Solvia

The real Approbation deadline is not 1 November — it's 30 September 2026

homologation 7 min read · English

Everyone repeats that "the law changes on 1 November 2026." That's true — but incomplete, and the difference can cost you the direct-recognition route. We read the text the Bundestag actually passed, and the transitional clause says something else: only applications filed by 30 September 2026 keep today's procedure.

What the new law changes

On 26 March 2026 the Bundestag passed the Gesetz zur Beschleunigung der Anerkennungsverfahren ausländischer Berufsqualifikationen in Heilberufen (confirmed by the Bundesrat on 8 May). It takes effect on 1 November 2026 and changes the procedure for doctors, dentists, pharmacists and midwives with non-EU degrees:

The fine print nobody quotes: §15

The transitional provision (new §15 Bundesärzteordnung) reads, verbatim:

„Für Anträge auf Anerkennung einer in einem Drittstaat erworbenen Berufsqualifikation, die bis zum Ablauf des 30. September 2026 gestellt worden sind, gilt § 3 Absatz 2 und 3 in der bis zum 30. September 2026 geltenden Fassung weiter."

Translation: applications filed by 30 September 2026 are processed under current law — the mandatory document review first. With no decision deadline: file in September 2026 and even a 2028 decision still runs under the old law.

What about applications filed in October 2026? They fall into a gap: the new law isn't yet in force when you file, but §15 protection ends on 30 September. Parliament moved the start date (from 1 October to 1 November) without moving the §15 date. Nobody knows yet how that limbo month will be resolved. The only safe date is 30 September.

What this means in practice

  1. If your documents are (nearly) ready — degree, certificates, apostilles — an application filed before 30 September guarantees you the document review first. Count backwards: sworn translations take 2–4 weeks, apostilles in your home country weeks more. Practically, your documents need to be complete by mid-August.
  2. If you're missing a lot, an empty application won't help: manifestly incomplete files can end up in the KP anyway. Better a realistic plan for the KP route — also a valid path, just with one more exam.
  3. Filing from abroad is possible in several federal states. Hamburg, for instance, accepts proof of connection as light as a booked German course; other states want you to substantiate your intent to work there. Choosing the right Bundesland matters — timelines and requirements vary widely. Find the competent authority in our Approbation authorities directory.
  4. Nurses: this law does not affect you. It amends the rules for doctors, dentists, pharmacists and midwives. Nursing recognition is unchanged. Austria is unchanged too.

FAQ

Is direct recognition closing forever?

No. After 1 November it survives as an opt-in (4-week binding election). What closes on 30 September is the guaranteed route: documents first, by law.

Does the filing date or the decision date count?

The filing date (Antragstellung). A September 2026 application keeps the old law even if decided years later.

Can I file without a job offer?

Generally yes — federal law requires neither employment nor German residence, but you must substantiate which Bundesland you intend to work in, and each state interprets that differently.

What if I file in October 2026?

Legal grey zone (see above). Our advice: don't leave it to October.

Sources

Solvia checks free of charge whether your file can be submitted before 30 September — take the 2-minute check or book 15 minutes with David. Public prices, from €1,490.

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