Appendices

Appendix 1. Overview of Travel Document Issuance in the E.U. and the Schengen Area Countries for 2023–25

REGULATORY FRAMEWORK AND REQUIREMENTS. In Austria, the issuance of travel documents is regulated by the provisions of the Aliens and Asylum Act (Fremdenpolizeigesetz, FPG). Recognized refugees are issued a Convention Travel Passport (Konventionsreisepass) — on application, on the basis of asylum status (Art. 94 FPG). Persons granted subsidiary protection are not entitled to a Convention Passport, but may apply for a “foreigner’s passport” (Fremdenpass). The law (Art. 88–90 FPG) lists the cases when a Fremdenpass is issued: for stateless persons or persons of undetermined citizenship without a valid national passport, as well as for other foreigners with a permanent residence permit who are unable to obtain a passport of their own country. The documents are usually valid for five years and are not renewable (a new one is issued when the term expires).

STATISTICS AND TIMELINES. Austria issues several thousand travel documents every year. The exact annual figures are not publicly reported, but are proportional to the number of people granted asylum. For example, in 2021, 6,900 people were granted asylum, and most of them requested conventional passports. Positive decisions prevail as refugees are issued the document almost automatically, upon application; refusal is possible only for reasons of national security. The average processing time is several weeks. In cases of the Fremdenpass for additional protection/nationals, the applicant needs to prove the impossibility of obtaining a passport of his/her own state. This can delay the process: applications take one to three months to process, and refusals occur if the authorities believe that a person can obtain a national passport. Nevertheless, the share of refusals is low (according to human rights defenders’ estimates, no more than 5%–10%), as most applicants manage to prove justified reasons.

TRENDS. Since 2015 (immigration crisis), Austria has posted an increase in the number of travel documents issued due to a surge in recognized refugees. The mechanism is generally well established, but human rights defenders note bureaucratic difficulties for persons with subsidiary protection: it is often difficult for them to prove their inability to obtain a passport, which delays the issuance of the document. In 2023–24, Austria has not recorded a significant influx of applications from Russian/Belarusian citizens outside of normal cases, but is closely monitoring the situation.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Belgium, the procedure for issuing a Titre de voyage for refugees is set out in the Law of December 15, 1980, on access to the territory, stay, settlement, and return of aliens and in the Royal Decree of October 8, 1981. Recognized refugees receive a refugee travel document automatically upon granting status (valid for two years, renewal on request). Persons with subsidiary protection can only obtain an alien travel document (Titre de voyage pour étranger) if they prove that they cannot obtain a passport of their own country. Similarly, stateless persons recognized by the Commission for the Recognition of Stateless Persons are entitled to a document for a stateless person.

STATISTICS AND TIMELINES. According to the Belgian Migration Service, in 2022, about 4,500 travel documents were issued to refugees and ~600 to persons with subsidiary protection. In 2023, the numbers increased by about 20% following an increase in the number of recognized refugees (in total, more than 7,000 people were granted status in 2023). Application processing time in the commune of residence is usually one month, but in practice delays of up to 2–3 months are possible in large cities. Refusals are rare for refugees (less than 1% in 2023 for reasons of threat to national security). For applicants with subsidiary protection, the denial rate is higher (up to 15%–20%); the main reason for denial is unconfirmed inability to obtain a native passport. However, following court decisions in 2021–22, the requirement to present a letter of refusal from the consulate of the country of origin has been relaxed.

TRENDS. The Belgian system is considered relatively efficient, but the workload has increased. In 2024, queues for applications were reported due to the digitalization of the process. Overall, the mechanism is sustainable, but a possible mass influx of Russian applicants (e.g. opposition activists without passports) may create new challenges: timelines may increase, more staff will be needed.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Bulgaria, the issue is regulated by the Law on Asylum and Refugees and the Rule on its implementation. Refugees receive a travel document for refugee status for a period of five years. Recipients of humanitarian status (analogous to subsidiary protection) may obtain a travel document for aliens (for foreigners) only if they are unable to obtain a passport of their own country. Bulgaria also recognizes stateless persons under the procedure and issues a travel document for stateless persons. The decisions are taken by the State Agency for Refugees together with the interior ministry.

STATISTICS AND TIMELINES. The number of issued travel documents in Bulgaria is small due to the relatively small number of recognized refugees. In 2022, about 300 documents were issued to refugees and about 50 to humanitarian status holders. In 2023, the numbers have increased (≈500 and 80, respectively) following the increase in applications for protection. The average issuance time is up to 30 days from the date of the request, although in practice refugees often wait two to three months due to administrative delays. Refusal rates are low: refugees are almost never refused (less than 2%), while humanitarian status persons were refused more frequently (around 10%–15% of applications) due to the requirement to prove the absence of a passport. In 2024, there was a case when the Interior Ministry denied a document to a person with humanitarian status, considering that he had not taken all steps to obtain a national passport; however, the administrative court sided with the applicant and obliged to issue the document.

TRENDS. The system in Bulgaria suffers from staff shortages and general bureaucracy. It is not uncommon for refugees to take a long time to receive their documents, which restricts their movement. In case of a surge in applications (e.g., if many Russians apply for asylum) Bulgaria risks serious delays, the mechanisms are sluggish and poorly scalable.

REGULATORY FRAMEWORK AND REQUIREMENTS. Croatia, which joined the Schengen Area in 2023, regulatated these issues in the 2013 Aliens Act and the 2015 International Protection Act. Refugees receive a Putna isprava za izbjeglice (refugee travel document) for five years. Persons with subsidiary protection—Putni list za strance—for two years if necessary. Issuance is supervised by the Ministry of the Interior (Directorate for Foreigners).

STATISTICS AND TIMELINES. Croatia has so far accepted few refugees (in 2023, 63 persons were granted asylum). Accordingly, only dozens of documents are issued per year (15 in 2022 and 22 in 2023). Time limit: one to two months. No refusals (in 2022–23, all granted).

TRENDS. No significant changes are expected. The system copes with the current load, there is a safety margin.

REGULATORY FRAMEWORK AND REQUIREMENTS. The Republic of Cyprus (E.U., non-Schengen Area) regulates the issue in the Refugee Law of 2000 and the 2020 amendments. Refugees 28 receive a ταξιδιωτικό έγγγραφο πρόσφυγα (refugee travel document) for two years. Persons with subsidiary protection can request a ταξιδιδιωτικό έγγγραφο αλλοδαπού if they are unable to obtain a passport from their country of citizenship. The Civil Registry and Migration Department (CRMD) decides. For stateless persons, there is a separate procedure for recognizing and issuing a document for two years.

STATISTICS AND TIMELINES. Cyprus has experienced an increase in refugees (especially Syrians) in recent years, but many arrive with passports. Approximately 250 travel documents were issued in 2022 (mostly to Syrian refugees) and ~300 in 2023. The timeframes are relatively short: for applications made in Nicosia, documents were ready in four to six weeks. In other areas there were delays of up to three months due to forwarding requests to the central office. Refusals: to refugees,m only a few (if they violated the condition not to travel to their home country); to additional protection, up to 10% of refusals (Cyprus required an official letter from the embassy about the refusal to issue a passport).

TRENDS. Cyprus, being a small state, in general copes, but financial barriers are noted — the state duty for the document is about €60, which is tangible for some refugees. In the context of Russians, there are almost no such cases so far, but Cyprus could potentially become a refuge for IT professionals and government critics, in which case the flow of applications will increase.

REGULATORY FRAMEWORK AND REQUIREMENTS. In the Czech Republic, Act No. 325/1999 On Asylum and the Act on the Residence of Foreigners provide for the issuance of a Cestovní doklad uprchlíka (refugee) and Cestovní průkaz totožnosti (foreigner’s document). For refugees, the document is valid for 10 years (or until the child turns 15). For holders of subsidiary protection, it is granted for one year if there is no national passport. The procedure is conducted by the Interior Ministry.

STATISTICS AND TIMELINES. The Czech Republic only granted asylum to 55 persons in 2023 (most refugees from Ukraine received temporary protection, which does not require a travel document within the E.U.). Therefore, only ~50 documents were issued in 2023. Timeframe: about one month. There have been no refusals.

TRENDS. After 2022, the Czech Republic has effectively shut off from Russian/Belarusian ntationals (including suspending the acceptance of new asylum applications from Russians). Thus, there is no influx of new refugees, and the system’s numbers are quite low.

REGULATORY FRAMEWORK AND REQUIREMENTS. Although Denmark does not participate in the revised EU Qualification Directive, it fulfills the obligations of the 1951 Convention.The Danish Aliens Act (Udlændingeloven) and the Integration Act regulate the issuance of the Rejsepas til flygtninge (refugee travel document). Refugees receive it for a period of five years (or until the end of their residence permit). Persons with temporary protection or humanitarian status can only obtain a Fremmedpas (alien’s passport) if they are unable to use a national passport. The Immigration Service handles the processing and the police handle the issuance.

STATISTICS AND TIMELINES. Denmark has a relatively small number of refugees; ~350 Rejsepas were issued in 2022 and about 500 in 2023 (after the influx of Syrians and Eritreans). The average processing time is short, about two weeks, as the procedure is streamlined (the document is made at the national passport production facility). Refusals are sporadic (less than five per year) — mostly for security reasons or if it turns out that a person has restored a national passport.

TRENDS. Denmark is known for its strict migration policy, but it fulfills its Travel Document obligations. There are practically no complaints about delays. However, if the number of applicants increases significantly, there may be political decisions to limit the granting of statuses, and hence travel documents. No special measures have been added for Russians/ Belarusians, except for general visa restrictions.

REGULATORY FRAMEWORK AND REQUIREMENTS. Estonian legislation on the issuance of travel documents for refugees is regulated by the Residence of Aliens Act (Välismaalaste seadus) and supplementary regulations of the Estonian Ministry of the Interior. These regulations establish the conditions for obtaining refugee status and issuing an alternative document for international travel when the passport of the country of origin is not available. In Estonia, the document issued is called Reisidokument for persons granted asylum or recognized as stateless. It grants the right to travel internationally and also serves as a basis for obtaining visas and temporary residence permits in other countries under international agreements. It is a recognized substitute for a national passport for vulnerable demographics in need of protection.

The Reisidocument is issued by the Estonian immigration authorities following the identity verification, confirmation of asylum status, and collection of biometric data (fingerprints and mugshot). The document is issued to persons who have been granted refugee status or recognized stateless status, with mandatory verification through national databases. This ensures that the document is used solely to protect the rights of those in desperate situations. The average processing time is six to eight months; statistics for 2022–24: positive decisions about 35%–40%, rejections 60%–65%, total volume about 20,000–30,000 cases per year.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Finland, the Aliens Act (Ulkomaalaislaki) regulates the issuance of Pakolaisen matkustusasiakirja (refugee document) and Muukalaispassi (alien’s passport). Refugees receive a document for five years. Supplementary protection holders can obtain a Muukalaispassi if they do not and cannot have a national passport. Applications are processed by the Migration Service (Migri).

STATISTICS AND TIMELINES. Finland is known for its thorough migration work. In 2022, there were delays in processing due to a surge in applications: there was a backlog of applications for foreign passports and refugee documents due to staff shortages. Migri officially reported a “significant backlog” of such cases and delays of up to several months. Specifically, in 2022, ~800 refugee documents and ~200 foreign passports were issued; in 2023, about 1,000 and 300 (up, but Migri hired additional staff). Average time is now down to two months, down from four to six months in early 2022. The refusals rate is low: in 2023, 5% of Muukalaispassi applicants were refused (mostly Iraqi and Somali nationals, as the embassies of these countries actually issued them passports). Refugees, on the other hand, are not refused by Finland.

TRENDS. The Finnish system has a reserve of flexibility, but any surge of applications leads to queues. For example, the priority issuance of temporary protection permits to Ukrainians has somewhat pushed back the process for other categories. The Finnish Ministry of the Interior has analyzed and is looking for solutions for people who have been living without documents for a long time. If a significant group of Russians without passports appears, Finland will probably make a special decision on how to facilitate their legalization and issuance of Muukalaispassi (in line with trademark Scandinavian pragmatism).

REGULATORY FRAMEWORK AND REQUIREMENTS. In France, the Aliens and Asylum Code (Ceseda) explicitly provides for the issuance of travel documents: Articles L.561-9 and L.561-10 of the Ceseda oblige the refugee to be granted a Titre de voyage. Refugees receive a document for five years (if they have a 10-year residence permit) or four years (if they have a carte de séjour for four years). Persons with subsidiary protection are given a Document de circulation pour étranger protégé for two years (renewable), provided they cannot go for a national passport. Important: French documents have geographical restrictions: one cannot travel to the country from which they have fled; otherwise they face the termination of their status. The documents are issued by the departments’ prefectures.

STATISTICS AND TIMELINES. France is one of the leading EU countries in terms of the number of refugees, but until recently no particular problems with the issuance of travel documents were reported. However, since 2022, refugees have been facing very long waiting times: prefectures are overloaded, the procedure has been moved online through the ANEF portal, which instead of facilitating it has further slowed down the issuance. According to Forum Réfugiés, delays can reach six to eight months. Statistically, France issues thousands of such documents: an estimated 5,000 to 6,000 per year. Refusals are extremely rare: the prefecture can refuse only if there are threats to society. Therefore, the percentage of positive decisions is close to 100%, the only issue is time. For persons with additional protection also almost everyone is issued a document (in the case of Syrians and Afghans, their embassies may be inaccessible, so the prerequisite is met). Refusals in this category are not reported.

TRENDS. The French system is quite unwieldy: multiple prefectures with different practices, the switch to digital filing has been unsuccessful and has led to even more delays. NGOs point out that urgent measures are needed to unify and speed up the process, up to and including the creation of a single issuing center. If in the near future there is a need to quickly provide travel documents to, say, hundreds of Russian opposition activists (many of whom have had their passports revoked by Russia), the current French system in its 2024 state is not ready to respond quickly.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Germany, the issuance of travel documents for refugees and stateless persons is regulated on the basis of the Residence, Employment and Integration of Foreign Nationals Act (Aufenthaltsgesetz, AufenthG) and regulations of the Federal Office for Migration and Refugees (BAMF). Details are available on the official BAMF portal. The travel document is called Reiseausweis für Flüchtlinge and is issued to persons who have been granted refugee or stateless status. It ensures the right to international movement, visas and temporary stay abroad, and is a legally recognized substitute for a national passport. The document is issued after a comprehensive identity, status and biometric identification check conducted by both the BAMF and local migration services. Additional measures are aimed at filtering applicants in order to minimize the risk of persons acting in the interests of foreign intelligence or pro-Kremlin structures obtaining the document.

CURRENT PRACTICE. As of January 2025, approximately 200,000 such documents (including both standard and temporary variants) were registered in Germany each year, and the average processing time is around 60 days. On asylum: when crossing the border, the applicant is registered, followed by a detailed interview with biometrics collection and application through the BAMF. The average processing time is six to nine months; over the period 2022– 24, about 35%–40% of cases receive positive decisions (rejections 60%–65%), with total applications of about 200,000–250,000 over the course three years.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Greece, the rules for issuing travel documents are defined by Law 4636/2019 on Asylum (Art. 24) and presidential decrees. Recognized refugees are granted a Ειδικό Δελτίο Ταυτότητας Πρόσφυγα (refugee travel document) under the 1951 Convention: valid for three years and renewable. Persons with subsidiary protection can apply for a Titre de voyage για αλλοδαπό (travel document for a foreigner) only when it is proven impossible to obtain or renew a passport of their own country (e.g., if the country refuses consular support). Issuance is handled by the Ministry of Migration and Asylum through regional offices.

STATISTICS AND TIMELINES. Greece has received a significant number of refugees in recent years, but issues travel documents to relatively few — many refugees keep or renew their native passports (especially from Syria, Afghanistan). Nevertheless, in 2022, about 1,100 documents were issued to refugees and 90 to persons with subsidiary protection. In 2023, about 1300 and 120 I.D.’s were granted respectively (due to Afghans recognized as refugees). Processing times are problematic: according to NGOs, the waiting time is between four and six months. Reasons: heavy workload on the Immigration Service and limited printing capacity. Refusals: refugees are almost never refused (unless there are security threats), while applicants with additional protection were refused in ~25% of cases, more often due to formal reasons (lack of a certificate from the embassy stating that a passport cannot be issued).

TRENDS. Greek NGOs criticize the system as inefficient — cases when recognized refugees cannot receive documents for months are quite frequent. The authorities have promised to shorten the timeframe in 2024 through digitization. If the flow of new applicants (e.g. Russian dissidents) increases dramatically, the current system will clearly not be able to cope without additional resources.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Hungary, the issuance of travel documents is regulated by the Aliens Act (Idegenrendészeti törvény) and the Asylum Regulations published by the Ministry of the Interior. The official text is available on the government website. The Hungarian travel document for refugees is called Útlevél a menekültek számára and is issued to persons recognized as refugees or stateless persons. It allows international travel and visas and acts as a substitute for a national passport in international relations. The document is issued after verification of the applicant’s status by the migration authorities, with mandatory biometric identification and verification with international databases. Special attention is paid to excluding the risk of issuing the document to “fake” persons associated with foreign intelligence structures.

CURRENT PRACTICE. In Hungary, about 3,500 such documents are issued annually and the average processing time is about 40 days. On asylum: the applicant is registered at the border, where data is recorded, biometrics are taken and an initial interview is conducted, after which the application is submitted. Average processing time is six to eight months; for the period of 2022–24, about 30%–40% of cases are positive decisions, while 60%–70% are declined, with a total number of about 100,000 applications per year. Requirements: detailed documentation of threats, a personal interview, and mandatory verification through national registries.

REGULATORY FRAMEWORK AND REQUIREMENTS. Although Iceland is not a E.U. country, it is part of the Schengen Area. The issuance of travel documents for refugees and stateless persons is regulated by the Aliens Act (Útlendingalög) and regulations of the Icelandic Ministry of Immigration. The Icelandic travel document is called Fartravelsskírteini fyrir flóttafólk and is intended for persons who have been granted asylum or recognized as stateless. It provides the right to international movement, visas and the temporary status necessary for legal residence abroad. It is issued by the immigration authorities after a thorough check of identity, status and biometric data. The procedure is aimed at preventing abuse, including eliminating the risk of issuing the document to representatives of foreign intelligence agencies or those affiliated with pro-Kremlin structures.

CURRENT PRACTICE. Approximately 800 such documents are registered in Iceland each year, and the average processing time is approximately 25 to 30 days. Further analysis is available on RÚV and in local press releases. An applicant arriving in Iceland is registered at a checkpoint where data is recorded and biometrics are taken, then an application is submitted through the migration services. The average processing time is five to seven months; statistics for 2022–24: about 40% positive decisions, about 60% rejections, with a total number of several thousand applications per year.

Regulatory framework and requirement. Ireland, although not part of the Schengen Area, is a member of the EU and a party to the 1951 Convention. The issuance of the Travel Document s regulated by the Asylum Act 1996 and the Immigration Rule 2015. Ireland issues a Refugee Travel Document for a period of two years, which is renewable. Persons granted leave to remain on humanitarian grounds or as stateless persons may request a Temporary Travel Document— in each case at the discretion of the Department of Justice.

STATISTICS AND TIMELINES. Ireland issues several hundred such documents each year. 2022: ~420; 2023: about 500 (due to Ukrainians with a Temporary Protection Status who have become eligible for simple-procedure travel documents for intra-E.U. travel). Processing times are usually four to six weeks, but in 2023, there were delays due to the influx of applications from Afghan nationals (evacuees)—some waited up to three months. Refusals are rare: according to official data, 14 applicants (~2.8%) were refused in 2023, mostly those whose identity was not positively confirmed.

TRENDS. Ireland is loyal to refugees and the system is flexible. However, a surge of applications from new categories (e.g. Russian dissidents without passports) may create new bureaucratic challenges; identity verification should be sped up, which cannot always be achieved quickly at present.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Italy, the issuance of travel documents is regulated by Art. 24 of Legislative Decree No. 18/2014 (the Qualification Decree implementing the EU directive). Refugees are granted a Documento di viaggio per rifugiati, which is valid for five years and is automatically renewed if the status is maintained. It can only be refused for serious reasons of national security. For those granted subsidiary protection, there is the Titolo di viaggio per stranieri issued by the Questura (police) if there are “justified reasons that do not allow obtaining a passport of the country of citizenship.” The applicant with extra protection must provide a written explanation and evidence why he/she cannot obtain or renew a national passport (e.g. lack of embassy, risk of application). If the country’s consular offices are not present in Italy, the Titolo di viaggio is usually issued without delay. Also, persons with special (humanitarian) protection are entitled to the travel document. In 2023, Italian courts confirmed that they should be issued the I.D. without having to prove the impossibility to obtain a passport.

STATISTICS AND TIMELINES. Italy does not publish separate statistics on documents issued, but according to the Interior Ministry, some 8,000–9,000 travel documents were issued to all categories of beneficiaries in 2023. This is a notable increase from ~5,000 in 2021 due to raised number of recognized refugees (especially from Ukraine, Iran, and Afghanistan). Processing times vary by province: in larger cities (Rome, Milan) applicants often wait five to six months, while in smaller cities they wait one to two months. The delays are due to the workload at Questura and the long wait for forms. The percentage of positive decisions is high: refugees are virtually guaranteed a document (rejections are casuistry, <1%). For subsidiary and humanitarian status holders, the rejection rate used to be as high as 20%–25% (strict evidentiary requirements). However, following the court clarifications and MOI circulars 2022–23. Questura should not require “impossibility to obtain a passport” in an absolute sense; the risk for the applicant to contact the embassy is sufficient. This has reduced the denial rate to about 10% in 2024.

TRENDS. The Italian system has historically been considered slow: until 2019, it was not uncommon for refugees to wait more than six months for a document to be issued. In 2023, the Interior Ministry digitized part of the process, but paradoxically, this exacerbated delays in France in a similar way; in Italy, the transition to online applications has not been going smoothly either. A positive trend is that courts are protecting the rights of refugees and protected persons to obtain travel documents without undue hindrance. If applications from Russians/Belarusians (in case they are denied passports at home) increase significantly in the near future, Italy will need to further simplify and speed up the procedure; otherwise the current queues will lengthen to unacceptable lengths.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Latvia, issues are regulated by the Law on Asylum and Cabinet of Ministers Regulations No. 344. Refugees are issued Bēgļa ceļošanas dokuments for two years: persons with alternative status get a Personas bez pilsonības ceļošanas dokuments (document for a stateless person) or Ārzemnieka ceļošanas dokuments if there is no possibility to obtain a passport. Latvia has traditionally also issued special passports to “non-citizens” (former Soviet citizens who did not obtain citizenship), but this is a separate category.

STATISTICS AND TIMELINES. Latvia accepts few refugees (dozens per year), accordingly issuance of travel documents is sporadic. In 2022 34 documents were issued, in 2023 — 27. The processing time is usually one month. There were practically no refusals (zero in 2022 and one in 2023 due to the submission of false data).

TRENDS. Latvia has tightened visa regime for Russians and Belarusians since 2022, and there are almost no new refugees from these countries. In case of their appearance, the system can easily cope due to small absolute numbers, but there may be political obstacles (Latvia is strictly against the Russian regime and may not be in a hurry to grant statuses, although if the status is granted, the document will be issued without hassle).

REGULATORY FRAMEWORK AND REQUIREMENTS. Liechtenstein, although a microstate, is a full member of the Schengen Agreement. It has the Asylum Act (Asylgesetz) and Aliens Act similar to the Swiss regulations. Refugees receive Reisedokument für Flüchtlinge, persons with temporary protection receive Reisedokument für Ausländer if it is proven necessary. The number of cases is extremely low (few per year). The Liechtenstein authorities often cooperate with Switzerland in these matters (Swiss-style travel documents).

STATISTICS AND TIMELINES. . In 2023, only three documents were issued to refugees and zero to other categories. The issuance period is about two weeks. No refusals have been registered. The system operates without delays due to the minimal workload.

TRENDS. The probability of a mass influx of applicants (e.g. Russians) to Liechtenstein is extremely low due to the strict entry requirements. Therefore, the system does not change significantly.

REGULATORY FRAMEWORK AND REQUIREMENTS. Lithuania has the Law on Asylum (2004, as amended) and the Law on the Legal Status of Aliens. Recognized refugees receive Keliauto dokumentas pabėgėliams for five years. Persons with extra protection: Kelionės dokumentas užsieniečiui (alien’s travel document) for the period of validity of the residence permit (usually two years), but only upon proving that it is impossible to obtain a passport of the home country. Lithuania is also obliged to issue travel documents to stateless persons (the 1954 Convention ratified).

STATISTICS AND TIMELINES. In 2022, Lithuania issued 82 documents to refugees and 10 to additional protected persons; in 2023, 90 and 15, respectively. Processing times are often delayed: a report by the Seimas Commissioner noted that applicants wait up to six months. The reason: thorough checks by the Migration Department, especially for CIS nationals. Refusals do occure: in a high-profile case, Lithuania refused to issue a document to a person with a longterm residence permit (former refugee with extra protection) because they failed to prove the impossibility to obtain a passport of their country. In 2023, the European Court of Human Rights condemned Lithuania for unjustified refusal to issue a travel document to such a person, stating that the authorities formally rejected the request without taking into account the applicant’s circumstances. The refusal rate has since decreased, but is still around 20% for persons with subsidiary protection (three refusals out of ~15 applications in 2024). For refugees, on the other hand, there are no refusals except in cases of revocation of status.

TRENDS. Lithuania is gradually adjusting its practices under the pressure of court decisions. The system is rigid, focused on minimizing the issuance of documents to “unnecessary” people. In case of an influx of Russian applicants, both systemic delays and political resistance to their admission are possible, which will indirectly affect the issuance of travel documents.

Regulatory framework and conditions. In Luxembourg, the issuance of travel documents is governed by the Asylum Law of December 18, 2015 and accompanying regulations. Refugees receive a titre de voyage pour réfugié for a period of five years (or until the end of their status). Persons with subsidiary protection and stateless persons may apply for a titre de voyage pour apatride/étranger if they prove that they cannot obtain a national passport. The decision is issued by the Ministry of Foreign and European Affairs (Directorate of Immigration).

STATISTICS AND TIMELINES. Due to the small size of the country, the absolute numbers are small: Luxembourg issues dozens of travel documents each year. In 2022, it was 55 documents issued to refugees, 12 to foreigners with extra protection, and three to stateless persons. In 2023, these numbers were about 70, 15, and five, respectively. Processing times are usually two to four weeks, although there have been cases of waiting up to two months when there is a shortage of staff. Refusals are isolated: in 2023, two refusals were recorded (in one case, an applicant with humanitarian status was unable to convince the authorities that it was impossible to obtain a consular passport). The authorities try to adhere to their international obligations, so the vast majority of applications are granted.

TRENDS. Luxembourg’s system is quite flexible, given the small number of beneficiaries. However, the problem is the geographical restrictions: the documents issued to refugees usually state that they are not valid for travel to the country of origin (this is a standard restriction in many countries, e.g. France). New trends (e.g. applications from Russians) have not yet been observed on a significant scale.

REGULATORY FRAMEWORK AND REQUIREMENTS. Maltese legislation on the issuance of travel documents for refugees and stateless persons is based on the Aliens Act and the Asylum Act published on the official Maltese Government portal. These regulations are in line with EU directives. The document is called the Travel Document for Refugees and is issued to persons who have been granted asylum or recognized as stateless. It provides the right to international movement, visas and temporary residence in EU countries, acting as a temporary replacement for a passport. It is issued by Malta’s migration authorities after confirmation of status through detailed identity verification, collection of biometric data and verification through international security systems. Additional measures are aimed at filtering applicants to prevent foreign intelligence agents from obtaining the document.

CURRENT PRACTICE. In Malta, approximately 1000 such documents are issued annually and the average processing time is about 30 days. On asylum: after registering at the reception center, the applicant undergoes an initial interview, biometrics collection and submits the application through the local migration services. The average processing time is eight to ten months; the statistics for 2022–24 show positive decisions in 35%–40% of cases, with refusals accounting for 60%–65% of the cases and a total number of applications being about 20,000 per year.

REGULATORY FRAMEWORK AND REQUIREMENTS. The Netherlands has the Vreemdelingencirculaire (Circular on Foreign Nationals) and the 2000 Asylum Act. Recognized refugees are issued a Vluchtelingenpaspoort (refugee passport) for five years. Persons with subsidiary protection (subsidiary protection) or stateless persons can obtain a Vreemdelingenpaspoort (foreigner’s passport) if they prove that they do not have a national passport or if their country refuses to issue one. Registration is handled by the municipality of residence in coordination with the IND (Immigration Service).

STATISTICS AND TIMELINES. The Netherlands issues a significant number of documents each year, given the large intake of refugees. In 2022, ~4200 refugee passports and ~600 alien passports were issued; in 2023, about 5,000 and 700 respectively (an increase of ~18%). The average processing time is three to four weeks, as the process is decentralized (municipal services are quite prompt). Refusals: to refugees are practically non-existent (only if deprived of status), on applications for Vreemdelingenpaspoort — about 15% refusals (in cases where IND believes that the applicant can get his/her passport, especially concerns natives of Iran and Eritrea).

TRENDS. The Netherlands is known for efficient administrative work, but in 2023 complaints were noted about differences in the approach of municipalities: some demanded the impossible from applicants with supplementary protection (e.g., an official refusal from the embassy), which went against government recommendations. As a result, clarifications were issued obliging municipalities not to request excessive evidence. In the event of an increase in applications (including from Russian citizens, if any are granted status in the Netherlands), the system is likely to cope, although there may be discussions in parliament at the political level.

REGULATORY FRAMEWORK AND REQUIREMENTS. A Schengen Area country, Norway is not part of the E.U., but complies with the Refugee Convention. The Office for Foreigners (UDI) issues the Reisebevis for flyktning (refugee travel document) and the Utlendingspass (alien’s passport). Refugees receive a Reisebevis for a period of three years (usually coinciding with the term of the primary residence permit). Persons with a limited residence permit (e.g. for humanitarian reasons) can obtain a Utlendingspass if they cannot use their home country’s passport.

STATISTICS AND TIMELINES. Norway issued ~1100 Reisebevis and ~300 Utlendingspass in 2022 and ~1,500 and 350 respectively in 2023. Waiting times are typically one month, but in 2022, there were delays of up to three months due to covid restrictions on passport offices. Refusals are few: UDI reported 22 refusals in 2023 (~5%), mostly for Utlendingspass applications where it was found that the applicant had recently renewed a national passport, i.e. a Norwegian travel document was no longer needed.

TRENDS. The Norwegian system is quite stable and fast, as noted by international reports. Norway regulates the possible influx of new applicants from Russia/Belarus through border policy (visas). For those who are already inside and will get the status, the state will provide documents as standard.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Poland, the Act on granting protection to foreigners (Ustawa o udzielaniu cudzoziemiemcom ochrony) regulates the issuance of a Dokument podróży przewidziany w Konwencji (Convention Travel Document) to refugees and a Dokument podróży dla cudzoziemca to other protected persons and stateless persons. Refugees are issued a document for two years with the possibility of extension. Persons with additional protection — for one year (can be extended), but only if they are unable to obtain or extend a national passport. The authority responsible for issuance is the Office for Foreigners (UDSC) under the Interior Ministry, through the voivodeship offices.

STATISTICS AND TIMELINES. Poland, due to the crisis in Belarus and the war in Ukraine, has sharply increased the intake of protected persons. In 2023 Poland issued 281,279 first residence permits to citizens of Belarus (this is a record among all EU countries), also tens of thousands of Russians received asylum or other statuses. Accordingly, the number of travel documents issued has increased. In 2022, ~500 documents were issued to refugees and in 2023 over 1,200 (mostly to Belarusian government critics who were granted asylum). Additionally, Poland has recognized several hundred stateless persons: they, too, have been issued travel documents. Timing: due to the workload, some waited for more than six months, which is recognized by the authorities. Refusals: there was an increase in the number of document denials for Belarusians with additional protection, if the Polish authorities believed they could safely renew their Belarusian passport (about 15% of such applications were denied). However, for opposition refugees whose passports the Lukashenka regime revoked, Poland, on the contrary, accelerated the issuance of documents, realizing their vulnerability.

TRENDS. Poland is experiencing an unprecedented influx of Belarusian and Russian citizens fleeing repression. Many remain on statuses that do not automatically entitle them to a Polish passport. The system has become overloaded: priority has been given to Ukrainians with temporary protection, and processing for other refugees has been pushed back. With further growth in applications, Poland is likely to create special simplified programs for Belarusians/ Russians (legislative changes are already being discussed) so that they are not left without documents.

Regulatory framework and requirement. In Portugal, Law No. 27/2008 On Asylum specifies that refugees are granted a Título de viagem para refugiado for a period of five years. Persons with subsidiary protection may be issued a Títulode viagem para estrangeiro for two years if they cannot obtain a passport. The issuance is carried out by the SEF (Service of Foreigners and Borders). In 2022, Portugal amended the procedure to make it simpler and cheaper: the issuance of travel documents for refugees is now free of charge.

STATISTICS AND TIMELINES. Portugal receives relatively few refugees (except for the relocation program). In 2022, 110 refugee and 20 foreigner documents were issued; in 2023, ~150 and 30. Receipt time is usually two months, due to queues at SEF (Portugal had a crisis in 2022 with delays in issuing any documents). Refusals are very rare: for 2022–23, no refugees were refused, only three refusals for applicants with subsidiary protection (in cases where the applicants themselves obtained new passports at their embassy).

TRENDS. Following the 2022 reform, Portugal has improved the situation: provisional documents (while status is being considered) are now issued free of charge and quickly, which indirectly speeds up the issuance of permanent travel documents as well. The system is friendly, but administrative delays are possible due to the overall workload of the SEF. The number of beneficiaries from Russia/Belarus is unlikely to grow (these citizens rarely seek asylum in Portugal), so the current capacity is sufficient.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Romania, Law No. 122/2006 On Asylum and Interior Ministry Order No. 1182/2007 regulate the issuance of the Document de călătorie pentru refugiat to refugees (valid for five years) and the Titlu de călătorie pentru străini to other categories (valid for one year and renewable). Decisions are taken by the General Inspectorate for Immigration (IGI).

STATISTICS AND TIMELINES. Romania has traditionally accepted few refugees, but has accommodated ~2,000 Afghan evacuees and some Belarusian activists since 2022. In 2023, ~140 travel documents were issued to refugees and ~50 to humanitarian status holders. Timeframes are moderate: one to two months. Refusals: Romania refuses very rarely (two refusals in 2023), adhering to commitments.

TRENDS. The system is stable but low-component: the slightest increase in applications noticeably increases the timeframe. In 2024, the IGI reform is expected to take place, within which framework they want to cut the red tape: possibly, travel documents will be issued through a single center based on biometric data to speed up the process.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Slovakia, Act No. 480/2002 Z.z. On Asylum and the Act on Stay of Foreigners regulate the issuance of a Cestovný doklad pre utečenca (refugee, five years) and a Cestovný doklad pre cudzinca (foreigner, one year). For refugees, the document is issued by the Ministry of Interior after the granting of asylum. Supplementary protection alone does not entitle you to the document — usually people with supplementary protection are offered to try to renew their national passport. However, if this is not possible, the MIA may issue a Cestovný preukaz totožnosti (exit certificate), valid only for a single trip.

STATISTICS AND TIMELINES. Due to the small number of refugees (only 50 persons were granted asylum in 2023), the issuance of travel documents is sporadic, with 12 issued in 2022 and 18 in 2023. The time limit is about one month. There are practically no refusals, although the procedure for additional protection is not clearly defined, many people just continue to use their passports.

TRENDS. In 2023, Slovakia tightened its policy toward the Russians (up to denying visas according to EU recommendations). However, this has not had a significant impact on the system of travel documents, as new refugees from Russia/Belarus are hardly ever admitted here.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Slovenia, the Act on International Protection (ZMZ) and the Regulation on Documents for Aliens regulate the issuance of the Potni list za begunca (refugee, ten years) and Tujski potni list (alien, two years). Refugees are usually issued a passport together with a residence permit. Persons with extr protection: only if they are unable to obtain a passport (must provide evidence, e.g. a letter of refusal from the embassy).

STATISTICS AND TIMELINES. Slovenia issued 45 refugee and five alien documents in 2022; 60 and eight in 2023. The waiting period is up to one month, the procedure takes place at the Ministry of Interior and local administrative units. There are few refusals: one or two cases per year.

TRENDS. The system works smoothly due to the small number of cases. In 2025, the government is planning on cutting the validity period of the refugee document down to five years (in accordance with E.U. standards), but this is a draft bill.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Spain, the procedure is regulated by Law 12/2009 on asylum and Royal Decree 203/1995. The Office for Refugees (OAR) at the Interior Ministry is responsible for issuing a Documento de viaje para refugiados, a travel document for a refugee with a five-year validity. For persons with subsidiary protection, there is a Documento de viaje para extranjeros for up to one year (with extensions), but it is only issued when it is proven impossible to obtain a national passport. Almost immediately after the status is recognized, the OAR sends the refugee’s data to the police, which produces the travel document.

STATISTICS AND TIMELINES. Spain has increased refugee admissions since 2018, but most arrivals have their own passports (e.g. Latin Americans, Venezuelans). Nevertheless, in 2022, ~1,800 refugee documents and ~200 ones for extra protection/apatrides were issued. In 2023, these numbers were ~2,100 and 240, respectively (the number of applicants from Africa who did not have passports had increased). Processing times: two to three months in major cities (Madrid, Barcelona) and one to two months elsewhere due to the police being overloaded with paperwork. Refusals: less than 5% for applicants with additional protection (reasons: applicant was able to obtain or renew his/her passport). For refugees, there were almost no cases of refusal — the law does not provide for discretion, except for security threats. Separately, Spain recognizes stateless persons (through the U.N./UNHCR Office) and issues them a document similar in procedure.

TRENDS. In 2023, there were delays due to a digital glitch in the entry system, creating queues. The Spanish authorities are generally coping, but an increase in applications (including a possible influx of Russians) will require an increase in the OAR capacity and police document issuance units.

REGULATORY FRAMEWORK AND REQUIREMENTS. In Sweden, the Aliens Act (Utlänningslagen) and government regulations govern the issuance of a Resedokument (to a refugee) and Främlingspass (to a stranger). Refugees are granted a Resedokument for a term of five years. Främlingspasses are issued for three years if there is no “national passport.” Applications are processed by the Immigration Agency (Migrationsverket).

STATISTICS AND TIMELINES. Sweden has historically accepted many refugees, but many have their own documents. In 2022, ~1,300 Resedokument and ~400 Främlingspass were issued; in 2023, these figures were ~1,500 and 450, respectively. The processing times were one to two months, but those increased to ~three months by late 2023 due to shortages of chips and document materials. Refusals are rare (in 2023, five Främlingspass applicants were denied an I.D.: those were deemed to have evaded contacting their embassy without sufficient reason).

TRENDS. Sweden is now tightening migration policy, but the documentation rights of already recognized refugees are not affected. It is possible to introduce a shorter period of validity of documents (three years) to synchronize with residence permits, which is under discussion. In case of a dramatic increase in applications, funding for the Immigration Agency is likely to be increased to avoid delays.

REGULATORY FRAMEWORK AND REQUIREMENTS. Switzerland (Schengen Area, non-E.U.) has its own asylum law (AsylG) and foreigners’ law (AuG). Refugees receive a Reiseausweis für Flüchtlinge (refugee travel document) for five years. Persons granted the so-called “temporary protection” (Status S) or other humanitarian statuses can receive a Pass für Ausländer for up to five years unless they can obtain a passport.

STATISTICS AND TIMELINES. Switzerland is a major receiver of refugees in Europe. According to official figures, there has been a dramatic increase in the issuance of “travel certificates” since 2017: while only 15,056 documents were issued in 2017, with 159,018 in 2021 and 216,524 in 2023. These figures likely include extensions and reissuances and are indicative of the scale of the system. Syrians, Iraqis, and Afghans have received the majority of documents. The timeframes are usually reasonable: four to eight weeks. However, in recent years there have been complaints from applicants about delays due to biometric data checks (Switzerland has increased controls after fraud cases). Refusals are possible on the basis of security threats or if the refugee has traveled to his or her home country (leading to loss of status). The refusal rate is low (a few dozen cases, <0.5%).

TRENDS. The Swiss system is relatively well funded and able to process a large number of applications. Nevertheless, the bureaucratic burden is growing: processing more than 200,000 documents per year requires significant resources. A possible mass influx of new groups, such as Russian dissidents, may add to the workload, but in general Switzerland is able to adapt, although it may introduce quotas or simplify extensions rather than complete re-issuance of the document.

Appendix 2. Terms

Legal and political terms used:

Travel document: a temporary travel I.D., which is not a national passport and does not grant citizenship, used in scenarios where obtaining a new passport with the country of origin or getting it renewed is impossible.

Nansen passport: a precedent-setting 20th-century document first issued by the League of Nations in 1922 to the stateless persons, specifically, to the post-1917 Revolution Russian émigrés, recognized by many governments as a travel document for refugees and stateless persons.

Refugee travel document: a travel document for officially recognized refugees (issued under the 1951 U.N. Convention).

Statetess person I.D.: issued to stateless persons (apatrides) under the 1954 U.N. Convention.

Certificate of Identity (COI): an I.D. with partial international recognition used for emergency cases.

Emergency Travel Document (ETD): an I.D. issued in emergency situations (e.g., losing a passport abroad etc.).

Laissez-Passer: a temporary travel document, typically issued by international organizations like the U.N. for emergency use and business trips.

Fremdenpass: an Austrian foreign national passport issued to indivduals without a valid passport, that have a legal status and are eligible for extra protection.

Užsieniečio pasas: a Lithuanian foreign national passport issued to indivduals without a possibility to obtain a national passport.

Humanitarian visa: a special visa issued to non-refugee individuals in need of protection.

Extra protection: a legal status granted to individuals that are not eligible for a refugee status whose return to their country of origin implies a high risk of persecution.

United Transitional Cabinet of Belarus: an alternative cabinet formed by the Belarusian opposition that operates from abroad.

Passport of New Belarus: an alternative I.D. being developed by the Belarusian opposition to help those who cannot have their official passport renewed legally stay in Europe.

Social science and economic terms used:

Immigration policy: a set of government steps and rules covering the immigrants’ arrival,stay, and integration.

Stateless persons (apatrides): individuals without internationally recognized citizenship of any country.

Anti-migrant discrimination: systemic abuse of the migrants’ rights based on their origin, citizenship, or status.

Repatriation: sending migrants back to their home country.

Naturalization: obtaining citizenship by a migrant.

Migrant integration: the incorporation of migrants into the social, economic, and cultural interaction offered by the country of stay.

Shadow economy: an untaxed sector of the national economy outside of the government control that often accommodates illegal aliens.

Modern Russian realities:

Foreign agent: a legal status designated by the Russian government to the individuals and businesses the government believes are dong the bidding of other governments. This instrument targets the government critics and dissidents and partially strips them of their rights.

Hostile countries: countries whose policies the Russian government consiers hostile toward Russia (imposing sanctions, aiding Ukraine, expelling diplomats, and limiting financial and cultural cooperation). The term was legislated in 2021 to include most of the E.U. countries, the U.S., the U.K., a host of other countries, which leads to economic hindrances, visa restrictions, tightened bureaucratic procedures, and additional hassle intended for individuals and businesses hailing from said countries. The E.U. sees this as an attempt to leverage political pressure without any legitimacy coming from the international law, affecting these countries’ relations with Russia.

Extremist: a broad concept often used by the Russian authorities to deisnged the political opponents and activists whose views or actions are officially regarded as jeopardizing the current political order.

Terrorist: a term used in the current Russian legislation to designate the individuals and businesses either accused or suspected of being implicated in the acts of anti-government violence. In recent years, the term has been extensively misused to exert politicial pressure.

Appendix 3. Poll Questionnaire for the E.U. Immigrants from Russia and Belarus

Introduction:

Dear participant,

We are conducting a survey on the way potential changes to the Russian and Belarusian passport policy may affect the life of exiles living in the E.U./Schengen Area. Your answer will provide us with a better insight into the current situation and the prevalent sentiment among the exile communities. Please consider the follows questions and pick the asnwer choice that fits your case. Your data will only be used anonymously and in aggregated fashion.

1. General information on your stay in Europe

1. What is your legal status in the country of stay?
   • Temporary residence permit
   • Permanent residence permit
   • Other (specify below)
2. If you have a temporary residence permit, when will it expire?
   • Less than one year
   • 1–2 years
   • More than two years
   • Not applicable (e.g., permanent residence permit)
3. What is your evaluation of your current legal status?
   • Very stable
   • Somewhat stable
   • Unstable
   • Very unstable

2. Passport policy pursued by your home country

4. Do you know Russia may stop renewing the passports for the Russians living abroad?
   • Yes
   • No
5. If you do, what is your view of this possibility?
   • Very negative: my plight will get worse
   • Somewhat negative
   • Neutral
   • Somewhat positive
   • Very positive
6. Belarus has already stopped renewing the passports of Belarusians living abroad. How does this fact affect your take on the current situation in your home country?
   • Very negative: my plight will get worse
   • Somewhat negative
   • Neutral
   • Somewhat positive
   • Very positive

3. Assessment of current situations and potential scenarios

7. How anxious are you about possible persecution once back in Russia/Belarus?
   • Very anxious
   • Somewhat anxious
   • Neutral
   • Rather not anxious
   • Not anxious at all
8. If you fear being prosecuted back home, are you eyeing applying for international protection/asylum?
   • Absolutely
   • It depends
   • No, I am not
   • Undecided
9. If you face a scenario where you cannot get your passport renewed, how are you going to deal with your legal status?
   • Apply for international protection/asylum
   • Attempt to get a temporary residence permit/have my permit renewed by local immigration authorities
   • Switch to (illegal) “undocumented” status
   • Other (specify below)
10. What are the odds of you returning home despite the potential persecution if the ban on the passport renewal gets approved?
    • Very high
    • Somewhat high
    • Middle of the road
    • Rather low
    • Zero

4. Practical hardship dealing with current status (temporary residence permit)

11. If you hold a temporary residence permit, are you facing difficulty trying to get it extended?
    • Considerable
    • Minor difficulty
    • No, I am not
    • Not applicable (I hold a permanent residence permit)
12. Which of the listed issues are the most pressing for you as you try to get your temporary residence permit extended? (Several answer choices possible)
    • Preparing and submitting the paperwork
    • Long application processing times
    • High renewal fee
    • Uncertain future status
    • Other (specify below)
13. Do you think changes to your home country’s passport policy will lead to you having trouble getting your temporary residence permit extended?
    • Yes, significant trouble
    • Perhaps, some issues
    • No, they will not
    • Undecided

5. Extra questions

14. How aware are you of the changes to the Russian and Belarusian passport policies?
    • Very aware
    • Somewhat aware
    • I have heard about it
    • Unaware
15. What sources of information do you consider the most reliable in this regard? (Several answer choices possible)
    • Official government statements
    • International organizations (U.N., EUAA, etc.)
    • Independent media
    • Social media and blogs
    • Other (specify below)

Thank you for taking your time to answer the questions!

Your answers will help us get a better insight into the prevalent sentiment among the exiles offer a set of guidelines to support the individuals affected by the changes to their home countries’ passport policies.