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Your first permit is a stepping stone, not a life sentence

Non-EU nationals who've lived legally in an EU country for 5 years can apply for EU Long-Term Resident status — and then move to almost any other EU member state to live and work. This is Directive 2003/109/EC, recently recast to make the transfer even easier.

How it actually works

Step 1 — Get your first permit

Pick the country and visa that fits your situation right now (D7 in Portugal, DNV in Spain, Blue Card in Germany — whatever). Live there legally for 5 continuous years. Absences are allowed: up to 6 months at a stretch, max 10 months total over the 5 years.

Step 2 — Apply for EU Long-Term Resident status

After 5 years, apply to your current country's immigration authority. You'll need to show stable income, sickness insurance, and (in some countries) language skills. The permit looks different in each country but carries the same EU-wide rights.

Step 3 — Move to the next country

With EU LTR status, apply for a residence permit in the second EU country. Under the 2024 recast (Directive 2021/1883), the second country can no longer impose labor market tests or employment quotas on LTR holders — you must be allowed to start work within 30 days of applying.

The fine print nobody mentions

Denmark and Ireland opted out of Directive 2003/109 entirely. LTR status doesn't give you the right to live or work in either country — you need their own national permits.

Equal treatment, mostly. LTR holders get the same access to employment, education, social security, and tax benefits as nationals of the second country. But member states can restrict core social assistance in the first 3 months and limit study grants to established residents.

You can lose it. Absence from the EU for 12+ consecutive months revokes LTR status (the recast extends this window slightly and adds a re-acquisition procedure for longer absences). Absence from the issuing country for 6+ years also triggers revocation.

It's not citizenship. LTR is a permanent-ish permit with mobility rights, but you're still a third-country national. No passport, no voting, no unconditional re-entry. Citizenship — if you want it — is a separate process with its own (usually longer) timeline.

Country-by-country: what 5 years buys you

Every EU country (except Denmark and Ireland) participates. Here are the ones Townleap covers with visa paths, plus their citizenship timelines and local quirks.

🇵🇹 Portugal

LTR: 5 yrCitizenship: 5 yr

Shortest path in the EU — citizenship after 5 years of legal residence with basic Portuguese (A2).

AIMA (immigration agency) backlogs can delay LTR applications by 6–12 months beyond the 5-year eligibility date.

🇪🇸 Spain

LTR: 5 yrCitizenship: 10 yr

10 years for most nationalities. 2 years for citizens of Latin American countries, Philippines, Equatorial Guinea, Andorra, and Portugal.

Absences over 6 months in any single year reset the 5-year clock. Arraigo social (3-year irregular-to-legal) counts toward LTR.

🇩🇪 Germany

LTR: 5 yrCitizenship: 8 yr

8 years standard, 6 with special integration efforts (B2 German, civic engagement). Dual citizenship now permitted since 2024.

Requires B1 German and proof of livelihood (no Bürgergeld) for LTR. Germany's own Niederlassungserlaubnis (settlement permit) is a separate status — you can hold both.

🇫🇷 France

LTR: 5 yrCitizenship: 5 yr

5 years of residence. French language at B1 required. Naturalisation by decree (discretionary).

Carte de résident longue durée-UE issued by the préfecture. France additionally offers a 10-year national carte de résident after 5 years — different from the EU LTR.

🇳🇱 Netherlands

LTR: 5 yrCitizenship: 5 yr

5 years. Must pass civic integration exam (inburgeringsexamen). Dual nationality restricted — you must renounce previous citizenship in most cases.

Kennismigrant (highly skilled migrant) time counts toward LTR. IND processing currently 6+ months for LTR applications.

🇮🇹 Italy

LTR: 5 yrCitizenship: 10 yr

10 years — longest in the EU. 4 years for EU citizens. Processing backlogs can add 2–3 years to the theoretical 10.

Permesso di soggiorno UE per soggiornanti di lungo periodo. Italy's Flows Decree (Decreto Flussi) historically limited intra-EU LTR transfers via annual quotas.

🇪🇪 Estonia

LTR: 5 yrCitizenship: 8 yr

8 years with at least 5 on a permanent residence permit. Estonian language at B1 required.

Annual immigration quota (1,378 slots as of 2024) historically applied to intra-EU LTR transfers — recast directive should eliminate this.

🇨🇿 Czech Republic

LTR: 5 yrCitizenship: 10 yr

10 years of continuous residence. Czech language exam required.

Relatively straightforward LTR process. Blue Card holders can count time in other EU states toward the 5 years (up to 18 months).

The “take Spain first, move to NL later” strategy

This is the most-asked question from non-EU movers: can I pick an easy-entry country now and transfer to a harder one later? Short answer: yes, that's exactly what the directive enables.

The tradeoff is time. You're committing 5 years to Country A before you can move to Country B — and you need to actually live there, not just hold a permit while staying elsewhere. If Country B is your real goal, compare:

  • Direct route: Apply to Country B from outside the EU. Higher income threshold, harder visa, but you start your 5-year clock in the country you actually want.
  • Stepping-stone route: Enter via Country A (lower bar), build 5 years of LTR-eligible residence, then transfer. Total time to living in Country B: 5+ years. But you were in the EU the whole time.

Neither is universally better. The stepping-stone works well when Country A is a genuine place you want to live for a while (Portugal for lifestyle, Estonia for e-Residency builders, Spain for weather) — less well if you're just enduring it to get the permit.