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D2 Visa: VFS flag on B2B service proposal / generic scope

Hi everyone,


I’m applying for the D2 visa as an independent service provider/consultant. VFS flagged my corporate client service proposal, stating it's too generic and lacks a clear local nexus to Portugal.


My client is already established and expanding their operations in Portugal (covering Portugal and Spain), and I will be executing these B2B consulting services directly from my home base in Portugal.


Because the final corporate contract is still moving through internal sign-offs, we are using a detailed service proposal alongside an email confirmation from company leadership.


Has anyone dealt with a similar VFS flag for a "generic scope"? Did your consulate accept a detailed proposal plus a leadership confirmation letter while waiting on final contract execution?


Any advice is appreciated!

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Hi and Welcome.


To satisfy D2 (independent activity), the authorities need to see why your activity must or will be carried out from Portugal and how it connects to the local economy. If your client is an international entity and the proposal reads like a standard remote consulting agreement without referencing Portuguese operations, VFS flags it as lacking a territorial link.


Consulates do regularly accept a strong proposal coupled with a formal letter of intent from company leadership, provided the documentation meets three main requirements:


  1. It proves the client's concrete operational expansion/presence in Portugal (e.g., local branch/entity NIPC, local project scope, local team, or client onboarding in Portugal/Iberia).


  1. It establishes why you need to execute these services from Portugal (e.g., proximity to Iberian clients, time zone, local operational needs).


  1. It contains a firm commitment to execute the formal contract upon visa approval or residence status.




To clear the flag, submit a Revised Document Package addressing both the scope and the local link:


Revised Proposal

  1. Replace general consulting terms with clear, milestone-driven deliverables and timelines.


  1. Mention the client's Portuguese operations, local market objectives, or Iberian region focus.


  1. Specify that work will be delivered by you as an independent contractor based in Portugal.


Client Confirmation Letter

  1. Written on corporate letterhead and signed by an authorized director/executive.


  1. Must reference the client's Portuguese/Iberian expansion and state why your presence in Portugal is strategic.


Personal Statement / Motivation Letter

  1. Mention your Portuguese Tax Number (NIF), local bank account, and registration of activity (início de atividade) with Finanças.



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If you don’t go into all these details, they won’t understand why you chose the D2 visa rather than the D8 digital nomad visa. Why you want to open an independent activity in Portugal,  rather than just be a digital nomad in Portugal... That’s the problem.

1 member reacted to this post

@JohnnyPT

Thank you so much for the reply and the information so quickly! I will make those adjustments for sure. The client knows I am moving and suggested working with the Portugal and Spain office but we were not going to add that into scope until i arrived. I will talk to them and satisfy the requirements you shared.

@JohnnyPT

Could i ask if you went this route before? Would a pro-bono consulting engagement with a Portuguese nonprofit satisfy or help address the Embassy's concern about a written proposal for professional services in Portugal? If so, would you want the nonprofit to formally accept the proposal, or would an unaccepted proposal be sufficient?

Need help with immigration or administrative procedures in Portugal?
Get in touch with an immigration lawyer

@Amy,


The D2 visa (trabalhador independente) evaluates whether you are establishing a commercially viable, self-sustaining economic activity in Portugal. 


Pro-Bono can help because it proves genuine local integration, network-building, and localized execution (e.g., proving you are physically or operationally engaged with Portuguese organizations). It adds weight to your motivation letter and local ties.


But Pro-Bono, in my point of view, is not enough on its own. It lacks commercial value, revenue flows, and tax-contributing activity. Relying solely or primarily on unpaid work will lead to a rejection based on a lack of financial sustainability.



D2

https://aima.gov.pt/pt/trabalhar/autori … -89-o-n-o1

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