Germany's new Approbation law from 1 November 2026: what changes for doctors with a non-EU degree

2026 law 9 min read · English · Updated 3 November 2026

By David Emanuel Rehrl, founder of Solvia

Two texts, two dates

The law was promulgated on 28 July 2026 and amends the Bundesärzteordnung (BÄO), the federal medical practitioners act. The regulation that implements it, the Approbationsordnung für Ärzte (ÄApprO), appeared in the Bundesgesetzblatt on 30 October 2026, two days before it took effect. Until that day almost everything circulating about "the new exam" was draft text. What follows comes from the two published texts, each point with its section so you can check it.

Both texts entered into force on 1 November 2026 (article 6 of the regulation). The law concerns doctors, dentists, pharmacists and midwives with a non-EU qualification. Nursing is unchanged. So is Austria.

The two routes since 1 November

The new § 9d BÄO reorganises the procedure for third-country degrees. Your training qualifies if, in the country that issued it, it gives direct access to the medical profession, and if you have the knowledge and skills needed to practise in Germany (§ 9d Abs. 1). There are two ways to prove the second point:

One catch in the second route: if the documents cannot be supplied in full for reasons outside your control, the authority sends you to the Kenntnisprüfung anyway (§ 9d Abs. 3, last sentence). An incomplete file is not repaired by choosing the document review. The authority must inform you that the option exists and what follows from it (§ 9d Abs. 2, last sentence).

How to decide within four weeks

We always plan on the Kenntnisprüfung. The route on request makes sense only when the file is complete from day one, with the curriculum broken down by subject and hours, and when that comparison has a real chance. Under the old rules, where the review was mandatory, about a third of cases ended in full equivalence. For everyone else the review only added months before the same exam. If you are not sure, the default route is the shorter one: application, exam, decision, with a written deadline at every step.

The new Kenntnisprüfung as § 37 describes it

The exam changes shape. It is an oral and practical exam preceded by a patient-based preparation, and both parts take place on the same day (§ 37 Abs. 2).

• Patient-based preparation: history and examination of a patient, real or simulated, from internal medicine or surgery, in at most 20 minutes, with no prior access to the patient file. You then write a report with history, diagnosis, prognosis, treatment plan and epicrisis, in at most 30 minutes (§ 37 Abs. 4).
• Oral and practical exam: opens with your case and your report, then questions and practical tasks. 60 to 90 minutes per candidate, at most four candidates at a time (§ 37 Abs. 10).
• Content: internal medicine and surgery, plus emergency medicine, clinical pharmacology and pharmacotherapy, imaging, radiation protection, the legal framework of medical practice, and communication with the patient, relatives and other health professions (§ 37 Abs. 3). The extra subject each authority could add is gone.
• Board: three members, at least one from internal medicine or surgery (§ 37 Abs. 7 and 8). The invitation must reach you at least five calendar days before the exam (§ 37 Abs. 9).
• Dates and repeats: the exam must be offered at least twice a year and may be repeated twice, so three attempts in total (§ 37 Abs. 12). If you fail the third attempt, the authority informs the other federal states (§ 37a).
• Passing: the board judges the whole performance, including the report, where structure and clarity count as well (§ 37 Abs. 11).

The exam is in German. Fees are set by each state and range from EUR 400 to 1,350 (Marburger Bund 09/2025 and chamber pages, July and September 2026). Medical German is still proven in the Fachsprachprüfung at the state medical chamber, EUR 400 to 700. The usual order remains Fachsprachprüfung, temporary permit, Kenntnisprüfung; what each exam covers is in Fachsprachprüfung and Kenntnisprüfung (Spanish).

The documents on the default route

§ 39c ÄApprO sets the list for an application on the Kenntnisprüfung route:

1. Proof of identity.
2. A CV in table form listing your training and your employment.
3. The degree or certificate that gives access to the medical profession.
4. A certificate that you are entitled to practise in the country that issued the degree.
5. A declaration that you have no other Approbation or Berufserlaubnis procedure open in another federal state.
6. Proof of personal reliability, health and German: police certificate plus the equivalent documents from the country of the degree, a medical certificate, and the language certificate (§ 3 Abs. 1 Nr. 2, 3 and 5 BÄO, detailed in § 39e).

Police and medical certificates may not be older than three months when submitted (§ 39e Abs. 2). The curriculum with hours is not on this list; it belongs to the equivalence route (§ 39d Nr. 6). The authority may ask for information on the content and duration of your training if it needs it (§ 33a Abs. 3).

Three changes in form (§ 33a ÄApprO):

• Documents are submitted as plain copies or electronically. Certified copies and originals may only be demanded on justified doubts about authenticity.
• Anything not in German or English is translated into German or English by a sworn translator. In justified exceptional cases the authority may demand German. It may also accept other translators or translate the documents itself with software.
• If in doubt, the authority may contact the authority of the country that issued your degree directly.

For a Latin American or Asian degree this means less legalisation up front, but not less care: a file the authority considers doubtful goes back to the slow lane of originals and certified copies. Which documents to gather and in which order is in our documents guide.

The deadlines the authority must meet

These deadlines are new and they sit in a regulation, not in the law; if an authority misses them, the remedy is an administrative complaint, not an automatic licence. The figures published so far are far away: Bavaria reported 18 to 24 months from the complete file to the decision for doctors trained outside the EU (Bavarian parliament, Drs. 19/9417, 2 February 2026), Thuringia up to 671 days in 2025. We will publish state-by-state figures once there is data under the new regime; until then they are in how long recognition takes (Spanish).

Where to file

The law now says it in writing (§ 12 Abs. 2a BÄO): if you live in Germany you file in the state of your habitual residence; if you live abroad, in the state where you intend to practise. Only one procedure may be open at a time, and you declare that in the application (§ 39c Nr. 5). Because fees and exam waiting times still differ across the 16 states, the choice of state remains the most important decision in the file. We file where it is best for the doctor.

What happens to October applications

Applications filed by 31 October 2026 are processed under the old rules: mandatory document review first (§ 15 BÄO in the law and § 42 Abs. 2 of the new ÄApprO). The filing date counts, not the decision date. The details of that cutoff are in the cutoff is 31 October.

Solvia FlexKapG, based in Salzburg, accompanies doctors trained outside the EU through their recognition in Germany. Under the new rules the work moves: less legalisation, more exam preparation, and one decision to take within four weeks with a file that is already complete. We always plan on the Kenntnisprüfung. Fees: from EUR 1,490. Answer three questions and see your route.

Frequently asked questions about the 2026 law

Has the document review been abolished?

No. It still exists, but only if you request it within four weeks of filing (§ 9d Abs. 3 BÄO). The choice is binding for the whole procedure. If you request nothing, you go straight to the Kenntnisprüfung.

Can I choose the review and, if it fails, sit the exam?

Yes, but you save no time. If the authority finds substantial differences it issues a Bescheid, at most four months after it has all documents (§ 38 Abs. 3 ÄApprO), and then you sit the Kenntnisprüfung, which must be possible within the following six months. And if your file cannot be completed for reasons outside your control, you sit the exam anyway (§ 9d Abs. 3).

How long is the new exam?

Everything on one day: up to 20 minutes of history and examination, up to 30 minutes for the written report, then 60 to 90 minutes of oral and practical examination per candidate, with at most four candidates at a time (§ 37 Abs. 4 and 10 ÄApprO).

How often can I repeat it?

Twice, so three attempts in total (§ 37 Abs. 12 ÄApprO). After the third fail the authority informs the other federal states (§ 37a), so you cannot start from zero in another state.

Do I need German translations of all my documents?

Anything not in German or English is translated by a sworn translator into German or English (§ 33a Abs. 1 ÄApprO). The authority may demand German in justified exceptional cases. Documents are submitted as plain copies or electronically; originals and certified copies are requested only on justified doubts.

I filed in October. Does the new law affect me?

No. Applications filed by 31 October 2026 follow the old rules, with the mandatory document review first (§ 15 BÄO and § 42 Abs. 2 ÄApprO). The filing date counts.