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Information note to administrations for access to rights · prot. 0124209 del 15/07/2026

Questura of Bologna — Immigration Office, 4th Section, 13 July 2026

Unofficial translation of the SOS Patto summary. The original decision or document is available in Italian only.

Subject

The Questura of Bologna informs AUSL, the Municipality, the Revenue Agency and the Chamber of Commerce that, with the entry into force of the Pact and Decree-Law 100/2026, at the end of registration of the application the residence permit for asylum application is no longer issued: the only document available to the applicant is the Certificate of expression of the wish to apply (Article 29(1) of Regulation (EU) 2024/1348; Article 4(1) of Legislative Decree 142/2015). During the transitional regime in force until 31 October, registration of the application takes the place of lodging, so that the Certificate remains the only document until the outcome of the proceedings. The recipient administrations are reminded to guarantee, on the basis of the Certificate, registration with the National Health Service (Article 21(1) of Legislative Decree 142/2015), education of minors (Article 21(2)), the right to work after 90 days (Article 22(1)) and registration in the population register (Article 5-bis(1)).

Note from the Questura of Bologna (police headquarters) — Immigration Office, addressed to the AUSL, the Municipality, the Revenue Agency and the Chamber of Commerce of Bologna. It serves an operational liaison function: it explains to those who will interact daily with the applicant which document he or she will present from now on, in place of the residence permit for asylum application, and with what effects on access to rights.

The new document: the «Certificate of expression of the wish to apply»

The communication starts from the legal premise — Regulation (EU) 2024/1348 applicable from 12 June 2026 and Decree-Law 100/2026 adapting the national legal order — and notes the practical consequence: at the end of registration at the Immigration Office «the issue of the temporary residence permit for asylum application is no longer provided for». The foreign national is issued «solely a Certificate of Expression of the Wish to Apply (Article 29(1) of Regulation (EU) 2024/1348; Article 4(1) of Legislative Decree 142/2015), on which a photograph of the applicant and his or her tax code will be affixed (where generated by the system)». Where the applicant is accompanied by minor children, the Certificate also shows their photograph with personal details and tax code.

The role of the Certificate in the transitional regime

The substantive point lies in the coordination with Italian law. The note recalls that, «although the Certificate bears the wording according to which within 21 days the applicant must proceed to lodge the application with the Territorial Commission», during the transitional regime in force until 31 October 2026 «registration of the application takes the place of lodging». It follows that «the Certificate of expression of the wish to apply will be the only document in fact available to the applicant for international protection, until the outcome of the proceedings». It is the operational reverse of the Italian choice to postpone lodging before the Commissions: the only document in circulation is the one issued at the time of registration.

The recipient administrations and the applicant's rights

The rationale of the communication is the same as that of the clarifications already circulated in other Questure: to ensure that the Certificate is accepted as a valid title for the exercise of the rights granted to the applicant for protection by the legislation in force. The note recalls four specific references: registration with the National Health Service (Article 21(1) of Legislative Decree 142/2015); education of minors (Article 21(2)); access to work after ninety days from the application (Article 22(1)); registration in the population register (Article 5-bis(1)). The institutional interlocutors (AUSL, municipal registry office, Revenue Agency for the tax code, Chamber of Commerce for registration in the Business Register) are advised that the Certificate is the only documentation with which, at this stage, the holder will be able to claim the corresponding benefits.

Practical usefulness for the defence

The note is a useful documentary confirmation, which can be relied on in a complaint or a brief, when the local administration objects to the applicant's lack of a paper residence permit or denies him or her a benefit for insufficiency of title. The Questura of Bologna expressly describes the Certificate of expression of the wish to apply as the «only document in fact» of the applicant during the transitional regime, and traces access to rights back to the national legislation already in force. It should be read together with the certificate of the Questura of Trento published on this site, which shows the model of the document handed to the applicant.

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