Overview

• The BMI issued targeted exceptions allowing paper photo submissions until September 30 in parts of Bavaria, Baden-Württemberg and Mecklenburg-Vorpommern due to scanner and service gaps.
• No further deadline extensions will be granted beyond these rural regions as the nationwide digital-only requirement takes full effect on August 1.
• Many municipal offices remain under-equipped, with just one in three authorities owning photo terminals and residents facing journeys of up to 50 kilometres for digital portraits.
• Automatic photo-validation software has proven unreliable, marking non-compliant images as acceptable and forcing staff to reject green-flagged submissions manually.
• Although around three million documents have been processed with digital photos since May, citizens report confusion over self-service requirements and longer waiting times at offices.