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FRANCE – Fingerprint Requirement for Residence Permits Causing Severe Delays in Paris

Applications for residence permits (titres de séjour) in Paris are currently subject to severe delays due to a new fingerprinting requirement for certain categories of applicants. The delays are affecting both first time applications and renewals; companies should note that lead time of five to six months is currently required for obtaining residence permits for affected categories in Paris.

Who Needs to Give Fingerprints?

Fingerprints must be submitted for new or renewal residence permit applications, in accordance with European Union (EU) regulation 380/2008. All European Union member states were required to implement biometric residence permits by 1 May 2011; however, many have experienced delays. The biometric residence permits are supposed to be more secure than previous documents, plus must be issued in a uniform format across the EU.

Currently, the following categories of applicant are required to submit fingerprints in support of residence permit applications in France:

  • All salarié (local hires) first time and renewal residence permit applications (NOTE: applicants who arrive in France with long stay "VLS-TS" visas do not need to apply for residence permits until the VLS-TS visa has expired, at the end of the first year.)
  • Salarié en mission – i.e. intra company transfers - (whether local hire or not) renewal applications only (not first time, currently)
  • All temporary detachés being renewed (not for first time applications)

The following categories are currently unaffected; however this is subject to change and should be checked on a case by case basis:

  • Students changing status
  • Blue Card applicants, first time or renewal
  • EU nationals, who are not required to apply for residence permits (although note that a declaration must be made to the labour inspectorate for EU nationals assigned to France).

Intra company, Blue Card and Skills and Talents permits, and their spouses will eventually all be required to go through the fingerprinting process once the biometric machines are installed in all of the Préfectures.

Fingerprints will remain valid for a five year period, so will not need to be taken at each renewal stage. After five years, the applicant will be required to have these taken again at the Préfecture.

Delays in Paris

The Paris Préfecture operates a two-stop system for obtaining residence permits: the application is first submitted, either by post or in person at an appointment, following which, the Préfecture will issue an appointment date for the fingerprints.

Due to this extra requirement the processing time frame is now five to six months. Note that after fingerprints have been submitted, it will take the Préfecture another four to six weeks to issue the actual residence permit card.

It is anticipated that the delays will be resolved as the Paris Préfecture becomes accustomed to the new procedure; additional staff are likely needed.

Other Locations in France

Since June, fingerprinting has been put in place for eight of the French counties or departments:

  1. Alpes-Maritimes
  2. Essonne
  3. Hauts-de-Seine
  4. Loire-Atlantique
  5. Puy-de-Dôme
  6. Saône-et-Loire
  7. Seine-et-Marne
  8. Paris

The new process will gradually be rolled out to all departments in France.

Note that delays have not been apparent at locations outside Paris.

Temporary Residence Permits

Individuals who need to travel outside France but who do not yet have residence permits due to the delays may apply for temporary residence permits. These can be applied for in person either on the day of expiry of the current residence permit or visa, or in some cases, in advance, if urgent and necessary business travel can be proved by means of a company letter and evidence of travel bookings.

Action Items

  • For assignees/employees in Paris, initiate your immigration provider at least 6 months in advance of expiry date for renewal applications to allow time to obtain the residence permits
  • Note that first time applications are also affected and be prepared to apply for temporary residence permits in case of urgent travel need
  • Note that the situation is still changing; additional categories of applicant and additional locations in France may become affected by the delays

This alert was drafted using information provided by Expat Partners in Paris

DISCLAIMER: The information contained in this immigration alert has been abridged from laws, court decisions, and administrative rulings and should not be construed or relied upon as legal advice. If you have specific questions regarding the applicability of this information, please contact Peregrine © 2017 Peregrine Immigration Management Ltd.