The IRN confirms, according to Executive Digest, that nationality applications are counted, for the purposes of applying the law, from the date of their submission. In other words, applications made before the new law was approved will be reviewed under the criteria of the previous law, including the shorter residency requirements in Portugal.

In addition to the IRN's confirmation, the President of the Republic, António José Seguro, has already demonstrated the need to transition the administrative process in a cohesive manner, in order to "ensure that pending processes are not – effectively – affected by the legislative change, which would constitute an undesirable breach of trust in the State, both internally and externally."