BELGIUMMarch 31, 2014

Although no official announcement has been made at this time, the Department of Federal Immigration at the Ministry of Home Affairs confirmed that it has started to accept applications directly for the renewal of residence permits. Up to now, renewal applications could only be filed at the local Town Hall of the applicant’s place of residence, which then forwards the application to the Ministry.

Although this new direct application procedure is intended to streamline the renewal application process, it remains to be seen how much effect it will actually have on processing times. Not only do many Town Halls forward the renewal applications to the Ministry on the day of their filing, but (at the time of this writing) the Ministry has also not indicated that it will give priority to those applications filed directly with the department. Current average processing times for residence permit renewal applications is 2 weeks from date of application for the employee and another 3 weeks for the accompanying dependents.

Pro-Link GLOBAL’s standard practice is to follow up directly with the Ministry after filing the application at the Town Hall to ensure the application has been received, will be processed quickly, and to inform the authorities if a nearing expiration date and/or urgent travel plans may require faster processing times. It is needless to say that, going forward, Pro-Link GLOBAL will continue to apply this active approach, either when filing through the Town Hall or submitting at the Ministry directly.

One of the other suggested advantages of this new process is that the applicant does not need to visit the Town Hall in-person to submit the application; instead the application can be filed on the person’s behalf. Although this might sound like a huge improvement for applicants, in practice it might not have as much of an effect as it may appear. Foreign employees will still need to collect their new work permit at the local Town Hall before they can apply for the renewal of the residence permit and often the application for the residence permit renewal takes place during that same visit. In addition, residence permit renewal applications for accompanying family members still need to be submitted in person at Town Hall, as these are not currently being accepted by the Ministry directly.

Note that regardless of where the application itself has been submitted, upon approval the applicant will need to visit Town Hall to submit the application for the residence permit card. Since Belgium is currently implementing biometric residence permits, soon all applicants will need to provide their fingerprints both at time of application for the card as well as at time of collection. This fingerprinting requirement has been implemented at various Town Halls already, including Brussels, and will be implemented throughout Belgium in the upcoming months.

Pro-Link GLOBAL will continue to monitor the implementation of both new processes and will assess on a case-by-case basis whether or not a direct renewal application at the Ministry might be advantageous to the applicant.