There have been several questions that have been raised about the “right” to the Consumption Subsidy by holders of a Non-Permanent Resident Identity Card with expired validity, but which are in the process of recognized renewal. That is, that on a date prior to the end of the validity of the Non-Permanent Resident Identity Card, its timely renewal was requested, thus maintaining its resident status.
The answer to this question is, in our view, set out in paragraph 1 of article 4 of Administrative Regulation No. 6/2020, which states that the holders of the Macau SAR Resident Identity Card (Permanent and Non-Permanent) valid or renewable are eligible for the said grants.
However, what has raised the most questions is the fact that the holders of an expired Non-Permanent Resident Identity Card were unable to register with those “expired” identification documents on the Macau Monetary Authority ( AMCM) website within the set deadline, that is, from March 18 to April 8, 2020. This is not understandable given the wording of paragraph 1 of article 4 of Administrative Regulation no. 6/2020, which also attributed eligibility to the holders of renewable MSAR Resident Identity Card.
This impossibility will certainly result from a “glitch” of the computer system that needs to be corrected since, as we have seen, the legal diploma already ensures the existence of such a right for residents in those circumstances. Paragraph 2 of article 4 establishes that, in cases where citizens were qualified to the issue of Residents Identity Cards and had not yet been issued, they should proceed to their registration within that period with the Identification Department (DSI), armed with the receipt for the handling of the respective identification document issued by the DSI. Therefore, if there were another understanding, this should also have been expressly established in the Regulation. Consequently, those cases could have been given equal treatment as to the cases referred to in paragraph 2 of article 4, since this is a similar situation.
What seems undoubted to us is that, by means of interpretation of paragraph 1 of article 4 of Administrative Regulation no. 6/2020, the holders of a Non-Permanent Resident Identity Card undergoing renewal are eligible for the granting of the Consumption Subsidy.