Berufserlaubnis vs Approbation: the difference for doctors
Redaktion · 7 October 2026 · 3 min read
In short
The Approbation is the full, permanent licence to practise medicine in Germany, not tied to any job. The Berufserlaubnis under § 10 of the Federal Medical Code (BÄO) is a temporary permit, usually limited to one employer and role, for two years at most in total. For both, the authorities ask for German at B2 plus a passed Fachsprachprüfung.
The two permits side by side
| Approbation | Berufserlaubnis | |
|---|---|---|
| Legal basis | § 3 Bundesärzteordnung (BÄO) | § 10 BÄO |
| Duration | permanent | two years at most in total, all federal states added together |
| Scope | not limited to roles or workplaces | can be limited to specific roles and employers |
| Medical requirement | equivalent training or a passed Kenntnisprüfung | a completed medical degree |
| German | the knowledge needed for the job (§ 3(1) no. 5 BÄO) | in practice the same: B2 plus the FSP |
| Degrees from the EU, EEA, Switzerland | yes | no, excluded |
What limits the Berufserlaubnis
The two years are a lifetime cap. The Lower Saxony licensing office (NiZzA) explains: all permits, including those from other states, are added up, even if you never used them. If you already had one year elsewhere, you can only get one more year.
The Bavarian Medical Chamber adds that with a Berufserlaubnis you work under the supervision of a licensed doctor. You cannot open your own practice. Only in exceptional cases, such as local care needs, does § 10(3) BÄO allow more than two years.
What you submit for a Berufserlaubnis
The NiZzA checklist includes:
- application form, CV, medical certificate and police clearance
- job offer or employment contract stating the exact period
- proof of your completed medical degree, with apostille or legalisation
- a B2 language certificate; without it you cannot register for the FSP
- a passed Fachsprachprüfung
- certified German translations
What changes on 1 November 2026
The law in the Federal Law Gazette 2026 I No. 225 amends § 10 BÄO from 1 November 2026. The word "temporary" is dropped. A new paragraph 3a allows a permanent Berufserlaubnis in two narrow cases, for example when an Approbation is permanently impossible because of serious health limits. The two-year cap in paragraph 2 stays for everyone else. For the Approbation, the Kenntnisprüfung becomes the standard route; see Kenntnisprüfung 2026 for foreign doctors.
Who decides?
Both permits are issued by the licensing authority of the federal state, not the medical chamber. In many states the chamber only runs the FSP. In Lower Saxony it is NiZzA; in Bavaria, for degrees from outside the EU, the Regierung von Oberbayern. How the FSP works in your state: FSP exam in Germany: cost and format.
Frequently asked questions
How long is a Berufserlaubnis valid?
Two years at most in total. All permits from all federal states are added up, including unused ones (NiZzA Lower Saxony).
Do I need the FSP for a Berufserlaubnis?
In practice yes. Lower Saxony, for example, asks for a B2 certificate and a passed FSP; Bavaria names German that includes C1 level.
Can I open a practice with a Berufserlaubnis?
No. It can be limited to one employer and role, and according to the Bavarian Medical Chamber you work under the supervision of licensed doctors.
Can EU doctors get a Berufserlaubnis?
No. § 10(1) BÄO excludes degrees from the EU, EEA and Switzerland. They apply for the Approbation directly.
Who grants the Approbation?
The licensing authority of the federal state where you want to work. The medical chamber usually only runs the FSP.
Sources
- Bundesärzteordnung § 3 (Approbation), checked 7 October 2026
- Bundesärzteordnung § 10 (Berufserlaubnis), checked 7 October 2026
- NiZzA Lower Saxony: checklist Berufserlaubnis for doctors (PDF, January 2024), checked 7 October 2026
- Bavarian Medical Chamber: practice and Berufserlaubnis, checked 7 October 2026
- Federal Law Gazette 2026 I No. 225 (BÄO amendment from 1 November 2026), checked 7 October 2026
