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Immigration Policy

How to Respond to an AIMA Refusal Notice & Exercise Your Preliminary Hearing Rights (Portugal, 2025)

Received an AIMA refusal notice? Learn how to respond to a preliminary hearing notice, prepare a strong defence, and maximise your chances of residence permit renewal approval in Portugal.

Guilherme Lima - Founder & CEO

Guilherme Lima

Founder & CEO

October 22, 2025
8 min read
How to Respond to an AIMA Refusal Notice & Exercise Your Preliminary Hearing Rights (Portugal, 2025)

Received a notification from AIMA (Agência para a Integração, Migrações e Asilo) about a possible refusal of your residence permit renewal? Don't panic — this notice usually opens a preliminary hearing (a legal opportunity to present a defence), not an automatic refusal. At GetFastVisa, we specialise in Portuguese immigration support and help applicants respond to AIMA refusal decisions, prepare a strong preliminary hearing response, and maximise the chances of a successful renewal.

Important: If your notification contains the Portuguese phrase "Projeto de Decisão de Indeferimento — audiência prévia de interessados", that is the same preliminary hearing process explained below (Article 78.º, n.º 2 of Law 23/2007). The notice is normally sent in Portuguese by AIMA, so search for those exact words in the AIMA Renewal Portal if you need to confirm it.

What This Notice Means (and What It Doesn't)

A preliminary hearing notice from AIMA does not automatically mean your renewal is denied. Instead, AIMA is signalling an intent to refuse unless you present clarifications or documentation within the stated deadline. This is your legal right under Portuguese immigration law — an opportunity to correct or complete your file before a final decision.

Think of it as AIMA giving you a chance to address their concerns before they make a final determination. Many applicants successfully overturn proposed refusals by submitting a well-prepared response during this preliminary hearing phase.

Article 78.º, n.º 2 of Law 23/2007 (Foreigners Law) guarantees the right to a preliminary hearing before any administrative refusal is finalised. AIMA must:

  • Notify you of the proposed refusal
  • State the reasons that justify the possible refusal
  • Set a deadline for you to respond
  • Consider your defence before issuing the final decision

This legal protection ensures due process and gives applicants the opportunity to address any issues or misunderstandings before a final administrative decision is made.

Common Reasons AIMA Issues a "Project of Decision of Refusal"

From GetFastVisa's experience helping D7 and D8 visa holders and residents, the most frequent issues flagged are:

1. Insufficient Means of Subsistence

Incomplete proof of required income (bank statements, payslips, contracts). AIMA requires clear evidence that you can support yourself financially during your stay in Portugal.

2. Absence of Social Security (NISS)

Missing NISS (Número de Identificação da Segurança Social) or no proof of Social Security contributions. This is a common issue for new residents who haven't yet registered with Portuguese Social Security.

3. Tax Irregularities / Tax Clearance (AT)

Missing tax debt certificate or proof of regularity with Finanças (Portuguese Tax Authority). You must be up-to-date with your tax obligations.

4. Social Security Irregularity

Outstanding contributions or incomplete documentation related to Social Security payments or registration status.

5. Accommodation Proof Issues

Problematic lease, declaration of hospitality (termo de responsabilidade), or lack of proof of address. AIMA needs to verify where you're actually residing in Portugal.

6. Missing Apostilles or Uncertified Translations

Documents without apostille or certified translation for portal upload. Foreign documents must be properly authenticated and translated.

The notice usually specifies the reason in Instructor's observations or under c) Other information section of your AIMA portal notification.

Deadlines & How to Respond

⏰ Time is critical. The notice sets a deadline (commonly 10 business days) to submit your defence and documents via the AIMA Renewal Portal. After the deadline the portal can close uploads, so act quickly.

How to Prepare Your Response:

  1. Read the notification carefully and identify the exact objection raised by AIMA.
  2. Gather the missing documents (NISS, tax clearance, bank statements, employment contracts, certified translations, apostilles).
  3. Prepare a clear, factual defence that addresses AIMA's concerns and shows compliance with residency criteria. Use Portuguese or have your response professionally translated.
  4. Submit via the AIMA Renewal Portal or in person (VFS appointment or AIMA mission office) as the notice specifies.
  5. Save copies and timestamps of all uploads for your records.

GetFastVisa Services and Practical Support

GetFastVisa provides tailored support for Portuguese visas and residence permit renewals. We offer:

📋 Rapid Case Triage

Quick assessment of your AIMA notice and identification of required documents and response strategy.

📝 Document Checklists

Customised checklists for D7 and D8 renewals tailored to your specific situation.

✍️ Response Preparation

Draft and format responses to AIMA's preliminary hearing that directly address their concerns with supporting evidence.

🏛️ Portal & VFS Guidance

Step-by-step help with AIMA portal uploads and VFS appointments.

🔒 NISS & Tax Clearance

Secure NISS registration and obtain Tax Clearance certificates from Finanças.

🌐 Translations & Apostilles

Coordinate certified translations and apostille services for all required documents.

Our team knows the evidential standards AIMA expects for different visa categories — whether you're renewing a D7 (passive income / digital nomad / retiree) or a D2 (entrepreneur / business) permit — and we prepare responses that directly address AIMA's points with supporting documentation.

Practical Document Checklist (Quick)

When preparing your response, ensure you include at minimum:

  • Recent bank statements proving subsistence (clear, dated, covering required period)
  • Employment contract / proof of income (payslips, invoices for self-employed)
  • NISS / Social Security registration proof or evidence of contributions
  • Tax Clearance (AT) certificate showing no outstanding tax debt
  • Proof of accommodation (rental agreement, declaration of hospitality, utility bills)
  • Certified translations and apostilles for foreign documents
  • Additional evidence where relevant: employer letters, school enrolment, medical records

Strategy & Professional Recommendation

Although you can respond personally, professional support is strongly recommended for complex cases, cross-border income, or self-employment evidence. An expert can:

  • Identify submission errors that could lead to refusal
  • Anticipate AIMA's counter-arguments and address them proactively
  • Maximise the chance of reversing a proposed refusal
  • Prepare appeal strategies if needed
  • Save you time and reduce stress during tight deadlines

💡 Good News: An initial proposed refusal is not the end. Many cases are successfully overturned with a well-documented preliminary hearing response, and administrative appeals are available when needed.

After You Submit Your Response

  • AIMA will review your defence — processing commonly ranges from 30–60 days, though times can vary.
  • Monitor the AIMA Renewal Portal and your email for updates regularly.
  • If the final decision is a refusal, administrative appeal options exist — GetFastVisa can refer trusted immigration lawyers to evaluate the merits and prepare filings.

Emergency Turnaround & Urgent Packages

If your deadline is close, GetFastVisa offers urgent response packages that include:

  • Same-day document triage — urgent case assessment
  • Expedited response drafting — preliminary hearing reply preparation
  • Priority portal upload guidance — step-by-step AIMA portal assistance
  • Fast-track VFS appointments — urgent booking assistance
  • Rush tax and social security certificates — expedited document retrieval
  • Express translations and apostilles — ready-to-submit certified documents

We prioritise time-critical AIMA refusals and understand the stress of tight deadlines. Our team works quickly to ensure your response is complete, accurate, and submitted on time.

Why Choose GetFastVisa?

GetFastVisa delivers practical, fast, and precise support across the Portuguese immigration process — from initial visa applications to AIMA preliminary hearing responses, VFS bookings, and administrative appeals.

🚨 Received a Project of Decision of Refusal?

Contact GetFastVisa for an urgent review — we'll provide a clear checklist, draft a strong response, and help submit everything on time.

🔗 AIMA Renewal Portal

Check your notification for the exact link to access your application and preliminary hearing response portal.

Visit AIMA Official Website →

📜 Law 23/2007 (Foreigners Law)

Article 78.º on preliminary hearing rights (audiência prévia de interessados).

Read Full Legal Text →

🏢 Portuguese Tax Authority (Finanças)

Portal das Finanças for tax clearance certificates and tax compliance.

Access Portal das Finanças →

👥 Portuguese Social Security

Segurança Social for NISS registration and contribution verification.

Visit Segurança Social →

📑 Apostille Information

Hague Conference on apostille requirements for document authentication.

Learn About Apostille →

Disclaimer: This article provides general information about AIMA preliminary hearing procedures and is not legal advice. For specific legal guidance on your case, consult a qualified Portuguese immigration lawyer. GetFastVisa provides administrative support and document preparation services but does not offer legal representation.

Tags

AIMA refusalPortugal residence permitpreliminary hearingaudiência préviaD7 visa renewalD8 visa renewalPortugal immigrationAIMA appealresidence permit refusal
Guilherme Lima - Founder & CEO

Guilherme Lima

Founder & CEO

Guilherme is the founder and CEO of GetFastVisa, a serial entrepreneur who previously co-founded two Fintechs recognized by the Central Bank of Portugal for his initiatives. Through his company and team, he has helped hundreds of applicants navigate the Portuguese visa application process by streamlining visa services and appointment booking, making Portugal relocation more accessible for digital nomads and entrepreneurs worldwide. Please note: Guilherme is not an attorney and does not provide legal advice.

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