What is the change? Applicants are experiencing significant delays in preapprovals for Intra-Company Transfer cards in Germany.

What does the change mean? Preapproval processing times for ICT cards is estimated at eight to 12 weeks, according to a statement from German authorities. This is a significant delay in processing, which usually takes two to four weeks.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: ICT cards.
  • Who is affected: Non-EU/EEA managers, specialists or trainees transferring from outside the EU to work in Germany for more than 90 days.
  • Business impact: Applicants should expect delays in the issuance of preapprovals for ICT cards.

Background: Germany implemented the European Union’s ICT Directive last year. Only employees with at least six months of experience in a corporate group are eligible to apply for ICT cards. Assignments for ICT card holders cannot be longer than three years for managers and specialists or longer than one year for trainees. ICT card applicants must apply for the cards before traveling to Germany.

Earlier this year, German authorities experienced delays in issuing ICT cards due to a system integration error. Authorities settled on an interim solution, but applicants continue to experience delays.

BAL Analysis: Employers should anticipate delays in the issuance of ICT cards for non-EU/EEA intra-company transfers. Other permit categories for non-EU/EEA intracompany transfers may be preferable, depending on transferees’ nationality, length of stay and the activities they will conduct while in Germany. Employers should consult with BAL to determine which option is best for any employees they are transferring or posting to Germany.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

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