"The Association of Estonian Cities and Rural Municipalities appeals to you due to the delay in the extension of temporary protection residence permits. We have been approached by several local authorities concerned about Ukrainian war refugees who have submitted applications for extension of temporary protection residence permits to the Police and Border Guard Board within the deadline, but have not received a decision on the extension of temporary protection residence permits within the deadline," the letter states.

Veikko Luhalaid, the head of the association, said that the above is illustrated by an example from the municipality of Elva, where a non-working mother raising children alone submitted an application for herself and the children to the PPA three months before the expiry date of the temporary protection residence permit. The family's temporary protection status expired in mid-April, while the self-service indicates that their application will be processed in June.

As reported by Luhalaid, local officials have said that the procedure of renewing residency permits for many Ukrainian war refugees has become so lengthy that both children and adults have run out of residency permits.

"The war in Ukraine continues, and even if the residence permit of a person who came to Estonia as a war refugee expires, the need for temporary protection remains," Luhalaid said.

He said that because of the lack of a residence permit, people no longer receive the state pensions and benefits they are entitled to, or the benefits and services guaranteed by local authorities.

"While the Social Insurance Board (SKA) has confirmed that if the PPA allows the residence permit to be valid retrospectively, the SKA will provide benefits retrospectively based on the duration of the residence permit, it should be understood that Ukrainian war refugees may be without any means of subsistence other than benefits and allowances and a support network. As a result, if a person's residency permit and benefits/benefits expire, they may not have sufficient means of sustenance left," the letter states.

"Also, if a war refugee's residence status expires, their employers have to end working with them. Employers know that foreign recruitment laws prohibit continuing an employment contract after the residency permit expires. This prevents people from working and makes them dependent on social benefits," Luhalaid said.

The expiration of the residence permit will also affect health insurance coverage and the possibility of participating in language courses.

"Estonia's social services are primarily based on the principle that a person has a residence permit or other legal basis to stay in the country. According to local authority services, the person must have a registered place of residence in the population register. If a person does not have the above-mentioned reasons for staying in Estonia and does not have a valid registration of residence in the population register, it is important to note that, according to the Social Welfare Act, a person without a residence permit is only entitled to receive essential social assistance in the municipality," Luhalaid said.

"Thus, from the point of view of local government service delivery, people are also in a situation where the local government cannot pay social benefits because they do not have a valid residence permit," the letter concludes.

On its website, the PPA justifies the situation by stating that the volume of applications for temporary protection is currently high, which means that the PPA may decide on the extension of temporary protection on the last day of the residence permit or even later.

"In this case, the residence permit will be renewed retroactively by the PPA and will be valid from the day following the expiration of the previous residence permit. If the residence permit is renewed after the expiry date, this may affect the entitlement to benefits and allowances. It is therefore advisable for persons whose temporary protection is renewed after the expiry of their residence permit to check whether a new application for benefits and allowances is required," states the police website.

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