Ad Hoc Query on registration of applications for international protection
This ad hoc query seeks to gather information on how EU Member States implement the procedures for making, registering and lodging applications for international protection under the Asylum Procedures Directive (2013/32/EU). It addresses how the process is organised in law and practice, the accessibility of registration centres, and the assessment of applicants’ vulnerabilities. The query also covers the use of extended registration deadlines, difficulties in meeting registration timelines, and measures taken when applicants cannot be registered on time.
Background:
The Asylum Procedures Directive (2013/32/EU) establishes common procedures for granting and withdrawing international protection. Under Article 6, Member States must register applications within three working days, or up to ten days in cases of large-scale arrivals, and ensure applicants can lodge their claim promptly. Article 28 allows Member States to consider an application implicitly withdrawn if it is not lodged. The CJEU clarified in case C-36/20 that a person becomes an applicant from the moment they make an application, acquiring the rights and obligations under the Directive.
Belgium launched this ad hoc query to collect information on how other Member States implement these rules in practice.
Respondents:
24 EMN Member Countries (including BE) provided a public answer to this query.
Findings:
A preliminary analysis of the results of the ad hoc query shows that:
- Most responding countries aim to complete the processes of making, registering and lodging applications for international protection as closely together as possible, often on the same day.
- Accessibility to registration points varies across countries. In BE, a single central registration centre in Brussels (Rue Belliard/Belliardstraat 68) uses separate lines to prioritise families, minors, women, and other vulnerable persons.
- Almost all responding countries indicated that a vulnerability assessment is conducted during the registration process. In BE, staff at the registration centre identify vulnerabilities through visual assessment while applicants wait and by asking about medical or other needs during registration.
- Most countries reported that they have not activated the provision under Article 6(5) of the Asylum Procedures Directive allowing for the extension of the registration deadline from three to ten working days. BE has applied the extension since 2021 due to capacity constraints linked to rising application numbers.
- Countries that experienced registration challenges reported adopting mitigating measures. These include prioritising vulnerable groups such as families, minors and single women (BE, EL, IT, LT, NL, SE), expanding registration capacities or opening new centres (AT, BG, LT), increasing staffing levels (AT, BG, LT), and scheduling applicants for later registration dates (BE).
For more information, please refer to the summary of responses above, and for full details, see the compilation of responses also attached above.