In force since 1 January 2026: every German employer recruiting a third-country national from abroad must hand the new hire a written notification on or before their first working day — and collect a signed confirmation. The requirement sits in §45c Aufenthaltsgesetz (AufenthG) — a statutory duty most HR teams have never heard of. This guide tells you exactly what to do.
All thresholds and obligations in this article reflect the rules in force in 2026.
Key employer takeaways
- Day-one obligation: hand every non-EU hire recruited from abroad the official Fair Integration leaflet on or before their first working day and collect a signed confirmation (§45c AufenthG).
- Official leaflet only: it must be the government leaflet from faire-integration.de — a custom document does not satisfy the requirement.
- Four existing duties still apply under §4a(5) AufenthG: verify right to work, keep a permit copy, monitor renewals, notify the Ausländerbehörde within 4 weeks of early termination.
- No fine currently attaches — §45c is not in the penalty catalogue of §98 AufenthG — but it is a statutory duty, and a missed notice is non-compliance that can surface in an audit by the FKS or the Ausländerbehörde.
- Placement agencies: if the worker came via a Zeitarbeitsfirma, the agency carries the notification duty — not you.
What the 2026 §45c obligation actually requires
From 1 January 2026, every German employer must give each non-EU national newly recruited from abroad a written notification on or before their first working day, and obtain a signed confirmation. The obligation was introduced into §45c AufenthG as part of the Fachkräfteeinwanderungsgesetz reform package. It applies regardless of the residence title held — EU Blue Card, general skilled-worker visa, ICT permit, or any other title permitting employment.
The rule is more specific than many summaries suggest. It does not ask you to draft a custom document. It requires you to hand the employee a pre-prepared official leaflet about the Fair Integration advisory service — a free, nationwide, multilingual counselling service for third-country nationals — and to obtain a signed confirmation that they received it.
Official leaflet only
The notification must be the government leaflet from faire-integration.de, available in German, English, Arabic, Turkish, Ukrainian, and Russian. A custom-written document does not satisfy the legal requirement.
What is Fair Integration?
Fair Integration is a free, government-backed advisory service covering employment law, social security, and worker rights — available in 6 languages across all 16 German federal states. Employees can turn to it for support on topics such as:
- Working hours, leave, and sick-leave entitlements
- Termination, warnings, and temporary work
- Social security — health, pension, and accident insurance
- The rights and obligations of both employees and employers
Who is affected by the §45c obligation?
Any German employer that directly recruits a non-EU/EEA national from abroad under a work-permitting residence title. There is no company-size threshold. In practice that includes:
- Companies hiring international talent directly from abroad
- Employers sponsoring an EU Blue Card or a skilled-worker visa
- Employers transferring staff from non-EU subsidiaries under ICT permits
Important exception
If the employee was recruited through a placement agency (Zeitarbeitsfirma), the agency — not the end employer — carries the §45c notification duty. If you hire directly, the duty is yours. Cross-border worker placements arranged under §299 SGB III are a separate case: the notification duty does not arise at all for those placements.
Exactly what you need to do
The notification must be delivered in a language the employee understands. German is acceptable if the employee demonstrably understands it; otherwise a translation is strongly advisable. Based on the legislative text and guidance from the Bundesministerium für Arbeit und Soziales (BMAS), the steps are:
Download the official leaflet
Get the employee leaflet from faire-integration.de in the employee's language (DE / EN / AR / TR / UK / RU).
Mark the nearest advice centre
On the leaflet, tick the Fair Integration advice centre(s) closest to the employee's place of work. The full list by federal state is on faire-integration.de.
Deliver on day one and get a signature
Hand the completed leaflet to the employee on or before their first working day. They sign the confirmation section — name, date, place, signature. For remote hires, use a tracked digital method (e-signature or registered email).
File and retain it
Store the signed copy in the personnel file and retain it — with proof of delivery — for at least 5 years. This is your evidence of compliance in an FKS inspection.
The four other employer duties you must also follow
The §45c notification is a 2026 requirement — but it sits alongside four existing employer duties under §4a(5) AufenthG that many HR teams still handle inconsistently. Here is the full picture for onboarding new employees from abroad.
| Duty | What it involves | When |
|---|---|---|
| 1. Verify right to work | Confirm the employee holds a valid residence title that explicitly permits the employment offered — including type, validity dates, and any restrictions. | Before employment begins |
| 2. Hand over the Fair Integration leaflet (§45c) | Download the official leaflet, mark the nearest advice centre, deliver it, and collect the signed confirmation. File it for at least 5 years. | On or before first working day |
| 3. Keep a permit copy | Store a copy of the valid residence title in electronic form for the duration of employment. | On hire; update on renewal |
| 4. Monitor expiry and renewals | Track expiry dates of visas and residence permits, and start renewals before the deadline. A lapse can make continued employment illegal. | Ongoing |
| 5. Notify authorities of early termination | Inform the competent Ausländerbehörde within the deadline if employment ends early. See what happens to residence permits after job termination. | Within 4 weeks of early exit |
Free download: the §45c onboarding compliance checklist
We’ve turned everything above into a printable one-page checklist for your HR team — every §45c step grouped by before day one, on day one, and ongoing, plus the five statutory employer duties and their deadlines. Add your work email and we’ll send it over.
§45c Onboarding Compliance Checklist
A printable one-pager covering every step of the day-one notification, the five employer duties under §45c and §4a(5) AufenthG, and the 5-year retention rule. Built for HR teams onboarding non-EU hires.
No spam. Business emails only.
What happens if you don’t comply?
A missed notification is non-compliance with a statutory duty — but no fine currently attaches: §45c is not in the penalty catalogue of §98 AufenthG. The duty is still real, and gaps can surface when the Finanzkontrolle Schwarzarbeit (FKS) or your local Ausländerbehörde reviews your onboarding records.
What this means in practice
A Berlin company hired 3 engineers from India in January 2026. HR completed onboarding but missed the §45c notification. During a routine Ausländerbehörde check, the gap surfaced — three hires with no leaflet handover and no signed confirmation on file, and no way to evidence that the statutory duty was met.
- No fine currently attaches. §45c is not in the penalty catalogue of §98 AufenthG.
- Each hire is a separate gap. Every missing notification and confirmation is its own finding in an audit.
- Two enforcing authorities. The FKS and your local Ausländerbehörde both conduct inspections.
- Systemic non-compliance carries extra risk. Repeated violations can damage your standing with immigration authorities and slow future visa applications — a real concern if you rely on a pipeline of international talent.
How relokate keeps you compliant
relokate guides employers in Germany through the entire relocation process — from visa applications and communication with authorities to §45c-compliant onboarding documentation and ongoing monitoring of residence permits and renewal deadlines. For relokate clients, the leaflet handover, signed confirmation, and document retention are built into the standard onboarding workflow, so your HR team doesn’t manage it separately.
Only need the monitoring side?
Compliance Watch covers §45c employer-duty alerts and case-matched regulatory updates — available as a standalone subscription, and included (with permit-expiry tracking) in every relokate engagement.
For the wider context on the 2026 rules, see our guide to the Fachkräfteeinwanderungsgesetz and an overview of Germany’s 2026 immigration changes.
Frequently asked questions: §45c employer notification
Who exactly does §45c apply to?
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§45c applies to any employer based in Germany that recruits a third-country (non-EU/EEA) national from abroad under a residence title permitting employment — including EU Blue Cards, skilled-worker visas, and ICT permits. There is no minimum company size or headcount threshold; the obligation is the same whether you have one international hire or hundreds.
What happens if I miss the day-one deadline?
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Missing the deadline means non-compliance with a statutory duty, but no fine currently attaches — §45c is not in the penalty catalogue of §98 AufenthG. A missed notice can surface in an audit by the Finanzkontrolle Schwarzarbeit (FKS) or the Ausländerbehörde, and repeated or systematic non-compliance can also affect your standing in future permit applications.
Does the notification replace the employment contract?
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No — the §45c notification is a separate, standalone document. Although some content overlaps with the contract (role, salary, start date), the notification has a distinct purpose: informing the employee of their rights and the conditions under which they are employed. Issue it as its own signed document rather than embedding it in the contract.
Does the notification need to be in German?
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The law requires it to be delivered in a language the employee understands. German is acceptable if the employee demonstrably understands it, but for most international hires a translation — typically English — is strongly advisable. Issuing a German-only document to a non-German speaker undermines the purpose of the obligation and could be challenged in an inspection.
Do we need to re-issue the notification if the role or salary changes?
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Yes. Any material change to employment conditions — a promotion, salary increase, change in job title, or relocation to a new work address — should trigger an updated notification, especially where the change affects the conditions under which the permit was approved. Treat it like a written amendment to the contract.
Can relokate help us draft and manage these notifications?
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Yes. relokate provides end-to-end support for employers hiring international talent in Germany — from visa sponsorship and permit applications to compliant onboarding documentation and ongoing monitoring. That includes §45c notification handling, bilingual delivery, compliance reviews for existing hires, and fully managed relocation support for new arrivals.
Key official resources
Compliance support
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Check visa eligibility →About the author
Hanna Kovacs
Product Manager, Global Mobility
Professional experience across the US, Hungary, and Germany in product management and operations. Deep expertise in German immigration law and the regulatory landscape for skilled worker migration. At relokate, Hanna owns the product roadmap, drives platform automation, and develops the compliance frameworks and immigration content that HR teams rely on.
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