notice of substantial differences in training

How does a notice of substantial differences arise?

The process begins with the equivalence assessment under § 3(3) of the Federal Medical Act. The authority compares the curriculum, hours, subjects, and examination content of the foreign degree with the requirements of the Medical Licensing Regulations. It frequently obtains an expert opinion from the Advisory Centre for Health Professions for this purpose. If no substantial difference is found, the licence follows. If gaps are identified, the notice specifies which subjects they concern. Professional experience and documented continuing education can offset such differences, which must be acknowledged in the notice.

What next? The route via the knowledge test

After a notice of substantial differences, the route to the medical licence leads through the knowledge test under § 37 of the Medical Licensing Regulations. It is oral and practical, lasts between 60 and 90 minutes per candidate, is taken before a panel of three physicians, and covers internal medicine and surgery as well as questions on emergency medicine, clinical pharmacology, imaging, radiation protection, and legal aspects of professional practice. In addition there is a patient-related section with history-taking and physical examination. The examination may be retaken twice. In the meantime, many work under a provisional licence under § 10 of the Federal Medical Act. Waiting times for an examination date of several months are common depending on the state, and preparation courses involve additional costs.

What applies to graduates from EU countries?

Those who obtained their degree in Bulgaria, Romania, Hungary, Croatia, Malta, or the Baltic states and whose qualification is listed in Annex V point 5.1.1 of Directive 2005/36/EC will not receive a notice of substantial differences: these qualifications benefit from automatic recognition under Article 21. Those primarily affected are graduates from Serbia and Bosnia and Herzegovina, as well as cases where a degree was obtained before the training country's EU accession and no certificate of conformity exists.

What changes from November 2026?

The Act on Accelerating Recognition Procedures in Healthcare Professions, announced in July 2026, reverses the procedure: from 1 November 2026, the knowledge test becomes the standard pathway, and the document-based equivalence assessment is only carried out on application, which must be submitted within four weeks of the start of the procedure.