The Irish government has announced that any Irish Residence Permits (IRP) holders in Dublin may now renew their residency permission online rather than having attend an in-person appointment. This will initially be open to only those with an urgent need to travel and require a valid IRP card. Additionally the Burgh Quay (Dublin) Registration Office will re-open for first time registration appointments on 20 July 2020.

The Immigration Act 2004 requires non-nationals (non-EU/EEA & Swiss plus some other exceptions) to register if they have been given permission to remain in the State for longer than 3 months. Alongside the initial requirement to register upon arrival in the State, the registration / permission to remain must be renewed, usually on an annual basis.

Key points:

• Implementation time frame:
  - From 7th July 2020, the online IRP renewal system is available for non-EEA nationals whose residency permission has expired, or expires in the next month and who have an urgent need to travel.
  - From 20th July 2020, the online system will be open to all individuals whose IRP/GNIB cards have expired, or are due to expire in the next month.
  - From 20th July 2020, non-EEA nationals seeking to complete their first time registration in Ireland, may attend the Burgh Quay Registration Office

• Who is affected: All holders of an IRP card who are resident in Dublin will be impacted by this development. All stamp types are eligible for renewal. Non-EEA nationals can use the online renewal platform if their IRP card expires within a month from the online submission date.

• Next Steps: Employers should update all employees who hold IRP cards and are resident in Dublin. Those whose IRP cards have expired, or expire in the next 4 weeks, and who have an urgent need to travel, should apply for their renewal online here. The individual will be required to create an online account. To complete the renewal application online, the relevant documents will need to be uploaded to the online platform. They will then be requested to submit original documents. Employees should be aware that they may not be able to travel until their passport and renewed IRP cards are returned.
  

Analysis & Comments: Deloitte welcomes this permanent change to the IRP renewals process. This will allow the resumption of IRP renewals, without the need for an in-person appointment.

This removes the challenges in booking an IRP appointment at the Burgh Quay Registration Office which we seen to date. It should create more available appointments for first time registrants. It further allows non-EEA more flexibility in renewing their permission as they no longer to attend an in-person appointment. This will be a welcome change given the current Covid-19 restrictions in Ireland.

The resumption of IRP renewals also will allow for visa required nationals to obtain permission that will allow them to travel and re-enter Ireland.

We note that we expect a high volume of applications due to a back log as a result of office closures and therefore non-EEA nationals should anticipate a potential delay in receiving back their renewed IRP cards and passports. It is the first time this system will have such a significant number of applicants and therefore applicants should be aware that further updates may be issued regarding the process and documents required. We further want to flag that it will be important that applicants are aware that they may be without their passports whilst their renewal application is processing. Both their passport and their renewed Irish Residence permission will be sent out separately to the home address provided.

This change will not affect non-EEA nationals who have not yet registered and received their first IRP card in Ireland; such individuals will still need to book and attend an in-person appointment. For this population, Deloitte welcomes the re-opening of the Burgh Quay Registration Office. This means that first time registrants can apply for their IRP cards, and thus will have the relevant permission to travel in and out of Ireland.

Immigration Service Delivery (who manages the above) deals with registrations for those resident in Dublin. The Garda Naturalisation and Immigration Bureau (GNIB) deals with applications outside of Dublin through the Garda Station network. GNIB are currently considering how they can reopen registration offices countrywide while adhering to public health guidelines, and applicants should contact their local office to confirm when they will reopen.

If you have employees or potential new hires who may be impacted by the above changes, please contact the Deloitte immigration team to assist. We have created a guidebook for non-EEA nationals to use when setting themselves up on the system and how we will support them through this new process. We continue to update our FAQ for employers found here.