups that are positively signaled by certified incubators and that present a plan to maintain their business and a recovery of their business in the post-crisis period.

To be able to make use of this support, Startups must:

  • Keep all the employees in 2020
  • Be registered at StartupHub
  • Present a statement proving the negative impacts of the pandemic on their economic activity
  • Have had previous funding
  • Have been involved in technology transfer processes
  • Preferably, have business that involves circular economy or energy efficiency
  • Have a mentor assigned to monitor the company’s activity, for a maximum period of 12 months (this cost is included in the investment)
  • Operate the financing line through Portugal Ventures


Launch of the instrument Covid19 – Portugal Ventures

It facilitates the reinforcement of the liquidity of the startups, in cooperation with already existing shareholders who hold at least 30% of the capital, through the Operation Follow-Ons of Portugal Ventures, for investments in strartups, with an amount of investments (tickets) from EUR 50,000.

This measure, aimed at startups in all sectors, is financed by the Development Finance Institution (IFD); Portugal Ventures; and Imprensa Nacional Casa da Moeda.


Measures already existing and adapted to startups:

200M Fund

This fund, which already existed before the crisis we are going through, makes it possible to provide technological start-ups with greater investment capacity, in late seed and Series A and B phases. It consists of a co-investment between qualified private investors and the 200M Fund, allowing rounds of 10 million euros or more.

This measure allows significant capitalization of companies, to support them in this phase of uncertainty, and boost growth after COVID-19.

To join this measure, startups should only be based in Portugal and have qualified and experienced private investors interest to invest in their capital, in at least EUR 500,000.


Co-investment Fund for Social Innovation

It aims to provide the social impact startups with greater investment capacity, in late seed and Series A and B phases.

It is, essentially, a co-investment, between private investors and the Fund for Social Innovation (a public instrument aimed at boosting social impact investment in Portugal). The minimum public investment will be EUR 50,000 and the maximum EUR 2.5 million.

This measure will allow for a significant capitalization of companies with strong social impact, supporting them during the crisis and boosting their post-COVID-19 growth.

Contact us for more details.

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The minor or incapacitated children of individuals who have acquired Portuguese nationality derived after the birth of their children may apply for the acquisition of Portuguese nationality, expressing such will and proving the fulfillment of the applicable legal requirements.

However, this claim can be opposed by the Public Prosecutor’s Office, through a legal action opposing the acquisition of nationality, and one of the grounds that the Public Prosecutor’s Office can use in this action is the lack of an effective link of the applicant to the Portuguese community.

If the Public Prosecutor’s Office decides to oppose the acquisition of nationality, it will still have to prove that the person concerned does not have such link as, since 2006, and after express confirmation by the Supreme Administrative Court in 2016, it has been clear that the applicant for nationality only has to declare, and no longer has to prove, that he has an effective connection to the Portuguese community.

It is true that, in 2019, an Internal Service Guideline was issued by the Central Registry Office, which determined the presumption of the existence of an effective connection to the national community by all minors under 14 years of age, with the aim, among others, of relieving the pressure that had been generated on the courts in the past with the submission of several legal actions opposing the acquisition of nationality by the Public Prosecutor’s Office.

However, in October 2022, Internal Guidance ceased to apply, and the Registry Services began to consider that a case-by-case analysis should be carried out and that situations in which the Registrars had well-founded suspicions of the lack of an effective connection to the national community should be reported to the Public Prosecutor’s Office, regardless of the age of the person concerned.

How can one justify the opposition to the acquisition of Portuguese nationality?

We are waiting to see whether the Conservatives will only report cases where they have “well-founded suspicions” that there is no effective link or whether they will do so in all cases, leaving it to the Public Prosecutor’s Office to investigate and, if it so decides and has sufficient evidence, to take legal action against the opposition to nationality.

It also remains to be seen whether the Public Prosecutor’s Office will file opposition actions in all cases, regardless of the evidence it can (or cannot) gather, leaving the final realization of justice in the case in the hands of the judges, or whether it will only file an opposition judiciously when it has evidence of the absence of an effective link.

In addition to these doubts, there is also perplexity and concern about the counting of the 1 year available to the Public Prosecutor’s Office to file an opposition. In 2022, the Portuguese Nationality Regulation was amended in such a way that the time limit will be counted from the date of registration of the acquisition of nationality, instead of the date of the fact on which the acquisition of nationality depends (i.e., the applicant’s manifestation of the will, which occurs with the submission of the file), and which was the solution previously in force.

This means that, as of April 15, 2022, and even about cases that were already pending on that date (except cases based on the descent of Sephardic Jews), the Public Prosecutor’s Office can now oppose the acquisition of nationality, even after it has already been registered in the Portuguese Civil Registry.

From our experience, we can say that there are already Civil Registry Officers who are notifying the interested parties in cases submitted more than 1 year ago that they may report their cases to the Public Prosecutor’s Office on the grounds of lack of effective connection to the national community.

However, we continue to follow these cases closely to see what the practice of the Civil Registry and the Public Prosecutor’s Office will lead to in these matters.

Do not hesitate to contact our team if you have any questions about this matter or need advice on any other related to obtaining Portuguese nationality or citizenship.

In this article, we will explore the time limit for opposing nationality acquisition in Portugal, as defined in Article 56, number 1, of the Nationality Regulation (Decree-Law no. 237-A/2006, dated 14th December). Recently, there have been amendments to the regulation that have significant implications for the process. We will discuss these changes and their potential impact on individuals seeking Portuguese nationality.

We mention “recent” changes, but the amendment has been in effect for over a year since April 2022. Despite this, it seems that the activity of the Registry Office has become more intense now, and considering the numerous questions we receive daily on this topic, we deemed it necessary to write an article to explain.


The Previous Time Limit and its Basis

Under the previous version of the Nationality Regulation, the one year for opposition to nationality was calculated from “the date of the fact on which the acquisition of nationality depends.” In practical terms, this referred to the date of submission of the nationality acquisition process, where the individual’s will to acquire nationality was manifested.


Recent Amendment – DL 26/2022

In 2022, a notable amendment (DL 26/2022) was made to the Nationality Regulation, coming into force on 15th April. Surprisingly, this change was implemented with minimal announcement by the government. The amendment introduced a significant change to the time limit for opposing nationality acquisition.


Current Time Limit for Opposing Nationality

As per the amended Article 56 of the Nationality Regulation, the Public Prosecutor now has one year from the date of registration of nationality acquisition to file a judicial action in administrative and tax courts to oppose the acquisition of nationality by the will.

This means that the registration date, which is the date of the nationality grant, allows the initiation of legal action at any point during the process and even within one year after the process is concluded.


Early Identification and Concerns

Being vigilant of legislative changes, we were among the first to draw attention to the amendment before it was enacted. We expressed concerns about this change, considering that the previous time limit for opposing nationalities was more favorable to applicants.


Cases Pending and Notifications

According to the law of 2022, the amended Decree-Law applies to cases pending on the date of its entry into force. As a result, the Registry Office is indeed notifying cases pending for more than one year since the date of submission.


Our Ongoing Cases

Concerning our specific cases, despite having several ongoing processes, we have received notifications in only a few cases where the process was initiated in 2021 and the notifications were received in 2023. Interestingly, these notifications were not solely related to connection proof; there were other factors involved.

In response, we handled these cases strategically, and, so far, none of them have escalated to court. Nevertheless, we must remain vigilant, as the possibility remains.



Understanding the time limit for opposition to nationality is crucial for individuals seeking Portuguese nationality. The recent amendments to the Nationality Regulation have shifted the basis of this time limit, impacting the process and potential legal actions. We advise applicants to be well-informed and proactive during the process and seek legal guidance to navigate any challenges effectively.

If you wish to do so or have any questions about this topic (or any other), don’t hesitate to contact us. Our team of lawyers is available to assist you anytime!


This article was written by our lawyer and managing partner Ana Sofia Lamares.

She has dealt with countless Portuguese nationality requests and her experience is highly sought-after for those seeking help when it comes to granting Citizenship or Nationality. Don’t hesitate to get in touch with her here.

The HQA Visa promises to be an alternative solution to the well-known Golden Visas due to the reduced requirement regarding the minimum periods of stay in Portugal. Is this the case?

Before explaining this new type of visa, let us explain the context in which it emerged.

Portugal continues to experience a growing influx of migrants. However, the limit on the minimum length of stay in the national territory is a factor that weighs on the decision of those wishing to move to the country.

Residence Permits for Investment Activities, popularly known as Golden Visas, emerged in 2012 with the benefit of breaking the barriers inherent to mandatory periods of stay, as, by the provisions of Article 65-C of Regulatory Decree 84/2007, the holder of this type of residence permit needs to remain in national territory for an average annual period of 7 days.

It turns out that the popular Golden Visas, as set out in Article 90-A of Law 23/2007, not only entail very large capital spending for investors but, in recent times, have seen their survival questioned in some respects (we’ve written about it here).

Considering these factors, the “HQA VISA” has been hailed as a much more cost-effective solution that encompasses the benefits of Golden Visas. This means that, with a considerably lower investment, the holders of the “HQA Visa” would not have to comply with mandatory minimum periods of stay in national territory, acquire the possibility to circulate throughout the Schengen area without limitations and, after 5 years, give its holder the possibility to apply for the attribution of Portuguese nationality.

But is the HQA Visa all that? The answer is: yes and no.

The truth is that the HQA VISA, which is nothing more than the Residence Visa for Highly Qualified Workers, is not a low-cost alternative to Portuguese Golden Visas.

Once a residence permit has been granted in any of its modalities, except in the case of Golden Visas, the foreign resident still must comply with certain minimum stay rules in the national territory to ensure that his/her residence permit is not canceled.

According to paragraph a) of no. 2 of article 85 of Law no. 23/2007, of July 4, during the valid period of the temporary residence permit, its holder must not leave the country for a period exceeding six consecutive months or eight interposed months. The granting of permanent residence also requires compliance with the periods of stay in the national territory, this time by the provisions of paragraph b) of paragraph 2 of Article 85 of the Aliens Act.

According to this legal provision, the holder of permanent residence, which is valid for 60 months, may not be absent from the country for a period exceeding 24 consecutive months or 30 interpolated months.

However, there are several exceptions to the obligation to comply with these deadlines and which, as exceptions, do not result in the cancellation of the residence permit. The existence of weighty reasons of a personal, family, or professional nature that led to the need to be absent from the country for periods longer than those mentioned above, does not affect the maintenance of the residence permit of the third-country national.

Therefore, if the highly qualified worker holding the “HQA VISA” is absent from the country for periods longer than those indicated above and these absences are justified with professional reasons and documented, he/she should not be disadvantaged.

This exception applies not only to Residence Permits for Highly Qualified Workers but also to all other types of Residence Permits. This exceptionality, which allows the absence of the holders of these residence permits for longer periods, can never be confused with the flexibility inherent in Residence Permits for Investment activity.

If you have any questions regarding these types of visas, residence permits, or any other, please do not hesitate to contact our team of lawyers.

Get in touch with us for further information.

Lamares, Capela & Associados is committed to protecting and respecting your privacy and we will only use your personal information to manage your account and provide the products and services you have requested. Occasionally, we would like to contact you about our products and services and also about other matters that may be of interest to you.