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Changing Employer on a Germany Skilled Worker Visa (§18b): 2026 HR Guide

7
min read
Created
May 27, 2026
Last updated
May 27, 2026
Carolin Urich
A Global Mobility expert with 10 years of immigration experience, ensuring that all immigration requirements are met while providing guidance and support throughout the process. Clients can confidently navigate their relocation journey relying on her experience and expert assistance.
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HR manager reviewing Germany §18b Skilled Worker Visa employer change documents at a deskHR manager reviewing Germany §18b Skilled Worker Visa employer change documents at a desk

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

Scenario 2026 Threshold Notes
§18b standard, no fixed floor Market-rate wage for the role Verified by the Federal Employment Agency against collective bargaining benchmarks
§18b applicant over 45 years old €55,770 gross/year (€4,647.50/month) Applies to first-time §18a/18b permits; updated January 2026
EU Blue Card — standard €50,700 gross/year Triggers EU Blue Card eligibility for degree holders; consider upgrading route where eligible
EU Blue Card — shortage occupations €45,934 gross/year Applies to IT, engineering, healthcare, and selected STEM roles
Federal Employment Agency waiver threshold €45,934 gross/year Salaries at or above this level often waive the Federal Employment Agency labour market review

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

1
Confirm Qualification Match
Verify the new role aligns with the employee’s recognised qualifications using anabin or immigration guidance before proceeding with the employer change.
2
Check Salary Compliance
Ensure the proposed salary meets market standards and immigration requirements. Assess whether eligibility for an EU Blue Card applies.
3
Prepare Supporting Documents
Gather the signed employment contract, qualification records, and employer documentation required for the application.
4
Book Ausländerbehörde Appointment
Schedule an appointment with the local immigration authority as early as possible, as waiting times in major cities may be several weeks.
5
Submit the Application
The employee files the employer-change application with the local Ausländerbehörde, supported by documentation from the new employer.
6
Federal Employment Agency Review
Where required, the application is reviewed by the Federal Employment Agency. Lack of response within the review period may be treated as approval.
7
Receive Updated Residence Permit
A new residence permit linked to the employer and role is issued. Temporary work authorisation may be provided while the card is processed.
8
Provide §45c Counselling Notice
By the employee’s first working day, provide written information regarding access to free labour and social-law counselling services.

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

Document Details
Valid Passport Must remain valid for at least 6 months beyond the intended permit end date
Current Residence Permit Existing §18b permit/card must still be valid at the time of application
New Employment Contract Signed by both parties; must specify role title, salary, working hours, and employment start date
Qualification Recognition Certificate ZAB, IHK/HWK, or professional body recognition document; must cover the field of the new role
Job Description Detailed duties confirming alignment with recognised qualifications
Employer Declaration Written confirmation of offer conditions and compliance with collective bargaining agreements where applicable
Biometric Passport Photo Current photo meeting German biometric standards
Registration Certificate (Anmeldung) Current German address registration; must be up to date
Proof of Health Insurance Evidence of statutory or private coverage from the first day of employment

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.

Frequently Asked Questions, Germany Skilled Worker Visa Employer Change

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