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Reform of Medical Education 2026 - State of the Licensing Regulations and the Cost Dispute

Reform of Medical Education 2026 - State of the Licensing Regulations and the Cost Dispute

28.08.2026

15 min read Lesezeit

On 18 February 2026 the Medical Faculty Association (MFT) and the Association of the Scientific Medical Societies (AWMF) published joint recommendations on the further development of medical education in Germany. The title says it all: "Develop rather than wait". MFT President Prof. Dr Martina Kadmon is quoted in it saying that Germany cannot afford to "wait further years for political decisions". That describes the state of the reform in a single sentence.

The revision of the Licensing Regulations for Doctors (Approbationsordnung) has been in preparation since the Medical Studies Master Plan 2020, agreed between the federal government and the states in 2017. Several ministerial drafts have been produced since, the planned entry into force has been pushed back from October 2025 to October 2027, and the decisive open question to this day is not teaching methodology but funding.

Here is what applies in law, what the revision provides for in substance, how the cost dispute between the federal government and the states is unfolding, and how other European systems have solved the same task. All details are sourced and reflect the position as at 14 August 2026.

What actually applies in August 2026

The legal basis of medical education in Germany remains the Licensing Regulations for Doctors of 2002. On its topic page on these regulations, the Medical Faculty Association expressly states that the current version dates from 2002 and was last amended in 2023. A revised set of licensing regulations has still not come into force.

This clarification is necessary because the content of the reform has been described publicly in detail for around six years. Anyone reading only those descriptions can easily gain the impression that they are already law. They are not: this is draft stage. For students starting in the 2026/2027 winter semester, the existing structure therefore continues to apply, with the three sections of the state medical examination and the final practical year in its current form.

New licensing regulations take the form of a statutory instrument of the Federal Ministry of Health. It has to be agreed within the federal government and then requires the consent of the Bundesrat. It is at this second hurdle that the process is stuck, as the MFT describes on its topic page.

From the 2020 Master Plan to a postponed entry into force

The political starting point is the Medical Studies Master Plan 2020, agreed between the federal government and the states in 2017. It set out the aim of making the degree more practice-oriented, more competence-based and more strongly geared to outpatient care. Implementation was to happen through new licensing regulations.

DateStep
2017Federal government and states agree the Medical Studies Master Plan 2020 (MFT)
November 2020First ministerial draft from the Federal Ministry of Health (Deutsches Ärzteblatt)
August 2021Refined ministerial draft (Deutsches Ärzteblatt)
May 2023Revised draft as an interim position; planned entry into force now 1 October 2027 instead of 1 October 2025 (Deutsches Ärzteblatt, BDC)
Autumn 2023Position of the states: no room for manoeuvre without the federal government covering the costs (Rheinisches Ärzteblatt)
February 2024The states' science ministries write to the Federal Health Minister asking for a financial contribution from the federal government (Bavarian State Medical Chamber)
September 2024By its own account, the MFT no longer expects new licensing regulations "any time soon"
18 February 2026MFT and AWMF publish recommendations for further development without the revision
August 2026The 2002 licensing regulations, in the 2023 version, continue to apply

What is notable about this chronology is that the direction of travel has been largely uncontested from the start. In January 2024 the Rheinisches Ärzteblatt summed up the position by saying that everyone involved agrees on the need for change – more practice, more general practice and outpatient care, digital teaching formats, alignment with actual clinical competencies. What remained open was the question of who pays.

What the revision provides for in substance

The Federal Ministry of Health's draft describes a reform that shifts fewer individual subjects than it changes the architecture of the degree. The most important elements:

  • The national learning objectives catalogue as a binding basis. The National Competence-Based Learning Objectives Catalogue for Medicine (NKLM) is to be anchored in the licensing regulations and thereby become a binding basis for teaching and examinations.
  • An end to the strict separation of preclinical and clinical study. Under the draft, theoretical and clinical content is to be taught in connection with one another from the first semester onwards.
  • Longitudinal rather than block-based thinking. Content such as scientific working or communication skills is to be built up across the whole degree instead of in isolated courses.
  • General practice substantially strengthened. The draft provides for compulsory block placements in primary care amounting to six weeks, as well as a stronger presence of general practice in the final practical year.
  • Fewer lectures, more blended learning. To limit the burden, the revised draft provides for a reduction in lectures of around 30 percent in favour of digital formats (Deutsches Ärzteblatt).
  • Public health services. Strengthening public health within the degree is also among the draft's aims.

The planned restructuring of the state examinations

The reform would be most visible in the examinations. The draft still provides for three examination sections but redistributes the formats: the first section consists of a written and an oral-practical part, the second section is written, and the third section combines an examination with a patient and a circuit examination.

The circuit examination is the real change of system. Instead of testing knowledge alone, practical and communication competencies are examined in a structured way at several stations – internationally established as the OSCE. This is precisely the format that MFT and AWMF recommended in February 2026 independently of the revision, because it can be fitted into the existing legal framework.

The draft also provides that general practice will not only receive more teaching time but will have a fixed role as a subject in its own right in the final examination. That is the point at which primary care would for the first time gain the same visibility in examination law as internal medicine and surgery.

The compulsory outpatient quarter in the final practical year

Under the draft, the final practical year would consist of four training sections of twelve weeks each: internal medicine, surgery, a section in primary care or a specialty, and one further specialty. The third quarter is to be completed in teaching practices or in outpatient care facilities under Social Code Book V. That would anchor a compulsory outpatient quarter for the first time.

This is also where a large part of the costs sits: outpatient teaching practices have to be recruited, qualified, coordinated and paid. In its February 2026 recommendations the MFT therefore identified better access to outpatient teaching and learning opportunities as a field of action in its own right. How the practical year works organisationally and financially is covered in detail in our linked article on it; here it is placed in the context of the revision as a whole.

The cost dispute between the federal government and the states

The figures are the heart of the matter. The original draft was estimated to cost the states around 300 million euros a year in additional expenditure. After the 2023 revision the Federal Ministry of Health put the annual additional costs at 177 million euros and the one-off additional costs at 94 million euros; the latter had previously been estimated at 88 million euros (Deutsches Ärzteblatt, BDC).

In January 2024 the Rheinisches Ärzteblatt reported that the Medical Faculty Association continues to see the actual cost at over 300 million euros a year, while the federal government assumes 177 million euros. The states, for their part, have made clear that there is currently no room for a reform with significant financial consequences without the federal government covering the costs. In early February 2024 the states' science ministries wrote to the Federal Health Minister asking for a federal financial contribution to the implementation costs (Bavarian State Medical Chamber).

Behind this lies an understandable question of competence: the licensing regulations are federal law, while universities and their funding are a matter for the states. The federal government can set the requirements; the bill falls to the states. MFT Secretary General Dr Frank Wissing pointed out as early as 2023 that, even after the proposed reductions, the burden on everyone involved remains very high.

Why the faculties are no longer waiting

The MFT and AWMF recommendations of 18 February 2026 are the logical consequence of this situation. They name six priority fields of action that the faculties can implement themselves within the existing legal framework:

  • a longitudinal curriculum for scientific thinking with a formal assessment,
  • better access to outpatient teaching and learning opportunities,
  • examination of practical competencies, for instance through circuit examinations,
  • improved conditions in the final practical year,
  • further development of the state examinations with digital support,
  • integration of new topics such as disaster medicine and digitalisation into the learning objectives catalogue.

AWMF President Prof. Dr Rolf-Detlef Treede justifies the emphasis on scientific rigour by saying that scientific thinking and practice must be "more explicitly than before a subject of the degree". The practical effect: students at individual faculties already benefit from reform content even though the revision is not in force. The price is inconsistency – binding licensing regulations would have greater binding force, as MFT and AWMF themselves stress.

Model degree programmes show that this route works. The Rheinisches Ärzteblatt pointed out that RWTH Aachen, for example, has been continuously developing its curriculum since 2003 under the model clause and is therefore less dependent on the revision.

An international comparison with the Netherlands, the United Kingdom and Switzerland

All three countries have already answered questions that the German revision is still negotiating: how binding is a catalogue of learning objectives? How do you examine practical competence centrally? And how do you structure the degree towards practice?

CountryStructure of the degreeBinding frameworkFinal examination
GermanyContinuous state-examination degree with the practical year at the end; separation of preclinical and clinical study under the 2002 licensing regulationsThe national learning objectives catalogue so far has no binding anchoring in the licensing regulationsThree sections of the state medical examination under the 2002 regulations in the 2023 version
NetherlandsBachelor in medicine three years, followed by a three-year master's; clinical placements (coschappen) shape the master's phase (Utrecht University, Leiden University)Raamplan Artsopleiding as the faculties' national frameworkNo central state examination; with the master's diploma you are a basisarts (Utrecht University)
United KingdomUndergraduate medical degree at the medical schools with clinical attachmentsGMC "Outcomes for Graduates", supplemented by "Practical skills and procedures"; these replaced "Tomorrow's Doctors"Medical Licensing Assessment (MLA) consisting of an Applied Knowledge Test and a Clinical and Professional Skills Assessment; all UK students must pass it before registration (GMC)
SwitzerlandTiered structure of bachelor's and master's degrees in human medicine at the university facultiesPROFILES 2023 from SMIFK/CIMS with CanMEDS roles, Entrustable Professional Activities and Situations as Starting PointsSwiss federal examination; PROFILES operationalises the aims of the Medical Professions Act and determines the content of the examination (SMIFK/CIMS)

Three observations are relevant to the German debate. First: in Switzerland the competence catalogue is not merely a recommendation but directly determines the content of the federal examination – exactly the role the German catalogue would only acquire through the revision. Second: with the MLA, the United Kingdom has created a central examination that expressly combines a knowledge part with a clinical and practical part; according to the GMC, the PLAB test for internationally trained doctors was aligned with the MLA requirements in 2024. Third: the Netherlands achieves practical relevance through structure – the three-year master's phase consists largely of coschappen, and at Utrecht University the first coschap begins, according to the university, as early as the third bachelor year.

This does not diminish the German discussion; it puts it in order. The revision would not take Germany into new territory but to a standard that comparable systems have already reached.

What this means in practice for prospective students

For everyone starting a medical degree in 2026 or 2027, four sober conclusions follow. First, the existing licensing regulations apply, and planning should build on them. Second, thanks to the model clause and the MFT and AWMF recommendations, individual faculties can already teach in a far more practice-oriented way – looking at a faculty's actual curriculum is worth more than looking at the draft text. Third, entry into force on 1 October 2027 is not assured given the current state of the process. And fourth, the revision does not change access to the degree: it governs training and examinations, not the allocation of study places.

Anyone also considering a degree elsewhere in Europe will in some places find exactly the elements the German revision is aiming at – early patient contact, longitudinal clinical placements and structured practical examinations. Which option suits your own circumstances is best discussed case by case: you can book a free consultation with us at any time.

This article reflects the state of research as at 14 August 2026 and does not constitute legal advice. What is authoritative is solely the version of the licensing regulations in force at the time and the rules of the responsible state examination offices.

The author's view

I have followed this process for years with a certain sympathy for everyone involved. In substance the revision is a good draft. Longitudinal curricula, a binding catalogue of learning objectives, circuit examinations and a compulsory outpatient quarter are exactly the things that turn students into capable doctors sooner. That it hangs on funding rather than on teaching methodology is no reproach to any side – it is the honest consequence of a federal structure in which the central government sets the requirements and the states pay for the universities. Both sides argue coherently from their own areas of responsibility.

What interests me most in this debate is something else. I studied abroad myself, in Sofia, and am now a Swiss-licensed dentist; I run Medschool Experts from Bern. Both systems showed me how strongly the learning effect depends on working early and regularly with real patients – and how little it depends on which country the lecture theatre stands in. With PROFILES, Switzerland demonstrates how a competence catalogue can be more than paper and actually steer the final examination. It is exactly this binding force that is being fought over in Germany.

For prospective students I draw a very practical recommendation from this: do not wait for the licensing regulations. Over the past years, in near-daily videos and interviews with students abroad, I have seen that the people who started in 2018 or 2020 have long since been working as fully licensed doctors – while the draft is still in the process. A study place you have beats any reform you are waiting for. Anyone studying in Bulgaria, Hungary, Poland or Croatia will often find early practical phases and small groups there, and can then return to Germany through European recognition.

And one more point that matters to me: in February 2026 the faculties showed that they are not standing still. That MFT and AWMF are saying, we will do this now within the existing framework, strikes me as professional and quietly courageous. For prospective students, though, it means that the differences between locations will grow over the coming years rather than shrink. Looking at the specific curriculum of a location is therefore more valuable today than any general statement about "the German medical degree".

Summary

  • In August 2026 the Licensing Regulations for Doctors of 2002, in the 2023 version, still apply; the planned revision is not in force.
  • Entry into force of the revision has been pushed back from October 2025 to October 2027 and, given the state of the process in August 2026, is not assured.
  • The dispute is about funding: the federal government calculates 177 million euros a year and 94 million euros as a one-off cost, while the Medical Faculty Association calculates over 300 million euros a year.
  • The ministerial draft provides for the national learning objectives catalogue as a binding basis, more general practice, circuit examinations and a compulsory outpatient quarter in the final practical year.
  • On 18 February 2026 the MFT and AWMF recommended six fields of action that the faculties can implement within the existing legal framework without new licensing regulations.

The position in August 2026 can be summed up clearly: the Licensing Regulations for Doctors of 2002, in the 2023 version, apply. The ministerial draft for the revision has existed since November 2020 and was revised in 2021 and 2023; the planned entry into force was moved from October 2025 to October 2027. The decisive point of conflict is funding: 177 million euros a year on the federal government's calculation, over 300 million euros on the Medical Faculty Association's assessment, plus a one-off 94 million euros. Without the costs being covered, the states see no room for manoeuvre.

In substance the revision would be a sensible step: the learning objectives catalogue as a binding basis, an end to the strict separation of preclinical and clinical study, general practice as a subject in its own right in the examinations, circuit examinations and a compulsory outpatient quarter in the practical year. That MFT and AWMF began in February 2026 to implement these aims within the existing legal framework is the most pragmatic news of the year. Anyone planning a medical degree today should plan on the basis of the law as it stands and examine the specific location – and is welcome to book a free consultation on that.

Further reading

Frequently asked questions about the reform of medical education

Are the new Licensing Regulations for Doctors already in force?

No. According to the Medical Faculty Association, the Licensing Regulations for Doctors of 2002, last amended in 2023, continue to apply. The revision is at draft stage.

When is the revision due to come into force?

The revised 2023 draft named 1 October 2027; originally 1 October 2025 was envisaged. Given the current state of the process, that date is not assured.

Why is the reform delayed?

The federal government and the states do not agree on funding. The licensing regulations are federal law, while university funding is a matter for the states. Without the federal government covering the costs, the states see no room for manoeuvre, according to the Rheinisches Ärzteblatt.

What sums are involved?

After the revision, the federal government put the states' annual additional costs at 177 million euros and the one-off costs at 94 million euros. The original draft was estimated at around 300 million euros a year; the Medical Faculty Association continues to see the burden at that order of magnitude.

What exactly would change for students?

Under the draft, clinical and theoretical content would be linked from the first semester, the national learning objectives catalogue would become a binding basis, general practice would gain considerably more weight, practical competencies would be examined in a circuit examination, and one quarter of the final practical year would have to be completed in outpatient care.

What is the NKLM?

The National Competence-Based Learning Objectives Catalogue for Medicine describes which competencies graduates should attain. So far it is not bindingly anchored in the licensing regulations; the revision would change precisely that.

What is a circuit examination?

A structured practical examination in which candidates work through defined tasks at several stations one after another. Internationally this format is established as the OSCE; MFT and AWMF recommended it in February 2026 independently of the revision.

What do the MFT and AWMF recommendations of February 2026 mean?

Both organisations named six fields of action that the faculties can implement without new licensing regulations – among them a longitudinal science curriculum, better access to outpatient teaching, practical examination formats and better conditions in the final practical year.

How do other countries handle the binding force of learning objectives?

In Switzerland the PROFILES 2023 competence catalogue determines the content of the federal examination. In the United Kingdom the GMC's "Outcomes for Graduates" sets the framework, with examination through the Medical Licensing Assessment consisting of a knowledge test and a clinical and practical assessment.

How is the medical degree structured in the Netherlands?

According to Utrecht University and Leiden University it is divided into a three-year bachelor's in medicine and a three-year master's, the focus of which is on clinical placements (coschappen). With the master's diploma you are a basisarts.

Does the reform change anything about the allocation of study places?

No. The licensing regulations govern training and examinations. The allocation of study places continues to follow the existing procedures and quotas.

Should you wait for the revision before starting the degree?

There is no factual reason to. Since entry into force is open and individual faculties are already implementing reform content within the existing framework, looking at the actual curriculum of a given location tells you more than waiting for the regulatory text.

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About the author

Marcel Kloos

Swiss-licensed dentist and founder of Medschool Experts

Marcel Kloos founded Medschool Experts while studying abroad; since then, over 500 study places have been secured. The Stuttgart-born dentist studied dentistry from 2015 to 2021 in Sofia and holds a Swiss dental licence.

Today he lives in Bern and runs Medschool Experts full-time as its owner.

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