British in Austria is also keeping the Embassy informed about the situation. In very rare cases we have been able to get BMI to remind MA35 about their obligation to resolve cases within six months. I have regular contact with BMI and invariably point out procedural irregularities, and cards seem to appear miraculously quickly. Bear in mind though that Art 50 EUV card applicants are receiving considerably better treatment than all other 3CNs applying for a residency permit. The only further way I can think to escalate proceedings is through the Volksanwaltschaft – but this might just gum up another channel. Alternatively I will have a look with the other Admins from British in Austria about a letter that individual applicants should send to MA35 (as a registered letter, advising that you will be seeking assistance from legal representation to conclude your application. (If you don’t have a Rechtschutzversicherung this would be a good opportunity to get one).