Work Permit for Section 24 Residence Permit Holders Without a University Degree

A Section 19c(1) AufenthG permit matters for one core reason: unlike Section 24 AufenthG, it can count toward a settlement permit and naturalization. Section 24 AufenthG is tied to the duration of the EU temporary protection scheme, currently extended in Germany to March 4, 2027, and time spent under it alone does not bring a person closer to either. Section 10(1) No. 2 of the Nationality Act (Staatsangehörigkeitsgesetz, StAG) lists residence purposes that do not count toward naturalization by entitlement, and Section 24 AufenthG is on that list.

A residence permit under Section 19c AufenthG is different: it is not on the excluded list in Section 10(1) No. 2 StAG, so time spent under it does count. Naturalization by entitlement under Section 10 StAG otherwise requires five years of lawful habitual residence in Germany, a secure livelihood without reliance on state benefits (with an exception for applicants who have worked full time for at least 20 of the preceding 24 months), German language skills at level B1, a passed naturalization test covering German legal and social structures, and no relevant criminal convictions. A Section 19c(1) AufenthG permit also counts toward the residence period required for a settlement permit under the general rules in Section 9 AufenthG. Holding a Section 19c(1) AufenthG permit alongside Section 24 AufenthG therefore gives a person a future that does not depend on whether temporary protection is extended again.

This is a meaningful distinction from the switching routes available to Section 24 AufenthG holders who do hold a university degree or recognized vocational training, such as the skilled worker permits under Sections 18a and 18b AufenthG. Those routes remain the stronger option for people with recognized qualifications. This route exists for those who do not have one.

Which route actually fits depends on details that are easy to get wrong from the outside: whether a foreign qualification could be recognized after all, whether the three-year residence period has genuinely run without interruption, or whether a role that looks unqualified on paper might still support a stronger route. Our lawyers assess this against the specifics of the individual case before recommending a direction, rather than assuming the absence of a degree settles the question.

Understanding why this route helps starts with knowing exactly what Section 19c(1) AufenthG does. Section 19c(1) AufenthG allows a residence permit to be granted for employment without any requirement that the applicant qualify as a skilled worker. The precondition is that the Employment Ordinance (Beschäftigungsverordnung, BeschV) or an intergovernmental agreement permits the applicant to take up that particular employment. On its own, this provision does not specify who qualifies: it depends entirely on which BeschV provision applies to the person’s situation.

For Section 24 AufenthG holders without a degree or vocational qualification, the relevant BeschV provision is Section 9(1) No. 2. Under this rule, no approval from the Federal Employment Agency (Bundesagentur für Arbeit) is required for a job if the applicant has resided in Germany lawfully, on a Duldung (toleration), or with an Aufenthaltsgestattung (permission to reside pending an asylum decision) for three years without interruption. A second, alternative route under Section 9(1) No. 1 BeschV applies to anyone who has already worked two years in Germany in employment subject to compulsory social insurance contributions.

Because Section 24 AufenthG itself constitutes lawful residence, holders who have lived in Germany continuously since the scheme’s early phase in 2022 have generally already reached the three-year threshold. Those who arrived later, whose status began at a different point, or whose residence was interrupted should have their individual timeline calculated rather than assume the threshold applies. Once the threshold is met, the job in question no longer needs Federal Employment Agency approval, and the immigration authority may issue a residence permit under Section 19c(1) AufenthG for that employment, without regard to whether the applicant has a university degree or completed vocational training.

It is worth being precise about what this route does and does not do. Section 19c(1) AufenthG in conjunction with Section 9 BeschV removes the qualification requirement and the labor market test. It does not, on its own, guarantee approval: the decision remains discretionary (the law uses “kann,” meaning the authority “may” grant the permit), and the general requirements of Section 5 AufenthG, including a secure livelihood and a clarified identity, continue to apply.

Because the decision sits within the authority’s discretion rather than being an entitlement, how the case is presented genuinely matters. Our lawyers build the application around the evidence an authority is most likely to weigh: continuous documentation of the residence period, a clearly structured employment offer, and proof of income that leaves no room for the authority to question whether the livelihood requirement is met.

It is also worth knowing what this route is not blocked by. Section 19f(1) No. 1 AufenthG bars temporary protection beneficiaries, the category that Section 24 AufenthG holders fall into, from switching into certain other residence titles, including the EU Blue Card under Section 18g AufenthG and a residence permit for study under Section 16b AufenthG. Section 19c AufenthG is not on that list. This route is genuinely open to Section 24 AufenthG holders even while temporary protection continues, not merely a theoretical option undercut by a blocking provision elsewhere in the law.

• A valid residence permit under Section 24 AufenthG (or a fiction certificate confirming continued lawful residence while an application is pending)
• Three years of uninterrupted lawful residence, toleration, or permission to reside pending an asylum decision, counted under Section 9(1) No. 2 BeschV
• A concrete job offer or employment contract
• A secure livelihood under Section 5(1) No. 1 AufenthG (the law sets no fixed income figure; the authority checks whether income covers living costs, including health insurance, without reliance on public benefits, and this varies by location and household size)
• Identity clarified and passport requirements met
• No grounds for expulsion

In practice, we see applications most often succeed when the employment offer is full-time, indefinite, and clearly documented. Applications most often stumble when the residence history has an unexplained gap or the offer is part-time or short-term.

Since Section 24 AufenthG already constitutes lawful residence in Germany, an application for a Section 19c(1) AufenthG permit can generally be submitted to the immigration authority without leaving the country and without a separate visa procedure. If the application is submitted before the current Section 24 AufenthG permit expires, the so-called fiction effect under Section 81(4) AufenthG applies: the existing permit is treated as continuing until the authority decides.

Because the decision is discretionary and depends on demonstrating both the three-year residence period and a secure livelihood, it is worth preparing the supporting documentation carefully before submission: proof of continuous residence, the employment contract, and evidence of income.

The most frequent reason this route fails is incomplete evidence of the three-year residence period, particularly where residence has been interrupted by travel outside Germany or gaps between different permits. The calculation also has technical limits worth checking in advance: time spent under a residence permit for study purposes (Section 16b AufenthG) counts toward the three years at only half its value and only up to a maximum of two years, and for the alternative two-year employment route, periods before an earlier departure from Germany, time-limited employment, or employment already exempted from approval under an intergovernmental agreement do not count. It is also worth checking the employment offer against the requirements of Section 5 AufenthG before applying, since a marginal or short-term position may not be treated as securing a livelihood. Because the decision is discretionary, a well-documented application materially improves the chances of a favorable outcome.

These are exactly the details our lawyers at Schlun & Elseven review before an application goes in. A residence history that looks continuous to the applicant can contain a gap the authority reads differently, and an employment offer that looks sufficient can still fall short of what a specific Ausländerbehörde (immigration authority) expects to see. Catching this before submission, rather than after a rejection, is usually the difference between a straightforward approval and months of delay.

For Section 24 AufenthG holders who do hold a recognized degree or vocational qualification, see our related guide on switching from a Section 24 residence permit, which covers the skilled worker and EU Blue Card routes.

At Schlun & Elseven, our lawyers assess whether the Section 19c(1) AufenthG route in conjunction with Section 9 BeschV applies to your situation and advise you on the strongest path toward long-term residence, including the follow-on options for a settlement permit and naturalization.

We also provide full support throughout the application process, including:

• Calculation of your qualifying residence period and review of supporting evidence,
• Preparation and compilation of all application documents,
• Communication with the immigration authority,
• Enforcement in the event of delay or inaction by the authority,
• Advice on the settlement permit and naturalization once the permit is granted.

We represent you as well in the event of a rejection, through an appeal, interim legal protection, or litigation.