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.

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?

Changing employers under the German Qualified Employment Permit (QEP) is possible, but it requires prior approval and careful planning.

• The QEP is issued with a Zusatzblatt (supplementary sheet) that ties the permit to a specific employer and job role.
• Employees cannot start working for a new employer until the local immigration authority (Ausländerbehörde / LEA) formally approves the change.
• Unlike the EU Blue Card, the QEP does not provide automatic employer mobility after a certain period.
• EU Blue Card holders can change employers freely after 12 months of qualifying employment without formal approval, but QEP holders must seek approval every time they switch employers.
• In practice, employers should expect a transition timeline of approximately 6–12 weeks between the new job offer and the legally permitted start date.

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

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

Document Checklist

Required documents for a QEP employer change application

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

Processing Time and Fees - German Employer Change

Processing timelines and fees for Germany employer change applications vary significantly depending on the city and local immigration authority workload.

• In Berlin, the LEA is processing employer change applications in approximately 8–12 weeks as of early 2026.
• Munich and Hamburg are generally faster, with average processing times of 4–8 weeks, while smaller cities may process applications more quickly.
• Frankfurt and Düsseldorf typically fall within the mid-range processing timeline.
• The standard government fee for amending a residence permit is €100.
• If the application is refused and must be resubmitted, the government fee applies again.
• A Fiktionsbescheinigung (bridging certificate confirming the employee may continue working while the application is pending) usually costs approximately €10–25 depending on the immigration office.

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?

• Every time a QEP holder changes employer, it is worth assessing whether the employee now qualifies for an EU Blue Card.
• If the new role offers a salary at or above the 2026 EU Blue Card thresholds (€50,700 for standard occupations or €45,934.20 for shortage occupations), and the employee’s degree is already recognised in Germany, they may apply directly for an EU Blue Card instead of simply amending the QEP.
• This can provide a significantly more favourable long-term immigration pathway for the employee.
• An EU Blue Card holder with B1-level German language skills may become eligible for permanent residency after 21 months.

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

Managing a Germany employer change correctly typically takes between 6–12 weeks.

• If the process is mismanaged, delays can increase significantly and may risk the employee temporarily losing their legal right to work during the transition period.
• There is a genuine compliance risk for employers. If the employee starts working before the Ausländerbehörde approves the employer change, both the employer and the employee may be in breach of the residence permit conditions.
• Beyond compliance, a well-managed process also supports employee retention and trust.
• QEP holders who see that their employer actively manages immigration and permit transitions are generally more confident in their long-term employment stability.
• Providing a clear and well-supported employer change process demonstrates that your company takes international talent mobility and compliance 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.