Changing Employers in Germany on a Qualified Employment Permit: HR Guide 2026

Your employee has a new offer. They hold a Qualified Employment Permit (QEP) under §18b or §18a AufenthG. The question is not whether they can take the job, they can, it is whether you have filed the right paperwork before day one. Get this wrong and your new hire cannot legally start work, and your outgoing employee may face permit complications.

This guide covers employer changes for Qualified Employment Permit holders. If your employee holds an EU Blue Card, see our EU Blue Card employer change guide. For Skilled Worker Visa holders, see our [Skilled Worker Visa employer change guide] (placeholder, link to be added once live).

What Is the Qualified Employment Permit?

The Qualified Employment Permit (Qualifizierte Beschäftigung) is a German residence permit for non-EU workers with a recognised qualification. It comes in two forms:

• §18b AufenthG, for workers with a recognised academic degree whose salary falls below the EU Blue Card threshold
• §18a AufenthG, for workers with a recognised vocational qualification (Berufsausbildung), such as nurses, electricians, and mechatronics technicians

The QEP is not the same as the EU Blue Card (§18g AufenthG), which requires a higher salary. It is also distinct from the Skilled Worker Visa category as commonly referenced in the 2023 Fachkräfteeinwanderungsgesetz reforms, though the terms overlap in casual usage. In practice, QEP holders take a slower path to permanent residency (3–5 years vs. 21 months for Blue Card holders with B1 German) but face fewer salary entry barriers.

Use our Germany pre-hiring visa eligibility tool to confirm which permit category applies before you proceed.

Can Your Employee Change Employer?

Yes, but not freely, and not automatically. The QEP is issued with a Zusatzblatt (supplementary sheet) that restricts employment to the specific employer and role listed on the permit. Changing employer requires a formal amendment from the Ausländerbehörde (LEA) before the new employment can begin.

This is different from the EU Blue Card, which unlocks free employer mobility after 12 months of qualifying employment without any formal approval. QEP holders have no equivalent threshold. Every employer change requires prior approval, regardless of how long the employee has held the permit.

The practical consequence: plan for at least 6–12 weeks between the new offer and the permitted start date. Honestly, most companies underestimate this timeline, and delays at the Ausländerbehörde in Berlin, Munich, and Frankfurt are common.

Eligibility Conditions for the New Role

The new role must satisfy three conditions for the permit amendment to be approved.

1. Qualification match

The employee’s recognised degree or vocational qualification must cover the new role. For non-regulated professions, the 2023 Skilled Immigration Act broadened acceptable matches, so a software engineer with a computer science degree can move into a product management role at a new employer without triggering a full re-evaluation in most cases. Regulated professions (doctors, nurses, engineers in certain Länder) require a completed Anerkennung for each new role context. If the field shift is significant, say, from engineering to finance, the Ausländerbehörde will scrutinise the match more closely. Our Germany qualification recognition guide covers the Anerkennung process in detail.

2. Federal Employment Agency involvement

Whether the Bundesagentur für Arbeit (BA) needs to approve the new employment depends on permit type and salary:

• §18a (vocational): BA approval is always required. The BA checks that the offered salary and conditions match the German market rate and that no equally qualified German or EU candidate was available.
• §18b (academic degree, standard salary): BA approval is generally not required if the salary meets or exceeds the standard market rate for the role.
• §18b (shortage occupation / reduced salary band): BA approval is required. Expect an additional 2–4 weeks of processing.

BA involvement happens internally between the immigration office and the BA, your employee does not submit a separate BA application. But it does add time, so build it into your onboarding schedule.

3. Salary and market-rate compliance

The QEP has no fixed statutory minimum salary, unlike the Blue Card. However, the offered salary must reflect German market rates for the role, sector, and location. The BA (where involved) will verify this. If it doesn’t, the application will be rejected or referred back.

2026 Salary Reference Points

The QEP has no hard salary floor. What matters is market conformity. That said, the EU Blue Card thresholds serve as useful reference points:

2026 salary thresholds at a glance

Permit 2026 Salary Threshold Notes EU Blue Card, standard €50,700 gross/year All non-shortage professions EU Blue Card, shortage occupations €45,934.20 gross/year STEM, IT, healthcare; BA approval required QEP (§18b / §18a) No fixed minimum Must be market-conforming; BA verifies where applicable

If the new role’s salary meets either Blue Card threshold, it is worth checking whether your employee qualifies for a Blue Card instead. That single decision can accelerate permanent residency by years. See the section below on upgrade paths.

Step-by-Step: How to Handle the Employer Change

1. Confirm eligibility, Verify the degree or vocational qualification is recognised for the new role. Check whether the new role is regulated. Run the Germany Employer Change Checker to flag any issues before you proceed.
2. Prepare the employment contract, Signed offer letter or employment contract confirming start date, salary, role title, and working hours. The contract must reflect German market rates.
3. Gather documents, See the checklist below. Collect these in parallel with drafting the contract to avoid delays.
4. Submit to the Ausländerbehörde, File the application for permit amendment online or in person, depending on the relevant LEA. In Berlin, the process is fully online via the Berlin.de service portal. Other cities vary.
5. BA review (if applicable), The LEA forwards to the BA for salary and market review. No separate action required from you, but monitor the timeline.
6. Await approval, Do not allow your employee to start work until the amended permit or a written Fiktionsbescheinigung (bridging certificate) has been issued.
7. Notify under §45c AufenthG, From 1 January 2026, you must provide written notice of Fair Integration advisory services to all incoming third-country skilled workers on day one of employment.

Document Checklist

Required documents for a QEP employer change application

Document Details Valid passport Copy of all pages; original may be requested at appointment Current residence permit (QEP) Photocopy of permit card and Zusatzblatt New employment contract Signed; must state start date, salary, role, and hours Qualification recognition certificate ZAB, anabin confirmation, or IHK/HWK certificate as applicable Company registration extract Handelsregister excerpt of the new employer (not older than 6 months) Job description (Stellenbeschreibung) Confirms the role matches the qualified profession Salary declaration Confirmation that salary is market-conforming; may be part of the contract Proof of registered address Anmeldebestätigung; must show the employee’s current German address

Individual Ausländerbehörden may request additional documents. Always check the specific requirements of the relevant office before submitting.

Processing Time and Fees

Realistic timelines vary significantly by city. In Berlin, the LEA is processing employer change applications in 8–12 weeks as of early 2026. Munich and Hamburg tend to be faster at 4–8 weeks; smaller cities can be quicker still. Frankfurt and Düsseldorf sit in the middle range.

The standard fee for amending a residence permit is €100. If the application is refused and must be resubmitted, the fee applies again. A Fiktionsbescheinigung (bridging certificate, confirming the employee may continue working while the application is pending) costs approximately €10–25 depending on the office.

Start the process at least 8 weeks before the intended start date. If you are dealing with Berlin or a known backlog city, 12 weeks is safer.

What Happens If Your Employee Loses Their Job

The 2023 Skilled Immigration Act introduced a 3-month grace period for QEP holders who become unemployed. This is a meaningful change, previously, a permit could be revoked much faster. During the grace period, the permit remains valid and the employee can search for new qualifying employment.

As the outgoing employer, your obligations are:

• Notify the Ausländerbehörde within 4 weeks of the employment ending, using the official form (Mitteilung über die Beendigung des Beschäftigungsverhältnisses)
• If BA approval was required for the original hire, notify the BA as well
• Provide a reference letter (Arbeitszeugnis), your employee will need it to demonstrate qualification match for their next permit
• Inform them of the 3-month grace period and their right to register as a job seeker with the Agentur für Arbeit

This differs from the EU Blue Card, which also carries a 3-month grace period but provides broader intra-EU mobility options during that window. For QEP holders, the search is restricted to Germany unless they hold another qualifying status.

Could This Trigger an Upgrade to an EU Blue Card?

Yes, and this is worth checking every time a QEP holder changes employer. If the new role offers a salary at or above the 2026 Blue Card threshold (€50,700 for standard roles; €45,934.20 for shortage occupations), and the degree is already recognised, your employee can apply for a Blue Card directly instead of amending the QEP.

Why it matters: a Blue Card holder with B1 German can reach permanent residency in 21 months. A QEP holder takes 3–5 years. If the salary fits, upgrading during an employer change costs the same in administrative terms but delivers a substantially better outcome for the employee, and often helps with retention.

Our Germany Qualified Employment Permit service page and our EU Blue Card employer change guide cover both pathways in detail. Use the Germany Employer Change Checker to run the comparison instantly.

Compliance Notes for HR

Two compliance obligations that frequently catch HR teams out:

§45c AufenthG, Fair Integration duty: From 1 January 2026, every employer hiring a third-country national skilled worker must inform them in writing about Fair Integration advisory services on the first day of employment. This applies to incoming QEP employees changing employers. Document it. Our employer obligations guide has the full detail.

Degree recognition during transition: If the original Anerkennung was conditional (partial recognition with a compensating measure outstanding), check whether that condition has been satisfied before the new employer change application is filed. An outstanding compensating measure can block the amendment.

Why This Process Matters for HR and Retention

An employer change that is handled correctly takes 6–12 weeks. One that is mismanaged takes longer, and risks the employee losing their right to work entirely during the gap. The compliance risk is real: if your new hire starts before the Ausländerbehörde approves the change, both you and the employee are in breach of the terms of the permit.

Beyond risk, there is a retention angle. QEP holders who know their employer actively manages permit transitions are less likely to look elsewhere. Providing a clear, supported process signals that your company takes international talent seriously.

Our Germany Change of Employer service handles the full process, from eligibility check to approved permit amendment, so your team can focus on onboarding. Book a demo to see how it works.

Disclaimer: Immigration rules change quite frequently; please verify with official sources or contact us for the latest info before making any decisions.