Executive Summary
- A paid Praktikum is treated as employment under German immigration law, duration (even two weeks) does not change this classification.
- The EU Blue Card's supplementary sheet (Nebenbestimmung) may restrict work to the original employer, making any work for a new company unauthorized until reviewed.
- After two years, employer changes on a Blue Card are permitted without prior approval, but the new role must still qualify as Blue Card-eligible employment; a below-threshold internship usually does not.
- HR must review the actual permit and supplementary sheet before onboarding begins; proceeding without this creates unauthorized employment liability for the company.
Question: Can an employee use an existing EU Blue Card for a paid two-week internship if it was issued for a previous employer and that job has ended?
Answer:
Not without a permit review first. A paid internship (Praktikum) is usually treated as regular employment under German immigration law unless it is a mandatory university requirement. An EU Blue Card is employer-specific in the first year; after two years, employer changes are allowed, but the new role still must qualify for Blue Card eligibility. A low-paid internship likely does not. HR should check the residence permit and Nebenbestimmung before onboarding.
Scenario Overview
What HR Needs to Know Before Onboarding This Intern
The Legal Position
Under German immigration law, a paid internship (Praktikum) is usually treated as regular employment (Beschäftigung) unless it is a mandatory Pflichtpraktikum. The EU Blue Card’s work authorization is set by its permit conditions, and the Nebenbestimmung controls whether the employee may work for your company. In many cases, it names the original employer or limits employment to a specific sector, so the actual document must be checked.
The Practical Path Forward
If the card is in its unemployment grace period, the holder may remain in Germany and seek new qualifying employment, but they cannot start paid work without confirming the Nebenbestimmung. If the post-two-year phase had already begun, employer-change rules are more flexible, but the new role must still meet EU Blue Card salary and eligibility requirements. A typical paid Praktikum is usually below the Blue Card threshold and therefore non-qualifying.
HR Guidance
- Obtain and review the physical Blue Card and its supplementary sheet before any onboarding discussion , confirm whether work authorization is open or employer-restricted.
- Establish whether the role meets Blue Card employment criteria , if the internship salary falls below the applicable threshold, the engagement cannot be covered by the Blue Card and a separate permit route is required.
- Do not start the intern on payroll until written confirmation of authorized work status is in hand , proceeding on the assumption that a valid card covers all employment is a common and costly mistake.
- If the engagement is commercially important, assess whether a short-term qualified employment permit or a re-scoped role could qualify , a two-week trial placement under Section 20 AufenthG (probationary employment for qualified workers) may offer a compliant alternative path.
Key Risks
- Unauthorized employment risk: Hiring a paid intern without confirming work authorization can expose the company to fines and create immigration issues for the employee, even for short internships.
- Permit expiry during onboarding: If the residence permit expires without a timely renewal or extension application, the employee can lose both residence and work rights during the internship period.
- Internship misclassification: Many compliance issues arise when companies assume a short or informal Praktikum does not require work authorization. In most cases, paid internships are still treated as employment under immigration rules.
FAQs: EU Blue Card and Paid Internships at a New German Employer
This covers the following use cases:
- Can a Blue Card holder in Germany work for a new employer during their three-month unemployment grace period?
- Does a paid two-week internship require a work permit for a non-EU national already in Germany?
- What does the supplementary sheet on a German EU Blue Card say about working for a different employer?
- Can we onboard a non-EU candidate who has a valid German Blue Card from a previous job?
- Is a Praktikum in Germany considered employment under the Residence Act?
- Does the two-year rule on the EU Blue Card mean an employee can take any job after that point?
- What is the salary threshold an internship must meet to qualify under a German EU Blue Card?
- Can an Indian national use their existing EU Blue Card for a short placement at a different German company?
- What is the difference between a Pflichtpraktikum and a voluntary internship under German immigration law?
- Can a Blue Card holder take up trial employment (Probearbeit) under §20 AufenthG without a new permit?
- What is unauthorized employment in Germany and what are the fines for HR teams?
- Can a Ukrainian national on an EU Blue Card from a previous employer do a paid internship at our company?




