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§19c(1) AufenthG with §3 No. 3 BeschV

Hiring skilled workers without German recognition: the §19c visa route

You have found someone with years of experience, but their training from abroad isn't recognised in Germany? You may still be able to hire them. For specialists with company-specific know-how, the Federal Employment Agency can approve the job without recognition and without a fixed salary threshold.

Short answer

Employers in Germany can hire someone whose qualification isn't recognised there if that person has special, especially company-specific knowledge for a qualified job and the Federal Employment Agency approves. The legal basis is §19c(1) AufenthG with §3 No. 3 BeschV: a residence permit for employment regardless of a qualification as a skilled worker. The agency checks that pay and working conditions are at least as favourable as for comparable German staff; there is no recognition, no ZAB confirmation and no fixed salary threshold.

Legal basis checked on gesetze-im-internet.de and in the Federal Employment Agency's guidance (Fachliche Weisungen, as of 12/2024) on 22 October 2026.

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Martin Gawlak, FoodspringNadine Heinemann, MarquardtKatja Szonn, MedwingEmilie Declercq-Lienard, CODE University

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From relokate's cases · as of October 2026

Proven in relokate's cases: specialists in aviation and MRO

relokate has successfully relocated several specialists in these roles. Wheels-and-brakes mechanics and aircraft technicians went through the same specialist route (§19c(1) AufenthG with §3 No. 3 BeschV) as the example below.

Aircraft painter

Painting and coating aircraft and components

Wheels-and-brakes mechanic

Overhaul of wheels and brakes in the component shop

Aircraft technician

Maintenance and repair of aircraft

relokate case: aircraft painter at an aviation company in Hamburg

  • Vocational training from abroad, not recognised in Germany; many years of aerospace experience.
  • Federal Employment Agency pre-approval (§36(3) BeschV) under §39 AufenthG with §19c(1) AufenthG and §3 No. 3 BeschV.
  • The pre-approval came about two weeks after the employer's declaration on the employment relationship reached the agency.
  • It is for this person and this job and valid nationwide; the agency states it is bound by it for nine months.
  • The Hamburg immigration office confirmed that the fast-track procedure (§81a) is open for the case too.

relokate's experience, October 2026. Every case is decided individually.

Three routes without German recognition

In legal terms, a skilled worker (Fachkraft, §18(3) AufenthG) has German vocational training or foreign training found equivalent to it, or a German, recognised or comparable foreign university degree. If vocational training from abroad hasn't been found equivalent, the skilled-worker permit under §18a is out, even if the person works as a skilled worker in practice. For a university degree, comparability (for example via anabin or a ZAB statement of comparability) is enough, so §18b or the EU Blue Card may still be open; relokate checks that first. In IT jobs, an EU Blue Card can also be possible without a degree, with at least three years' IT experience in the last seven (§18g(2) AufenthG). §19c AufenthG covers employment regardless of skilled-worker status, in three ways:

Specialist route

§19c(1) AufenthG with §3 No. 3 BeschV

Who it fits
Specialists with special, especially company-specific knowledge for a qualified job, e.g. in aviation and MRO.
What's needed
A concrete job offer for a qualified job and proof of the specialist knowledge: years in the role, references, certificates. No recognition, no ZAB confirmation.
Federal Employment Agency
Approval needed, at the agency's discretion. Pre-approval possible (§36(3) BeschV).
Salary rule
No fixed threshold. Pay and conditions at least as favourable as for comparable German staff (§39(3) AufenthG). Under the agency's guidance, pay can also indicate the specialist knowledge: it should match someone with several years' experience or significant responsibility.

Experience route

§19c(2) AufenthG with §6 BeschV

Who it fits
People with at least two years' experience in the last five that enables them for the job.
What's needed
A vocational qualification (at least two years' training) or a degree, state-recognised in the country where it was obtained and confirmed by a German expert body such as the ZAB, or a vocational qualification issued by a German Chamber of Commerce Abroad (AHK). IT jobs are exempt from the qualification requirement.
Federal Employment Agency
Approval needed.
Salary rule
At least €45,630 a year (2026), unless the employer is bound by a collective agreement and pays under it. For a first approval at 45 or older: at least €55,770 (2026) or adequate pension provision (§1(2) BeschV).

Public interest

§19c(3) AufenthG

Who it fits
Justified individual cases with a public, especially regional, economic or labour-market interest in the job.
What's needed
A well-founded case that shows the public interest; the authorities decide case by case.
Federal Employment Agency
Approval needed (§39(3) AufenthG).
Salary rule
No fixed threshold. Pay and conditions at least as favourable as for comparable German staff.

Also worth checking: the recognition partnership (§16d(3) AufenthG) for a qualification state-recognised in the country where it was obtained (at least two years' training, or a degree) and confirmed by a German expert body, with at least A2 German, a job offer for a qualified job and an agreement with the employer to start the recognition procedure no later than right after entry; recognition then runs alongside the job. The Western Balkans regulation (§26(2) BeschV): nationals of six countries, approval with a priority check, up to 50,000 approvals a year; a cut to 25,000 is planned but not in force. §26(1) BeschV: nationals of Andorra, Australia, Canada, Israel, Japan, the Republic of Korea, Monaco, New Zealand, San Marino, the United Kingdom and the United States, any job, approval with a priority check, no quota. And the skilled-worker permit (§18a AufenthG) once a qualification is recognised.

How relokate works with you in 3 steps

  1. Understand your needs

    A conversation with relokate to understand your needs and check whether the case works in general.

  2. Pre-approval with one talent

    relokate obtains the Federal Employment Agency's pre-approval with one talent for the role, before an employment contract is signed. The agency itself notes that a pre-approval does not generally speed up the procedure; relokate uses it to give you certainty before you commit to a contract.

  3. Contract, then visa

    Only then do you sign the contract, and relokate continues with the visa process: regular or accelerated (fast-track), depending on the country, the required timeline and the case.

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Social recruiting: fill your talent pool

Companies often run a social recruiting campaign for these roles and fill their talent pool this way. Because the route doesn't depend on German recognition, experienced specialists can apply even if their training would never be recognised here.

Before you invest in interviews, relokate checks candidates against the route. You only spend time on people with a realistic path to a permit.

What relokate checks for each candidate

  • Years in the exact role, and where
  • The specialist and company-specific knowledge your job needs
  • References and certificates that prove it
  • Pay and hours at least as for comparable German staff, at the level of an experienced specialist
  • Licences the role needs, e.g. EASA Part-66
The playbook contains screening questions for your campaign.

Which roles can fit?

Done in relokate's cases

  • Aircraft painter
  • Wheels-and-brakes mechanics
  • Aircraft technicians

Worth checking case by case

  • Industrial painters and coating specialists
  • Maintenance technicians for specific machinery
  • Specialised welders

These are examples, not a promise of approval. relokate checks case by case: the Federal Employment Agency decides on every job at its discretion, and there is no entitlement to approval.

What to know before you start

One person, one job

The pre-approval is for a named person and a specific job. Another candidate or a different job needs a new approval. In relokate's Hamburg case it applies nationwide, and the agency states it is bound by it for nine months. The visa has to be issued within that time; filing the application in time is not enough.

Pay and conditions are checked

The job must be a qualified one, needing skills usually gained in qualified vocational training (at least two years) or a degree (§2(12b) AufenthG); a helper job does not fit. Pay and conditions must be at least as favourable as for comparable German staff (§39(3) AufenthG). Under the agency's internal guidance, pay can also be an indicator of the specialist knowledge: it should match someone with several years' experience or significant responsibility.

The embassy still decides

The agency's approval, including a pre-approval, is internal to the authorities (Federal Administrative Court, 19 November 2019, 1 C 41.18). The embassy decides on the visa, so a pre-approval is not a visa guarantee.

Licences can be a condition

If the job needs a licence to practise (Berufsausübungserlaubnis), the residence permit can only be issued once it has been granted or promised (§18(2) No. 3 AufenthG), and the employer tells the agency whether one is needed (§39(4) AufenthG). In aviation, certifying staff who release aircraft after maintenance generally need an EASA Part-66 licence; in Germany the Luftfahrt-Bundesamt is responsible. Clarify this for each role, for example with or without certifying privileges, before the declaration goes in.

The long term

The residence permit is issued for up to four years (§18(4) AufenthG). After five years with a residence permit, a settlement permit is possible if the other conditions of §9 AufenthG are met, including 60 months of pension contributions and German at level B1.

Free playbook · PDF in English

The specialist route playbook

Hiring skilled workers without German recognition: the detail this page leaves out.

What's inside

  • Decision tree: §19c(1), §19c(2), §19c(3), §16d(3), §26 BeschV, §18a or the EU Blue Card for IT
  • What the Federal Employment Agency looks at in the employer declaration, with do's and don'ts
  • Document checklist for employer and candidate
  • relokate's 3-step process in detail
  • Social recruiting: running a campaign so candidates fit the route, with screening questions
  • A short FAQ
Free PDF playbook

The specialist route playbook: hiring skilled workers without German recognition

For HR teams and hiring managers. PDF, as of October 2026.

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Questions about the §19c visa

What is the 19c visa in Germany?

"19c visa" is the common name for a residence permit under §19c AufenthG: employment regardless of a qualification as a skilled worker. Paragraph 1 (§19c Abs. 1 in German citations) covers jobs the Employment Ordinance (BeschV) allows, such as specialists with company-specific knowledge (§3 No. 3 BeschV); paragraph 2 covers people with pronounced professional experience (§6 BeschV); paragraph 3 covers justified individual cases with a public interest. The visa is applied for at the German embassy, and in Germany the immigration office issues the residence permit.

What is the difference between §19c(1) and §19c(2)?

§19c(2) AufenthG with §6 BeschV is the experience route: at least two years' experience in the last five, a vocational qualification or degree state-recognised in the country where it was obtained and confirmed by a German expert body such as the ZAB (or a qualification from a German Chamber of Commerce Abroad), and a salary of at least €45,630 (2026) unless the employer is bound by a collective agreement and pays under it (for a first approval at 45 or older, at least €55,770 or adequate pension provision). §19c(1) AufenthG with §3 No. 3 BeschV is the specialist route: special, especially company-specific knowledge for a qualified job, with no ZAB confirmation and no fixed salary threshold. Both need the Federal Employment Agency's approval.

The experience route (§19c(2)) in detail →

Is there a salary threshold?

Not for §19c(1) AufenthG with §3 No. 3 BeschV. The Federal Employment Agency checks that pay and working conditions are at least as favourable as for comparable German staff (§39(3) AufenthG). There is no minimum figure, but under the agency's internal guidance (Fachliche Weisungen, 19c.3.4) pay can be an indicator of the specialist knowledge: it should match a person with several years' experience or significant responsibility, and pay clearly above a regular skilled worker's points to special knowledge. The agency judges each case individually. The experience route (§19c(2) AufenthG with §6 BeschV) has a threshold of 45% of the pension contribution ceiling, €45,630 in 2026, unless the employer is bound by a collective agreement and pays under it; for a first approval where the person starts work at 45 or older, §1(2) BeschV requires at least €55,770 (2026) unless they prove adequate pension provision.

Does the candidate need their qualification recognised?

No. §19c(1) AufenthG applies regardless of a qualification as a skilled worker. The job itself must be a qualified one, and the candidate must have the specialist knowledge it needs, usually shown through years in the role, references and certificates. Licences for regulated activities, such as EASA Part-66 for certifying aircraft maintenance staff, have their own procedure; where the job requires one, it must be granted or promised before the permit is issued (§18(2) No. 3 AufenthG).

Can we get the pre-approval before signing the employment contract?

Yes, that is possible. Under §36(3) BeschV the Federal Employment Agency should, before the embassy or immigration office sends its request for approval, either approve or check whether the labour-market conditions for a later approval are met, if the employer has provided the information it needs and this speeds up the procedure. The information usually comes in the declaration on the employment relationship (Erklärung zum Beschäftigungsverhältnis) for a concrete job offer. Whether it approves remains the agency's decision. That is how relokate works: pre-approval first, then the contract, then the visa. In relokate's Hamburg case the pre-approval came about two weeks after the employer's declaration reached the agency.

Does the fast-track procedure (§81a) work for §19c?

§81a AufenthG names the skilled-worker routes and extends the procedure to other qualified employees (§81a(5)). The Federal Employment Agency's guidance counts §19c(2), §19c(3) and §19c(1) with §3 BeschV among them. The immigration office runs the procedure and decides: in relokate's Hamburg case it confirmed that the fast-track procedure is open. Elsewhere relokate checks with the responsible office before the start.

How the fast-track procedure works →

Does the candidate need to speak German?

§19c(1) AufenthG and §3 No. 3 BeschV set no German language requirement. Whether the job needs German is up to you as the employer. German matters later: a settlement permit generally requires German at level B1 (§9(2) AufenthG).

How long does it take?

There is no legal total duration. The law sets deadlines for single steps. When the embassy or immigration office asks the Federal Employment Agency for approval, the approval counts as given unless the agency reports within two weeks that it needs more information; in the fast-track procedure this period is one week (§36(2) BeschV). With a pre-approval already in hand, the agency usually does not need to be asked again. Only in the fast-track procedure: once the immigration office has given its advance approval of the visa (§81a(3) No. 6 AufenthG) and the candidate has asked for an appointment, the embassy offers one within three weeks and usually decides within three weeks of a complete application (§31a AufenthV). How long the immigration office reviews before that depends on the city. A pre-approval the employer asks for directly (§36(3) BeschV) has no fixed deadline; in relokate's Hamburg case it came about two weeks after the employer's declaration.

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