Author
The Portuguese authorities are bound by a duty to issue travel documents to refugees and beneficiaries of subsidiary protection.[1]
The refugee travel document consists of an electronic travel document,[2] following the Refugee Convention format,[3] which, since 2022, is valid for five years and renewable.[4] The document is to be issued unless imperative national security/public order require otherwise.[5] The authorities competent for granting refugee travel documents consist of the Board of AIMA[6] for applications made on the national territory, and consulates[7] for applications made abroad.[8]
In 2025, refugee travel documents were subject to a fee of €34.40, reduced to €25.80 when applications were submitted digitally or through assisted in-person attendance.[9]
In the case of beneficiaries of subsidiary protection, the issuance of travel documents is left to the discretion of national authorities, at odds with Article 25(2) of the recast Qualification Directive. The Asylum Act states that a Portuguese passport for foreigners may be issued to beneficiaries of subsidiary protection who cannot demonstrably obtain a national passport unless imperative motives of national security/public order require otherwise.[10]
Beneficiaries of subsidiary protection are thus required to present a valid residence permit and to demonstrate their inability to obtain a national passport, notably on the basis of relevant proof or credible statements showing a potential risk to their own safety or the refusal of their country’s consular representation to issue such a passport.[11] The standard for this analysis is not further specified by law and guidance in this regard is not publicly available.
In the context of the right of reply of the authorities to the 2024 draft AIDA report, AIMA stated that Portuguese passports for foreigners may also be issued to holders of extraordinary residence permits, which are generally issued to reunited family members of beneficiaries of international protection.[12]
This understanding seems to be at odds with the provisions of the Asylum Act, since the effects of the international protection regime granted must be declared extendable to the family member of the sponsor[13] and thus it is unclear as to why a family member of a refugee is not entitled to a refugee travel document per se.
The issuance of the Portuguese passport for foreigners is assigned to the Institute of Registries and Notary (Instituto dos Registos e Notariado, IRN).[14] Following queries made within the context of the provision of legal assistance to beneficiaries of international protection, CPR learnt that such documents were not being issued until March 2024 due to operational issues.[15]
The Portuguese passport for foreigners is valid for a period of up to two years,[16] and, in 2025, had a cost of €111.[17]
According to AIMA, 117 refugee travel documents were issued in 2025. According to IRN, 35 Portuguese passports for foreigners were issued to beneficiaries of subsidiary protection.
In CPR’s experience, in 2025 cases where beneficiaries encountered difficulties in obtaining travel documents involved individuals who held a receipt confirming the renewal of their residence permit, but whose residence card had not yet been issued. Notwithstanding, the length of the procedure for issuing a travel document can be considered reasonable overall and does not exceed a couple of months.
According to AIMA, no refusals of refugee travel documents were recorded in 2025. Regarding refusals of passports for beneficiaries of subsidiary protection, IRN did not provide information, noting that competence for their issuance lies with the Ministry of Foreign Affairs and AIMA.
[1] Article 69 Asylum Act; Article 19 Immigration Act.
[2] Ministerial Order no. 302/2015 of 22 September 2015 and Ministerial Order 412/2015 of 27 November 2015.
[3] Article 69(1) Asylum Act.
[4] Article 19 Immigration Act. An amendment to the Immigration Act enacted in 2022 extended the validity of the refugee travel document from one to five years.
[5] Article 69(1) Asylum Act.
[6] Upon favourable opinion of the Borders and Foreigners Coordination Unit.
[7] Upon favourable opinion of the Borders and Foreigners Coordination Unit and AIMA.
[8] Article 20 Immigration Act.
[9] Ministerial Order no.307/2023 of 13 October, available here. AIMA’s fee table is available here.
[10] Article 69(2) Asylum Act.
[11] Decree-Law 83/2000 of 11 May 2000, as amended by Decree-Law 138/2006 of 26 July 2006.
[12] Information provided by AIMA on 22 August 2025.
[13] Article 68(2) Asylum Act.
[14] Article 3(1)(b) Act n. 73/2021 of 12 November 2021 approving the restructure of the Portuguese system of border control, reshaping the regime of the forces and services responsible for internal security and establishing other rules for the redistribution of competences and resources of the Immigration and Borders Service, last amended by Act n. 53/2023, of 31 August 2023, available here.
[15] Although there is no official information, it resumed during 2024.
[16] Article 38 Decree-Law 83/2000 of 11 May 2000.
[17] According to information publicly available here. Ministerial Order no.307/2023 of 13 October does not provide for the cost of the Portuguese passport for foreigners.