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Recognition of Foreign Qualifications in Healthcare 2026 – EU Route and Third-Country Route

Recognition of Foreign Qualifications in Healthcare 2026 – EU Route and Third-Country Route

17.09.2026

19 min read Lesezeit

On 28 July 2026 it appeared in the Federal Law Gazette. The Act to Accelerate the Recognition of Foreign Professional Qualifications in Healthcare comes into force on 1 November 2026. The Bundestag passed it on 26 March 2026 on the basis of parliamentary paper 21/3207, and the Bundesrat dealt with it in its second reading on 8 May 2026. Four academic healthcare professions are covered: doctors, dentists, pharmacists and midwives.

The most important figure first. The Federal Ministry of Health expects savings of just under 16 million euros a year, of which around 12 million euros and some 7,000 working hours fall to applicants themselves, because numerous translations and certifications are no longer required. That said, this concerns only some of the people reading this article. The new rules are aimed at qualifications from countries outside the EU.

German law recognises two separate routes, and Directive 2005/36/EC of 7 September 2005 keeps them strictly apart. A qualification from an EU member state is recognised automatically under Article 21, without an equivalency assessment and without a competency examination. The entire debate about competency examinations, temporary practice permits and expert opinions concerns the other route. The two can be cleanly separated – compared here across Germany, Switzerland, Austria and the United Kingdom, with first-hand experience at the points where I know the procedure myself.

Last reviewed: August 2026

Is a medical degree from the EU recognised automatically in Germany?

Yes. Under Article 21 of Directive 2005/36/EC of 7 September 2005, Germany automatically recognises the evidence of formal qualifications from EU and EEA states listed in Annex V. There is no equivalency assessment of course content in 2026, and no competency examination either. The German medical licence (Approbation) itself must nevertheless be applied for at the responsible state examination office.

FeatureQualification from the EU/EEAQualification from a non-EU country
Legal basisArticle 21 and Annex V of Directive 2005/36/ECnational professional law, equivalency procedure
Equivalency assessmentnoyes, from 1 November 2026 only on request
Competency examinationnoyes, the standard route from 1 November 2026
Temporary practice permit as an interim stepnot provided forcustomary and time-limited, in future open-ended in exceptional cases
Decision deadlinethree months after complete documents, Article 51no deadline under EU law, state law applies
Proof of languagegenerally B2, specialist language examination usually C1same requirement, examination can in future be brought forward

Anyone completing their degree in Bulgaria, Hungary, Poland, Croatia, Romania, the Czech Republic or Slovakia never enters the procedure that the legislature is currently rebuilding. This is not a question of interpretation. It follows from EU law.

Which healthcare professions are recognised automatically in the EU and which are not?

Directive 2005/36/EC harmonises the minimum training of several health professions and lists them in Annex V. Doctors appear there under number 5.1.1, dentists under 5.3.2, veterinary surgeons under 5.4.2 and pharmacists under 5.6.2. Psychology and psychotherapy are not on this list in 2026.

ProfessionReference in Annex VRoute into Germany, position in 2026
Doctor, basic training5.1.1automatic recognition, then the medical licence from the state examination office
Dentist5.3.2automatic recognition, then the licence from the state examination office
Veterinary surgeon5.4.2automatic recognition, then the licence from the state examination office
Pharmacist5.6.2automatic recognition, in Germany additionally a specialist language examination
Psychological psychotherapynot listedno automatic route, licence under the reformed Psychotherapists Act

I compiled this overview from the text of the directive itself, because the numbers almost never appear in the usual guidance literature. They are precisely the key. If evidence of formal qualifications is listed in Annex V, recognition is an obligation of the host state. If it is not listed there, an entirely different procedure begins.

Anyone studying psychology elsewhere in Europe therefore plans differently from someone studying human medicine or dentistry.

What does the law change from 1 November 2026 for non-EU qualifications?

From 1 November 2026 the Act to Accelerate the Recognition of Foreign Professional Qualifications in Healthcare reverses the order. The competency examination becomes the standard route for qualifications from countries outside the EU. The document-based equivalency assessment remains, but as an option that, under the government draft, applicants can expressly choose within four weeks.

Until now the file comparison came first. The authority compared curricula, teaching hours and examination content with German training, and only where substantial differences emerged did the competency examination follow as a compensating measure. In its questions and answers on the law, the Federal Ministry of Health describes precisely this preliminary review as the most laborious hurdle of the old procedure. In future the competency examination is a professional admission examination with a uniform standard and relates to the content of the state final examination.

The law's path can be told in dates: cabinet decision on 1 October 2025, first reading in the Bundesrat on 21 November 2025, first reading in the Bundestag on 18 December 2025, hearing in the health committee on 28 January 2026, adoption by the Bundestag on 26 March 2026, second reading in the Bundesrat on 8 May 2026, promulgation on 28 July 2026. What is amended above all is the Federal Medical Practitioners Act and the parallel professional legislation for the three other healthcare professions; the ministerial draft names among other things the new Sections 9b to 9e and 10b.

On the compliance burden, the same draft names case numbers that are rarely quoted: around 3,900 applications a year from doctors with expected savings of about two million euros, around 500 applications in dentistry with about 250,000 euros, around 300 applications from pharmacists with about 150,000 euros and around 330 applications from midwives with about 100,000 euros. After the law was passed, Federal Health Minister Nina Warken justified the project by saying that recognition procedures must "no longer be the bottleneck in the rapid integration of qualified professionals". Implementation remains a matter for the federal states.

Language, deadlines, digitalisation

  • The states can in future require proof of German language skills before the professional qualification is assessed. This applies exclusively to non-EU qualifications. The Federal Dental Chamber called for precisely this at the hearing, because an oral and practical examination presupposes conversational ability in any case.
  • Documents and notifications may be transmitted electronically, including alert notifications between authorities.
  • The permit for temporary professional practice can be granted on an open-ended basis in narrowly defined exceptional cases, for instance where there are significant health limitations or for people who were first granted a permit before 1 April 2012.

Partial access to a profession is expressly regulated. It follows the EU Professional Qualifications Directive and, according to the Federal Ministry of Health, applies only to qualifications from the EU and the EEA in medicine, dentistry and pharmacy, not to qualifications from other countries.

How long does a recognition procedure really take?

For Germany the Federal Ministry of Health gives an average duration of 97 days in 2022 against 129 days in 2017, in each case measured from the point at which the application is complete. Article 51 of Directive 2005/36/EC sets the legal framework: acknowledgement of receipt within one month, a decision no later than three months after complete documents are submitted.

I had my own foreign diploma recognised, most recently for Switzerland through the Medical Professions Commission MEBEKO. What has stayed with me from that is less the duration than the waiting itself. Between the day the documents go out and the decision, nothing happens as far as you can see from outside. You count in months. And you cannot shorten that time by trying harder: an unfamiliar experience for people who have spent five years able to influence every examination through their own work.

Honesty requires naming the limits of this statistic too. The 97 days are an average and only start once the application is complete. The weeks beforehand, in which certificates are obtained, translated and certified, appear in no measure at all. In my assessment this run-up is the longer part of the procedure for most applicants, even though it is nowhere measured. Anyone planning should factor it in.

What do the authorities actually want to see in a recognition case?

In 2026 the state examination offices assess four things: the professional qualification, personal reliability, health fitness and language skills, at B2 level in general language and as a rule at C1 level in specialist language. For EU qualifications, the EU certificate of conformity issued by the state of training proves that the evidence of qualifications is listed in Annex V of Directive 2005/36/EC.

From my own procedure I take away an unspectacular insight. Authorities do not assess motivation, they assess paperwork. A complete, properly certified bundle with the same spelling of your name throughout achieves more than any covering letter. Every gap costs a round of post, and every round of post costs weeks.

The legal basis of the certificate of conformity is in Annex VII number 2 of the directive. For German qualifications in medicine, dentistry and pharmacy it is issued by the Federal Institute for Drugs and Medical Devices, and for qualifications from other member states by the relevant authority there. A special rule applies to states that joined later, Bulgaria and Romania since 2007 and Croatia since 2013: for training begun before the respective cut-off date, provisions on acquired rights apply. For those starting a degree today this no longer plays any role.

On the non-EU side, the Assessment Office for Health Professions checks the authenticity of foreign certificates by contacting the issuing bodies in the country of origin and comparing register entries. According to the Federal Government there were around 3,350 authenticity checks in 2024, in which five forged certificates were identified. The Marburger Bund has suggested expanding this office and giving it central responsibility for the equivalency assessment.

Why do the figures on foreign doctors contradict each other?

As at 31 December 2025 the German Medical Association counted 71,480 foreign doctors in Germany, that is 16 percent of everyone in active practice. The Federal Statistical Office arrives at 13 percent without German citizenship for 2024. Both figures are correct. They come from different sources, namely the registration data of the state medical chambers and official statistics.

The largest groups in the 2025 workforce statistics came from Syria with 7,959, Romania with 4,617, Turkey with 3,532, Russia with 3,138, Austria with 3,076 and Greece with 2,963 people; around 35 percent came from EU states. For 2024 the Federal Statistical Office also counted around 79,100 positive recognition decisions across all professions, 11,000 of them in the medical professions, and around 7,000 medical qualifications recognised as fully equivalent. 87 percent of all successful applicants had obtained their qualification outside the European Economic Area.

My assessment, clearly marked as such: citizenship is the wrong measure for this question. What matters is where someone trained. A German citizen with a diploma from Sofia counts as "German" in both statistics but follows exactly the same route as any other graduate of an EU university. Anyone looking for figures on students abroad should therefore always check what exactly has been counted.

How do Switzerland, Austria and the United Kingdom handle recognition?

In 2026 Switzerland, Austria and the United Kingdom likewise distinguish between European and non-European qualifications. Switzerland has adopted automatic recognition through the Agreement on the Free Movement of Persons and the EFTA Convention, Austria applies the directive directly, and the United Kingdom lost this automatic route with Brexit.

CountryResponsible bodyQualification from the EU/EEA or EU/EFTAQualification from a non-EU country
GermanyState examination offices, supported technically by the Assessment Office for Health Professionsautomatic recognition under Article 21 of Directive 2005/36/ECequivalency procedure, from 1 November 2026 competency examination as the standard route
SwitzerlandMedical Professions Commission MEBEKO, plus the relevant cantondirect recognition only with Swiss or EU/EFTA citizenship, followed by a cantonal licence to practiseno direct recognition; MEBEKO sets the conditions for a Swiss federal diploma
AustriaAustrian Medical Chamber, nostrification at the medical universitiesrecognition under the directive, plus entry in the medical registernostrification with a curriculum comparison and supplementary examinations
United KingdomGeneral Medical Councilno automatic recognition since Brexitregistration via PLAB or a recognised specialist qualification

Behind the table are figures that make the difference tangible. The FMH medical statistics report for 2024 that 41.3 percent of the 42,602 doctors in active practice in Switzerland obtained their diploma abroad, close to half of them in Germany; the OECD average is 19 percent. The Federal Office of Public Health gives fees of 800 to 1,200 francs for recognition and processing times of currently up to six months. The University of Vienna gives a fee of 150 euros for nostrification and a decision generally within three months.

The United Kingdom is the most instructive case, because there is a before and an after. The General Medical Council's 2025 workforce report counts 20,060 doctors with a non-UK qualification who took up a licence in 2024, against 10,384 with a UK qualification. Moving on into employment, however, is taking longer: only 13 percent of the international graduates who joined via PLAB in 2024 were connected to a designated body within six months, against 26 percent in both 2021 and 2022. The loss of automatic recognition has therefore not slowed immigration but slowed entry into practice.

What is still open in mid-August 2026?

The design of the competency examination is still open. The Act to Accelerate Recognition Procedures sets only the framework; scope, duration and content are governed by the respective licensing regulations. No corresponding regulatory text for human medicine was publicly available by mid-August 2026. Until then the Licensing Regulations for Doctors of 27 June 2002, in the version of 7 June 2023, continue to apply.

  • The German Medical Association considers a nationally comparable examination at a high standard to be sensible, as long as the document-based equivalency assessment remains as an alternative. Without the details in the licensing regulations, it says, "a conclusive assessment of the effects on quality and patient safety is not possible". President Klaus Reinhardt stresses that substantial improvement will only succeed if the whole process is taken into view.
  • The Medical Faculty Association suggests an additional written part modelled on the second section of the state medical examination and points to the difficulty of recruiting enough examiners.
  • The Federal Dental Chamber supports the competency examination as the standard route and calls for proof of language beforehand.
  • The Marburger Bund argues for a central recognition body.

What convinces me about this debate is that it is being conducted honestly. A uniform examination is more predictable for candidates than a file comparison whose outcome can differ from one federal state to the next. Whether it becomes faster in practice hangs on a question the law does not answer: whether enough examiners are available. I would keep an eye on that point.

Anyone already studying abroad or planning a degree should factor in the difference between the two routes from the outset. Which situation applies in an individual case is something we are happy to clarify personally. You can book a free consultation on this at any time.

This article reflects the position as at August 2026 and serves general information purposes. It does not replace legal advice in an individual case; binding information is provided by the competent authorities.

The author's view

I studied dentistry in Sofia from 2015 to 2021 and am now a Swiss-licensed dentist; I run Medschool Experts from Bern. Both stages hang on precisely the mechanism at issue here. A Bulgarian qualification is listed in Annex V of Directive 2005/36/EC. My recognition was therefore not an evaluation of my curriculum but the confirmation of a right that already existed. MEBEKO decided on the same logic for Switzerland.

I read the July 2026 law with approval and with one caveat. Approval, because a professional admission examination with a uniform standard is more honest for colleagues from outside the EU than a file comparison whose outcome can diverge between authorities. That the document-based assessment remains available as an option strikes me as sensible.

The caveat concerns a misunderstanding I meet constantly. Parents and prospective students read "competency examination becomes the standard" and conclude that in future everyone with a degree from abroad will have to sit an examination in Germany. That is not the case. The reform concerns only qualifications from outside the EU and the EEA.

What I took from my own procedure is more sober than such texts usually sound. Recognition is administrative work. It takes time, it cannot be sped up by diligence, and it demands patience at a stage when you actually want to start working. Moving from the degree into practice was a bigger leap for me than any examination before it: in the treatment chair in Bern sits a person in pain, and nobody asks which language you learned anatomy in.

The figures speak for themselves. In Switzerland 41.3 percent of doctors in active practice hold a foreign diploma; in Germany foreign doctors make up 16 percent of those in active practice. A diploma obtained elsewhere in Europe is not an exception in these health systems but a load-bearing part of care. When we started Medschool Experts, that still needed explaining; we were the first agency to show on YouTube, in near-daily videos and interviews with medical students abroad, what this route really looks like, free of charge.

Anyone facing the decision today should therefore do one thing above all: understand the difference between the EU route and the non-EU route before choosing a place of study. That single distinction saves more time later than any shortcut within the procedure.

Summary

  • The Act to Accelerate the Recognition of Foreign Professional Qualifications in Healthcare comes into force on 1 November 2026 and covers doctors, dentists, pharmacists and midwives.
  • For qualifications from countries outside the EU, the competency examination becomes the standard route from 1 November 2026; the document-based equivalency assessment remains available as an option.
  • Qualifications from the EU and the EEA continue to be recognised automatically under Article 21 of Directive 2005/36/EC, that is, without an equivalency assessment and without a competency examination.
  • The sectoral professions in Annex V are recognised automatically: doctor 5.1.1, dentist 5.3.2, veterinary surgeon 5.4.2, pharmacist 5.6.2. Psychological psychotherapy is not among them and runs in Germany through the reformed Psychotherapists Act.
  • The Federal Ministry of Health expects annual savings of just under 16 million euros and gives a procedure duration of 97 days in 2022 against 129 days in 2017.
  • According to the German Medical Association's workforce statistics, 71,480 foreign doctors were registered in Germany as at 31 December 2025, that is 16 percent of everyone in active practice.

The reform reorders the non-EU route: competency examination as the standard, file assessment as an option, proof of language that can be brought forward, more digital procedures. The EU route is untouched by it. It rests on Article 21 and Annex V of Directive 2005/36/EC, on harmonised minimum requirements of five years and 5,500 or 5,000 hours respectively, and on the three-month decision deadline under Article 51.

A look across the border shows what this structure is worth. Switzerland recognises EU and EFTA diplomas directly but requires the corresponding citizenship and, on top of that, a cantonal licence to practise. Austria applies the directive and requires entry in the medical register. The United Kingdom lost the automatic route with Brexit, and entry into practice there has taken visibly longer since.

For anyone considering a degree, one sentence remains: a degree in medicine or dentistry in an EU member state leads back to Germany without a recognition hurdle. The reform currently being written about so widely concerns a different group of people. If you would like your own case assessed, you can book a free consultation.

Further reading

Frequently asked questions about the recognition of foreign healthcare qualifications

From when does the new law apply?

The Act to Accelerate the Recognition of Foreign Professional Qualifications in Healthcare was promulgated in the Federal Law Gazette on 28 July 2026 and comes into force on 1 November 2026. The Bundestag passed it on 26 March 2026 and the Bundesrat dealt with it in its second reading on 8 May 2026.

Do I have to sit a competency examination after a medical degree in the EU?

No. The competency examination concerns only qualifications from countries outside the EU. For evidence of formal qualifications from the EU and the EEA, automatic recognition applies under Article 21 of Directive 2005/36/EC. In its questions and answers, the Federal Ministry of Health makes clear that nothing changes in the order of the procedure for EU and EEA qualifications.

Which healthcare professions are recognised automatically in the EU?

Annex V of Directive 2005/36/EC lists the sectoral professions: doctor under number 5.1.1, dentist under 5.3.2, veterinary surgeon under 5.4.2, pharmacist under 5.6.2. Anyone holding evidence of qualifications listed there is entitled to recognition in every member state.

Does automatic recognition also apply to psychology and psychotherapy?

No. Psychology and psychotherapy are not harmonised as sectoral professions in Directive 2005/36/EC and are not in Annex V. In Germany the route to a licence as a psychotherapist runs through the reformed Psychotherapists Act, with an individual assessment of the qualification obtained abroad.

What exactly is the difference between an equivalency assessment and a competency examination?

The equivalency assessment is a file comparison: the course content and teaching hours of the foreign degree are compared with German training. The competency examination is an actual examination based on the content of the state final examination. From 1 November 2026 it is the standard route for non-EU qualifications, with the file assessment remaining selectable within four weeks.

How long may an authority take to decide?

For recognitions under the EU directive, Article 51 sets the framework: acknowledgement of receipt within one month, a decision no later than three months after complete documents are submitted, extendable to four months in general-system cases. For practice, the Federal Ministry of Health gives 97 days in 2022 against 129 days in 2017.

What minimum requirements does the EU set for the degree?

Article 24 of Directive 2005/36/EC requires at least five years and at least 5,500 hours of theoretical and practical training for basic medical training, and Article 34 requires at least five years and at least 5,000 hours for basic dental training. This harmonisation is the precondition for automatic recognition.

What is the EU certificate of conformity?

It confirms that evidence of formal qualifications meets the minimum requirements of the directive and is listed in Annex V; the legal basis is in Annex VII number 2. It is issued by the competent body of the state of training, and for German qualifications in medicine, dentistry and pharmacy by the Federal Institute for Drugs and Medical Devices.

Do I still need a licence with an EU qualification?

Yes. Automatic recognition of the qualification does not replace the application to the state examination office. What is assessed is personal reliability, health fitness and language skills, at B2 level in general language and as a rule at C1 level in specialist language.

What does the Assessment Office for Health Professions do?

It supports the responsible state authorities technically and checks the authenticity of foreign certificates, among other things by enquiring with the issuing bodies in the country of origin. According to the Federal Government there were around 3,350 authenticity checks in 2024, in which five forged certificates were identified.

What does Switzerland require in addition to MEBEKO recognition?

The Medical Professions Commission MEBEKO recognises diplomas from EU and EFTA states directly, but only where the applicant holds Swiss or EU/EFTA citizenship. This is followed by the licence to practise issued by the canton in which the person will work. The Federal Office of Public Health gives fees of 800 to 1,200 francs and processing times of up to six months.

What applies in Austria?

Austria applies Directive 2005/36/EC but additionally requires entry in the medical register of the Austrian Medical Chamber in order to practise. Non-EU qualifications go through nostrification at a medical university; the University of Vienna gives a fee of 150 euros for this and a decision generally within three months.

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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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