AIMA Activates a Dedicated Submission Track for Foreign-Born Babies and Minors Under Article 124 on Monday 18 May — Six-Month Deadline from the Assento and One Parent's Valid Residence Title Required

The Agência para a Integração, Migrações e Asilo confirmed on Monday 18 May 2026 that a dedicated submission track for the residence-authorisation requests of babies and minors born in Portugal to foreign-resident parents is now live on the agency's contact-form portal at contactenos.aima.gov.pt. The new track narrows what had been a generic Autorização de Residência appointment queue into a single channel governed by Article 124 of Lei n.º 23/2007 — the Lei de Estrangeiros — and binds the parent to a six-month window from the date the Conservatória do Registo Civil issues the child's assento de nascimento.

The agency framed the move in operational rather than legislative terms: the legal route has existed since the 2007 statute, but until now foreign-resident families had to send the request through the same generic contact form that AIMA uses for every other category of appointment, which in 2026 has carried a median assignment delay of 9 to 14 weeks and a 38% refusal-or-redirection rate when the assunto category was selected incorrectly. The Article-124 track removes that ambiguity.

How the New Track Works

The portal at contactenos.aima.gov.pt is the same multi-step form AIMA introduced in late 2024 to replace the legacy SEF-era email channels. The parent selects, in sequence: Tipo de Assunto — Autorização de Residência, then the new Subtipo de Assunto — Pedido Agendamento Bebés/Menores Estrangeiros Nascidos Portugal – Art. 124. AIMA's notice explicitly warns that forms submitted under this subtype but for any other purpose will be 'automaticamente desconsiderados', a hardening of the discard rule that previously applied only to clearly-misclassified asylum or family-reunification requests.

The documentary chain at submission stage is short by AIMA standards. The parent uploads: a digital copy of the child's assento de nascimento issued by a Portuguese conservatória; a digitised copy of the parent's valid título de residência — or, where both parents are foreign residents, the títulos of both; and a digitised passport page of the parent or parents involved. AIMA does not currently require a NIF for the child at submission, because the conservatória já comunica the new fiscal number directly to the Autoridade Tributária through the inter-agency RNCG / SICAE registry chain, but the working assumption is that the child's NIF will be requested at the in-person appointment stage.

The six-month deadline is the operative constraint: the request must be filed within six months of the assento de nascimento, with the registry date — not the date of birth — anchoring the clock. The Conservatória do Registo Civil window for declaring a Portuguese birth is 20 days under article 96 of the Código do Registo Civil, but the actual assento can take a further 5 to 30 days to issue in writing, particularly for foreign-born parents who do not present a Cartão de Cidadão at the registo. Practical reading: foreign-resident families have effectively about 6 to 7 months from a child's birth to file the Article-124 request, after which the residual route is the standard non-derivative residence-authorisation path under article 88, which carries a longer documentary chain and a tighter eligibility test.

Who the Track Is For — and Who It Is Not

Eligibility is bounded by the parent's status, not by the child's nationality. At least one parent must hold a valid Portuguese residence title — autorização de residência, autorização de residência temporária, autorização de residência permanente, or a CPLP-Mobility certificate under the 2022 Acordo de Mobilidade. The track does not cover children born outside Portugal: those cases stay on the reagrupamento familiar — family-reunification — route, which has its own dedicated portal that reopened for the CPLP cohort 72 hours before Lula's April visit and was extended to CPLP minor children at the end of April.

The track also does not cover children born in Portugal who are entitled to Portuguese nationality at birth under the reformed regime signed into force by President Seguro on 4 May. Children of two foreign-resident parents who hold a Portuguese residence title at the time of the child's birth, or children with at least one parent who has held residence for a year before the birth, can claim Portuguese nationality directly through the conservatória rather than going through the AIMA residence-authorisation route — and for that population, the assento de nascimento doubles as a nationality-acquisition act, with no further AIMA submission required.

The Article-124 track therefore catches a specific population: babies and minors born in Portugal whose parents hold a residence title but who do not, themselves, qualify for Portuguese nationality at birth. That includes the children of short-stay residents who have not yet hit the one-year threshold for nationality-by-residence under the new law, the children of CPLP-Mobility certificate holders whose primary residence status is the mobility-track rather than the full autorização de residência, and the residual stack of cases where the parents' residence titles are valid but contested.

The 385,000-File Backdrop

The new submission track sits on top of the broader AIMA caseload that has dominated the 2026 immigration file. The mission-structure inside AIMA validated 385,000 new immigrant files through 2024, and the residual caseload running into 2026 still carries a sizeable child-residence component. Half of all babies born in Greater Lisbon in 2025 had foreign mothers, according to the INE vital-statistics file we covered earlier this month, and INE's preliminary 2025 figure for foreign-mother births nationwide stands at roughly 28,400 — a structurally rising share of the country's 86,500 total live births.

The implication for the Article-124 track is that the steady-state queue is non-trivial. Rough arithmetic: if even 40% of the foreign-mother birth cohort is non-nationality-eligible at birth and needs the Article-124 route, that is around 11,300 new requests a year — about 950 a month, or roughly 1.5% of AIMA's full annual residence-authorisation throughput. The agency has not published a target service level for the new track, but the choice to break it out into a dedicated subtype suggests the design is geared to processing this cohort faster than the generic Autorização de Residência queue's 9-to-14-week median.

What This Means for Foreign-Resident Families

• If a baby was born in Portugal in the last six months and your residence title is current: file through contactenos.aima.gov.pt under the new Subtipo within the six-month window. Older cases will need to go through the slower Article-88 path. The new Subtipo will not retroactively rescue requests filed under the wrong category — AIMA is treating misfiled requests as automatically discarded.
• If both parents are non-EU residents: the Article-124 route gives the child a derivative residence permit aligned with the parents' titles, including the validity end-date. When the parent renews, the child's title renews alongside on a coupled refresh. The coupling means a single misfiled parental renewal can cascade into the child's status — the renewal-certificate extension cycle covered the underlying file.
• If one parent is a Portuguese national: the Article-124 track is irrelevant — the child acquires Portuguese nationality at birth under article 1 of Lei n.º 37/81 and the conservatória records the nacionalidade portuguesa directly. The Cartão de Cidadão is then issued at the next IRN counter visit; our CC and Chave Móvel Digital guide covers the digital-ID side that follows.
• If you receive a 'desconsiderado' notice from AIMA: resubmit immediately under the correct Subtipo and keep the original receipt. The discard rule applies to the request, not the underlying eligibility — and the six-month deadline runs from the assento date, so resubmission is possible inside that window.
• If you are a CPLP-Mobility certificate holder: the Article-124 track is the correct path even though your primary residence is the mobility-track rather than the full autorização. AIMA's notice did not distinguish between the two parental status types at submission stage, but the agency has confirmed informally that the eligibility test is 'any valid title at the date of the assento'.

The dedicated submission track is the smallest of several procedural fixes AIMA has rolled into the May calendar, sitting alongside the renewal portal opened for July-August expiries earlier this month and the scam-alert refresh reminding foreign residents of the five official appointment channels. None of the May fixes change the underlying legal architecture — that work is now lodged in the post-promulgation phase of the new nationality law and in the still-pending implementing regulations that the Ministério da Presidência is preparing — but each one tightens the operational queue by a measurable amount. For the families who actually need the Article-124 track, the practical change is that there is now a button to push, and a six-month clock that started, for some, the moment their child was registered at the conservatória.