Author
Responsibility for reception
Since 29 October 2023, the primary responsibility for the provision of material reception conditions is assigned to the Ministry in charge of Migration.[1] Nevertheless, the responsibility for the provision of material reception conditions to asylum applicants who pass the admissibility procedure and are in the regular procedure lies with the Ministry of Employment, Solidarity and Social Security.[2] The authorities can cooperate with other public entities and/or private non-profit organisations within the framework of a MoU to ensure the provision of such services.[3]
In the past, the practical framework for the reception of asylum applicants in Portugal stemmed from bilateral MoUs,[4] the resolution of the Council of Ministers no. 103/2020 of 23 November 2020, establishing a single system of reception and integration of applicants for and beneficiaries of international protection, and the internal regulations of the Single Operative Group (SOG) it created.[5] The process of termination of the activity of SEF and ACM led to the suspension of the activity of the SOG,[6] with the exception of the social monitoring subgroup, which continues to meet, but bilaterally.
This social monitoring subgroup is the structure for referral and follow-up on the provision of reception conditions to spontaneous asylum applicants, taking into account, furthermore, the transfer of powers between ministries. The meetings are chaired by AIMA and take place fortnightly. In 2025, attendance at these meetings was limited to AIMA, which holds primary responsibility for the provision of material reception conditions under the Ministry in charge of Migration, the reception entity where the applicant was accommodated during the accelerated/admissibility procedure, and the entity to which the referral is made, under the responsibility of the Ministry of Employment, Solidarity and Social Security (ISS or SCML). There is no involvement of other reception entities, and the meetings do not serve as a space for broader discussion.
According to ISS, since October 2024, the criteria for determining the entity responsible for the provision of material conditions under the responsibility of the Ministry of Employment, Solidarity and Social Security is based on the location of the applicant’s residence at the time of referral: SCML is responsible for applicants residing in the municipality (not district) of Lisbon, while ISS is responsible for the remainder. Previously, the determining criterion was the stage of the procedure: ISS was responsible for applicants admitted to the regular procedure and SCML for those at appeal stage following inadmissibility or rejection.
In practice the following entities are competent to provide reception conditions to spontaneous applicants, depending on the type and stage of the procedure and/or the profile of the applicant:
- The Institute for Social Security (ISS) provides material receptions conditions to asylum applicants residing outside the municipality of Lisbon, following admission to the regular procedure or rejection in an accelerated/admissibility procedure, as well as certain categories of asylum applicants such as unaccompanied children;
- Santa Casa da Misericórdia de Lisboa (SCML) provides material reception conditions to asylum applicants residing in the municipality of Lisbon, following admission to the regular procedure or rejection in an accelerated/admissibility procedure;[7]
- The Agency for Integration, Migration and Asylum (AIMA) provides accommodation to asylum applicants in the admissibility (including Dublin) and accelerated procedures in national territory, through its Reception Management Unit. AIMA does not have its own reception facilities and cooperates with other entities within the framework of a MoU/contract service to ensure the provision of accommodation;
- While the Asylum Act determines that the Ministry in charge of migration is responsible for the provision of material reception conditions to applicants detained at the border,[8] the Public Security Police (PSP) manages the provision of material reception conditions within the context of border procedures and procedures in detention following a removal order (see Conditions in Detention Facilities) due to the transfer of competences previously assigned to SEF. PSP is a police authority under the Ministry of Home Affairs.[9]
Since the beginning of AIMA’s operations, some changes have occurred in the practical arrangements in place for the provision of material reception conditions to asylum applicants. As documented in previous editions of this report,[10] from the end of 2023 CPR faced significant constraints in ensuring accommodation to all spontaneous asylum applicants, linked to capacity limitations and funding delays during the transition between financial frameworks.[11] According to AIMA, as a contingency measure, the Agency initially provided accommodation directly through the youth hostel network (Movijovem – Pousadas da Juventude). From the second half of 2024, AIMA expanded its reception capacity by signing MoUs/contract services with new reception entities, namely Adolescere, Convento Balsamão, JRS, and Together International, in addition to CPR.
According to AIMA, in 2025 the Agency provided accommodation through 5 main reception entities (CPR, Adolescere, JRS, Convento de Balsamão, and Amato Lusitano). The Agency also resorted to the youth hostel network.
Civil society organisations continued to face significant financial difficulties in 2025. As the State channels funding mostly through AMIF and projects are implemented for a limited period, organisations must continuously apply to new funding calls, while ensuring uninterrupted provision of accommodation. Responses to these applications are frequently delayed, meaning in practice organisations have not yet received a response by the time implementation is due to begin. Furthermore, organisations are subject to substantially reduced values at the tender stage (5%) and significant delays in reimbursement during project implementation, requiring them to advance funds without certainty as to when reimbursement will occur, undermining the predictability and stability of the reception system. This situation led at least one organisation to cease accommodating asylum applicants altogether, as was publicly reported, resulting in the loss of around 154 places in the reception system.[12]
In a response to Parliament in December 2025,[13] the Government stated that AIMA had monitored the situation throughout 2025 and maintained regular dialogue with the host entity. While not answering directly regarding the need for a more stable financing model than AMIF funding, the Government stated that there was no interruption in accommodation provision and that the reorganisation of the national reception system was foreseen under the National Implementation Plan of the EU Pact on Migration and Asylum.[14]
The right to reception and sufficient resources
The law provides for the right of asylum applicants to material reception conditions regardless of the procedure they are in,[15] with the exception of a possible withdrawal or reduction of those conditions in the case of ‘unjustified’ subsequent applications.[16]
Asylum applicants are entitled to support from the moment they apply for asylum,[17] and until a final decision is reached on their asylum application,[18] without prejudice to: (i) the suspensive effect of appeals,[19] and (ii) the provision of material reception conditions beyond the final rejection in case of ongoing need for support on the basis of an individual assessment of the applicant’s social and financial circumstances.[20]
Only asylum applicants who lack resources are entitled to material reception conditions.[21] The law provides for criteria to assess the sufficiency of resources that consist in either the lack thereof or a level of financial resources which is inferior to the ‘social support allowance’,[22] which until 2023 was interpreted by ISS as referring to the social pension (pensão social).[23] From 2023 onwards, this has been interpreted as referring to a reference value of the Social Support Reference Index (Indexante de Apoios Sociais, IAS),[24] updated annually (see Forms and levels of material reception conditions). According to ISS, cases are reassessed every three months and the provision of material reception conditions is maintained where indicators of a lack of resources subsist.
Asylum applicants can be requested to contribute,[25] or reimburse,[26] partly or in full, the cost of material reception conditions and health care depending on the level and the point in time when the authorities become aware of their financial resources. However, neither the law nor administrative guidelines specify at what point the asylum applicant is required to declare any financial resources they might have.
According to AIMA, following referral by CNAR, the Reception Unit carries out a social assessment, including a reassessment of vulnerabilities and evaluation of the applicant’s economic means. Based on this assessment, the applicant is informed of the reception or support model for which they are eligible, or that they do not meet the criteria for economic support. Where eligible for accommodation, the necessary consents are collected and the applicant is informed of the reception entity to which they will be referred. AIMA’s criteria for selecting a host entity at the time of referral are unclear, including whether the allocation of applicants among reception centres follows predefined criteria or is based solely on capacity management and the availability of places.
CPR does not proactively engage in means assessments for the duration of the provision of material reception conditions given that access to paid employment is, in practice, limited at this stage. Nonetheless, if the applicant has an employment contract, the termination of this provision may be negotiated. The policy of AIMA and the other host entities in this regard is unclear.
In previous years, and despite practical challenges and concerns, spontaneous asylum applicants did not face systematic obstacles in gaining access to available material reception conditions (e.g., due to delays in the issuance of the individual certificate of the asylum application or a strict assessment of resources).
Since late 2023, AIMA has been directly providing accommodation to asylum applicants in the admissibility (including Dublin) and accelerated procedures under the competencies assigned by the Asylum Act to the Ministry in charge of Migration.[27] In 2024, CPR received consistent reports of significant issues affecting applicants accommodated directly by AIMA, particularly through the youth hostel network, including lack of information, isolation, lack of access to material reception conditions, and instances of withdrawal of accommodation following notification of a negative decision. AIMA denied this occurred.[28]
In 2025, while the difficulties documented in 2024 appear to have diminished somewhat, several concerns persisted. As conceded by AIMA, access to services continued to be hampered by difficulties in contacting AIMA outside Lisbon, with registration of asylum applications only accepted in Lisbon, Porto and Coimbra, directly impacting the provision of reception conditions. Cases were also reported of applicants being told they required appointments or being directed to other AIMA offices. Reports of a lack of information, social support and reception solutions following the presentation of an application persisted, including reports of applicants (notably those released from administrative detention facilities) having to resort to the 144 social emergency line due to the absence of reception solutions.
Furthermore, difficulties encountered in accessing AIMA services to obtain information notably outside of Lisbon, carry out procedural formalities or renew documentation 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. AIMA argues that most reception entities are located in major urban areas, where direct access to services is possible. However, based on CPR’s experience in providing legal support, applicants accommodated in Braga have to travel to Porto to be assisted by AIMA’s services. The same applies to applicants in Macedo de Cavaleiros. As for applicants in Castelo Branco, they have to travel to Lisbon.
Access to the accommodation provided by the host entities – such as CPR’s Refugee Reception Centre (Centro de Acolhimento para Refugiados, CAR) that accommodates isolated adults and families – is dependent on written referral from AIMA-CNAR. The same stands for the provision of material conditions such as financial assistance by CPR to asylum applicants who have opted for private housing with relatives.
Following admission to the regular procedure, or if the application is deemed inadmissible or is rejected in an accelerated procedure,[29] the asylum applicant is generally referred by frontline service providers to the social monitoring subgroup chaired by AIMA. The subgroup decides on the provision of material reception conditions in the regular procedure or at appeal stage, based on an individual report that includes information on the socio-economic circumstances of the individual. Given that asylum applicants admitted to the regular procedure are often unemployed, and lack financial resources, it is not common to cease the provision of material reception conditions at this point.
Although a 15-day transfer period is specified from the time of notification in the subgroup (30 days in exceptional cases), these deadlines are not always feasible.[30] CPR ensures accommodation until ISS or SCML take over and asylum applicants only leave its facilities when alternative accommodation is secured.
Upon release from detention, asylum applicants may face challenges in accessing reception conditions as AIMA claims not being responsible for reception of applicants already notified of a decision on admissibility, inadmissibility or rejection in an accelerated procedure. It should be noted that, at this stage, the cases have not yet been referred to the ISS or SCML in the context of the social monitoring subgroup. According to PSP, applicants are advised to contact AIMA and ISS to request support upon release. On some occasions, PSP has to take action to identify solutions. CPR received reports of applicants having to resort to the social emergency line (144) due to the absence of reception solutions.
As for unaccompanied children, PSP refers the case to the Family and Juvenile Court. ISS later identifies a reception facility, such as CPR’s CACR, according to the court order.
CPR is aware that in some cases in 2025 the release from detention was delayed due to the lack of reception responses on national territory, including applicants with special reception needs, even where a court order for release had been issued.
According to the report covering 2024,[31] the National Preventive Mechanism reported cases at UHSA and EECIT Lisbon where detention was prolonged, with the detainee’s consent, due to vulnerability and the absence of timely reception solutions. According to the Mechanism, at EECIT Faro, in several cases it was PSP itself – in the absence of action by AIMA – that contacted the 144 social emergency line on behalf of released asylum applicants. The Mechanism recommended that a social assessment be conducted prior to release to identify those in need of support, reiterating that social support for asylum applicants, including reception conditions, is a legal obligation of the Portuguese State.
[1] This includes admissibility procedures (including Dublin procedures); accelerated procedures, border procedures, subsequent applications and applications following a removal decision: Article 61(1) Asylum Act.
[2] Article 61(2) Asylum Act.
[3] Article 61(1) and (2) in fine Asylum Act.
[4] Notably MoUs between the Ministry of Home Affairs / SEF and CPR, between ISS and CPR, and between ISS and Santa Casa da Misericórdia de Lisboa (SCML).
[5] Resolution of the Council of Ministers no. 103/2020 of 23 November 2020, available here. For more information on the main features and subgroups of the SOG, please refer to previous AIDA reports.
[6] The last meeting of the extended line-up of the SOG took place on 20 September 2023.
[7] This stems from a MoU between ISS and Santa Casa da Misericórdia de Lisboa (SCML).
[8] Article 61(1) Asylum Act.
[9] PSP’s competencies at the border were used by AIMA in public statements to reject any responsibility for the situation of asylum applicants detained at the border, a position hardly compatible with the provisions of the Asylum Act. See, for instance: Rádio Renascença, “Há pouco que a AIMA possa fazer” pelos migrantes que dormem no aeroporto, 25 January 2024, available here.
[11] On the one hand, there were significant delays in the provision of AMIF funding at national level, on the other since the beginning of its operations AIMA publicly stated that it wanted to evaluate the provision of services by the organisation before renewing any cooperation frameworks. While AIMA and CPR signed a contract for the provision of accommodation for a limited number of asylum applicants in January 2024, this did not ensure the payment of services previously ensured by the organisation and did not provide sufficient resources for CPR to continue ensuring the usual reception model. In fact, by the end of the 2023 and 2024 the organisation often faced financial constraints leading to delays in the payment of financial allowances to asylum applicants and salaries to employees. See, for instance: Público, Conselho Português para os Refugiados confirma salários e verbas em atraso, 8 January 2024, availble here. AIMA confirmed that the transition between financial frameworks created constraints but affirmed that such constraints had been overcome by June 2024 (Information provided by AIMA on 25 June 2024). Nevertheless, CPR was still experiencing the aforementioned repercussions in the end of 2025, given that the non-payment of the 2023 amounts prevents the organisation from fully recovering financially.
[12] Jornal Expresso, Centros de asilo podem fechar e não há certezas para quem lá vive agora, 20 November 2025, available here.
[13] Parliament, Question 689/XVII/1, December 2025, available here.
[14] Parliament, Answer to Question 689/XVII/1, December 2025, available here.
[15] Articles 51(1) and 56(1)-(2) Asylum Act.
[16] Article 60(3)(f) Asylum Act. The reference to an “unjustified subsequent application” seems to indicate that the potential withdrawal or reduction would only occur at the end of the 10-day admissibility/preliminary assessment as per Article 33(4). AIMA’s practice in this regard is not yet clear.
[17] Articles 51(1), 56(1) and 2(1)(ae) Asylum Act that entitle third-country nationals or stateless persons who have “presented” an asylum application to material reception conditions. The presentation of the asylum application is to be understood as preceding the registration of the asylum claim under Article 13(1) and (7) Asylum Act.
[18] Article 60(1) Asylum Act.
[19] Articles 60(1) in fine and 30(1) Asylum Act.
[20] Article 60(2) Asylum Act.
[21] Articles 51(1) and 56(1) Asylum Act.
[22] Article 56(3) Asylum Act.
[23] Decree-Law no. 464/80. According to the referred Decree-Law, the social pension is measure of solidarity to offer social protection to the most vulnerable populations. It is provided, among others, to nationals, who are not entitled to a pension from the contributory social security system who lack any revenue or whose revenue is below the value of the social pension (Article 1).
[24] Act no.53-B/2006, of 29 December as amended.
[25] Article 56(4) Asylum Act.
[26] Article 56(5) Asylum Act.
[27] Article 61(1) Asylum Act.
[28] Within the context of the right of reply of the authorities to the 2023 draft AIDA report, AIMA noted that all asylum applicants are informed of the available accommodation and its conditions, and that all asylum applicants were offered accommodation. It has also noted that asylum applicants are duly informed of changes to their accommodation arrangements, and that applicants are referred to healthcare authorities. AIMA did not provide further information regarding the procedures and criteria for withdrawal of accommodation. Information provided by AIMA, 25 June 2024.
[29] This includes rejected asylum applicants released from the border after the expiry of the 60-day time limit (see Duration of Detention).
[30] According to JRS, significant delays were observed in ISS’s response following referral.
[31] Ombudsperson, Mecanismo Nacional de Prevenção – Relatório à Assembleia da República 2024, July 2025, available here, 61-62.