Germany is changing the recognition process for doctors with foreign qualifications. From November 2026, the procedure is intended to become more digital, more uniform and less dependent on extensive document comparisons. A recently submitted regulation would also require authorities to accept many documents in English and would state clearer processing deadlines.
Legal status as of 7 September 2026: The main reform law has been enacted and is scheduled to apply largely from 1 November 2026. The supplementary regulation containing the detailed English-document and deadline rules was sent to the Bundesrat on 3 September 2026 and still requires its consent. Those details are therefore not yet final.
This distinction matters. Applicants should not assume that every authority must already accept English documents or that every Approbation application will be completed within three months.
This article explains what has already become law, what remains pending, which applicants are affected and what the deadlines would actually mean in practice.
What has already been enacted?
The Gesetz zur Beschleunigung der Anerkennungsverfahren ausländischer Berufsqualifikationen in Heilberufen was enacted on 22 July 2026 and published in the Federal Law Gazette on 28 July 2026. Most of its provisions are intended to take effect on 1 November 2026.
The reform covers doctors, dentists, pharmacists and midwives. For doctors, one of its most significant changes concerns qualifications obtained outside the EU, EEA and Switzerland.
Under the new model, the direct Kenntnisprüfung becomes the standard route for many third-country applicants. An applicant may still choose a document-based assessment of equivalence, but the system will no longer require that complex comparison in every case.
The Federal Ministry of Health explains that applicants who use the direct examination route will generally no longer have to provide the detailed curricula and other extensive educational documents needed for an individual equivalence assessment. This is intended to save applicants translation and certification costs while reducing the workload of the state authorities.
However, the reform does not lower the professional standard. The Kenntnisprüfung remains a German medical licensing examination, and the requirements concerning professional competence, reliability, health and German-language ability remain relevant.
Will Approbation authorities have to accept documents in English?
If the supplementary regulation is approved in its current form, yes, as a general rule.
The proposed new §33a of the German Medical Licensing Regulations states that documents may be submitted as copies or electronically. Documents originally issued in German or English would not require a translation simply because they are in English.
If a document was issued in another language, the applicant would normally attach a translation into either German or English. That translation would generally have to be prepared by a publicly appointed or sworn translator.
The authority could still require a German translation in a justified exceptional case. It could also request originals, certified copies or further evidence when it has justified doubts about authenticity, content or the accuracy of a translation.
What this does not mean: English would not replace the German-language requirements for practising medicine. Applicants would still need the German and medical-language competence required for Approbation, and the Fachsprachprüfung and Kenntnisprüfung would remain in German.
It also does not mean that applicants should immediately ignore the document checklist of their chosen Bundesland. Until the regulation is approved, promulgated and in force, the authority’s current published requirements remain the safest guide.
What processing deadlines are proposed?
The proposed §39f would collect and clarify the decision deadlines for medical Approbation applications.
One month to confirm receipt and identify missing documents
For relevant applications involving foreign qualifications, the authority would have to confirm receipt of the application and documents within one month and tell the applicant which documents are missing.
Normally three months for the decision
The authority would normally have to decide on the Approbation application within three months after the applicant has submitted all documents that the applicant is required to provide.
Four months in certain equivalence cases
In certain cases involving an individual assessment of whether a foreign qualification is equivalent to German medical training, the period would be extended by one month. A decision identifying substantial differences would likewise have to be issued within four months after all required documents are available.
Two months in the accelerated skilled-worker procedure
In a procedure under §81a of the Residence Act, the draft says that the decision should be made within two months. The word “should” is significant: this is not phrased as an unconditional guarantee in every case.
Why this is not a guaranteed three-month Approbation
The deadline starts only after the required documents are available. It does not necessarily begin on the day an applicant first emails a form or opens a file with the authority.
The authority may consider the application incomplete and request further material. Questions about authenticity or information from institutions in another country can also cause delay. Most importantly, an applicant may still need to meet separate conditions such as proof of German-language ability, the Fachsprachprüfung or the Kenntnisprüfung.
A deadline for the authority to make an administrative decision is therefore different from a promise that the applicant will receive Approbation within that period. The decision may also state that a requirement remains unmet or that an examination is necessary.
Exam availability is another practical issue. Even if the document-handling stage becomes faster, waiting for an FSP or Kenntnisprüfung appointment can continue to extend the overall journey.
There is another reason to describe the deadline carefully: the explanatory text accompanying the regulation says that some of these periods were already contained in the existing Medical Licensing Regulations and are now being reorganised in the new §39f. It would therefore be misleading to suggest that Germany previously had no processing periods at all.
Who would follow the new rules?
According to the transition provision in the proposed regulation, the previous Medical Licensing Regulations would continue to apply to people who submit their Approbation or professional-permit application by 31 October 2026.
The new procedure, including the direct Kenntnisprüfung model, is intended for applications submitted from 1 November 2026. Because the supplementary regulation still needs Bundesrat consent, applicants should check the final promulgated text before relying on that date.
EU and non-EU doctors are not affected in the same way
The direct Kenntnisprüfung as the standard route is mainly relevant to doctors whose qualification was obtained in a third country.
Doctors with EU, EEA or Swiss qualifications may fall under European rules on automatic or general-system recognition. The 2026 reform does not turn their route into the same process as the third-country route. Language, reliability, health and documentation requirements can still apply.
The proposed general document rule is broader: it would make German and English acceptable submission languages under the relevant licensing provisions. But an applicant’s exact route and required evidence still depend on where and how the qualification was obtained.
What applicants should do now
First, continue following the current checklist from your competent Approbationsbehörde. Do not rely on a news report alone when deciding whether to pay for translations or submit originals.
Second, if you plan to apply after 1 November 2026, monitor the Bundesrat decision and the final published regulation. The final wording, commencement date or transitional provisions could still change.
Third, ask the authority in writing before omitting a German translation. A written answer is especially useful during the transition period when websites, checklists and internal procedures may not all be updated at the same time.
Fourth, decide carefully between the direct Kenntnisprüfung and a document-based equivalence assessment. The examination route may reduce paperwork, but it is not automatically the easier choice for every doctor. An applicant with a closely comparable curriculum and substantial professional experience may have reasons to request an individual assessment.
Finally, keep preparing your medical German. Acceptance of English documents can reduce administrative cost, but it does not reduce the language level needed for safe medical practice in Germany.
Frequently asked questions
Can I submit English documents to an Approbationsbehörde today?
Only if the authority’s current rules permit it. The nationwide English-document provision described here is contained in a regulation that still requires Bundesrat approval. Until it takes effect, follow the current state authority checklist or obtain written confirmation.
Will I no longer need German translations after November 2026?
If the draft is approved unchanged, documents originally issued in English should generally be accepted without German translation. Documents in other languages could normally be translated into German or English. Authorities would retain the ability to demand a German translation in a justified exceptional case.
Does the three-month deadline begin when I submit my application?
Not necessarily. It begins when the documents the applicant must provide are complete. Missing evidence and unresolved requirements can prevent the substantive decision from being completed.
Does the deadline include the FSP or Kenntnisprüfung waiting time?
The deadline should not be understood as a guarantee that every examination, language requirement and licensing step will be finished within three months. Exam scheduling can make the total process considerably longer.
Will every non-EU doctor have to take the Kenntnisprüfung?
The direct Kenntnisprüfung becomes the standard route, but the enacted reform preserves the possibility of requesting a document-based equivalence assessment. Applicants should consider their own education, experience, costs and likely waiting times before choosing.
Official sources
The primary sources for this article are the law published in the Federal Law Gazette, the Federal Ministry of Health’s official FAQ, and Bundesrat printed paper 504/26 containing the supplementary regulation.
For a broader explanation of the existing process, read my step-by-step Approbation guide. You may also find the guides to Fachsprachprüfung preparation and Berufserlaubnis versus Approbation helpful.
Final caution: This article explains federal legislation and a pending federal regulation. It is general information, not legal advice. Implementation is handled by the federal states, practical procedures may differ, and the supplementary rules may still change. Always verify the current requirements with your competent Approbationsbehörde before submitting documents or making financial decisions.