The Approbation cutoff is 31 October 2026, not 30 September

homologation 7 min read · English

Updated 18 September 2026: an earlier version of this article named 30 September as the cutoff. That was the date in the bill. The promulgated law (BGBl. 2026 I Nr. 225) sets the cutoff at 31 October 2026.

Everyone repeats that "the law changes on 1 November 2026." That is true, and the promulgated text spells out what it means for your application: applications filed by the end of 31 October 2026 keep today's procedure. The bill still said 30 September, and that date is still circulating. It is outdated.

What the new law changes

The Gesetz zur Beschleunigung der Anerkennungsverfahren ausländischer Berufsqualifikationen in Heilberufen was promulgated on 28 July 2026 (BGBl. 2026 I Nr. 225). It takes effect on 1 November 2026 and changes the procedure for doctors, dentists, pharmacists and midwives with non-EU degrees:

Today, the authority must first review your documents (Gleichwertigkeitsprüfung). If your training is found equivalent, you get the Approbation without an exam. Historically about a third of these reviews ended in full equivalence.
From 1 November, the Kenntnisprüfung (KP) becomes the rule. Document review doesn't disappear, but becomes an option you must actively elect within 4 weeks of filing, and the election is binding. If your file is incomplete or hard to verify, the authority can route you to the KP even if you chose the documentary track.

The fine print: what §15 says now

The transitional provision (new §15 Bundesärzteordnung, Article 1 no. 16 of the law) reads, verbatim:

„Für Anträge auf Anerkennung einer in einem Drittstaat erworbenen Berufsqualifikation, die bis zum Ablauf des 31. Oktober 2026 gestellt worden sind, gilt § 3 Absatz 2 und 3 in der bis zum 31. Oktober 2026 geltenden Fassung weiter."

Translation: applications filed by the end of 31 October 2026 are processed under current law, with the mandatory document review first. There is no decision deadline: an application filed in time stays under the old rules even if it is decided much later.

Where did 30 September come from? The earlier drafts (Bundestag Drs. 21/3207 and the committee version, Drs. 21/4990) had 30 September in §15, while the law itself only takes effect on 1 November. That left applications filed in October in a gap. The promulgated text extends the date to 31 October and closes that gap: old rules for everything filed by 31 October, new rules from 1 November. The date that counts is 31 October 2026.

What this means in practice

If your documents are (nearly) ready (degree, certificates, apostilles), an application filed by 31 October keeps you in today's procedure: document review first. Count backwards from that date: sworn translations and apostilles from your home country take time, so assemble the file now.
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, which is also a valid path, just with one more exam.
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, because timelines and requirements vary widely. Find the competent authority in our Approbation authorities directory.
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. From 1 November it survives as an opt-in that you have to request (4-week binding election). What ends on 31 October is today's default: documents first, by law.

Does the filing date or the decision date count?

The filing date (Antragstellung). An application filed by 31 October 2026 keeps the old law even if it is decided much 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?

You are still in time. The promulgated §15 BÄO covers applications filed by the end of 31 October 2026. Earlier drafts stopped at 30 September, which is where the warnings about an "October gap" came from. From 1 November the new procedure applies. Our advice: don't leave it to the last days.

Sources

Promulgated law: BGBl. 2026 I Nr. 225 of 28 July 2026, Article 1 no. 16 (§15 BÄO): recht.bund.de/bgbl/1/2026/225/VO.html
Earlier draft, bill text (Bundestag, Drs. 21/3207), §15 BÄO still with 30 September: dserver.bundestag.de/btd/21/032/2103207.pdf
Earlier draft, health committee version (Drs. 21/4990): dserver.bundestag.de/btd/21/049/2104990.pdf
Federal Ministry of Health, press note 26.03.2026
Bundesrat, 1065th session, 08.05.2026, TOP 7
Ärztekammer Nordrhein on the 4-week election window (Rheinisches Ärzteblatt, April 2026)

Solvia checks free of charge whether your file can be submitted by 31 October: take the 2-minute check or book 15 minutes with David. Public prices, from €1,490.