Registration Certificate 'Annex 19': Elimination of the 3-Month Period to Complete a Request

The Law of 15 December 1980 on the access to the territory, residence, settlement and removal of foreigners establishes the legal framework for the residence of Union citizens and their families. The Royal Decree of 8 October 1981 specifies the procedures for implementing this law – particularly Articles 42 and following, relating to the registration certificate (known as 'Annex 19' for EU citizens, Swiss nationals, and their family members).

A Royal Decree dated 4 July 2025 (Royal Decree of 4 July 2025 amending the Royal Decree of 8 October 1981 on the access to the territory, residence, settlement, and removal of foreigners, regarding the introduction of the registration certificate request – M.B. 2025-07-24, p. 62543) modifies the 1981 decree concerning the submission of the registration certificate request, with the aim of increasing control over the conditions of the requested residence.

As of 1 September 2025, any application for a registration certificate must be accompanied by all supporting documents at the time of submission – the previous three-month period to complete the file is eliminated.

Therefore, the file must be complete upon submission. This includes:

1. Proof of EU citizenship.
2. Professional status:

•     - Employee: job offer or employment certificate.
•     - Self-employed: BCE registration and business number.
•     - Jobseeker: registration with the employment office and evidence of active job applications and real chances of being hired (diplomas, training, unemployment duration). However, it must be recalled that the Court of Justice of the European Union ruled in a judgment dated 17 December 2020 (CJEU, case C-710/19 (G.M.A. v. Belgian State)) that the host state must grant the applicant a 'reasonable period' to seek employment, during which it cannot immediately require proof of real chances of recruitment. Article 6 of the directive indeed grants a right of residence for up to 3 months without formalities (valid ID is sufficient) and during this time, additional requirements are not permitted.
• Other categories: students, dependents, persons with sufficient resources, family ties – each of these is detailed in Annex 19 under Article 50/§2 of the law.

Thus, municipalities can no longer accept incomplete applications and defer verification: any request not accompanied by documents from the start is considered inadmissible by default.

Upon submission, municipalities must immediately register the applicant in the waiting register, followed by a residence check. If the file is complete, the person is immediately registered in the foreigners’ register. If the file is incomplete, the municipality can make a decision of inadmissibility, which can be appealed to the Council of State within 60 days. It should be noted that ordinary courts can also incidentally review the legality of a refusal of registration.

Céline Verbrouck
Attorney at Altea
Specialist in immigration Law and International Family Law
This email address is being protected from spambots. You need JavaScript enabled to view it.
+32(0)2/894.45.70