KVR Munich Security Interview: Fiktionsbescheinigung

Executive Summary

The correct KVR Munich sequence is security interview first, then biometrics and RP issuance, when reversed, the biometrics case stays pending until the security interview is done.
Applicants with an imminent visa expiry can request a Fiktionsbescheinigung at the security interview appointment itself, before the RP appointment is scheduled.
The fictional effect under §81(3) AufenthG activates on application submission, lawful residence is protected even before the physical document is issued, provided the application was submitted before visa expiry.
HR must confirm application pre-submission timing and verify the Fiktionsbescheinigung wording includes Erwerbstätigkeit erlaubt to ensure uninterrupted work authorization.

Question: Can an applicant request a Fiktionsbescheinigung at the KVR Munich security interview if their visa expires before the residence permit appointment?

Answer:
Yes, when a visa is approaching expiry and the Germany residence permit (RP) appointment has not yet been scheduled, applicants can request a Fiktionsbescheinigung at the KVR Ruppertstraße security interview (Sicherheitsgespräch). The correct process sequence at KVR Munich is security interview first, then biometrics and RP issuance. When the sequence is reversed and biometrics happen before the security interview, the RP case is left pending until the security interview is completed. In both scenarios, the Fiktionsbescheinigung provides interim legal residence and, where the previous permit allowed employment, continued work authorization. HR teams should verify that the application was submitted before visa expiry to activate the fictional effect under §81(3) AufenthG.

At a Glance: KVR Munich Security Interview and Visa Expiry Scenario

SMS Function	Level 1 User	Level 2 User
Assign Certificates of Sponsorship	Yes	Yes (CoS they personally created only)
Report worker changes to UKVI	Yes (all sponsored workers)	Yes (only their own CoS)
Update organisation/licence details	Yes	No
Add or remove SMS users	Yes	No
Apply to renew sponsor licence	Yes	No
View full licence details and message board	Yes	No
Can be an agency temp worker	No	Yes
Required at application stage	Yes (one mandatory)	No (optional; added post-grant)

Security Interview Sequencing and Interim Status at KVR Munich

The Legal Position

Under §81(3) and §81(4) of the Aufenthaltsgesetz, a residence permit application submitted before visa expiry automatically triggers the fictional effect (Fiktionswirkung). This extends the employee’s lawful stay in Germany and, where the previous permit allowed work, usually preserves work authorization while the application is pending.

This protection applies immediately after submission, even if the Fiktionsbescheinigung has not yet been physically issued.

In Munich, the residence permit process is handled by the KVR’s Servicestelle für Zuwanderung at Ruppertstraße 19, including the mandatory security interview (Sicherheitsgespräch).

In practice:

The security interview is treated as a prerequisite step.
It should normally happen before the biometrics appointment.
If biometrics is scheduled first, the case often remains pending until the security interview is completed.
The residence permit is not issued until both steps are cleared.

For HR and mobility teams, this distinction matters. A biometrics appointment alone does not mean the permit approval process is complete.

Requesting the Fiktionsbescheinigung at the Security Interview

If the employee’s visa is close to expiry and no residence permit appointment has been scheduled, the security interview at Ruppertstraße is usually the right moment to request the Fiktionsbescheinigung directly from the KVR officer.

Employees should bring:

Original passport and visa
Residence permit application confirmation
Appointment letter
Supporting immigration documents already submitted

Depending on the case, the officer may:

Issue the Fiktionsbescheinigung during the appointment
Start the issuance process
Refer the applicant to the emergency services desk at Entrance A

If the document cannot be issued immediately, employees should request written confirmation that the application remains pending. This can serve as interim proof of lawful status.

Typical processing time after the interview ranges from a few days to around two weeks, depending on KVR workload.

HR Guidance

1. Verify filing timing first

The key compliance threshold is whether the residence permit application was submitted before visa expiry.

If filed on time:

The fictional effect applies
Lawful residence continues while the application is pending

2. Prepare the employee before the interview

Advise the employee to proactively request the Fiktionsbescheinigung during the security interview.

They should carry all originals, especially:

Application confirmation
Appointment letter
Existing visa documentation

3. Escalate early if timing is tight

HR or mobility teams should contact KVR Munich if:

The visa expires within 15 days, and
The security interview has not yet taken place

The contact to KVR Munich can be made through:

The Kontaktformular
Telephone consultation hours listed on stadt.muenchen.de

The goal is to flag urgency and request faster Fiktionsbescheinigung issuance.

4. Confirm work authorization wording

Once issued, carefully review the supplementary wording on the Fiktionsbescheinigung.

Look specifically for Erwerbstätigkeit erlaubt on the document.

Without this wording, lawful residence may continue, but employment authorization may not.

Key Risks

1. Application filed after visa expiry

If the Munich residence permit application is submitted late:

The fictional effect does not apply
Lawful residence status lapses
Work authorization is suspended until the permit is issued

This creates a direct immigration compliance risk for HR and payroll teams.

2. Biometrics completed before security interview

A biometrics appointment does not mean the case is approved.

If the Sicherheitsgespräch is still pending:

The residence permit process remains incomplete
The application may stay on hold until the interview is finished

HR should not treat biometrics attendance as confirmation of continued work rights. Read also about Residence permit missed delivery.

3. Fiktionsbescheinigung without work authorization wording

Some Fiktionsbescheinigungen confirm lawful stay but do not explicitly authorize employment.

If the document does not include Erwerbstätigkeit erlaubt the employee may not legally continue working.

Proceeding with payroll or onboarding in that situation can expose the employer to unauthorized employment risks under §4a AufenthG.

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Disclaimer

Immigration laws and policies change frequently and may vary by country or nationality. While we strive to provide accurate and up-to-date information, we recommend doing your own due diligence or consulting official sources. You’re also welcome to contact us directly for the latest guidance. Jobbatical is not responsible for decisions made based on the information provided.

About Jobbatical Expertise in Germany

Jobbatical has supported over 17,000+ international relocations across more than 45 countries, helping HR teams manage immigration operations, onboarding continuity, permit tracking, and compliance coordination. In Germany, our team works directly with local Ausländerbehörden including KVR Munich, tracking city-level procedural requirements — such as security interview sequencing and Fiktionsbescheinigung issuance timelines — that are not published on national portals.

FAQs: Fiktionsbescheinigung, KVR Munich Security Interview, and Visa Expiry

Q1: Can our employee request a Fiktionsbescheinigung during the security interview at KVR Ruppertstraße in Munich?

Yes. If your employee's visa is expiring before their residence permit appointment is scheduled, the security interview at KVR Ruppertstraße is the correct moment to raise this directly with the officer. Your employee should bring their original documents and application submission confirmation. The officer may issue or initiate the Fiktionsbescheinigung on the day, or direct the employee to the emergency service point at the same building.

Q2: What happens if our employee's biometrics appointment is scheduled before the security interview?

In Munich's KVR process, the security interview is intended to precede the biometrics appointment. When the sequence is reversed, the biometrics case is left pending until the Sicherheitsgespräch is completed. The residence permit is not issued until both steps are cleared. HR teams should not treat biometrics attendance alone as confirmation that the permit is imminent.

Q3: Is our employee still in legal status if their visa expires before the KVR appointment?

If your employee submitted their residence permit application before their visa expired, the fictional effect under §81(3) AufenthG activates immediately, their lawful residence continues even without a physical Fiktionsbescheinigung document. The application submission confirmation serves as interim proof. If submission happened after expiry, this protection does not apply and legal status is interrupted.

Q4: Does the Fiktionsbescheinigung automatically allow our employee to continue working?

Not automatically. The document must explicitly state Erwerbstätigkeit erlaubt in the supplementary provisions to extend work authorization. If that wording is absent, the Fiktionsbescheinigung covers lawful residence only. HR teams must check this wording before confirming payroll continuity for the employee.

Q5: What should HR do if the employee's visa expires before the security interview date?

Confirm the application was submitted before expiry to ensure fictional effect is active. Then use KVR Munich's Kontaktformular or telephone consultation hours to flag the urgency. The KVR can issue a Fiktionsbescheinigung without an RP appointment in documented emergency situations, and the security interview appointment itself is an appropriate moment for the employee to request this.

Q6: Does this process apply only to Russian nationals, or to employees of other nationalities as well?

The mandatory Sicherheitsgespräch requirement at KVR Munich was introduced in March 2025 for Russian nationals, but security interviews can also be required for applicants of other nationalities where the authority determines a review is needed. The sequencing logic and Fiktionsbescheinigung request process described here applies regardless of which nationality triggers the security interview requirement.

Q7: Can KVR Munich issue a Fiktionsbescheinigung without a separate appointment for our employee?

In urgent situations, such as imminent visa expiry with no RP appointment scheduled, the KVR Ruppertstraße emergency services channel (Entrance A) handles these cases. The security interview appointment also provides a direct interaction with KVR officers where the employee can raise the request. A separate emergency appointment can be requested by phone or via the KVR Kontaktformular if the interview date is still weeks away.

This covers the following use cases:

Can I get a Fiktionsbescheinigung at the KVR security interview in Munich before my visa expires?
What happens if my visa expires before my KVR Munich residence permit appointment?
My employee's visa expires in 15 days and the RP appointment hasn't been scheduled yet — what do we do?
Is the Sicherheitsgespräch at KVR Ruppertstraße required before biometrics for a residence permit in Munich?
What is the correct sequence for the security interview and biometrics appointment at KVR Munich?
Can a Russian national in Munich request a Fiktionsbescheinigung at the security interview if their work visa is expiring?
What does it mean when KVR Munich leaves a biometrics case pending after a security interview?
Can my employee work legally in Germany while waiting for the KVR Munich security interview to be completed?
How do I use KVR Munich's emergency services channel if my employee's visa is about to expire?
Does the fictional effect under §81 AufenthG apply when waiting for a KVR security interview?
What wording should I look for on the Fiktionsbescheinigung to confirm my employee can keep working in Munich?
What happens to an Indian national's residence permit application if KVR Munich requires a security interview?

Reviewed by:

Georgiy Serdiukov

Can Fiktionsbescheinigung be requested at KVR Munich Security Interview?