Defizitbescheid for doctors in Germany: what it means, what next
Redaktion · 7 October 2026 · 3 min read
In short
A Defizitbescheid is the licensing authority's decision that your foreign medical training shows substantial differences from the German degree. With a degree from outside the EU, you make up for them by passing the Kenntnisprüfung. Applications filed by 31 October 2026 stay under the old rules; after that, the equivalence check only happens if you choose it.
What does a Defizitbescheid contain?
"Defizitbescheid" is not a legal term but the common name for the decision under § 3(2) and (3) of the Federal Medical Code (BÄO). The authority compares your training with the German medical degree and records the subjects where it differs substantially. The law also requires it to weigh your work experience: knowledge from medical practice can make up for differences in full or in part (§ 3(2) sentence 5 BÄO).
The decision can be legally challenged. Under the current wording it must arrive within four months of all documents being in, or within two months in the fast-track procedure for skilled workers under § 81a of the Residence Act.
Which routes remain?
| Your degree | How the differences are made up | Basis |
|---|---|---|
| from a third country (outside EU, EEA, Switzerland) | Kenntnisprüfung on the content of the German state exam | § 3(3) BÄO |
| from the EU, EEA or Switzerland, not automatically recognised | aptitude test covering only the differences found | § 3(2) BÄO |
For doctors from third countries, this means: even if the notice names only a few subjects, the Kenntnisprüfung covers the content of the state exam, not just those subjects. Until you pass, you can work with a Berufserlaubnis, for two years at most.
What changes on 1 November 2026
Under the law in the Federal Law Gazette 2026 I No. 225, the Kenntnisprüfung becomes the standard route for third-country degrees (new § 9d BÄO). The equivalence check that can lead to a Defizitbescheid then only happens if you choose it within four weeks of applying. That choice binds you for the whole procedure.
| Application filed | Rules that apply |
|---|---|
| by 31 October 2026 | the old rules, § 3(2) and (3) BÄO in the previous wording (new § 15 BÄO) |
| from 1 November 2026 | Kenntnisprüfung directly; equivalence check only if chosen within four weeks |
If you are planning an application now, ask your authority early which route is faster for you. More on the new rule: Kenntnisprüfung 2026 for foreign doctors. You need the language on either route: FSP exam in Germany: cost and format.
Frequently asked questions
What is a Defizitbescheid?
The licensing authority's decision recording the subjects in which your foreign training differs substantially from the German degree. The word is informal; legally it is a decision under § 3 BÄO.
What do I do after a Defizitbescheid?
With a third-country degree you take the Kenntnisprüfung. With an EU, EEA or Swiss degree that is not automatically recognised, you take the aptitude test.
How long until I get the Defizitbescheid?
Under the wording valid until 31 October 2026, at most four months after all documents are in, or two months in the fast-track procedure.
Does the Defizitbescheid still exist after 1 November 2026?
Only if you choose the equivalence check within four weeks of applying. Otherwise you go straight to the Kenntnisprüfung. Applications filed by 31 October 2026 stay under the old rules.
Can work experience make up for deficits?
Yes, fully or partly. The authority must take medical practice and formally recognised further training into account (§ 3(2) sentence 5 BÄO).
Sources
- Bundesärzteordnung § 3 (licence, equivalence, decision), checked 7 October 2026
- Federal Law Gazette 2026 I No. 225: act to speed up recognition in the health professions, checked 7 October 2026
- Verwaltungsgerichtsordnung § 70 (deadline for objection), checked 7 October 2026
- Verwaltungsgerichtsordnung § 74 (deadline for court action), checked 7 October 2026
