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]
Between January 2023 and 28 October 2023, the issuance of the refugee travel document had a cost of €23.65.[9] From 29 October 2023 onwards, the cost increased to € 31,45.[10]
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.[11]
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.[12] 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.[13]
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[14] 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 Portuguese passport for foreigners is valid for a period of up to two years,[15] and, in 2024, had a cost of €111.[16]
The issuance of the Portuguese passport for foreigners is assigned to the Institute of Registries and Notary (Instituto dos Registos e Notariado, IRN).[17] 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.[18]
According to AIMA, 69 refugee travel documents were issued in 2024.[19] No information was provided on the number of Portuguese passports for foreigners issued to beneficiaries of subsidiary protection and family members of beneficiaries of international protection.
According to the experience of CPR, there have been challenges in getting appointments for the issuance of travel documents, in particular due to confusion over which service (AIMA or IRN) is responsible for the issuance. Notwithstanding, the length of the procedure for issuing a travel document can be considered reasonable overall and does not exceed a couple of months.
AIMA did not provide information on refusals for 2024.
[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. 1334-E/2010 of 31 December 2010 last amended by Ministerial Order 204/2020 of 28 August, available here. Amount applied in 2023, according to information publicly available here. Until September 2020 the refugee travel documents issued by the Portuguese authorities were not electronic and their issuance was free of charge.
[10] Ministerial Order no.307/2023 of 13 October, available here.
[11] Article 69(2) Asylum Act.
[12] Decree-Law 83/2000 of 11 May 2000, as amended by Decree-Law 138/2006 of 26 July 2006.
[13] Information provided by AIMA on 22 August 2025.
[14] Article 68(2) Asylum Act.
[15] Article 38 Decree-Law 83/2000 of 11 May 2000.
[16] 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.
[17] 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.
[18] Although there is no official information, it seems to have resumed during 2024.
[19] Information provided by AIMA on 22 August 2025 in the context of the right of reply of the authorities to the 2024 draft AIDA report.