✉️ Postal address and contact with authorities without a fixed address
In brief
Under the Bundesmeldegesetz (BMG, Federal Registration Act), a "dwelling" is any enclosed space used for living or sleeping (§ 20 Abs. 1 BMG) – so an emergency shelter in principle counts as a dwelling in the registration-law sense and must be registered within two weeks (§ 17 Abs. 1 BMG). For people who really live without any shelter at all, there is no express federal rule – registration authorities handle registration "without a fixed abode" inconsistently.
Step by step
- Register your emergency shelterIf you live in an emergency shelter or facility, register that address with the Einwohnermeldeamt (residents' registration office) within two weeks (§ 17 Abs. 1 BMG).
- Ask if you have no shelterIf you live entirely without shelter, ask the Einwohnermeldeamt specifically about its usual practice for registration "without a fixed abode".
- Set up a c/o addressSet up a c/o address for your post at an advice centre, day centre or railway mission.
- Consider poste restanteDeutsche Post's poste restante (Postlagernd) service can be an alternative for collecting items in person.
- Arrange to be reachableMake sure you visit important offices such as the Jobcenter or Sozialamt in person regularly if post does not reliably reach you.
Deadlines
- There is no express statutory exception from the registration obligation for people without shelter (§ 27 BMG does not mention them) – a violation can in principle be punished as an administrative offence (§ 54 BMG).
- The exact administrative practice for registration without a fixed shelter is not regulated uniformly nationwide and differs from municipality to municipality.
- A c/o address does not replace registering a dwelling if you actually live in a fixed shelter (including an emergency shelter) – then the regular registration obligation applies.
In depth · legal basis, figures and practice – for advisers and professionals
Concept of dwelling in registration law
§ 20 Abs. 1 BMG defines a dwelling very broadly as any enclosed space used for living or sleeping. Emergency shelters and comparable facilities fall under this, so that the regular registration obligation under § 17 Abs. 1 BMG (two weeks) applies.
Gap in cases of complete lack of shelter
§ 27 BMG provides for exceptions from the registration obligation (e.g. for very short stays), but does not expressly mention people without any shelter. In practice, many municipalities have developed their own procedures, not uniform nationwide, to nevertheless record people "without a fixed abode" for registration purposes – for example via the address of the Ordnungsamt or an advice centre. A uniform nationwide procedure for this could not be verified in this research.
Fine
A violation of the registration obligation is in principle an administrative offence under § 54 BMG that can be punished with a fine. Whether and how this is actually applied where registration is demonstrably impossible (for example for lack of any shelter) is not documented uniformly.
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