The Portuguese authorities are bound by a duty to issue travel documents to refugees and beneficiaries of subsidiary protection.
The refugee travel document consists of an electronic travel document, following the Refugee Convention format, which is valid for an initial one-year period and is renewable for identical periods. The document is to be issued unless imperative national security/public order require otherwise. The authorities competent for granting refugee travel documents consist of the National Director of SEF for applications made on the national territory, and consulates for applications made abroad.
A 2020 Ministerial Order determined that refugee travel documents were to be issued electronically and updated the corresponding cost. As such, since September 2020, according to the law, the issuance of refugee travel documents had a cost of €21.66. Until then, it was free of charge. According to the information provided by SEF, refugee travel documents issued since September are electronic.
While not amending the general provision on the validity of the refugee travel documents, according to the 2020 State Budget Act, such documents were valid for 5 years. It is unclear how this provision has been implemented.
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 national security/public orders requires otherwise.
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. The standard for this analysis is not further specified by law and guidance in this regard is not publicly available. The Portuguese passport for foreigners is valid for a period of up to two years, and in 2020 it had a cost of €111.
According to SEF, in 2020 a total of 135 travel documents were issued to beneficiaries of international protection, of which 113 to refugee status holders and 22 to beneficiaries of subsidiary protection.
According to the experience of CPR, the length of the procedure for issuing a travel document can be considered reasonable overall and does not exceed a couple of months.
In 2017, CPR recorded multiple instances of refusal of requests of a Portuguese passport for foreigners by beneficiaries of subsidiary protection from Ukraine. Despite the beneficiaries’ claims, SEF considered that they could contact the Ukrainian authorities for the issuance of travel documents or use passports previously issued by them and that were still valid. CPR has not recently received similar reports. According to the statistics provided by SEF, no request was refused in 2020.
 Article 69 Asylum Act; Article 19 Immigration Act.
 Ministerial Order 302/2015 of 22 September 2015 and Ministerial Order 412/2015 of 27 November 2015.
 Article 69(1) Asylum Act.
 Article 19 Immigration Act.
 Article 69(1) Asylum Act.
 Article 20 Immigration Act.
 Article 184 Act 2/2020 of 31 March.
 Article 69(2) Asylum Act.
 Decree-Law 83/2000 of 11 May 2000, as amended by Decree-Law 138/2006 of 26 July 2006.
 Article 38 Decree-Law 83/2000 of 11 May 2000.