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KEY TAKEAWAYS
- Section 19c(2) lets you hire experienced non-EU professionals without formal German degree recognition, saving 4–8 weeks on ZAB.
- The 2026 minimum salary threshold under 19c(2) is €45,630 gross per year; candidates over 45 need €55,770.
- Section 19c(1) is a broader catch-all route enabling employment under the Employment Ordinance or bilateral agreements, including the Western Balkans regulation.
- BA (Federal Employment Agency) approval is required for most 19c cases; it happens during visa processing and does not require a separate employer submission.
- Employer notification obligation under §45c AufenthG (since January 2026) requires that you must inform new non-EU hires about advisory services on the first day of work.
- Jobbatical handles all blue collar visas in full compliance with the German authority requirements.
Section 19c: Skip the Degree Recognition Bottleneck
If your candidate has 5+ years of experience but their degree isn't in the ZAB database, waiting 4–8 weeks for formal recognition can stall your onboarding.
Section 19c(2) is designed for this exact scenario. It is an experience-based route that skips German degree recognition entirely, cutting weeks off your hiring timeline.
This guide covers:
- Section 19c(2): Fast-tracking experienced professionals.
- Section 19c(1): Navigating special employment pathways.
- Employer Obligations: Your legal responsibilities as a visa sponsor.
What Is Section 19c AufenthG? Alternative Work Visa Routes
Section 19c of the German Residence Act covers employment options outside the standard Skilled Worker or Blue Card tracks. There are two main pathways for employers:
- Section 19c(1) – Special Regulations: Covers specific legal pathways or bilateral agreements, such as the Western Balkans regulation and sector-specific work permits.
- Section 19c(2) – Work Experience: The experience-based route. This allows you to hire professionals who have 2+ years of relevant experience and a qualification recognized in their home country. No formal German degree recognition is required.
Essential Facts for HR:
- Approval: Both routes require Federal Employment Agency (BA) approval, which is handled automatically during the visa application process.
- Discretionary: These visas are not a legal entitlement; approval is entirely at the discretion of the immigration authorities.
Section 19c(2): The Experience-Based Route
When hiring "without ZAB", this is the most common route. Here's how it works and who it applies to.
Who Qualifies
Your candidate must meet all four conditions:
- Holds a vocational or academic qualification recognised by the government of the issuing country
- Has at least 2 years of relevant professional experience within the last 5 years
- Has a confirmed job offer in a non-regulated profession in Germany
- Meets the 2026 minimum salary threshold (see below)
📌 The key phrase is "non-regulated profession."
- If the role falls under German professional licensing, doctors, nurses, pharmacists, lawyers, engineers in certain contexts, this route does not apply.
- For those roles, full professional recognition is mandatory regardless of the visa pathway.
Eligibility and Salary Thresholds, 2026
Section 19c(2) Quick Reference
| Requirement | Details |
|---|---|
| Qualification | Vocational or academic qualification recognised by home country (no German equivalency needed) |
| Work Experience | Minimum 2 years in the relevant profession within the last 5 years |
| Job Offer | Required; must match the candidate's qualification and experience level |
| Profession Type | Non-regulated professions only |
| Minimum Salary (under 45) | €45,630 gross per year (€3,802.50/month) as of 2026 |
| Minimum Salary (age 45+) | €55,770 gross per year, or proof of adequate pension provision |
| Language Requirement | No fixed minimum, but BA assesses working conditions; role-dependent in practice |
| ZAB Evaluation | Not required |
| BA Approval | Required; obtained during visa processing, no separate employer action needed |
| Permit Validity | Up to 4 years (tied to employment contract duration) |
| Path to PR | After 4 years of employment; not a legal entitlement like the EU Blue Card |
Section 19c(1): Special Employment Cases
Section 19c(1) is a broad category for hiring workers who do not meet standard qualification requirements, but fall under specific legal exceptions or bilateral agreements. It is highly useful for blue-collar, trade, and industry-specific roles.
Three Common Scenarios for HR:
- Western Balkans Regulation: Citizens of Albania, Bosnia, Kosovo, Montenegro, North Macedonia, and Serbia can work in any sector. They only need a job offer and BA approval—no formal qualifications required.
- Sector-Specific Permits: Designed for shortage sectors (like construction, agriculture, and hospitality). This allows you to hire talent without waiting for full vocational recognition.
- Local Hires ("Privileged Nationals"): Candidates already in Germany who hold a home-country degree and 2 years of relevant experience can apply for their residence permit locally.
HR Takeaway: Use Section 19c(1) as a fallback when the experience-based route (19c(2)) isn't an option, or when a country-specific agreement offers a faster, simpler pathway for your hire.
19c(1) vs 19c(2): Which Route Applies?
Comparison: 19c(1) vs 19c(2)
| Factor | Section 19c(1) | Section 19c(2) |
|---|---|---|
| Qualification Required? | Depends on specific BeschV provision; Western Balkans: No | Yes, home-country recognised qualification required |
| Experience Required? | Varies; some provisions require 2 years, others none | 2+ years in the last 5 years |
| Minimum Salary | No fixed threshold; BA assesses fair working conditions | €45,630/year (€55,770 for age 45+) |
| ZAB Recognition | Not required | Not required |
| Profession Type | Any, including regulated in some cases | Non-regulated only |
| Best For | Blue-collar, trades, Western Balkans nationals, sector schemes | Experienced professionals in IT, finance, logistics, non-clinical health roles |
| Legal Entitlement? | No, discretionary | No, discretionary |
Comparison of Germany Section 19c(1), 19c(2) and EU Blue Card work permit routes
If you're hiring construction workers, electricians, or tradespeople from Western Balkans countries, 19c(1) via the Western Balkans regulation is likely your fastest route.
For the full picture of blue-collar visa options, see Jobbatical's Germany Blue-Collar Visa service page.
The Application Process: Step by Step
Both 19c(1) and 19c(2) applications follow the same broad sequence. The critical path item is BA approval, but this runs in parallel with the embassy process, not before it.
Application Timeline
| Step | Who Does It | Timeline |
|---|---|---|
| 1. Pre-hire eligibility check | Employer / immigration specialist | 1–3 business days |
| 2. Document preparation | Candidate and employer together | 1–2 weeks |
| 3. Embassy appointment and D-visa application | Candidate at German embassy/consulate abroad | 4–8 weeks (2–4 weeks via fast-track) |
| 4. BA assessment | Federal Employment Agency (runs alongside step 3) | Concurrent with visa processing |
| 5. Entry and registration | Candidate | First 2 weeks after arrival |
| 6. Residence permit (Ausländerbehörde) | Candidate, with employer support | 2–4 weeks post-arrival |
Total: 8–14 weeks from offer to permit in hand. With the Beschleunigtes Fachkräfteverfahren (fast-track procedure), some employers bring this closer to 6–8 weeks. It's not magic, it just prioritises your case at the Ausländerbehörde and embassy queue.
Documents Your Employee Needs
- Valid passport (6+ months remaining validity)
- Qualification certificates with certified German translations
- Proof that the qualification was recognised by the home country at time of issue
- Evidence of 2+ years relevant experience (employment letters, contracts, pay records)
- Signed employment contract confirming role and salary
- Biometric photos
- Health insurance proof
Documents You Need to Provide as Employer
- Employment contract (role must match qualification level)
- Company registration documentation
- Declaration of Employment (Erklärung zum Beschäftigungsverhältnis), if required by the embassy
Fees and Costs
The direct visa fees are straightforward. The real costs are in time, delayed start dates, rejected applications, or compliance failures months down the line.
Section 19c, Fee Overview 2026
| Fee Item | Cost | Paid By |
|---|---|---|
| National D-visa (embassy) | €75 | Candidate (often reimbursed by employer) |
| Residence permit (Ausländerbehörde) | €100 | Candidate |
| Spouse residence permit | €100 | Candidate |
| Minor child permit | €50 per child | Candidate |
| Fast-track procedure (Beschleunigtes FKV) | €411 (employer-paid fee to Ausländerbehörde) | Employer |
| Translation and certification costs | €150–400 (typical range) | Usually employer-covered |
There are no recognition costs for 19c(2), that's one of its main advantages. The absence of a ZAB assessment (€200–485 and 4–8 weeks) is where the real saving lies compared to the standard qualified employment permit routes.
Compliance: What You Must Do After Hiring
This is where most HR teams get caught out. The permit is issued, and then the compliance clock starts.
New 2026 Obligation: Section 45c AufenthG
- From 1 January 2026, if you recruit a non-EU national from abroad, you must inform them in writing about the free advisory services available to foreign workers in Germany.
- Should happen by the first day of work, by email, letter, or attachment to the employment contract.
- If you use an immigration specialist who handles this as part of their mandate, you may be exempt.
- Hiring from within Germany is excluded from this obligation.
Ongoing Employer Obligations
- First 2 years: Notify the Ausländerbehörde of any material changes to the employment relationship (change of role, significant salary change, reduction in hours). Failure to do this puts the permit at risk.
- Job-qualification match: The role must continue to match the qualification and experience that justified the permit. Promotions that move the employee into a regulated profession require review.
- Renewal tracking: Permits are valid for up to 4 years. Your employee must apply for renewal before expiry. Automated tracking significantly reduces the risk of lapses, the Jobbatical renewals platform handles this automatically.
- Section 45c advisory notice: Required for all new non-EU hires from abroad from January 2026 onward.
Contact us for Germany employer compliance checklist for Section 19c permit holders 2026.
How Section 19c Compares to Other Germany Work Visa Routes
Understanding where 19c fits in the wider system saves time at the offer stage. Here's the practical decision rule:
- Candidate has a degree, salary meets €50,700: Go for the EU Blue Card (§18g). Better PR timeline, legal entitlement.
- Candidate has a vocational qualification, trades role: Consider §18a (Skilled Worker Visa) or blue-collar visa routes. See Jobbatical's Germany Blue-Collar Visa service .
- Candidate has experience but degree not ZAB-compatible, non-regulated role: Section 19c(2) is the right path.
- Candidate is from Western Balkans, no qualification required: Section 19c(1) via §26 BeschV.
- IT hire with 3+ years experience, salary above €45,934: The EU Blue Card for IT specialists (§18g(2)) gives faster permanent residency and is the stronger choice.
Honestly, the most common mistake is defaulting to the wrong route because it's the one you used last time. A 10-minute eligibility check before extending an offer saves weeks of rework.
How Jobbatical Manages Section 19c Cases
Jobbatical assigns a dedicated immigration case manager to every hire.
Once you share the candidate details:
- we assess eligibility
- select the correct route (including whether 19c applies or whether a stronger route is available), prepare the full document package
- coordinate the BA and embassy process
- and, track all post-arrival compliance obligations.
The Jobbatical immigration platform gives your team real-time visibility on every case, document deadline, and renewal window, so compliance gaps don't surface as surprises.
If you are managing multiple hires across different permits, 19c(2), §18a, and EU Blue Card, Jobbatical platform helps track them together and make sure you stay compliant and never miss a renewal window.
Disclaimer: Immigration rules change quite frequently; please verify with official sources or contact us for the latest info before making any decisions.
Frequently Asked Questions: Germany Section 19c Experience-Based Work Visa
Section 19c(2) of the German Residence Act (AufenthG) is a residence permit for experienced professionals who want to work in a non-regulated profession in Germany. It allows employment without formal ZAB degree recognition, provided the candidate holds a home-country-recognised qualification and has at least 2 years of relevant professional experience in the last 5 years.
The minimum gross annual salary is €45,630 (approximately €3,802.50 per month) as of 2026. For employees aged 45 or over, the threshold rises to €55,770 gross per year, unless adequate pension provision is demonstrated. Alternatively, if your company is bound by a collective bargaining agreement, that rate may satisfy the requirement.
No. Section 19c(2) specifically bypasses ZAB equivalency. The candidate's qualification only needs to be recognised by the government of the country where it was obtained. Germany does not require a comparability certificate under this route, which removes 4–8 weeks from the typical hiring timeline.
Section 19c(1) is a broad permit that allows employment where a specific legal regulation or bilateral agreement provides for it, for example, the Western Balkans regulation (Section 26 BeschV). No formal qualification is required. Section 19c(2) is a narrower route for experienced professionals: it requires 2+ years of experience and a home-country-recognised qualification, but skips ZAB. They serve different hire profiles and sectors.
No. Regulated professions, doctors, nurses, pharmacists, physiotherapists, require full professional recognition by the relevant state authority, regardless of the visa route. Section 19c(2) is limited to non-regulated professions. Non-clinical roles in the same sector (e.g. health IT manager, medical data analyst) can qualify.
Total end-to-end processing typically takes 8–14 weeks. Document preparation takes 1–2 weeks; the German embassy processes the national D-visa in 4–8 weeks; and post-arrival conversion to a residence permit at the local Ausländerbehörde takes another 2–4 weeks. Fast-track processing (Beschleunigtes Fachkräfteverfahren) can reduce embassy wait times to 4–6 weeks total.
From January 2026, under Section 45c AufenthG, you must inform all new non-EU hires in writing about the free advisory services available to them, no later than their first day of work. You must also ensure the job role matches the candidate's qualification level and notify the Ausländerbehörde of any material employment changes during the first two years of the permit.
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