It is possible to apply for the 10 year card already, and from our understanding the process uses the same form (make sure that you tick box 35 on the new form post November 2023, previously this was box 32 on the form) . The field is labelled “Inhaber eines Daueraufenthaltsrechts” or “Holder of a permanent right of residence”. You may need to resubmit some documents (in case of any changes in personal circumstances). We have been advised that priority will however be given to initial applications over “upgrades” to ensure that everyone is able to apply for their first Art 50 EUVAufenthaltstitel "Artikel 50 EUV" The Aufenthaltstitel "Art 50 EUV" is a residency title to be issued to British citizens from the end of the transition period. Its name is derived from Article 50 of the Treaty on European Union. The "Titel" refers to the document or card itself, and not the right, or permission that it confirms. card during 2021.
If the official informs you that you can only apply 3 months before the expiry date; please politely ask them to check with their superiors as this information is incorrect. Confirmation that you can apply early (as soon as you qualify) is also on the Official Austrian Government Brexit website; under the “Verlängerung” section on the German site and “Extension” section on the English site.
Note: Article 50 Applications now receive the same priority as every other residence permit!
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This question was also raised at the British Embassy’s Online Q&A session in April 2021 – you might like to see further Q&As via the Embassy’s blog.