Regular procedure

Author

Portuguese Refugee Council Visit Website

 General (scope, time limits)

The first instance determining authority is required to take a decision on the asylum application within 6 months. This time limit is additional to the duration of the admissibility procedure and can be extended to 9 months in particularly complex cases.^[1] The Asylum Act does not provide for specific consequences in case of failure to meet the time limit. Nevertheless, it establishes that when the six-month deadline is extended, the determining authority must inform the applicant accordingly. If the applicant so requests, the determining authority must also inform them of the reasons for the extension and of the expected timeline for the issuance of a decision.^[2] The asylum applicant receives a provisional residence permit valid for 6 months (renewable).^[3]

Asylum applicants are usually reluctant to act on the delay on the basis of general administrative guarantees, e.g., by requesting Administrative Courts to order AIMA to issue a decision on the application within a given time limit.^[4]

AIMA did not share an estimation of the average duration of the procedure at first instance for 2025. According to AIMA, cases decided in 2025 pertained to previous years, thus an average duration cannot be derived solely from 2025 data. There is no available statistics from other sources.

In July 2025, the Ombudsperson stated that AIMA’s first year in office was marked by serious delays in the processing of international protection applications, noting that among the complaints it received in 2024 was an application for international protection submitted in October 2016 that had still not been decided.[5]

In June 2025, the European Commission against Racism and Intolerance (ECRI) acknowledged Portugal’s generally positive legal framework for the protection and integration of refugees and other beneficiaries of international protection, whilst noting persisting challenges reported by civil society, including difficulties in obtaining information on asylum procedures, gaps in registration and implementation of the asylum procedure, and insufficient reception conditions, particularly for unaccompanied children.[6] ECRI also welcomed the recognition of CPR as an integral part of the national asylum system under the Asylum Act, and encouraged the authorities to consult and work with NGOs to address obstacles in integration.

The UN Human Rights Committee, in its Concluding Observations published in 2020, expressed concern with ‘[r]eported delays in the processing of regular asylum applications and in the issuance and renewal of residence permits.’ The Committee recommended that Portugal ‘continue its efforts to maintain and strengthen the quality of its refugee status determination procedures, in order to fairly and efficiently identify and recognise those in need of international protection and to afford sufficient guarantees of respect for the principle of non-refoulement under the Covenant.’^[7] As demonstrated throughout this report, these concerns remained particularly relevant in 2025.

According to CPR’s observation, very significant delays in the processing of regular asylum applications still persist.[8] CPR was able to gather information on 96 regular procedure decisions issued in the course of 2025, including decisions communicated by the authorities to CPR in accordance with the law, and decisions that came to CPR’s knowledge through direct contacts with applicants. In these cases, the overall duration of the procedure^[9] ranged from 104 to 3,099 days, with an average duration of 662 days. Most of the cases subject to regular procedure decisions in 2025 concerned Afghan evacuees, whose cases were fast-tracked by the asylum authority, thereby bringing down the average duration of the procedure.

Throughout the year 2025, CPR often contacted the determining authority, on behalf of asylum applicants, requesting information regarding the status of their application and the expected timeline for the issuance of a decision. AIMA consistently provided the same standard response and CPR/the applicant was merely informed that the analysis of pending international protection cases was being carried out taking into account, among other factors, the date of application, the stage of the proceedings and any situations of particular vulnerability identified. No estimate was ever given for its completion. This response is inadequate as it fails to clarify which criteria were used to prioritise cases, namely which submission dates or years were considered a priority and which vulnerabilities were taken into account, among others.

According to AIMA, in 2025 some difficulties in accessing asylum services were identified, particularly outside the main urban centres of Lisbon, Porto and Coimbra. These related to access to procedural information and clarifications on pending applications, and documentary services. The main underlying factors included an uneven territorial distribution of specialised asylum staff and constraints in AIMA’s IT systems. To mitigate these difficulties, AIMA reinforced and redistributed staff, trained personnel from other departments and regional offices to provide support, and strengthened internal coordination mechanisms. In AIMA’s view, the availability of a public CNAR email contact also served as a mitigating factor. The Agency argues that access to services improved over the course of 2025, though structural challenges outside Lisbon remain ongoing.

According to CPR’s observation, significant problems were encountered in access to services, obtaining information and in the renewal of provisional residence permits at AIMA offices outside Lisbon, requiring many applicants to travel long distances to renew their documents. This is particularly serious and rights-limiting given the significant delays in the regular procedure, combined with the six-month validity of provisional residence permits, which requires constant renewal. Difficulties in accessing services were not limited to areas outside the main urban centres, but were also observed on some occasions in Porto and Coimbra. These limitations are particularly concerning given AIMA and ISS’s policies on decentralising reception at any stage of the procedure. For instance, AIMA’s policy encompasses placing applicants in reception centres in Porto, Braga, Macedo de Cavaleiros and Castelo Branco. The intervention of civil society organisations was necessary in order to ensure access to information, services and documentation, as corroborated by CPR, JRS, Crescer, Aldeias de Crianças SOS, and Associação VITAE.

A study focusing on the situation of asylum-seeking unaccompanied children and ageing out in Portugal published in 2021 revealed that among those questioned, the majority waited for more than 12 months for a decision on their application for international protection.^[10]

In the context of the provision of legal assistance to asylum applicants in 2025, CPR has also at times observed significant delays in the execution of judicial decisions by AIMA, even when a deadline is set by the court. According to CPR’s observation, this mostly concerned the execution of judicial decisions ruling that an application should not be processed under an accelerated procedure and consequently ordering the Administration to reanalyse the case under the regular procedure, Dublin cases that should be reprocessed, and cases where the Administration is deemed to lack competence to carry out such an act. It was mostly thanks to the proactiveness of the applicant that the judicial decision was acted upon by AIMA.

According to AIMA, the number of pending cases at first instance by the end of the year was 8,836. This figure represents a significant increase compared with the number reported by the Agency the previous year (556) and is more in line with the perceived reality that there is a very significant backlog in the processing of cases.[11] Eurostat figures also rose from 130 in December 2024 to 8,595 pending asylum applications by the end of 2025.^[12]

Prioritised examination and fast-track processing

Unlike in previous years, in 2025, AIMA reported having adopted a fast-track processing on the basis of nationality in cases of Afghan women and families admitted in Portugal under the Humanitarian Admission Programme. The prioritisation was justified by the well-established risk profile of Afghanistan, high recognition rates, and the straightforward nature of these cases, which did not require complex factual or legal assessment.

According to AIMA, in 2025, 210 applications were subject to fast-track processing, with an average duration of one month.[13]

 Personal interview

The Asylum Act provides for the systematic personal interview of all asylum applicants in the regular procedure prior to the issuance of a first instance decision.^[14] The personal interview can only be waived where:

• The evidence already available allows for a positive decision; or
• The applicant lacks legal capacity due to long-lasting reasons beyond their control.^[15]

According to the law, if the interview is waived, AIMA is required to offer the applicant or their dependant(s) the opportunity to communicate relevant information by other means.^[16]

The asylum applicant is entitled to give their statement in their preferred language or in any other language that they understand and in which they are able to communicate clearly.^[17] To that end, the asylum applicant is entitled to the assistance of an interpreter when applying for asylum and throughout the asylum procedure, if needed.^[18] The asylum applicant can also be assisted by a lawyer but the absence thereof does not preclude AIMA from conducting the interview.^[19]

The transposition of the provisions of the recast Asylum Procedures Directive (APD) regarding the personal interview into national legislation presents some incompatibilities, most notably:

• Cases of applicants deemed unfit/unable to be interviewed due to enduring circumstances beyond their control – the final part of Article 14(2)(b) of the recast APD was not transposed (‘[w]hen in doubt, the determining authority shall consult a medical professional to establish whether the condition that makes the applicant unfit or unable to be interviewed is of a temporary or enduring nature’). The safeguard contained in Article 14(4) of the recast APD, determining that the absence of a personal interview in such situations ‘shall not adversely affect the decision of the determining authority’, was also not explicitly transposed to the Asylum Act.
• Conditions of the personal interview – the requirements set out in Article 15 of the recast APD, particularly those regarding to the characteristics of the interviewer and the use of interpreters (Article 15(3) recast APD), are not fully transposed. Furthermore, and without prejudice to Article 83 of the Asylum Act which refers to the adequate training of all staff working with applicants and beneficiaries of international protection, the specific training requirement for interviewers provided for in Article 4(3) of the recast APD was not transposed to the domestic order (‘[p]ersons interviewing applicants pursuant to this Directive shall also have acquired general knowledge of problems which could adversely affect the applicants’ ability to be interviewed, such as indications that the applicant may have been tortured in the past’).
• Content of the personal interview – the final part of Article 16 of the recast APD, establishing that the personal interview ‘shall include the opportunity to give an explanation regarding elements which may be missing and/or any inconsistencies or contradictions in the applicant’s statements’ was not transposed to the Asylum Act.

In practice, asylum applicants are only interviewed once throughout the asylum procedure, which means that the general rules and practice of the regular procedure apply to the vast majority of cases (except border procedures, applications following a removal order, and subsequent applications).

According to the information available to CPR, all interviews are conducted individually.The Asylum Act does not provide the right of the applicant to request the interviewer and/or the interpreter to be of a specific gender (Article 15(3)(b) and (c) of the recast APD). According to the information provided by AIMA, this can happen in practice at the applicant’s request and if possible, but applicants are not systematically informed of this possibility. AIMA states that if the interviewer identifies any vulnerability, discomfort, or gender-based issues, the applicant is informed of the possibility of requesting an interviewer and/or interpreter of a specific gender. Nevertheless, the majority of caseworkers are women.

The Agency states that the request for a specific gender is most likely be granted (1) if the applicant is a survivor of torture, sexual or gender-based violence, and/or trafficking in human beings; (2) if for a matter of cultural sensitivity the applicant may be distressed or deem inappropriate to discuss certain sensitive topics with someone of the opposite gender; or (3) if it is an evident cause of discomfort and insecurity that might jeopardise the quality and completeness of the applicant’s statements.

According to AIMA, 1,349 personal interviews were conducted in 2025. 35 applications were decided without a personal interview, all concerning Afghan women whose cases were fast-tracked given the well-established risk profile of Afghanistan and high recognition rates, consistent with CJEU case law and guidance from UNHCR and EUAA. Around 100 personal interviews were conducted by remote communication means, namely videoconferencing; AIMA did not clarify in which instances this might occur. The transcripts of statements do not clearly indicate in which cases the interviews were conducted remotely.

According to CPR’s observation in 2025, personal individual interviews were generally conducted in practice. CPR’s observation also confirms AIMA’s practice regarding cases from Afghanistan, having found that men are systematically interviewed whilst women are exempted from being interviewed,[20] and that in some households only the husband was interviewed. However, some interviews with Afghan women occurred in early 2025.

Also, CPR observed that some applicants accommodated in districts outside urban areas, as part of the policy to decentralise the accommodation of applicants for international protection, are believed to have been interviewed remotely by CNAR staff.

According to AIMA, as soon as vulnerability is identified, appropriate support can be given to applicants according to their needs and procedural guarantees can be promoted, such as adapted interview conditions (particularly with regard to the gender of the interviewer), interruption of interviews, and exemption from accelerated or border procedures if deemed inappropriate considering the applicant’s condition.

Yet, according to CPR’s observation, in most instances in 2025 vulnerable people were indeed subject to accelerated or border procedures and personal interviews at this stage.[21] In cases where AIMA identified vulnerabilities that did not allow the procedure to continue, the Agency systematically suspended proceedings under general administrative rules rather than providing special procedural guarantees (namely postponement of the interview or admission to the regular procedure), even in cases where the incapacity was evident and the Agency had itself requested medical reports. According to CPR’s observations, such suspensions tend to be prolonged, in some cases lasting several months, well beyond the 30 working-day limit established by law for accelerated and admissibility procedures.^[22]

Between 2023 and 2024, CPR observed a number of concerning practices regarding the conduct of interviews,[23] including interviews conducted outside CNAR by officials without clear training,[24] oversimplification of interviews,[25] interviews conducted late at night/early in the morning,^[26] and applicants not being informed of their procedural rights,[27] including the right to an interpreter,[28] the right to submit evidence,[29] and the right to reply or the right to legal assistance.[30] Most of these systematic practices eased during the second half of 2024.

Other concerning practices relating to interviews identified by CPR in 2025 include (1) inappropriate or intrusive questions relating to applications based on LGBTIQ+ or religious grounds; (2) insufficient follow-up questions to elaborate on relevant points, with interviewers strictly following the template;[31] and (3) problems with interpretation, particularly due to the language used or the lack of interpreters for certain languages.

Since 2021, CPR has observed the adoption of decisions not to proceed with the analysis of the application due to the impossibility of performing the personal interview (e.g., where the applicant absconded). These decisions are based on general administrative procedure rules.^[32] Procedures were also consistently suspended in cases while the results of age assessment procedures triggered by the Family and Juvenile Courts were pending,^[33] in some cases lasting for more than one year. AIMA did not systematically communicate these decisions to CPR.[34]

Until 2023, CPR was also informed of decisions extinguishing the asylum procedure according to Article 32 of the Asylum Act, either due to explicit or implicit withdrawal of the application.

According to the law, an application is deemed as implicitly withdrawn if the procedure is inactive for more than 90 days, namely if the applicant:

• does not provide essential information for their application when requested to do so;
• does not attend the personal interview;
• absconds without contacting AIMA;
• does not comply with the obligation to appear or to communicate with the authorities.^[35] The competence to determine the extinction of an application belongs to the National Director of Board of AIMA.^[36]

Notwithstanding, the applicant is entitled to reopen their asylum case by presenting themselves to AIMA at a later stage.^[37] In this case, the file is to be resumed at the exact stage where it was discontinued.^[38] According to CPR’s observation, the extinction of a procedure usually follows a decision to halt the analysis of an application.

For court decisions by TCA South regarding the right of the applicant to request legal aid to have a lawyer present during the interview, see Regular procedure – Legal assistance.

Interpretation

The Asylum Act does not provide the right of the applicant to request the interviewer and/or the interpreter to be of a specific gender (Article 15(3)(b) and (c) of the recast APD).

According to the information provided by AIMA, this can happen in practice at the applicant’s request and if possible, but applicants are not systematically informed of this possibility. As mentioned, the Agency established criteria to analyse such requests. However, according to CPR’s observation, it is unclear if it is possible given the widespread use of the telephone translation service.

The quality of interpretation services used for interviews remains a serious challenge. In many cases, service providers are not trained interpreters but rather individuals with sufficient command of source languages. Interpreters are bound by a legal duty of confidentiality. In 2025, AIMA did not have a code of conduct/guidance applicable to interpreters.^[39] There is no specific training for interpretations, nor are there cultural mediators provided in individual interviews.[40]

AIMA stated that in 2025 around 100 personal interviews were conducted by remote communication means, namely videoconferencing; AIMA did not clarify in which instances this might occur. The transcripts of statements do not clearly indicate in which cases the interviews were conducted remotely.

In addition, AIMA confirmed that remote interpretation, by telephone or videoconference, is available where in-person interpretation cannot be ensured. The use of remote interpretation is not included in the number of interviews conducted by remote means.

According to CPR’s observation, interpretation has been widely provided by the Telephone Translation Service managed by AIMA, including in the case of unaccompanied children and detained applicants. The vast majority of personal interviews are conducted with the support of remote interpretation, particularly in Mandarin, Lingala, Urdu and French.

In CPR’s view, the systematic use of the translation hotline for asylum interviews raises a number of concerns namely regarding confidentiality and the creation of an environment that assures the applicant and promotes the proper sharing of information. Most interpreters of the Telephone Translation Service are also not trained.

According to CPR’s experience, securing interpreters with an adequate command of certain target languages remains challenging (e.g., Amharic, Bambara, Bengali, Krio, Kurdish, Limbo, Lingala, Mandinka, Nepalese, Pashto, Punjabi, Sinhalese, Somali, Soninke, Swahili, Tamil, and Tigrinya).

Recording and reporting

The Asylum Act does not provide for the audio and/or video recording of the interview or for conducting interviews and/or interpretation through videoconferencing. According to the Asylum Act, following the interview, AIMA must prepare a transcript of the statements provided by the applicant or a detailed and factual report containing all the essential elements of the statements provided by the applicant.^[41] This provision of the Asylum Act was amended in August 2023 (entering into force on 29 October 2023). The previous wording only referred to the transcript of the statements provided by the applicant during the interview.^[42]

The applicant must be notified of the document and their right to reply to it.^[43]

It should be noted that, particularly during the first semester of 2024, CPR observed frequent changes of practice by AIMA regarding the documents and procedures connected to the interview and the summary report, leading to lack of clarity and to an increase in potential violations of procedural rights.[44]

At the beginning of AIMA’s operation in 2023, applicants received both a transcript of statements and a summary report outlining the information underlying the prospective decision to deem the application admissible / not unfounded and, as such, channel it into the regular procedure, or to reject it as inadmissible / unfounded (accelerated procedure). However, in CPR’s view, these reports tended to oversimplify applicants’ statements and offered a simplistic merits analysis, making it difficult for applicants to understand and comment meaningfully on their content. Moreover, the quality of the reports deteriorated progressively from October 2023 onwards, becoming increasingly laconic both regarding the information provided by the applicant and the grounds for the analysis. According to CPR’s observation, the summary report ceased to be issued in May 2024, replaced by the transcript of statements accompanied by a notification of the right to reply. Initially this notification included a reference to the prospective decision, but this was later dropped. As of 2025, the practice has stabilised as such.

In parallel, following an amendment to the Asylum Act, in October 2023, the deadline for applicants to submit comments in response to the transcript of the statements or summary report was reduced to 3 days (from 5 previously).^[45] This reduced deadline to reply to the report is highly concerning for a number of reasons. Firstly, there was no broad consultation in this regard, and no justification was provided for such a change. Secondly, according to CPR´s experience, the 3-day deadline is not sufficient to ensure the right at stake and will create obstacles to its effective exercise. This was confirmed by CPR’s experience in 2025. The right to reply to the interview report, provided for in article 17(2) Asylum Act, is an integral part of the right of the asylum applicant to be heard within the asylum procedure. Along with the personal interview provided for in article 16 Asylum Act, this is, in practice, the moment when the facts underlying the application for international protection are established.

Article 17(2) Asylum Act is also to be read in line with the right of applicants for international protection to access legal information and assistance (article 49(1)(e) Asylum Act). This is because, in practice, applicants usually resort to legal assistance in order to be able to fully exercise the right to respond in writing to the report on their application (which usually includes a proposal to reject the application either on admissibility grounds or under an accelerated procedure). According to CPR’s experience in providing legal assistance at this stage, in order to ensure that applicants can effectively exercise their right to reply it is, for instance, often necessary to involve interpreters. Furthermore, time is required for the provision of adequate information and to adequately take into account the individual characteristics of the applicant concerned.

Also, the written reply of the applicant is usually critical to a better understanding of the material facts of the application.

A deadline of 3 days cannot be deemed as reasonable to ensure an effective right to respond to the report. This is particularly the case when taking into account the structure and duration of the asylum procedure, as well as the importance of this procedural guarantee, and the practicalities required for its effective exercise. The reduction of this procedural guarantee will not only affect asylum applicants, it will also negatively impact the overall quality of the asylum procedure as it will reduce the information available to the asylum authority (and later, to judges) to conduct a fair and proper assessment of cases.

According to law, upon consent of the applicant, the report must also be communicated to UNHCR and to CPR, and the organisations may submit observations within the same deadline.^[46] The transcript of statements reports are usually communicated to CPR accordingly, although in a significant number of cases AIMA communicates them after the applicants’ 3-day deadline has passed. Notably, while the summary reports were issued until May 2024, these were the sole reports communicated to CPR. As such, access to interview transcripts by CPR depended on the applicant. The systematic non-communication of interview transcripts was an obstacle to the full monitoring of the national asylum procedure.

CPR provides systematic legal assistance to asylum applicants at this stage, with the support of interpreters, for the purpose of reviewing and submitting comments/corrections to the interview transcript. CPR is aware of cases in which the asylum authority summoned applicants and confronted them with these statements provided in writing, namely allegations of interpretation issues and a failure to verify certain formalities.

According to CPR’s observation, by 2025, clarifications/corrections provided in writing by applicants are not consistently analysed by the authority nor taken into account in the decision-making process. While right to reply submissions are generally mentioned and attached to decisions, they are not always reflected in the fact analysis, and where submitted directly by applicants, they are not always attached to the decision.[47]

As mentioned above, throughout 2024 AIMA systematically asked applicants during interviews if they wished to be immediately notified of the decision of their asylum application, without properly informing them that this implied a relinquishment of their right to reply to the interview/case report, and while they did not have access to legal information and assistance before making a decision. As a result, a significant number of applicants were unable to exercise their right to reply to the written report in 2024.[48] This practice was not observed in 2025.

According to CPR’s observations in 2025, the transcript of statements and the corresponding deadline to provide written comments are not systematically provided to applicants following admission to the regular procedure, nor systematically communicated to CPR. CPR has recorded instances where this notification was provided, but also instances where it was not, potentially depriving applicants of the opportunity to comment on the facts adduced during the interview before being notified of a decision at the final stage of the procedure.

CPR has made efforts to mitigate the negative impacts of this practice by adding the applicant’s comments to the file in accordance with article 28(5) of the Asylum Act, that allows the organisation to add observations on individual cases at any stage of the procedure.

This practice is problematic as it curtails the applicant’s right to submit comments and corrections to the interview report and may also impact the applicant’s ability to fully exercise other procedural rights at later stages of the procedure (e.g., replying to a proposal of decision on the grant of international protection). Moreover, it seems to be in contradiction both with the domestic legal framework and the recast Asylum Procedures Directive as the relevant requirements apply to the personal interview, regardless of the moment in which it is conducted.^[49]

A decision from TCA South issued in 2021 considered that, despite the absence of an explicit reference in the relevant norm,^[50] the authorities are bound by articles 16 and 17 of the Asylum Act (personal interview and report) within the examination of applications made following a removal order.^[51]

Worryingly, a decision from TCA South issued in 2023 considered that the information provided by the applicant in writing following the interview are irrelevant as such statements are not spontaneous and are, consequently, motivated by the willingness to fulfil the requirements to be granted international protection.^[52]

Appeal

First appeal before the Administrative Court

The Asylum Act provides for an appeal against the first instance decision in the regular procedure consisting of judicial review of relevant facts and points of law by the Administrative Court.^[53] The asylum applicant has 15 days to lodge the appeal, which has automatic suspensive effect.^[54]

The Asylum Act that provides for the free and urgent nature of procedures regarding the grant or loss of international protection both in the administrative and judicial stages.^[55]

Administrative Courts have a review competence, which allows them to either:

• confirm the negative decision of the first instance decision body;
• annul the decision and refer the case back to the first instance decision body with guidance on applicable standards;^[56] or
• overturn it by granting refugee or subsidiary protection status.^[57]

The Asylum Act qualifies the judicial review as urgent,^[58] and provides for a simplified judicial process with reduced formalities and time limits with the objective of shortening the duration of the judicial review.^[59]

A decision issued by TCA South in 2021 confirmed that, when legal aid is requested by the appellant, the appeal is deemed as having been filed on the date of submission of the request for legal aid.^[60]

The information provided by the High Council of Administrative and Fiscal Courts (Conselho Superior dos Tribunais Administrativos e Fiscais – CSTAF) for 2025 indicates that the average duration of appeals before first instance courts in 2025 was 77 days.

While the Asylum Act does not specifically provide for a hearing of the asylum applicant during the appeal procedure, such a guarantee is enshrined in the general rules.^[61] This is rarely used in practice by lawyers and accepted by the Court when requested, as procedures before the Administrative Court tend to be formalistic and essentially written.^[62] As a general rule, the hearing of the appeal body is public but the judge may rule for a private audience based on the need to protect the dignity of the individual or the smooth operation of the procedure.^[63] With the exception of TAC Lisbon, which did not provide information, all the other Courts confirmed that such hearings did not occur in 2025.

In practice, and without prejudice to issues such as the frequent change of accommodation location, poor quality of legal assistance and the merits test applied by the Bar Association, and language barriers that have an impact on the quality and effectiveness of appeals, all of which persisted in 2025, CPR is not aware of systemic or relevant obstacles faced by asylum applicants in appealing a first instance decision in the regular procedure.

According to CSTAF, a total of 510 appeals were lodged against negative asylum decisions in 2025, an increase of around 11% compared to 2024. The outcome of judicial reviews of first instance decisions indicates a 26% success rate at appeal stage. As mentioned in Statistics, these figures do not consistently make a distinction between the type of asylum procedure.

According to the information previously provided by CSTAF, in early 2022, the Working Group for Administrative and Fiscal Justice, created by the Ministry of Justice, proposed an amendment to the Statute of the Administrative and Fiscal Courts[64] that would allow CSTAF to create specialised sections in the Administrative Courts, namely in the field of asylum. In order for this to be implemented, the Statute would have to be amended and the CSTAF would then have to deliberate on the creation of the relevant section.

The national plan for migration and asylum announced in June 2024 by the Government[65] emphasised the work carried out by the Judicial High Council and CSTAF, including the discussions on the creation of a specialised jurisdictional structure for immigration and asylum matters. According to the Judicial High Council[66], the goal is for this structure to have exclusive powers in all matters pertaining asylum and immigration, including administrative law, family and children’s law, and detention and expulsion matters. By the end of 2025, there was no amendment to the Statute of the Administrative and Fiscal Courts that would allow the creation of this specialised jurisdictional structure. According to CSTAF, the creation of a specialised jurisdictional structure may materialise in 2026, should there be sufficient political and legislative will.

Onward appeal

In case of rejection of the appeal, an onward appeal may be presented to the Central Administrative Court (Tribunal Central Administrativo – TCA). This is a full judicial review of relevant facts and points of law,^[67] with automatic suspensive effect.^[68]

The law further provides for an additional appeal with automatic suspensive effect before the Supreme Administrative Court (Supremo Tribunal Administrativo, STA) on points of law but only in exceptional cases of fundamental importance of the appeal for legal and social reasons or to improve the quality of legal reasoning in decision-making more broadly.^[69] STA makes its own assessment and decision on the facts of the case.^[70] In both cases the asylum applicant has 15 days to lodge the appeal.^[71]

The rulings of second instance Administrative Courts (TCA) and the STA are systematically published.^[72]

Unlike previous years, according to information provided by CSTAF, Higher Courts are collecting autonomous data on asylum-related processes. In 2025, 68 appeals were lodged in the TCA against first instance decisions, with an average duration of 55 days. A further 14 appeals were lodged in the STA against second instance decisions, of which only one was accepted for review.

Legal assistance

The Portuguese Constitution enshrines the right of every individual to legal information and judicial remedies regardless of their financial condition.^[74]

 Legal assistance at first instance

The Asylum Act provides for the right of asylum applicants to free legal assistance at all stages of the asylum procedure, which is to be understood as including the first instance of the regular procedure.^[75] Such legal assistance is to be provided without restrictions by a public entity or by a non-governmental organisation in line with a Memorandum of Understanding (MoU).^[76]

Furthermore, under the Asylum Act, UNHCR and CPR as an organisation working on its behalf must be informed of all asylum applications and are entitled to personally contact all asylum applicants irrespective of the place of application to provide information regarding the asylum procedure, as well as regarding their intervention in the procedure (dependent on the consent of the applicant).^[77] These organisations are also entitled to be informed of key developments in the asylum procedure upon consent of the applicant,^[78] and to present their observations at any time during the procedure pursuant to Article 35 of the 1951 Refugee Convention.^[79]

In practice, CPR provides free legal assistance to spontaneous asylum applicants during first instance procedures on the basis of previous MoUs with the Minister for Home Affairs and UNHCR. It should be noted that the Minister responsible for migration has not signed a MoU solely for this purpose with CPR since AIMA began its operations. Nevertheless, CPR has continued to provide legal assistance under its operational partnership with UNHCR. The legal assistance provided by CPR at this stage includes:

• Providing information regarding the asylum procedure, rights and duties of the applicant;
• Conducting refugee status determination interviews in order to assist the applicants in reviewing and submitting comments/corrections to the report narrating the most important elements of their interview/application with the determining authority;
• Providing AIMA with observations on applicable legal standards and country of origin information (COI);
• Providing assistance in accessing free legal aid for appeals; and
• Assisting lawyers appointed under the free legal aid system in preparing appeals with relevant legal standards and COI.

Regarding particularly vulnerable asylum applicants, CPR provides specific legal assistance to unaccompanied asylum-seeking children. This includes the presence of a legal officer during the personal interview with AIMA (see Legal Representation of Unaccompanied Children) as well as the provision of information and assistance in the framework of procedures before the Family and Juvenile Court.^[80]

CPR also provides legal information and assistance to beneficiaries of international protection, including resettled refugees. This includes, for instance, providing information on the legal status, providing information and assistance in family reunification procedures, nationality acquisition and other integration-related matters, and submitting observations on applicable legal standards when relevant.

In 2025, CPR provided legal support to 1,139 spontaneously arrived and relocated asylum applicants in all types of asylum procedures lodged throughout the year, which represents around 65% of the total number of applications communicated to CPR according to the law (1,759) and the total number of applicants registered by the national authorities (1,765).

All the applicants whose cases are communicated to CPR that are not provided accommodation by the organisation are sent a letter setting out details of the legal assistance provided by CPR and relevant contacts. Bilateral contacts are also established with other organisations responsible for the reception of applicants for international protection. There are other organisations that provide legal information and assistance to asylum applicants such as JRS and Crescer. According to available information, other services remain residual, non-specialised and mostly focused on integration.

According to AIMA, under the current reception model, the entities responsible for accommodating applicants subject to accelerated/admissibility procedures also ensure the provision of legal support (see: Housing). In CPR’s experience, many of these entities do not have legal experts on their staff.

From 2026, UNHCR ceased its responsibility for funding the free legal assistance provided by CPR, which, under EU and national legislation, had never been its responsibility. In this context, at the end of 2025 CPR informed the authorities that it would be unable from 2026 onwards to provide free, universal and systematic legal assistance to all applicants for international protection in Portugal if the State failed to fulfil its obligations under current legislation. Despite repeated attempts by CPR, as of May 2026, there had been no progress.[81]

A number of decisions from TCA South issued in 2021 focused on the right of the applicant to request legal aid in order to have a lawyer present during the interview. According to the analysed decisions, the Court overall considers that:

• Applicants for international protection may request legal aid in order to have a lawyer present in the asylum interview;^[82]
• The performance of the asylum interview without a lawyer present per se does not violate the Portuguese Constitution;^[83]
• To effectively guarantee the applicant’s rights, the asylum authority must fully and correctly inform the applicant of the possibility to be accompanied by a lawyer in the interview and of the possibility to apply to legal aid to that purpose. If that does not happen, the decision on the asylum application may be annulled.^[84]

The appeal of one such case was decided by the Supreme Administrative Court (STA) in 2022.^[85] Overall, the Court considered that:^[86]

• CPR does not have legal representation powers, and its role does not prevent representation by certified lawyers;
• The Asylum Act determines that legal assistance in the administrative stage of the procedure is primarily provided by CPR, which is due to the non-governmental character of the organisation, its independence, impartiality and the gratuity of the support provided;
• While the role of CPR’s legal officers is not equivalent to that of certified lawyers, they are particularly suited to provide assistance in first instance procedures due to their specialisation in the field of asylum;
• The law provides CPR and UNHCR broad intervention powers in the asylum procedure;
• The legal framework as a whole does not lack avenues to access adequate legal assistance and information.

As such, the Court ruled that the asylum authority is not bound by a duty to inform applicants of international protection that they may request legal aid for the purposes of legal representation within the administrative stage of the procedure. Furthermore, it considered that, in extremis, CPR legal officers will explain the differences between the different types of assistance to applicants and facilitate access to legal aid if the applicant so wishes.

Legal assistance in appeals

Regarding legal assistance at the appeal stage, the Asylum Act provides for the right of asylum applicants to free legal aid in accordance with the law.^[87]

The legal framework of free legal aid provides for a ‘means assessment’ on the basis of the household’s income,^[88] as only applicants who do not hold sufficient income are entitled to free or more favourable conditions to access legal aid.^[89] The application is submitted to the Institute of Social Security (Instituto da Segurança Social, ISS) that conducts the means assessment and refers successful applications to the Portuguese Bar Association (Ordem dos Advogados).^[90]

The Bar appoints a lawyer,^[91] on the basis of a random/automatic selection procedure.^[92] The sole responsibility for organising the selection lies with the Portuguese Bar Association but such procedure should ensure the quality of the legal aid provided.^[93]

While the average duration of this procedure in 2025 was around 2-3 weeks in the Lisbon district, CPR is aware of delays of several months in other districts, particularly in the means assessment conducted by the ISS. The law provides for the suspension of the time limit for the appeal upon presentation of the free legal aid application and until the appointed lawyer submits the judicial appeal.^[94]

The national legislation provides for a ‘merits test’ to be conducted by the appointed lawyer. Accordingly, free legal assistance can be refused on the basis that the appeal is likely to be unsuccessful. In that case, the appointed lawyer can excuse themselves from the case and the Portuguese Bar Association can choose not to appoint a replacement.^[95]

CPR supported the submission of 641 applications for legal aid in the course of 2025. While a breakdown of application by type of procedure is not available, the overwhelming majority of such requests followed refusals in accelerated and Dublin procedures.

In general, asylum applicants enjoy unhindered access to free legal aid at appeal stage. However, in 2025, due to changes of accommodation location, resulting in significant distances, and/or lack of stable access to a letterbox, many applicants were unable to access legal aid at their place of residence, namely a lawyer with whom they could meet face-to-face. This led to situations where, in practice, applicants have been unable and/or unaware of the appointment of a lawyer.

Moreover, the practical implementation of the ‘means test’ conducted by ISS, and of the ‘merits test’ conducted by appointed lawyers have occasionally raise some concerns:

• In the case of the ‘means test’ conducted by the ISS, as reported in previous years, the fact that some asylum applicants are employed has at times resulted in asylum applicants having a level of income that excludes them from the free legal aid regime. In this case, given the usually limited levels of income, applicants can still be offered more favourable conditions to access legal aid such as payment in instalments. Occasionally, CPR has been informed of cases where legal aid requests by applicants within the regular procedure have been refused due to the residency documents presented and to the lack of proof of income (notably where such applicants were benefiting from social support provided by the ISS due to the lack of income). In addition, with the decentralisation of reception conditions for applicants in district centres other than Lisbon, there have been notifications to present documents that are incompatible with applicants’ situation of vulnerability in national territory and with the duration of their stay (e.g. bank statements; copies of land registry books; copies of property registry; a declaration from the Bank of Portugal attesting to the number of bank accounts; IRS declaration for the previous year, etc.). Up until now, this practice has mostly impacted applicants within Dublin/Admissibility/Accelerated procedures.
• In the case of the ‘merits test’, as reported in previous years, the practice of the Portuguese Bar Association remains inconsistent. CPR has observed cases where, following a refusal by the appointed lawyer to provide free legal aid on the grounds that the chances of success were limited, the Bar Association chose not to appoint a replacement. In some instances, this happened following the assessment of only one lawyer. The objective criteria for such decisions remain unclear. While CPR has provided support in the submission of revision requests, the Bar Association generally considers that it is up to the appointed lawyer to analyse whether the applicant’s position is legitimate and legally viable. As such, reversals are systematically refused.^[96] Up until now, this practice has mostly impacted applicants within Dublin/Admissibility/Accelerated procedures. This remains a concerning practice that may have an impact on the effective access to legal aid by asylum applicants.

Additional persisting challenges in this regard include the absence of an easily accessible interpretation service, which hinders communication between the lawyer and the client during the preparation of the appeal. Although AIMA’s translation hotline can constitute a useful tool in this regard, according to CPR’s experience, it is insufficiently used by lawyers.^[99] Moreover, the expenses for the preparation of the appeal, including for interpretation and translation of documents, need to be paid in advance by the appointed lawyer who can then ask the court for reimbursement.^[100]

A worrying practice identified in one instance in early 2026 was that the Bar Association made the recognition of the viability of an applicant’s case contingent upon the applicant being accompanied by an interpreter of their native language. Such a requirement runs counter to the system of access to justice and the courts, which should ensure that ‘no one is hindered or prevented, on account of their social or cultural background, or due to a lack of financial means, from knowing, exercising or defending their rights.’[101]

^[1] Article 28(2) Asylum Act.

^[2] Ibid.

^[3] Article 27(1) Asylum Act. Ministerial Order 597/2015 provides for the model and technical features of the provisional residence permit.

^[4] Article 129 Administrative Procedure Code; Article 66(1) Administrative Courts Procedure Code.

[5] Ombudsperson, Relatório à Assembleia da República 2024, July 2025, available here, 51.

[6 ECRI, ECRI Report on Portugal – sixth monitoring cycle, June 2025, available here, 21.

^[7] Human Rights Committee, Concluding Observations on the fifth periodic report of Portugal, CCPR/C/PRT/CO/5. 28 April 2020, par.35(a) and (b), available here.

[8] This has also been confirmed by Aldeias de Crianças SOS and Crescer to the 2025 AIDA Report.

^[9] Time comprised between the date of the application and the date of issuance of the first instance decision on the (regular) asylum procedure.

^[10] Sandra Roberto, Carla Moleiro, ed. Observatório das Migrações, De menor a maior: acolhimento e autonomia de vida em menores não acompanhados, April 2021, p.43, available here.

[11 Público, Pedidos de asilo pendentes duplicam e chegam quase aos 8800, 28 March 2026, available here.

^[12]  Eurostat, Persons subject of asylum applications pending at the end of the month by citizenship, age and sex – monthly data, available here.

[13] It is not clear whether a regular procedure decision has been reached in all cases, as neither the number of decisions nor the average duration are corroborated by decisions communicated by AIMA to CPR in 2025.

^[14]  Article 16(1) (2) and (3) Asylum Act.

^[15] Article 16(5) Asylum Act.

^[16] Article 16(6) Asylum Act.

^[17] Article 16(1) Asylum Act.

^[18] Article 49(1)(d) Asylum Act.

^[19] Article 49(7) Asylum Act.

[20] Pursuant to Article 16(5)(a) Asylum Act.

[21] Practice-based observation by CPR, January 2026.

[22] Article 20(1) Asylum Act.

[23] For further information on these practices, please see previous updates to this report: AIDA, Country Report: Portugal, available here.

[24] Practice-based observation by CPR, January 2025.

[25] In August 2025, AIMA affirmed that in response to a significant increase in applications for international protection registered from February 2024 onwards, the authorities temporarily conducted interviews using a ‘simplified script tailored to specific cases.’ According to AIMA, as standard case processing was reinstated during the second half of 2024, interviews were conducted in accordance with regular protocols.

^[26] In some cases, applicants in such situations have also reported not being provided adequate food in the meantime.

[27] In August 2025, AIMA affirmed that this procedure was not applied throughout 2024, but only in the first half of the year, monitored by UNHCR, and ended in July 2024; that it was applied exclusively to cases considered manifestly unfounded; and that all applicants were duly informed of their ‘right to waive the period established under Article 17(2)’ with a clear explanation of the legal framework and implications of this legal provision. CPR maintains that it is deeply worrying that the authority proposed the relinquishment of this right to the applicants to begin with, especially at a time where interviews were conducted in the same day of the presentation of the asylum application and/or without the applicants having access to legal information and assistance before making a decision on waiving this right. Moreover, it remains unclear the criteria considered by the asylum authority to deem an asylum application as manifestly unfounded before or during the interview, given that most applications were presented in the same day of the interview. Lastly, the fact that most applications were later 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.

[28] In August 2025, AIMA affirmed that throughout the asylum procedure applicants are consistently asked to indicate the language they communicate and/or understand, so as to ensure that proceedings are conducted in that language. CPR maintains that it has identified worrying practices pertaining to inappropriate language/absence of interpretation in 2024, particularly in the first half of the year, which is consistent with a time when applications were being subject to ‘temporarily accelerated procedures’, as conceded by the Agency, and at a time when interviews were conducted in the same day of the presentation of the asylum application. Cases identified by CPR were consistently reported by the organisation to AIMA.

[29] In August 2025, AIMA affirmed it has demonstrated openness and availability to receive supporting evidence throughout the asylum procedure. While practices pertaining to the refusal to receive evidentiary elements eased during the second half of 2024, and as stated, CPR observed that this occurred during the first semester of the year, which is consistent with a time when applications were being subject to ‘temporarily accelerated procedures’, as conceded by the Agency.

[30] In August 2025, AIMA affirmed that applicants are consistently informed of their right to receive legal assistance and of their right to reply to the interview transcript/report. As thoroughly explained in the 2024 update of the AIDA report, the ‘temporarily accelerated procedures’ adopted by the Agency, particularly during the first half of 2024, were done so to the detriment of imperative procedural guarantees, namely these two rights, as it is shown by the fact that many cases were interviewed and notified of a decision in the same day of the presentation of the asylum application.

[31] This has also been confirmed by JRS to the 2025 AIDA Report.

^[32] Article 119(3) Administrative Procedure Code.

^[33] Article 38(1) Administrative Procedure Code.

[34] In August 2025, AIMA affirmed there is no explicit legal provision requiring such decisions to be communicated to CPR as these administrative acts are provided for in the Administrative Procedure Code. Yet, considering the legal norms established by the Asylum Act that provide for the communication of decisions to CPR for the purpose of monitoring the asylum procedure, it remains unclear why, by analogy (as provided for in Article 10 of the Portuguese Civil Code), this does not occur.

^[35] Article 32(1) Asylum Act.

^[36] Article 31(2) Asylum Act.

^[37] The Asylum Act does not establish a deadline to do so.

^[38]  Article 31(3) Asylum Act.

^[39] Information provided by AIMA to CPR, May 2026. Contrary to the information provided in July 2025, it did not state that there were plans to engage interpreters in EUAA’s trainings.

[40]  Practice-based observation by CPR, January 2026. JRS has a pool of interpreters, which is more comprehensive than AIMA’s Telephone Translation Service and which, according to the organisation, is widely used by various organisations.

^[41]  Article 17(1) Asylum Act.

^[42] For information regarding the evolution of national practice in this regard, please refer to the previous AIDA reports.

^[43] Article 17(2) Asylum Act.

[44] For further information on these practices, please see previous updates to this report: AIDA, Country Report: Portugal, available here.

^[45] Article 17 (1) and (2) Asylum Act.

^[46] Article 17(3) Asylum Act.

[47] Practice-based observation by CPR, January 2026.

[48] In the context of the right of reply of the authorities to the 2024 draft AIDA report (22 August 2025), AIMA affirmed that this procedure was not applied throughout 2024, but only in the first half of the year (until July 2024), monitored by UNHCR; that it was applied exclusively to cases considered manifestly unfounded and that all applicants were duly informed of their ‘right to waive the period established under Article 17(2)’ with a clear explanation of the legal framework and implications of this legal provision.

CPR maintains that it is deeply worrying that the authority proposed the relinquishment of this right to the applicants to begin with, especially at a time where interviews were conducted in the same day of the presentation of the asylum application and/or without the applicants having access to legal information and assistance before making a decision on waiving this right. Moreover, it remains unclear the criteria considered by the asylum authority to deem an asylum application as manifestly unfounded before or during the interview, given that most applications were presented in the same day of the interview. Lastly, the fact that most applications were later 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.

^[49] Article 17(3) Asylum Procedures Directive. Articles 16 and 17 of the Asylum Act do not make a distinction between interviews conducted prior to admission and interviews conducted following admission to the regular procedure.

^[50] Article 33-A Asylum Act.

^[51] TCA South, Decision 139/21.9 BELSB, 23 September 2021, available here. Note that, while the decision systematically refers to subsequent applications, it is indeed analysing the rules applicable to asylum applications made following a removal order (article 33-A Asylum Act).

^[52] TCA South, Decision 3275/22.0BELSB, 23 March 2023, available here.

^[53] Article 30(1) Asylum Act; Article 95(3) Code of Procedure in Administrative Courts.

^[54] Article 30(1) Asylum Act.

^[55] Article 84 Asylum Act.

^[56] Article 71(2) Code of Procedure in Administrative Courts. In practice this is normally the case when the courts find that there are relevant gaps in the assessment of the material facts of the claim, thus requiring the first instance decision body to conduct further investigations.

^[57] Article 71(1) Code of Procedure in Administrative Courts.

^[58] Article 84 Asylum Act.

^[59] Article 30(2) Asylum Act; Article 110 Code of Procedure in Administrative Courts.

^[60] TCA South, Decision 1441/20.2BELSB, 18 March 2021, available here.

^[61] Article 90(2) Code of Procedure in Administrative Courts.; Article 466 Act 41/2013.

^[62] Quite strangely, despite having the possibility of hearing the applicant directly, TAC South determined in a 2019 decision that the opinion of the officer that conducted the applicant’s interview on his/her credibility is relevant as only direct contact with the applicant will allow to ascertain the credibility of his/her statement, as well as his/her general credibility “as a person”. Therefore, in the absence of a gross error of the determining authority, the court cannot query its assessment of the credibility of the statements. TCA South, Decision 713/18.0BELSB, 10 January 2019, unpublished.

^[63] Article 91(2) Code of Procedure in Administrative Courts; Article 606 Act 41/2013.

[64] Act no. 13/2002, of 19 February 2002, relating to the Statute of the Administrative and Fiscal Courts.

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

[66] Público, Novo tribunal vai tratar em exclusivo de processos de imigração e asilo, 6 June 2024, available here.

^[67] Article 149(1) Code of Procedure in Administrative Courts; Article 31(3) Act 13/2002.

^[68] Article 143(1) Code of Procedure in Administrative Courts.

^[69] Articles 143(1) and 150(1) Code of Procedure in Administrative Courts.

^[70] Article 150(3) Code of Procedure in Administrative Courts.

^[71] Article 147 Code of Procedure in Administrative Courts.

^[72] Decisions are available here.

[73] Applicants may apply for legal aid to have representation in the interview (see below), but this does not happen in practice. The access to free legal advice (provided by CPR) of the following box is automatic (i.e. does not entail an application for access to be granted) and incomparably more frequent. Thus, representation in the interview is not considered here as accessible in practice.

^[74] Article 20(1) Constitution.

^[75] Article 49(1)(e) Asylum Act.

^[76] Ibid.

^[77] Article 13(3) Asylum Act. See also Article 24(1) concerning applications at the border; Article 33(3) concerning subsequent applications; Article 33-A(3) concerning applications following a removal procedure.

^[78] Article 17(3) Asylum Act: document narrating the essential facts of the request; Article 20(1): decision on admissibility and accelerated procedures in national territory; Article 24(5): decision on admissibility and accelerated procedures at the border; Article 29(6) first instance decision in the regular procedure; Article 37(5): Dublin take charge decision.

^[79] Article 28(5) Asylum Act. In June 2025, ECRI welcomed the recognition of CPR as an integral part of the national asylum system under the Asylum Act. See: ECRI, ECRI Report on Portugal – sixth monitoring cycle, June 2025, available here, 21.

^[80] These procedures are provided in the General Regime of Civil Guardianship Process, 141/2015, and the Children and Youths at Risk Protection Act, 147/99.

[81] CPR reported this situation to the Ombudsperson in April 2026. Although it began preparations for the handover in 2025, UNHCR confirmed that, as of March 2026, there was no clarity on how legal assistance would be provided on a comprehensive basis.

^[82] TCA South, Decision 2285/20.7BELSB, 21 April 2021, available here.

^[83]  Ibid.

^[84]  TCA South, Decision 806/21.7BELSB, 23 September 2021, available here. TCA South, Decision 2144/20.3BELSB, 7 October 2021, available here.

^[85] STA, Decision 02144/20.3BELSB, 25 January 2022, available here.

^[86]  Following the same reasoning, see also TCA North, Decision 02331/21.7BELSB, 2 March 2022, available here.

^[87] Article 49(1)(f) Asylum Act.

^[88] Act 34/2004, of 29 July relating to access to justice and the courts; Ministerial Order 10/2008.

^[89] Article 8-A and Annex Act 34/2004.

^[90] Article 22 Act 34/2004.

^[91] Article 30 Act 34/2004.

^[92] Article 2(1) Ministerial Order 10/2008.

^[93]  Article 10(2) and (3) Ministerial Order 10/2008.

^[94] Article 33(4) Act 34/2004. See e.g., TCA South, Decision 10733/13, 2 April 2014, available in Portuguese here.

^[95] Article 34(5) Act 34/2004.

^[96] In such cases, the solution suggested by the Bar Association is to file a new application for legal aid, which raises questions with regard to respect for the applicable deadlines and the efficiency of the solution.

^[97]  Article 3(3)(c) Regulation of the Bar Association 330-A/2008 of 24 June 2008.

[98] This has also been confirmed by JRS to the 2025 AIDA Report.

^[99]  ACM’s interpretation hotline relied on a database of 60 interpreters/translators to enable communication with non-Portuguese speaking citizens. Access was free of charge (cost of a local call) and the line could be used on working days, between 9:00 and 19:00. It was possible to request the interpretation immediately (upon availability of interpreter) or to schedule a call. With the termination of ACM’s activity, the management of this hotline was transferred to AIMA. Since the beginning of 2024 access to the service is conditioned upon email request. Direct access by phone is theoretically available through AIMA’s general contact but, according to CPR’s experience, contact through this avenue is not practically possible. Additional information, including the list of languages covered, is available here.

^[100] Article 8(3) Ministerial Order 10/2008.

[101] Article 1(1) Act 34/2004.