Number of staff and nature of the first instance authority

Author

Portuguese Refugee Council Visit Website

Source: Information provided by AIMA (July 2025), and Asylum Act.

The reform of the national asylum authority[2] culminated in 2023 with the creation of the Agency for Integration, Migration and Asylum (AIMA), which began its operations on 29 October,[3] and with the termination of the Immigration and Borders Service (SEF). Until that date, SEF remained the national asylum authority. For further information on how the SEF operated, please see previous updates to this report.[4]

AIMA began its operation on 29 October 2023, having been created by Decree-Law in June.[5] The Decree-Law that created AIMA amended a number of legislative files, including the Asylum Act where the amendments focused on replacing references to SEF with references to AIMA, references to SEF’s National Director with Board of AIMA, and references to the Ministry of Home Affairs to the Ministry in charge of Migration. Between 29 October 2023 and the end of 2023, the Ministry of Parliamentary Affairs was in charge of migration. From 10 May 2024 onwards, the Minister for the Presidency was in charge of migration.[6]

The above-mentioned Decree-Law also created the Borders and Foreigners Coordination Unit (Unidade de Coordenação de Fronteiras e Estrangeiros, UCFE), responsible for the coordination of the activities of the police forces and other actors working in the field. The UCFE is primarily composed of officials from the two police forces with border control competencies (GNR and PSP).

The instrument further established AIMA’s structure. AIMA is a Public Institute with administrative and financial autonomy. The Agency works in the fields of equality and migration and is under the oversight and remit of the ministry responsible for such themes.[7]

Notably, AIMA is responsible for the execution of public policies within the fields of migration and asylum.

Among its main competencies within the field of asylum, AIMA is inter alia responsible for:[8]

• Supporting border points in issuing visas and in providing reception conditions to asylum applicants;
• Recognising the right to family reunification;
• Analysing and deciding applications for international protection and temporary protection;
• Coordinating and implementing solidarity programmes such as relocation and resettlement;
• Ensuring the existence of a single reception and integration system for applicants and beneficiaries of international and temporary protection;
• Ensuring the provision of assistance to applicants for international protection until a decision regarding their application is reached (including unaccompanied children);
• Ensuring the implementation of transition plans concerning financial allowances granted to applicants and beneficiaries of international protection, supporting their autonomy;
• Providing financial assistance to reception entities;
• Promoting civil society initiatives regarding reception and integration;
• Representing Portugal at EU and international level institutions and for a regarding asylum and migration, including being the national contact point for the EUAA.

Iniatially, the Agency was composed of three bodies – the Board, the Single Auditor, and the Council for Migrations and Asylum (CNMA).[9] In June 2024, the Observatory for Migration was added as a body.[10] In August 2024, the Council was autonomised from the Agency and redefined as a governmental advisory body.[11]

The internal organisation of AIMA is governed by its Statute, which was approved by the Government by the end of October 2023.[12]

Accordingly, from 29 October 2023, AIMA’s National Centre for Asylum and Refugees (CNAR) became the specialised determining authority in the field of asylum, in charge of:[13]

• Receiving asylum applications and processing determination procedures;
• Organising and processing applications for humanitarian residence permits;
• Organising and processing Dublin procedures and, where necessary, issuing laissez passer;
• Organising and processing submissions for resettlement of refugees and relocation;
• Issuing reasoned opinions on applications for the renewal and extension of refugee travel documents presented to Portuguese Consulates;
• Ensuring AIMA’s connection to the EUAA and preparing the corresponding strategic planning;
• Ensuring reception conditions according to the law; and
• Developing quantitative and qualitative indicators to assess elements such as its performance.

According to AIMA’s Statute, the Department of Administrative Procedures and Quality may participate in the analysis of applications for international protection and temporary protection.[14]

According to AIMA, CNAR has 39 staff members. Between January and the end of July 2024 the processing of asylum applications was carried out by 13 staff members. By the end of 2024, the team was reinforced to 22 members.

The decision-making process at CNAR involves one Coordinator of the Examination Unit, one Director of the International Protection Services, and one Head of Department of CNAR. In addition, staff members are divided per the following:

• Caseworkers – responsible for the examination of asylum applications regardless of the type of procedure (including interviews, COI research, and drafting proposals for decisions to grant or cease international protection). One of the caseworkers deals exclusively with unaccompanied children’s applications. There is a specialised team responsible for Dublin procedures. Some caseworkers also involved in the solidarity programmes, such as resettlement, relocation and humanitarian admission;
• First-line officers – responsible for receiving and registering asylum applications, screening and referring cases, and issuing or renewing documentation;
• Administrative support officer – provision of the necessary logistical and liaison assistance to the service, among other;
• Coordinator of the Examination Unit and the Head of Reception Staff – supervision and management of operations of case-processing teams, among other.

In October 2024, the Cabinet of the Minister responsible for the field of migration sub-delegated the following powers to the Board of AIMA:[15]

• Decide on the acceptance of resettlement applications;
• Declare the loss of the right to international protection;
• Decide on granting or refusing a residence permit to family members of a beneficiary of international protection;
• Decide on exclusion from international protection;
• Decide on the granting or refusal of international protection.

The institutional change also entailed that existing general police forces became responsible for border control and for executing expulsion decisions. As such:

• The National Republican Guard (Guarda Nacional Republicana, GNR) became responsible for the surveillance and control of maritime and land borders, and for executing expulsion decisions within its jurisdiction;[16]
• The Public Security Police (Polícia de Segurança Pública, PSP) became responsible for the surveillance and control of air borders, and for executing expulsion decisions within its jurisdiction;[17]

As a consequence of the reform, competencies regarding foreigners with a residence permit and the issuance of travel documents were attributed to the Institute of Registries and Notary (Instituto dos Registos e Notariado, IRN).[18]

In July 2023, the Ombudsperson published a report on activity and process of termination of SEF. The report noted, inter alia:[19]

• SEF’s increasing lack of capacity to provide timely responses to the requests received (e.g. lack of capacity of the contact centre, lack of availability of in-person appointments);
• The need to ensure the continuity of the public service during the transition.
• That the creation of a new entity would not, by itself, solve the problems identified in SEF’s activity.

Regarding the transition for the new immigration and asylum authority, the Ombudsperson noted, inter alia, that:[20]

• Such a wide reform has not been preceded by a wide public debate and no reports or studies analysing the proposed changes were made public;
• Regarding the administrative competencies, the choice of the type of entity created, and the definition of the scope of its functions caused concern to the Ombudsperson. In particular, the Ombudsperson highlighted that the termination of the High Commission for Migration, that had a role in providing support to migrants in Portugal, and its integration in the new administrative authority that would have decision-making powers, jeopardised the relationship of trust with migrants.
• While the process was necessarily complex, it was bewildering that it was so long and uncertain.
• The need for a medium- and long-term strategy to respond to requests by migrants.

The Ombudsperson issued a number of recommendations accordingly.

According to the Government, AIMA began its operation with 34 front desk services spread through the country and with a backlog of 347,00 pending procedures.[21]

In response to the Parliamentary Group of the Portuguese Communist Party in May 2024, the Government stated that there were 4,000 international protection cases pending a decision.[22]

According to CPR’s analysis, while the transition process was quite long, it was neither gradual, nor participatory. Notably, according to CPR’s analysis, it did not include a sustained strategy of cooperation with other relevant public entities and with civil society organisations.

While the separation between administrative and law enforcement-related competencies is a positive element, the beginning of AIMA’s operation presented multiple challenges and potential protection shortcomings.

With regards to asylum in particular, CPR observed multiple gaps in the implementation of legal norms concerning the asylum procedure and reception conditions, without proper account to the need to ensure the continuity of services despite institutional reforms.[23] Furthermore, there have been notable difficulties in obtaining information regarding the procedures adopted by the Agency, and a structural lack of adequate communication both with civil society organisations and with applicants for international protection.

CPR also observed a growing tendency for narratives focused on the need to contain and limit the number of asylum applications, which is highly concerning.

In June 2024, the Government announced a national plan for migration and asylum[24] as a response to problems and challenges it identified, namely:

• Defective process of termination of SEF;
• Operational incapacity of AIMA, with a backlog of 400,000 pending procedures (all procedures together);
• Significant operational disruptions in border control systems;
• Inoperability of the return system;
• Degradation of the system and policies for integrating migrants and applicants for and beneficiaries of international protection and difficulties in accessing education, healthcare and other services;
• Depletion of the capacity of administrative detention facilities and existing reception centres;
• Significant increase in the number of foreign citizens living in a context of vulnerability and exclusion; and
• Growth of human trafficking networks, exploitation and irregular immigration.

Among the 41 measures and policies the Government announced to tackle these matters, are the following:

• Create a Mission Structure of AIMA with additional human, material and financial resources, to handle backlogs on pending procedures;
• Create an Immigration and Borders Unit in the PSP, assigning it competence for border control, surveillance on the national territory and return cases;
• Restructure AIMA, removing its competences on return cases, autonomising the Council for Migrations and Asylum, reformulating the Observatory for Migration, redefining the location of AIMA front desk services, and providing it with additional human and technological resources;
• Build new administrative detention facilities and increase the capacity of existing ones;
• Prepare the national implementation plan of the European Union’s Pact on Migration and Asylum;
• Ensure that the deadlines for decisions in cases of granting international protection are met, accelerate judicial appeals against administrative decisions in international protection procedures, and prioritise family and children’s cases;
• Fulfil the commitments made regarding the resettlement and relocation of applicants for and beneficiaries of international protection, with the support of civil society;
• Strengthen cooperation agreements with non-governmental and social organisations to increase places in reception centres for applicants for and beneficiaries of international protection, and increase the capacity of specialised residential units to accommodate unaccompanied children; and
• Increase the capacity for temporary and urgent accommodation for immigrants and beneficiaries of international protection, through the National Pool of Urgent and Temporary Accommodation.

The Observatory for Migration (Observatório para as Migrações, OM) was reinstated by Decree-Law in June 2024[25] as a body within AIMA’s structure whose mission is to produce, collect, process and disseminate information and knowledge on the phenomenon of migration.

The Mission Structure of AIMA (Estrutura de Missão da AIMA) was established by Resolution of the Council of Ministers in July 2024,[26] under the responsibility of the Minister of the Presidency, becoming responsible for processing and finalising pending cases for the granting and renewal of residence permits until 2 June 2025. According to CPR’s observation, this measure had no impact on the processing of asylum applications. AIMA didn’t provide any indication of this either.

The National Council for Migrations and Asylum (Conselho Nacional para as Migrações e Asilo, CNMA) was created by Decree-Law in August 2024[27] and thus autonomised from AIMA, becoming a governmental advisory body on national migration and asylum policy and strategy. Among its competences, CNMA may comment on draft legislation relevant to asylum and migration and participate in the definition of asylum and migration policy measures and actions. It is composed of 20 members, from prominent citizens to relevant entities, including civil society organisations with recognised work in the field of asylum.[28][29] In 2024, the Council only held one meeting, on 28 October.

To prepare the national implementation plan of the European Union’s Pact on Migration and Asylum, the Government was initially assisted by the International Organisation for Migration (IOM). IOM consulted multiple actors relevant in the field of asylum and migration, including civil society organisations that provide support to applicants and beneficiaries of international protection, such as CPR.

In October 2024, the Government set up a working group with the mission of preparing, coordinating and ensuring the execution of the national implementation plan.[30] The working group consists of members with governmental and public functions.

In December 2024, a first version of the national implementation plan was submitted to the EU, in order to meet the deadline. The Government planned a more advanced version for the beginning of 2025, after national discussions in Parliament and in the National Council for Migration and Asylum. During the first semester of 2025, the national implementation plan was not yet public.

The creation of the Immigration and Borders Unit (Unidade de Estrangeiros e Fronteiras, UEF) in the PSP was rejected by the parliamentary committee on Constitutional Affairs, Rights, Freedoms and Guarantees in December 2024.[31]

AIMA did not provide any information on concrete measures to meet the deadlines for decisions granting international protection, nor to prioritise cases of children and families in relation to others by the end of 2024.

According to PSP, the development of two new administrative detention facilities is foreseen, as well as requalification and expansion of existing ones.

Quality assurance

According to AIMA, quality is ensured through the following quality assurance mechanisms: (1) internal supervision and review by senior officers and the head of examination unit; (2) standard operation procedures and guidelines, such as standard templates and models to ensure consistency; (3) monitoring and evaluation, which comprise performance indicators that include number of cases processed and recognition rates, and cooperation with external entities such as EUAA, the Portuguese Ombudsperson, and UNHCR for external quality assessments, guidance, and feedback.

CNAR’s new staff have received structured and compulsory initial training, which includes basic legal training provided by UNHCR and CPR (e.g., CPR’s training focused on the forms of international protection, determining protection needs, and the national asylum system and procedures). While CPR deems this as a positive aspect, according to the feedback of both CPR trainers and trainees, at the time the needs were wider and not fully addressed in the initial training. Also, caseworkers were already performing their duties.

According to AIMA, caseworkers receive continuous training, including EUAA’s modules, and are encouraged to attend further initiatives.

[1] According to the Asylum Act, the Ministerial competencies referred to in the table are attributed to the Minister responsible for the field of migration. Between 29 October 2023 and 9 May 2024, the Minister for Parliamentary Affairs was in charge of migration. From 10 May 2024 onwards, the Minister for the Presidency was in charge of migration.

[2] For detailed information on the process and its origins prior to 2023, please revert to previous AIDA reports. 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.

[3] Decree-Law no. 41/2023, of 2 June 2023 creating the Agency for Integration, Migration and Asylum, I.P., available here. Ministerial Order no. 324-A/2023 of 27 October, approving the Statute of Agency for Integration, Migration and Asylum, I.P., available here.

[4] AIDA, Country Report : Portugal, available here.

[5] Decree-Law no. 41/2023, of 2 June 2023, available here.

[6] Decree-Law no. 32/2024, of 10 May 2024 establishing the Organic Law of the Government, available here.

[7] Article 1 of the Annex to Decree-Law no. 41/2023, of 2 June 2023, available here.

[8] Article 3 of the Annex to Decree-Law no. 41/2023, of 2 June 2023, available here.

[9] Article 4 of the Annex to Decree-Law no. 41/2023, of 2 June 2023, available here.

[10] Decree-Law no. 41-A/2024, of 28 June 2024 reformulating the Observatory for Migration, available here.

[11] Decree-Law no. 53/2024, of 30 August 2024 creating the National Council for Migrations and Asylum, available here.

[12] Ministerial Order no.324-A/2023, of 27 October 2023, available here.

[13] Article 12 AIMA Statute.

[14] Article 10 (c) and (d) Ministerial Order no.324-A/2023, of 27 October 2023, available here.

[15] Ministerial Order no.12589/2024, of 23 October 2024, available here.

[16] Article 2(a) 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.

[17] Ibid, article 2(b).

[18] Ibid, article 3(1)(b).

[19] Ombudsperson, Monitorização da Actividade e do Processo de Extinção do Serviço de Estrangeiros e Fronteiras – Relatório, July 2023, available here.

[20] Ibid, pp.10 et seq.

[21] Governo de Portugal, Agência para a Integração, Migrações e Asilo: o primeiro dia de um novo paradigma, 29 October 2023, available here.

[22] Assembleia da República, Pergunta 25/XVI/1, Constrangimentos nas respostas da Agência para a Integração, Migrações e Asilo, April 2024, available here; Assembleia da República, Resposta à Pergunta 25/XVI/1, Constrangimentos nas respostas da Agência para a Integração, Migrações e Asilo, May 2024, available here.

[23] In the context of the right of reply of the authorities to the 2024 draft AIDA report (22 August 2025), AIMA affirmed that in response to a significant increase in applications for international protection registered from February 2024 onwards, accelerated procedures were temporarily implemented, with close monitoring by UNHCR, which made several visits and supervised the procedural steps taken during this period. Following a decrease in the number of applications for international protection and a change in strategic direction adopted by the new AIMA Board of Directors in July 2024, a comprehensive assessment of the processes was carried out. According to AIMA, standard case processing was reinstated during the second half of 2024 and has remained in effect to date.

According to CPR’s observation, and as described throughout the report, these ‘temporarily accelerated procedures’ were adopted to the detriment of imperative procedural guarantees and reception conditions. The fact that most applications were considered unfounded or inadmissible during this period is not in itself evidence of the need for these ‘temporarily accelerated procedures’, but it rather raises serious concerns regarding the quality of the analysis conducted by the authorities.

[24] Presidência do Conselho de Ministros, Plano de Ação para as Migrações: Problemas, Desafios, Princípios e Ações, June 2024, available here.

[25] Decree-Law no. 41-A/2024, of 28 June 2024 reformulating the Observatory for Migration, available here.

[26] Resolution of the Council of Ministers no. 87/2024, of 10 July 2024 creating the Mission Structure for the Recovery of Pending Cases at AIMA, available here.

[27] Decree-Law no. 53/2024, of 30 August 2024 creating the National Council for Migrations and Asylum, available here.

[28] Article 4 of the Decree-Law no. 53/2024, of 30 August 2024, available here.

[29] Resolution of the Council of Ministers no.140-A/2024, of 18 October 2024 appointing the chair of the Council, available here.

[30] Order no. 11856-A/2024, of 07 October 2024, available here.

[31] RTP, Chumbo de unidade de estrangeiros, 18 December 2024, available here.