According to the Lazio Administrative Court, a registered virtual address can count toward Italian citizenship residence requirements
Italian immigration and citizenship law — 7 November 2026. Italian citizenship by residence requires more than the physical fact of spending years in Italy. For non-EU nationals applying under Article 9(1)(f) of Law no. 91/1992, legal residence is a central requirement. But what if a foreign national lives in Italy lawfully and is registered with the municipality at a conventional or “virtual” address because he has no fixed accommodation? Can the Prefecture disregard those registered years and deny access to the naturalisation procedure? The Lazio Regional Administrative Court (TAR Lazio, Rome), Fifth-bis Division, addressed this question in judgment no. 6471 of 10 April 2026.
The background: a citizenship application and a disputed address
The applicant challenged a decision by the Prefecture of Rome, dated 21 June 2024, which had declared his application for Italian citizenship inadmissible. The Prefecture considered that he had not demonstrated the required uninterrupted period of lawful residence in Italy. In particular, part of his registration history involved a municipal address reserved for people without a fixed home. The authority took a restrictive view of such entries, treating a conventional address as insufficient evidence of lawful residence.
The applicant, who had held an EU long-term residence permit since November 2015, argued that the administrative authorities had wrongly treated his lawful municipal registration as though it were not a valid residence record. He also drew attention to a family comparison: his brother, with a substantially similar registration history, had obtained Italian citizenship. During the proceedings, the court ordered further documentary investigation. The resulting records confirmed that the brothers’ registration histories were nearly identical, while the Prefecture explained that its assessment policy concerning conventional addresses had changed.
The issue before the court was not whether the applicant had automatically earned citizenship through length of residence or possession of a long-term permit. It was whether the Prefecture could exclude periods of legally recognised municipal registration merely because the registered address was conventional rather than a physical street address.
The judgment: registration at a virtual address is not unlawful by itself
The court upheld the challenge and annulled the inadmissibility decision. It explained that, under the Italian municipal registration system, persons without a fixed abode must still be registered in the municipality where they have their domicile, subject to the relevant legal conditions. A municipality may use a specially designated conventional street address for this purpose. The mere fact that an address is called “virtual” or “fictitious” does not render the registration unlawful.
The court consequently held that lawful registration in the municipal population register through an officially designated conventional address may satisfy the requirement of legal residence for the citizenship application. The Prefecture cannot replace the statutory rules with a blanket administrative presumption that all such addresses are unacceptable. It must examine the individual circumstances, the legitimacy of the registration and the evidence of compliance with applicable requirements.
This is a decision about the legal status of municipal registration, not a ruling that any invented or false address can be used to qualify for citizenship. The court distinguished an address formally created by the municipality for homeless persons from deceptive declarations designed to circumvent the law. The administration remains entitled, and obliged, to investigate whether the person satisfies the statutory conditions.
Why the Italian residence record matters
For citizenship by residence, Article 9(1)(f) of Law no. 91/1992 refers to foreign nationals who have been legally resident in the territory of the Republic for at least ten years. The implementing regulation, Presidential Decree no. 572/1993, connects legal residence to compliance with both immigration and municipal registration rules. Italian law does not treat a person as legally resident solely because he or she has been physically present in Italy for many years.
Conversely, the municipal residence system must reflect legally established positions, including those of persons who do not have a stable home. Under Law no. 1228/1954, a person without a fixed abode is considered resident in the municipality where he or she has established a domicile and is required to provide the elements needed for the competent office to verify the existence of that domicile. Municipalities can therefore register persons using conventional addresses as an administrative mechanism, not as a fiction designed to avoid checks.
The Lazio court considered this mechanism consistent with the law because it allows the administration to identify and contact people who otherwise might be excluded from the population register. A formally recognised municipal registration is not made legally worthless by the absence of a traditional dwelling address.
The duty to remain contactable: registration creates responsibilities
One of the most important aspects of the ruling concerns the individual’s duties. Being registered at a conventional address does not remove the need to keep in contact with the municipality and the relevant authorities. The law requires the person to provide the information needed to confirm the domicile and to comply with subsequent registration obligations. For foreign residents, changes in residence and the updating of declarations following renewal of immigration documents can be relevant.
The court referred to the registration rules that allow public authorities to verify the actual connection with the municipality and, where the statutory conditions are met, to remove people from the register if they can no longer be traced. The decision therefore does not endorse a system in which a nominal address can remain indefinitely effective regardless of where the individual lives or whether authorities can locate them.
For a foreign national seeking naturalisation, the practical implication is straightforward: the validity of a municipal entry and the continuity of the registration history must be supported by evidence. The absence of a conventional house address may not be disqualifying in itself, but inaccurate declarations, disappearance from the municipal records or prolonged interruption of lawful residence may create real legal obstacles.
Legal residence must remain continuous
The court also recalled that the required ten-year period is not simply a threshold which becomes irrelevant once an application has been submitted. In its analysis, relying on Council of State case law and the implementing regulations, it explained that the conditions for a residence-based naturalisation application must continue to be satisfied until the oath of citizenship. Applicants must therefore pay attention to their legal and municipal status throughout the entire procedure.
Possession of an EU long-term residence permit is an important feature of a person's immigration status, but it does not, by itself, prove that every necessary condition for naturalisation has been satisfied. Similarly, documentary evidence of long physical presence cannot replace the statutory requirement to comply with residence and registration law. The relevant administrative history must be examined in full.
What applicants should check before filing
First, obtain the historical municipal residence certificate or equivalent record, rather than relying only on a current certificate. Confirm the dates of registration, possible cancellations, changes of municipality, registrations at conventional addresses and any periods during which the person was not listed in the population register.
Second, examine the correspondence between the registration history and the immigration history. Copies of previous residence permits, renewal receipts and other relevant documents may assist in establishing lawful stay at the appropriate periods. A gap in either history should be investigated before submission rather than explained only after a refusal.
Third, when a conventional address has been used, retain documentation showing that it was an official municipal registration for a person without a fixed abode. Where relevant, records of contact with municipal social services, official correspondence and registration confirmations can demonstrate compliance with the obligations associated with that status. The purpose is not to manufacture residence after the event but to document a legally existing position.
Fourth, if the Prefecture raises doubts about the address or continuity of residence, respond to the specific issues identified, supplying the documentary history and distinguishing lawful registration from inaccurate or deceptive records. A notice of intended refusal, when applicable, is an opportunity to address the factual and legal basis of the administration's position before a final decision.
What happens after a refusal?
A decision declaring a naturalisation application inadmissible requires careful analysis of its precise grounds. It may concern an alleged interruption of residence, missing documents, immigration-status problems or other statutory conditions. The appropriate judicial remedy, its time limits and the competent court depend on the actual decision and applicable law. An applicant should not assume that a written request for reconsideration automatically suspends the deadline for challenging the act.
Judgment no. 6471/2026 can be particularly relevant where the refusal is based specifically on the thesis that an officially registered virtual address cannot count toward legal residence. The court's ruling offers an argument against that general exclusion. It does not guarantee that every applicant with a conventional address will obtain naturalisation, nor does it dispense with verification of the other requirements or the authorities' powers under citizenship legislation.
The broader significance: legal residence is a verified condition
The decision illustrates why immigration and citizenship procedures need precise legal categories. A person without stable accommodation may nonetheless be legally registered and contactable; a person with a physical dwelling may, conversely, fail to satisfy immigration or registration requirements. A residential address is therefore not a sufficient substitute for an analysis of lawful status, continuity and actual administrative registration.
The court's approach preserves both sides of the legal relationship. Authorities must recognise legitimate forms of municipal registration and cannot invent blanket exclusions beyond the statute. Applicants must maintain an accurate legal and registration history, ensure that public offices can contact them and demonstrate that they meet the conditions for naturalisation. Citizenship by residence remains a legally regulated process, not an automatic result of time spent in the country.
Conclusion
According to TAR Lazio, judgment no. 6471/2026, registration at a conventional municipal address may be fully relevant when proving legal residence for an Italian citizenship application. The label “virtual address” does not itself make the entry invalid. The decisive questions are whether the person was registered in accordance with the law, maintained the required connection with the municipality and complied with the wider immigration and citizenship rules. The annulment of the Prefecture's inadmissibility decision required renewed lawful consideration; it was not an order granting citizenship immediately.
Judgment commented upon: TAR Lazio, Rome, Fifth-bis Division, judgment of 10 April 2026, no. 6471, Presiding Judge Rizzetto, Reporting Judge Giudice. Full decision in Italian, EIUS case-law archive.
Avv. Fabio Loscerbo
Lawyer admitted to practise before the Italian Court of Cassation
Registered in the Italian Chamber of Deputies' Register of Interest Representatives in the field of Immigration
Registered interest representative in the European Union Transparency Register, no. 280782895721-36, in the field of Migration and Asylum
ORCID: 0009-0004-7030-0428
This article was prepared with the assistance of AI tools under the author's direction, review and editorial responsibility.