Portugal D2 Business Plan in 2026: What AIMA Actually Accepts

AIMA evaluates Portugal D2 business plans in 2026 against four criteria: the proposed activity must contribute to the Portuguese economy, the financial projections must be internally credible (not optimistic round numbers), the plan must demonstrate a realistic job creation roadmap, and the founder's professional background must match the planned business. Two rules set the bar. The "complete application only" rule AIMA introduced on 28 April 2025 means an incomplete or template-level plan is returned without substantive review, not held pending additional documents. And Lei n.º 61/2025, de 22 de outubro, in force since 23 October 2025, rewrote Article 89 of Lei n.º 23/2007 (REPSAE), the article the D2 residence permit is issued under, tightening the means-of-subsistence test so that it now has to cover every member of the household without recourse to Portuguese social support. Understanding what AIMA looks for in each section of the plan, and which business types routinely fail, is the practical difference between a first-submission approval and a multi-month rejection cycle. The legacy SEF-era backlog was largely resolved by end-2025 (the Estrutura de Missão task force closed 31 December 2025); current pressure is court cases against AIMA, which peaked above 133,000 in October 2025 and stood at about 89,000 on 18 September 2026 after a judicial task force, which runs until 30 January 2027.

The legal stack: Article 60 visa, Article 89 permit

A D2 file passes through two different articles of the same statute, and the business plan is read at both stages.

The consular stage is a residence visa under Article 60 of Lei n.º 23/2007, granted to immigrant entrepreneurs who have either completed an investment operation in Portugal, or can show available financial means in Portugal (including finance obtained from a Portuguese financial institution) together with evidence of the intention to carry out an investment operation there. This is where the business plan does most of its work, because it is the document that evidences that intention.

The in-country stage is the residence permit under Article 89, which covers independent professional activity and immigrant entrepreneurs. Article 89(1) sets out what has to be true by the time the permit is granted:

1. you have incorporated a company under Portuguese law, or declared the start of activity with the tax and social security authorities as an individual, or signed a services contract for the exercise of a liberal profession;
2. you are qualified to exercise the independent activity, where qualification is required;
3. you have means of subsistence as defined by the portaria referred to in Article 52(1)(d);
4. where applicable, you produce a declaration from the relevant professional body that you meet its registration requirements.

The implementing regulation behind AIMA's documentary checklists is Decreto Regulamentar n.º 84/2007, republished by Decreto Regulamentar n.º 4/2022 and amended by Decreto Regulamentar n.º 1/2024, de 17 de janeiro, which adapted it to the dissolution of SEF and the creation of AIMA.

AIMA does not publish a scored rubric for D2 business plan evaluation. Its assessment framework is derived from the purpose stated in Articles 60 and 89, demonstrating viability of the proposed activity in Portugal, combined with those documentary requirements.

What Lei n.º 61/2025 changed

Lei n.º 61/2025 is the most consequential rewrite of the foreigners' law since AIMA replaced SEF. It amended Articles 45, 46, 52, 52-A, 57-A, 75, 87-A, 89, 98, 99, 101, 103, 104, 105, 106, 122 and 123 of Lei 23/2007, and it reached the statute book the long way round: an earlier version was sent for preventive constitutional review, the Constitutional Court declared five norms unconstitutional on 8 August 2025 (among them the restrictions on family reunification and the limits on appealing to the courts against AIMA), the President vetoed it the same day, and Parliament passed a revised text that was published on 22 October 2025.

For a D2 founder the operative change is in the third Article 89(1) condition. The means-of-subsistence requirement is no longer satisfied by showing that the applicant personally can get by: the means must be sufficient to support all members of the household, and sufficient without recourse to Portuguese social support. If you are moving with a partner and children, the savings side of your file has to scale with them, and the business plan's cash-flow bridge should be built on the household number rather than the single-applicant one.

Two timing points matter. Article 8 applies the amendments to administrative and judicial procedures initiated after the law came into force, so any file opened in 2026 is assessed under the new wording. And Article 6 opened a 180-day window from 23 October 2025, which closed in April 2026, for existing Article 88 and 89 permit-holders who met the Article 90(1) conditions to convert their title into a teaching, highly qualified or cultural activity permit. That window is gone; it is mentioned here only because it still circulates in advice written in late 2025.

There is no in-country fallback

Article 89(2), the route that let someone already in Portugal obtain a residence permit for independent activity with the residence visa waived, was revoked with effect from 4 June 2024 by Decreto-Lei n.º 37-A/2024, de 3 de junho, the same instrument that ended the manifestação de interesse regime. Work and independent-activity files now have to start in the applicant's country of nationality or legal residence, with the proper residence visa obtained before travel.

This is worth stating plainly because AIMA's own site still hosts a page describing the Article 89(2) visa-waiver procedure, and second-hand guides written before mid-2024 still present "enter as a tourist, then regularise" as a D2 strategy. It is not one any more. Combined with the "complete application only" rule, it means the consular submission is effectively your one clean attempt: there is no in-country lane to fall back into if the file is returned.

The four things AIMA actually weighs

In practice, consular officers and AIMA reviewers assess four elements:

1. Portuguese economic contribution: will this business create value in Portugal, or is Portugal merely a residency vehicle for a business that operates entirely elsewhere?
2. Financial viability: are the projections credible? Can the applicant sustain the whole household in Portugal during the ramp-up period (minimum savings: €11,040 for a single applicant in 2026, derived from 12 × the 2026 SMN of €920/month, and more where family travels with you: see the household arithmetic below)?
3. Job creation roadmap: does the plan show any intent to employ Portuguese residents or contributors, even at a modest scale?
4. Founder-background fit: does the applicant's CV, professional history, and skill set support the claim that they can execute this specific business?

The D2 business plan section-by-section

Executive summary

AIMA reviewers read the executive summary first and use it to form an initial read on whether the application warrants substantive engagement. A strong executive summary names the business type precisely (e.g., "B2B SaaS product for European logistics SMEs, to be incorporated as a Lda. in Lisbon"), states the planned legal structure, identifies the primary customer segment and their geography, gives a Year 1 revenue target with a one-line justification, and describes the Portuguese nexus explicitly, not as a formality but as a genuine part of the operating model.

What AIMA flags: a summary that could be a copy-paste template. Phrases like "our company will provide innovative services to the market" are read as signals that the rest of the plan will be equally vague. The summary should be specific enough that a reviewer can reject it on the spot if the business type is outside D2 scope, which means it should also be specific enough to demonstrate that it falls within D2 scope.

Market analysis

The market analysis must include a Portuguese economic contribution lens, not just a global or European market sizing. AIMA is not assessing the global TAM; it is assessing whether the activity will contribute to Portugal's economy. A market analysis that says "the global SaaS market is €200 billion" without connecting that to Portuguese revenues, Portuguese clients, or Portuguese employment is treated as non-specific.

A credible market analysis for D2 in 2026 names the specific Portuguese market segment (e.g., logistics SMEs in the Lisbon-Setúbal-Porto triangle), gives a realistic size estimate with a cited source, identifies 3-5 existing competitors in the Portuguese market, and explains the applicant's differentiation. For businesses serving European or global markets from a Portuguese base, the analysis must still articulate why Portugal is the operational hub, e.g., talent market, cost structure, access to EU market, time zone for serving both US and EU clients.

Financial projections

Three-year financial projections are the section where most D2 business plans fail. AIMA is not looking for optimism; it is looking for internal consistency. Projections must show:

• Year 1 monthly revenue build: not a single annual number. Show when the first client is expected, what that client pays, how many clients are expected by month 6 and month 12, and what the churn assumption is.
• Cost structure: fixed costs (rent, salaries, accounting, software subscriptions), variable costs per client or unit, and one-time setup costs. AIMA notices when Year 1 costs are suspiciously low relative to the activity described.
• Cash flow bridge: the applicant must demonstrate they can sustain the household and the business through the initial period without relying solely on business revenues that have not yet materialized. The €11,040 savings minimum is the floor for one applicant; well-prepared applications show 18-24 months of personal runway in conjunction with the business projections.
• Unit economics: for product businesses, revenue-per-customer and customer-acquisition-cost estimates (even rough ones) demonstrate that the founder has done the work. For services businesses, utilization rates and blended hourly rate assumptions serve the same purpose.

Round numbers in financial projections ("Year 1 Revenue: €100,000, Year 2 Revenue: €200,000, Year 3 Revenue: €400,000") without supporting assumptions are a consistent rejection signal. The growth rate must be explained, not asserted.

How the household savings figure is actually built

Article 89(1) does not name a euro amount. It points to the portaria referred to in Article 52(1)(d), which is Portaria n.º 1563/2007, de 11 de dezembro, and that portaria sets the means test as a percentage of the national minimum wage per person: 100% for the first adult, 50% for each additional adult, and 30% for each minor or dependent child.

The 2026 SMN is €920/month, set by Decreto-Lei n.º 139/2025, de 29 de dezembro. So the monthly reference figures are:

Two caveats worth building into your budget rather than arguing about at the counter. First, consular posts apply the family arithmetic with some variation, and several apply a stricter multiplier as administrative practice rather than as a reading of the portaria, so treat the table as a floor to clear comfortably and not a target to hit exactly. Second, D2 is not only a means test: it is an investment route, and practice favours showing genuine business capital on top of living costs, commonly €50,000 or more for a plan to read as credible, though no statute fixes that number. A file that shows exactly €11,040 and nothing else is technically arguable and practically weak.

Job creation roadmap

AIMA gives additional weight to business plans that show Portuguese job creation, even at a small scale. A plan that projects hiring one Portuguese-resident employee in Year 2, with a named role, a justification for when that hire becomes necessary (e.g., "at 20 active clients, a customer success function becomes required"), and a salary assumption, is materially stronger than an identical plan with no hiring intent.

The job creation roadmap does not need to be ambitious. Realism matters more than headcount. A founder who projects 12 hires in Year 1 when the business is a solo consultancy is less credible than a founder who projects 1 hire in Year 2 with a clear business logic.

Founder background and fit

AIMA cross-references the founder's CV against the business type. A software engineer applying to run a software consultancy, a logistics industry veteran applying to open a freight-brokering firm, or a designer applying to open a studio; these are straightforward fits. A former employee with a corporate background applying to run a hospitality or real estate business, with no evidence of sector experience, will receive additional scrutiny.

The founder background section of the plan should make the fit explicit rather than assuming AIMA will connect the dots. One paragraph that maps specific past roles to the planned activity ("In my 7 years as a backend engineer at [company], I built the data pipeline infrastructure that this product replicates for SME clients; here is the GitHub profile") is more useful than a resume attached without commentary.

4 plan types AIMA accepts

The following patterns describe business plan types that have been accepted under the D2 framework in 2025-2026, based on practitioner reporting and AIMA's published evaluation framework. Specifics are illustrative.

Tech product with EU market focus: A founder building a B2B SaaS product targets European SMEs. The plan shows a Lisbon Lda., a Portuguese developer hired in Year 2, a specific customer segment (e.g., mid-market accounting firms in the DACH and PT markets), a pricing model with documented assumptions, and a founder CV with 8 years in the domain. AIMA accepts because the Portuguese nexus is operational (incorporation, future hiring), the market is plausibly addressable from Lisbon, and the founder background fits.

Professional services with existing client letters: A UX design consultant has two existing clients, a German fintech and a Danish e-commerce company, who provide letters of intent confirming continued work. The plan projects Year 1 revenue from these two clients, adds two new client acquisition targets per quarter from the Portuguese startup ecosystem, and shows the founder attending Lisbon Tech events for lead generation. AIMA accepts because the initial revenue base is documented, the Portuguese nexus includes local community engagement, and the projections are conservative.

Agency model with Portuguese hiring intent: A founder proposes a content production agency targeting English-language clients. The business plan projects two freelance contractors in Year 1 (not direct employees, but service-provider relationships with Portuguese-resident contractors) and one direct hire in Year 2. The financial model shows the gross margin per project, the time required per project, and the pipeline needed to break even. AIMA accepts because the plan is internally consistent, the job creation is modest but real, and the market analysis names specific client types with realistic volume.

B2B product with validated demand in Portugal: A founder demonstrates demand validation through a 3-month discovery phase: 15 customer interviews with Portuguese businesses, a 30-company waitlist, and letters of interest from two anchor clients in the logistics sector. AIMA accepts because demand is substantiated, not projected from scratch; the Portuguese market analysis is specific; and the financial projections have a credible starting point.

Is your D2 business plan ready for AIMA? Relovisa reviews D2 business plans before submission and advises on plan structure, financial projection credibility, and company formation timing. See the D2 visa package or book a consultation.

4 plan types AIMA rejects

Generic services with no Portuguese market specificity: A plan describing "IT consulting services to international clients" without naming the client type, the specific service line, the Portuguese market role, or the founder's relevant background. AIMA reads these as residency-via-vehicle applications: the business has no genuine Portuguese nexus and the plan provides no basis for evaluating viability.

Financial projections without internal logic: Round-number three-year projections with no supporting assumptions. "Year 1: €80,000; Year 2: €160,000; Year 3: €320,000" with no explanation of how Year 1 revenue is generated, who the clients are, or why Year 2 doubles is treated as a template-filled plan rather than a credible business case. AIMA's focus on the "complete application only" rule extends to substantive quality, not just document completeness.

Business model outside AIMA's D2 framework: Real estate intermediation, property management, and similar investment-passive business models are assessed against whether the founder is conducting genuine economic activity under Article 89: managing real estate acquired for capital appreciation is not the economic activity D2 targets. Similarly, a plan to open a franchise in Portugal (e.g., an international food-service brand) is routinely rejected because the innovation and economic contribution criteria are not met by franchised operations.

Founder-background mismatch with no mitigation: A founder with a career exclusively in corporate finance proposes to operate a software development studio. No technical co-founder is named, no outsourcing plan is described, and no technical advisory support is indicated. AIMA rejects because the plan is not executable given the founder's stated background, and no mitigation for the skills gap is offered.

Company formation steps and document timeline

AIMA's "complete application only" rule means that by the time you file, you need to have taken concrete steps toward Portuguese company formation, not simply declared intent. The practical timeline, working backward from a target D2 filing date, looks like this:

NIF (Número de Identificação Fiscal): Obtain this first. The practical remote route is a filing submitted through the Autoridade Tributária's e-Balcão by someone who already holds Portal das Finanças credentials, typically a fiscal representative or a lawyer, at €50-150 a year for the representation service. Note what that fee is and is not buying: since Decreto-Lei n.º 44/2022 a fiscal representative is not legally required at the moment your NIF is issued for a third-country address, and where the obligation does later attach it can be replaced by subscribing to electronic notifications. The representative is doing the filing, not satisfying a representation requirement, and the full rule is set out in the Portuguese NIF guide for non-residents. Timeline: 2-4 weeks remotely.

The one D2 case where a representative is genuinely mandatory: if you take the Article 89(1) route of declaring the start of activity as an individual (pessoa singular) rather than incorporating, the Decreto-Lei n.º 44/2022 waiver does not reach you. A non-resident carrying on self-employed activity in Portugal must appoint a VAT fiscal representative resident in Portugal, and the appointment has to be made before the activity begins. Failure to appoint one is punishable by a fine of €75 to €7,500 and leaves you unable to exercise rights before the tax administration. Budget for it if your plan is freelance-shaped rather than company-shaped.

In-person NIF: treat a Serviço de Finanças visit as atendimento por marcação (appointment-based), booked through Portal das Finanças or the Centro de Atendimento Telefónico on +351 217 206 707, weekdays 09:00 to 19:00. The old advice about walking into a Lisbon or Porto tax office and leaving with a number the same day is branch-dependent at best and is not something to build a filing timeline on.

Company registration via Empresa Online: The quickest route for a Lda. (Sociedade por Quotas, minimum share capital €1 since Decreto-Lei n.º 33/2011) is the Instituto dos Registos e do Notariado's Empresa Online service, reached through the ePortugal / gov.pt portal. Turnaround is typically 1-3 business days for a standard Lda. Registration requires the NIF of every partner and a designated fiscal domicile. The step most foreign founders miss is authentication: Empresa Online requires a Cartão de Cidadão with an activated digital signature or a Chave Móvel Digital, neither of which a not-yet-resident applicant has. In practice a lawyer, notary or solicitor filing under their own professional digital certificate does it for you, or you use an Empresa na Hora counter in person, which issues the company the same day. Timeline: once the NIF is available, 1-3 business days online, same day at a counter, plus whatever lead time your filer needs.

Commercial lease agreement: AIMA expects evidence of a genuine business address: a co-working space membership agreement or a commercial lease is acceptable; a personal home address listed as the business address raises questions. Lisbon co-working memberships start at €150-300/month; fixed-desk or private-office arrangements run €400-1,200/month depending on location and size. Timeline: 2-8 weeks for search and signing in Lisbon, Porto, or Braga; co-working memberships can be activated within days.

Portuguese business bank account: Opening a Portuguese business bank account for a newly registered company takes 2-6 weeks depending on the institution. Caixa Geral de Depósitos, Millennium BCP, Banco BPI, novobanco and ABANCA all run business onboarding; some require at least one in-person visit. Two names have changed and are worth getting right in your own paperwork: EuroBic (Banco BIC Português) was acquired by ABANCA, with the legal integration, technology migration and brand retirement completed in November 2025, so the EuroBic brand no longer exists; and novobanco, a separate institution, was acquired by the French group BPCE. Portuguese-licensed neobanks (Banco CTT, some Revolut Business entities) can be faster but are less universally accepted for AIMA documentation purposes. Timeline: allow 4 weeks from company registration to a working account. The account-opening sequence, including what to do when the company does not exist yet, is covered in opening an EU business bank account before residency.

Government fees: budget roughly €550 per applicant across the two stages. The consular residence visa costs €110. On the AIMA side there are two separate charges, not one: €133 for recepção e apreciação do pedido (intake and examination) and €307.20 for the concessão (the grant of the permit), both on the tariff table in force since 1 March 2026, so about €440.20 on the AIMA leg. Every applicant pays these, so a family of three multiplies them. These are government fees only and exclude legal, translation, apostille and accounting costs.

Total preparation window: Realistically plan 8-12 weeks from first NIF application to a D2-ready application package. Filing while the business bank account is still pending, or before a commercial address is confirmed, puts you at risk under the "complete application only" rule, and since the Article 89(2) in-country route was revoked there is no lane to fall back into.

D2 applications filed with a complete package are subject to a 90-day statutory target; the realistic end-to-end timeline in 2026 is 9-18 months in Lisbon/Porto (biometrics wait 6-12 months + processing 3-6 months + card 6-11 weeks) and ~5-9 months via regional offices. After the consular D2 visa is issued, the holder enters Portugal on a 4-month entry visa and schedules an AIMA appointment for the 2-year residence permit. AIMA has also been treating the NISS (social security number) as a completeness item on residence-permit files, which is its own small gauntlet: see the NISS guide for D-visa holders.

On tax, the regime to plan for is IFICI, which sits in Article 58-A of the Estatuto dos Benefícios Fiscais (introduced by Lei n.º 82/2023, art. 263, and regulated by Portaria n.º 352/2024/1 as amended by 52-A/2025/1). It gives a 20% flat IRS rate on qualifying Portuguese employment and self-employment income for 10 years, plus broad exemptions on foreign-source income, and it applies to D2 holders on the same qualifying-activity test as D3 holders. Two mechanics decide whether you actually get it: registration is due by 15 January of the year following the one in which you became a Portuguese tax resident, and the 20% withholding starts from the point you show proof that the registration request was filed, not from approval, with the annual assessment retaxing at progressive rates if the registration is ultimately refused. The eligibility tests are broken down in the Portugal D3 + IFICI eligibility guide. Whether you cross into Portuguese tax residence at all is a separate question with its own traps, covered in the 183-day rule guide.

A comparison of D2 against other Portuguese visa options, including the income thresholds and use-case splits between D2, D7, and D8, is covered in the Portugal D2 vs D7 vs D8 comparison guide. For applicants whose profile does not cleanly fit any single visa type, the D2 rescue lane guide explains when D2 is the right fallback and how to frame it correctly in the business plan, and Portugal D2 vs Spain Startup sets the route against its closest cross-border alternative.

Ready to prepare your D2 application? Relovisa structures D2 applications from business plan preparation through AIMA filing, including company formation coordination, NIF, and commercial lease sourcing in Lisbon, Porto, and Braga. See the D2 visa package or book a pre-filing review.