The Kerpen immigration office archives approximately 6,000 files using AI.

In Germany, immigration offices are traditionally synonymous with mountains of paperwork, long waiting times, and files piling up on desks. The city of Kerpen is now demonstrating how things can be different : around 6,000 files from the local immigration office have been digitized using artificial intelligence – a process that, according to the office, has saved a year and a half of manual work. For international professionals , employers, and families who depend on the swift processing of their residence permits, this initially sounds like good news. From a legal perspective, however, it's worth taking a closer look at what AI can actually achieve in public administration – and where its limitations lie.

What exactly happened in Kerpen?

Until recently , the Kerpen immigration office operated entirely on an analog system: no digital files, but folders containing up to 400 pages per person – residence permits, official notices, certificates, criminal cases, administrative offenses, proof of service, external files, and family law documents, often spread across multiple volumes. With limited staff, there simply wasn't enough time to manually prepare this volume for a traditional scanning process, which requires marking each file section individually with separators. An AI, trained using sample files, took over the structuring and categorization work. The result: the files are now searchable via full-text search, which significantly saves case workers time and can expedite decisions – especially in the asylum sector, where processing time is crucial for those affected.

How far does AI support actually extend?

The distinction made by the authority itself is crucial: For building permit applications, the AI already provides recommendations for acceptance or rejection. However, it explicitly does not do this for asylum applications – there, the software merely sorts and structures the data; the final decision remains with a human. The authority does not comment on other procedures such as labor migration or family reunification , although there are indications that the same reticence applies. For applicants in the area of skilled worker immigration , for example, for an EU Blue Card or an Opportunity Card , this means that while the AI can shorten the path to the correct file and document, the substantive review and discretionary decision remain – rightly so – the responsibility of the caseworker.

What does this mean for skilled workers, employers, and families?

For HR departments that urgently need to bring a skilled worker from the USA , Great Britain , or Canada to Germany, any acceleration of administrative procedures is generally welcome. Faster document retrieval can shorten waiting times for appointments or inquiries. However, this does not create a legal entitlement to a specific processing time – the general obligation of the authorities to conduct procedures with reasonable speed still arises from administrative procedural law, not from the use of specific software. A similar issue arises in family reunification cases , where several interconnected files – such as those of a spouse or children – must be considered together: digital systems are only as good as their interconnection. If a family file is not technically linked correctly to the main file, delays can occur that are difficult for those affected to understand.

What are the risks of AI-supported record keeping?

Focusing on full-text search means that specific information can be found quickly – but the surrounding context of a file, the connections that aren't even searched for without a suitable keyword, are often crucial in immigration law. According to the principle of official investigation in Section 24 of the Administrative Procedure Act (VwVfG), the authority is obligated to fully investigate the facts of the case ex officio – an obligation that is not waived simply because AI has made the file searchable. If, during a change of caseworker, a file is only searched instead of being read in its entirety, the risk increases that crucial connections will be overlooked – with the consequence that decisions may become contestable. Furthermore, there is a data protection aspect that has so far received little attention in the public debate: immigration files regularly contain particularly sensitive data within the meaning of Article 9 of the GDPR – for example, concerning health, criminal proceedings, or family circumstances. The use of AI systems for the automated processing of such data requires special technical and organizational safeguards, and where software – as has already happened with building permit applications – makes recommendations, Article 22 GDPR on automated individual decisions also comes into focus.

What specific advice do we give to skilled workers, employers, and families?

Especially under pressure, the temptation is great to rely heavily on AI-supported systems. From our experience with hundreds of cases at various immigration authorities – from small municipalities to the Berlin State Office for Immigration – we know that the level of digitization and internal procedures vary considerably. We therefore recommend that applicants and employers keep their own complete copies of all submitted documents, actively request access to files in complex or interconnected cases, and seek legal advice early on if there are indications of an incomplete investigation of the facts – if necessary, with a view to potential legal proceedings . Digitization does not replace careful legal review; it merely changes the tools that authorities use.

Conclusion

AI-supported digitalization in Kerpen is a sensible step that can relieve authorities of administrative burdens and accelerate procedures without relinquishing the final decision to humans. However, for skilled workers , employers, and families , it remains crucial that the complete file – not just its searchable keywords – remains accessible. Where this is not guaranteed, we provide support with legal expertise and the necessary assertiveness towards the authorities.