ICT Card Germany — Intra-Corporate Transfer Residence Permit
The ICT Card under § 19 AufenthG allows non-EU nationals employed by a company outside the EU to be transferred temporarily to a connected group entity in Germany — as a manager, specialist, or trainee. The transfer must exceed 90 days. We advise international groups and transferred employees across the full procedure.
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What the ICT Card Is and Who It Covers
The ICT Card is a specialised residence permit for intra-group transfers. It is designed for professionals employed by a company outside the EU who are to be transferred temporarily to a subsidiary, branch, or establishment of the same corporate group in Germany.
The permit is based on EU Directive 2014/66/EU on intra-corporate transfers, implemented in Germany through § 19 AufenthG. It applies to three categories of transferee: managers, specialists with specialised knowledge, and — under stricter conditions — trainees within a structured training programme. The intra-corporate transfer to Germany must be intended to exceed 90 days.
The ICT Card differs from other employment titles in two important respects. There is no fixed salary threshold comparable to the EU Blue Card, and the Federal Employment Agency’s review is limited in scope. This makes it a practical instrument for international groups in certain constellations — but it is a specialist tool with detailed requirements that must be carefully met.
Eligibility Requirements
The conditions for the ICT Card are specific. At the time of application, the employee must have been continuously employed by the sending company outside the EU for at least six months. The employee must remain employed by the sending undertaking or group during the transfer period. The sending and receiving companies must be part of the same corporate group — as parent, subsidiary, or branch. The employee must qualify as a manager, specialist, or trainee. For specialists, it must be demonstrated that they possess specialised knowledge that is actually required by the receiving entity. The professional qualification must be evidenced — formal recognition of foreign qualifications is not required, but qualification, function, and proposed activity must be plausibly documented. The assignment in Germany is time-limited: up to three years for managers and specialists, up to one year for trainees.
Trainees are subject to additional requirements, including a higher education qualification and a paid traineeship aimed at career development or training in business techniques or methods.
A new ICT application may be barred if it is filed within six months after the end of a previous stay in Germany for the purpose of an intra-corporate transfer.
In practice, proving the corporate connection is frequently the first hurdle. Group structures that are clear in the home jurisdiction are not always straightforward to document for German authorities. We review the document basis at an early stage, before the procedure is initiated.
Remuneration Requirements
The ICT Card carries no fixed minimum salary threshold of the kind that applies to the EU Blue Card. However, the remuneration must be at least equivalent to that of comparable domestic employees — the equivalence principle. The appropriate comparator group depends on the role and sector.
Variable salary components, bonuses, and allowances are assessed on their actual structure. What matters is whether they constitute provable remuneration for the work performed. Assignment-related costs — travel, accommodation, subsistence — should not be treated as guaranteed remuneration for these purposes. Allowances can be relevant, but they should not be relied upon as fixed remuneration unless they are contractually guaranteed and comparable to salary.
We advise on structuring the employment contract or secondment agreement to show a clearly guaranteed base salary that withstands comparison with domestic employees.
Federal Employment Agency — Role in the ICT Procedure
The Federal Employment Agency (BA) is involved in the ICT Card procedure as a rule. Consent is obtained internally during the visa or residence permit process. The review is limited in scope: the BA examines the classification of the employee as manager, specialist, or trainee, and checks remuneration and working conditions. A classic priority review does not apply.
BA involvement is often manageable where role, remuneration, working conditions, and qualification are clearly documented. It can still become a practical obstacle where the role classification or salary structure is unclear.
ICT Mobility in the EU
EU mobility is one of the practical advantages of the ICT framework. A holder of a German ICT Card may, under the ICT mobility rules, work temporarily for the group in other participating EU member states. For short stays of up to 90 days within a 180-day period, notification to the competent authority in the destination member state may be sufficient, depending on that member state’s rules. For longer stays, the destination member state may require a mobile ICT residence title under its national implementation of the ICT Directive. Ireland and Denmark are not part of this system. The specific conditions vary by member state and must be assessed individually.
The German provisions in §§ 19a and 19b AufenthG mainly govern the reverse situation: intra-corporate transferees who hold an ICT title from another EU member state and come to Germany for short-term or long-term mobility.
ICT Card vs EU Blue Card vs Skilled Worker Visa
The ICT Card is not the right instrument for every international employment situation. It presupposes a connected corporate group structure and a temporary assignment. Professionals who are to be employed permanently in Germany need a different title.
The EU Blue Card (§ 18g AufenthG) is suited to academic-level professionals with a concrete job offer and a salary meeting the statutory threshold (€50,700 as a rule in 2026). It leads more quickly to a settlement permit and carries more favourable family reunification conditions. It does not require a group structure.
Skilled worker residence permits (§§ 18a, 18b AufenthG) also require no group structure, but do require qualification recognition and typically BA involvement. They cover both vocational and academic qualification routes.
The ICT Card is the appropriate instrument where the group structure and six-month prior employment conditions are met, the assignment is temporary, and the qualification and function requirements are satisfied. Where a longer-term or permanent stay is anticipated, a timely switch to a different title should be planned.
We assess which route fits the individual situation and advise on the transition where relevant. Further detail is on our pages for the EU Blue Card and the Skilled Worker Visa.
Conversion to Other Permits
ICT Card holders who wish to remain in Germany beyond the permitted period, or who are offered permanent employment, must switch to a different residence title before the ICT Card expires. The EU Blue Card is one option where the qualification and salary requirements are met. Skilled worker titles under §§ 18a or 18b may be alternatives depending on qualification and role. The transition should be planned well in advance of the end of the maximum ICT period.
Application Process and Documents
The ICT Card application is submitted at the competent German embassy or consulate in the employee’s country of residence as a rule. The competent immigration authority (Ausländerbehörde) in Germany is involved in the procedure. In Hamburg, responsibilities may involve the Hamburg Welcome Center or the competent immigration authority depending on the procedural stage and the applicant’s situation. The competent authority should be checked before filing.
Documents typically required include a valid passport, evidence of the corporate group connection between both companies (commercial register extracts, organisational chart, corporate documents), proof of six months’ prior employment with the sending company, the secondment agreement or employment contract with the German entity, evidence of qualifications, a job description classifying the role as manager, specialist, or trainee, and remuneration documentation. The competent authority may request additional documents.
Processing times vary considerably depending on the German mission abroad, BA involvement, document quality, and the competent immigration authority. Several months should be factored into the planning. The fast-track procedure under § 81a AufenthG is not the typical route for ICT Card applications; whether any form of procedural acceleration is available should be checked with the competent authority in the individual case.
Family Reunification
Spouses and minor children of ICT Card holders can join under the family reunification provisions. As with EU Blue Card holders, spouses of ICT Card and Mobile ICT Card holders are generally not required to prove A1 German language skills before entry. Other requirements — including livelihood, housing, and the duration of the principal holder’s permit — should still be checked in the individual case. The family member’s residence permit will generally be linked to the validity of the ICT Card or Mobile ICT Card.
The full procedure is set out on our family reunification page.
How We Advise
The ICT Card is a specialist instrument. Using it without detailed knowledge of its requirements risks refusal or significant delays. We advise international companies and corporate groups on whether the conditions are met, structure the document basis, and accompany the procedure through to the grant of the residence permit. Where a transition to another title is anticipated, we advise on the pathway and timing. Our firm advises in German and English; by prior arrangement also in Russian.
Advice by Alexander Kagan, Attorney at Law, admitted to the Hanseatic Bar Association Hamburg. As of: June 2026.
The contents of this page are for general information only and do not constitute legal advice. A mandate is established only upon express acceptance.
Frequently Asked Questions — ICT Card Germany
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The ICT Card is available to non-EU nationals employed by a company outside the EU who are being transferred to a connected group entity in Germany — as a manager, specialist with specialised knowledge, or trainee. The transfer must exceed 90 days. At least six months of continuous prior employment with the sending company is required, and the employee must remain employed by the sending undertaking during the transfer.
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Managers exercise a senior role directing the group entity or a department of it. Specialists must possess specialised knowledge that is actually required by the receiving entity — knowledge of the company’s products, processes, or sector. The distinction affects the documentation required. Trainees are subject to additional requirements including a higher education qualification and a paid traineeship, and are limited to a maximum of one year.
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Up to three years for managers and specialists. Up to one year for trainees. Extension within the maximum period may be possible. Anyone intending to remain in Germany beyond the ICT Card’s maximum duration should plan the switch to a different residence title well in advance of the end of the maximum ICT period.
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Yes, under the ICT mobility framework. A German ICT Card can facilitate short-term work for the group in other participating EU member states, subject to the destination state’s notification rules. For longer stays, that member state may require a mobile ICT title under its own implementation of the ICT Directive. Ireland and Denmark are not part of this system. In Germany, §§ 19a and 19b AufenthG regulate the reverse situation: ICT holders from another EU member state coming to Germany.
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Commercial register extracts from both companies, corporate documents such as articles of association and organisational chart, and a statement of the group relationship are typically required. Requirements can vary by authority. We review the document basis before the application is submitted.
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The ICT Card does not provide a privileged direct pathway to a settlement permit like the EU Blue Card or skilled worker titles. Because it is temporary and capped at three years for managers and specialists or one year for trainees, anyone planning long-term residence in Germany should switch to another title in time. Whether previous periods can be credited later should be assessed individually.
ICT Card Germany — Request Advice
Would you like to transfer an employee from a group company abroad to Germany, or check whether the ICT Card is the right instrument for your situation? We assess the group structure, role classification, remuneration, and documentation requirements and accompany the procedure through to the grant of the permit.
Please outline your situation briefly. Useful details include the group structure, the planned role, nationality of the employee, duration of prior employment with the sending company, and planned assignment period.
