Key Take aways for Change of Employer - Germany Skilled Worker Visa
- Your employee cannot simply start with you and notify later, a full permit reassessment is required every time a §18b holder changes employer in Germany.
- The new role must match the recognised qualification (Anerkennung) that underpinned the original permit; a mismatch stalls or kills the application.
- There is no automatic 12-month threshold before the change is permitted, unlike the EU Blue Card, §18b employer changes are allowed from day one but require prior approval.
- If the new salary meets the EU Blue Card threshold (€50,700 in 2026), this is your opportunity to upgrade the permit and accelerate your employee's path to permanent residency.
- As the new employer, you carry §45c compliance obligations from the employee's first day, this includes providing written information about free counselling services.
Changing Employer on a Germany Skilled Worker Visa (§18b)
- Your employee must get prior approval before starting work with you, no grace period applies.
- The new role must match the qualification that underpinned the original §18b permit.
- Federal Employment Agency review is required unless the role falls within an exempt shortage occupation.
- If the new salary meets the 2026 EU Blue Card threshold, a permit upgrade may be possible, and faster permanent residency along with it.
This guide covers employer changes specifically for Skilled Worker Visa (§18b) holders. If your employee holds an EU Blue Card, the rules differ, see our EU Blue Card employer change guide.
Who This Applies To
The §18b Skilled Worker Visa (Aufenthaltsgesetz) is Germany's work and residence permit for non-EU nationals who hold a recognised university degree. It sits alongside §18a (vocational training holders) and is distinct from the EU Blue Card (§18g), which targets higher-earning degree holders.
Your employee is on a §18b permit if:
- They hold a recognised academic degree (Anerkennung via ZAB or equivalent body)
- Their role at the time of the original application matched that degree
- Their salary at the time did not meet, or their employer did not apply for, the EU Blue Card threshold
The key difference from the EU Blue Card: §18b has no fixed minimum salary threshold (other than the market-rate requirement), and it does not come with the Blue Card's automatic 12-month flexibility window for changing employers. Every employer change requires a full reassessment. Every time.
Can Your Employee Change Employer?
Yes, but not freely. The §18b permit is employer-specific. There is no minimum time your employee must have worked with their current employer before a change is permitted. However, they cannot simply resign on Friday and start with you on Monday. The permit must be formally updated before employment begins.
The process mirrors a fresh permit application in many respects. The Ausländerbehörde (Foreigners' Authority) will reassess
- Whether the new role matches the recognised qualification
- Whether the Federal Employment Agency must approve the role
- Whether salary meets the applicable standard
In practice, start your process 8–12 weeks before your intended hire date. Applications can be filed while your employee is still employed elsewhere, and a Fiktionsbescheinigung (bridging certificate) may be issued to confirm the permit application is pending.
Eligibility Conditions for the New Role
Qualification Match
The new position must be in the same professional field as the qualification that was recognised for the original permit. A software engineer with a recognised computer science degree cannot use the same §18b permit to move into a finance role, even at the same seniority level. Run the Germany pre-hiring visa eligibility tool before extending an offer to confirm the fit.
If your employee's recognised qualification does not cover the new role's field, they would need a new recognition procedure, or a different permit type. Do not assume that because they already have a German permit, the change is automatic.
Federal Employment Agency Approval
Federal Employment Agency (Bundesagentur für Arbeit) review is required for most §18b employer changes. The Ausländerbehörde coordinates this, you do not approach the Federal Employment Agency directly.
Approval may be waived where:
- The role is in a recognised shortage occupation (e.g. IT, engineering, healthcare, certain STEM fields)
- The employer is bound by a collective bargaining agreement that covers the role
- The salary offered is at least €45,934 per year (the 2026 shortage occupation threshold)
Where approval is required, the Federal Employment Agency must respond within one week. If no response is received, approval is automatically granted, this is a meaningful protection for HR timelines.
Labour Market Test
A labour market test (checking whether suitable EU candidates exist for the role) may apply for roles outside shortage occupation lists. In practice, regulated professions and STEM roles are largely exempt. Your immigration adviser should confirm this for the specific role before filing.
2026 Salary Thresholds
Unlike the EU Blue Card, §18b does not have a single headline salary floor. The requirement is that pay matches the ortsübliche Bezahlung, the customary local wage for the role and sector. The Federal Employment Agency verifies this.
Key 2026 Salary Reference Points
If the new role's salary meets the EU Blue Card threshold and your employee holds a university degree, stop and consider the upgrade. The Blue Card brings a 21-month route to permanent residency (with B1 German) versus 4 years on §18b. That difference matters for retention.
Step-by-Step Application Process
Jobbatical's Germany Change of Employer service handles coordination with the Ausländerbehörde and Federal Employment Agency, reducing the risk of delays from incomplete submissions.
Documents Checklist
Required Documents for a §18b Employer Change Application
Requirements vary by Ausländerbehörde and individual case. Always confirm the full checklist with your local authority or Germany Employer Change Checker before submission.
Processing Time and Fees
Processing typically takes 6–12 weeks from submission, depending on location and case complexity. Berlin and Munich run slower than smaller cities, assume 10–12 weeks in peak periods (September to November, and January to February)
- Ausländerbehörde permit fee: €100–€140 per application
- Federal Employment Agency review: no additional fee to the employer
- Certified translations (if required): €40–€120 per document
The Fiktionsbescheinigung allows your employee to work legally while the new permit card is being processed. Confirm this is issued at the application appointment, do not allow your employee to start without it.
What Happens If Your Employee Becomes Unemployed
The §18b permit does not carry the same codified unemployment provision as the EU Blue Card. EU Blue Card holders get a defined 3-month grace period; §18b holders do not have an equivalent statutory right.
If employment ends, whether during a probationary period, redundancy, or resignation, your employee's permit is at risk. They must notify the Ausländerbehörde promptly. The authority has discretion to allow a short period for finding new qualifying employment, but this is not guaranteed.
As the employer, your obligations on termination
- Do not delay notifying the Ausländerbehörde, this is a compliance obligation
- Provide the employee with documentation they may need to demonstrate prior qualifying employment
- Inform the employee of their right to seek advice through Fair Integration or equivalent counselling services
This is one of the most material differences from the EU Blue Card and a genuine planning risk for HR. If retention is uncertain, the Blue Card's cleaner unemployment provision is another reason to explore upgrading at the point of the employer change.
Could This Employer Change Trigger a Blue Card Upgrade?
If your employee holds a university degree (the prerequisite for both §18b and the EU Blue Card) and your new role offers a salary of at least:
- €50,700 gross/year for standard roles
- €45,934 gross/year for shortage occupations (IT, engineering, healthcare, STEM)
then an EU Blue Card application is possible instead of, or alongside, the employer change. The benefits are significant: permanent residency in as little as 21 months (with B1 German), versus 4 years on §18b. EU mobility rights. A cleaner unemployment provision. For high-performing employees, upgrading at this transition point is one of the most impactful things you can do for their long-term retention in Germany.
Raise this at offer stage. Once the §18b application is filed, switching permit type adds time and complexity. See our EU Blue Card employer change guide for the parallel process.
Compliance Notes for the New Employer
§45c AufenthG, Counselling Notice Obligation
From 1 January 2026, every employer hiring a non-EU skilled worker must provide written information about the employee's right to free and independent labour and social-law counselling, for example, through the "Faire Integration" network. This notice must be given by the first day of work. It applies to every new non-EU hire, including an employer change. Failure to comply is a compliance breach. See our full guide on employer obligations under §45c for the exact wording and process.
Federal Employment Agency, Ongoing Obligations
You must ensure the employment conditions stated in the permit application remain accurate throughout the employment relationship. Material changes to role, salary, or working hours may require notifying the Ausländerbehörde and, in some cases, a further Federal Employment Agency review.
The permit is issued for a specific role. Promoting your employee into a significantly different function, particularly across fields, may require a new employer change process.
Why This Matters for HR
Getting this wrong carries real consequences. Your employee working without a valid updated permit is an illegal employment situation, for both of you. A rejected application due to a qualification mismatch costs weeks and may cost you the hire.
Start early. The Ausländerbehörde appointment is the single biggest variable in your timeline, and in major cities it is routinely 6–10 weeks out. Build that into your onboarding plan from the day the offer is signed, not from the intended start date.
And if the salary works, have the Blue Card conversation. It takes the same effort to file and delivers meaningfully better outcomes for your employee's long-term status in Germany. Use the Germany Employer Change Checker to assess both options simultaneously before you commit to a permit type.
Need support managing this process? Talk to Jobbatical's Germany immigration team, we handle employer changes, Federal Employment Agency coordination, and §45c compliance across all permit types.
Disclaimer: Immigration rules change quite frequently; please verify with official sources or contact us for the latest info before making any decisions.


