Why is this ruling important for many foreigners?
In practice, many naturalizations fail not because of language or residence, but because of the question: Has identity been sufficiently clarified?
Authorities often require a passport. If this is not available, the application is often rejected—even if other documents are available.
The new Federal Administrative Court ruling on Naturalization provides greater clarity and establishes firm rules in this area.
The specific case: Why the court had to make a new decision
The lawsuit was filed by a man who claims to be a Syrian citizen. He has been living in Germany as a recognized refugee since 2014 and has held a settlement permit since 2019. Settlement permit
His application for Naturalization was rejected by the authorities because he did not want to apply for a Syrian passport. Instead, he only presented a Syrian identity card.
The Düsseldorf Administrative Court initially considered this to be sufficient. However, the Federal Administrative Court disagreed and clarified that an identity card is not sufficient at the first stage of verification.
The step-by-step model of Clarification of identity now clearly regulated
The Federal Administrative Court has further developed its step-by-step model for identity verification and clearly defined it:
Level 1: Pass
- Identity must first and foremost be proven by means of a passport.
Level 2: Other official documents
- Only if no passport is available and obtaining one is objectively impossible or subjectively unreasonable,
- Passport replacement documents or other official documents with a photograph (e.g., identity card) may be used.
Further stages
- Only then can further evidence be examined.
- A change to a lower level is only permitted if it can be proven that everything has been tried.
The ruling does not rule outNaturalization a passport, but requires careful and comprehensible justification.
Difference between the Federal Administrative Court rulings: 2020 vs. 2025
Federal Administrative Court 2020 | Federal Administrative Court 2025 | |
|---|---|---|
Role of the passport | Pass not necessarily with priority | Passport must always be checked first |
Other documents | Recognized passport substitute, personal ID card, or identity card could already be taken into account at level 1. | Only permissible if obtaining a passport is not possible or unreasonable (level 2) |
Naturalization without passport | Possible | Still possible, but only after checking whether it is reasonable to expect the passport to be used. |
What does the ruling mean for you specifically?
The Federal Administrative Court ruling Naturalization means the following for those affected:
✔️ A passport is the norm, but not an absolute requirement
✔️ Naturalization isnot ruled out if you do not have a passport
✔️ The decisive factor is whether you can prove
– that you do not have a passport and
– that it is not possible or reasonable to obtain a passport
Blanket rejections are therefore no longer permitted.
Our recommended reading
Naturalization a national passport
Here you can find out about the Naturalization process Naturalization a passport and why Naturalization a passport is complicated for foreigners.
Checklist: What does the ruling mean for your naturalization application?
If your Naturalization has been denied or delayed Naturalization unresolved identity issues, you should now check the following:
✔️ Passport available or applied for
Do you have a valid passport or can you prove that you have tried to obtain one?
✔️ Reasons for not having a passport documented
Is there verifiable evidence as to why it is not possible or reasonable to obtain a passport?
✔️ Official replacement documents submitted
Have you submitted official documents with a photo (e.g., identity card or passport replacement), if available?
✔️ Received justification from the authorities
Have the authorities specifically explained why your identity is considered unclear?
✔️ Step-by-step model correctly applied
Was the legally prescribed sequence of identity verification followed?
Conclusion
The new Federal Administrative Court ruling on Naturalization 1 C 27.24) does not tighten the procedure across the board, but rather establishes clear rules.
A passport remains the most important document – but:
👉 Naturalization also possible without a passport if your identity can be verified in an orderly, traceable, and documented manner.
