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Residence card gaps due to admin delays: impact on nationality?

Christy132

Hi everyone,

I recently submitted my Belgian nationality application through the Antwerp commune and wanted to get advice from people who may have been in a similar situation.

My situation at a glance:


I Valid residence PR card (L card)

I have obtained Language certification and Integration certification

I live More than 5 years of full-time work in Belgium


The issue:

I've been legally working and residing in Belgium for over five years on a single permit. My first two jobs were on a fixed one-year contract, thus the residence card always expired after one year. During this time I changed employers twice, which created two administrative gaps in my residence card / annex coverage:


A gap of approximately 30 days

A gap of approximately 12 days


Before the end of each assignment or single permit, my new employer always applied one to two months prior for the renewal of my work permit.

Both gaps occurred because the ministry did not send a receipt for the renewal application, which meant the commune could not issue an Annex 15/49 bridging document in time. The renewals were ultimately approved and the subsequent Annex 46 permits were issued without issue.


Importantly, I was never deregistered from the commune during either gap. My attest van hoofdverblijfplaats met historiek shows a completely clean and uninterrupted address history throughout my entire stay in Belgium.

When I submitted my application, the commune staff flagged these gaps as a potential minor risk but left the decision to apply entirely up to me. They were very helpful overall.

My questions for the forum:


  1. Will the prosecutor (parquet) consider these administrative gaps an interruption in legal residence, given that my National Register record shows continuous registration throughout?
  2. I've read that absences of less than six months don't automatically constitute an interruption. Does the same logic apply to administrative gaps in residence card coverage?
  3. Should I proactively provide an explanation, proof, and information to the prosecutor even though I have already applied? Should I do this through extra documentation, either on my own or through a lawyer, or simply let it play out as it is?
  4. Has anyone had a similar situation and ended up having their application accepted or rejected?



Thanks in advance!

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