Written under our editorial standards.
Targeted official-source correction:12 October 2026. Checked suspension scope, exceptions, hardship, legal-remedy deadlines and refugee exemptions. Not a complete legal review, an individual deadline calculation or approval guarantee.
Section 104(14) suspends family reunification under section 36a to subsidiary-protection beneficiaries through the end of 23 July 2027, starting 24 July 2025. Sections 22 and 23 remain unaffected. The Foreign Office describes an IOM hardship-reporting and individual-review route; an exception, report or priority appointment is not an issued visa.
The law in brief
- Name of the act
- Gesetz zur Aussetzung des Familiennachzugs zu subsidiär Schutzberechtigten — the Act on the Suspension of Family Reunification with Beneficiaries of Subsidiary Protection.
- In force since
- 24 July 2025.
- Length of the suspension
- Family reunification under section 36a to subsidiary-protection beneficiaries is suspended through the end of 23 July 2027; sections 22 and 23 remain unaffected. Refugee status alone is outside this particular suspension, but the route retains its requirements and individual assessment.
- Stated aim
- To relieve the burden on Germany's admission and integration systems.
- What happens afterwards
- A review will be conducted in good time before the end of the period to consider whether the suspension can and should be extended. If the act is not extended or otherwise amended, the rules applicable before the suspension automatically regain their validity.
- What is unaffected
- Sections 22 and 23 of the Residence Act — hardship cases can still be claimed under those provisions.
Who is covered and who is not — the most important distinction here
The scope is family reunification under section 36a to subsidiary-protection beneficiaries, not every nationality or family application. We do not infer a reconciliation of differing section 25 references in current official texts; check the decision, current permit and application route.
Refugee status, work/study/BlueCard permits orreunification to a German national are not subject to this specific section 36a suspension merely on that basis. Each route retains its conditions; being outside the suspension does not automatically mean approval.
For recognised refugees, section 29(2) requires more than a three-month period for mandatory livelihood/housing exemptions in its specified spouse/minor-unmarried-child cases. The application must be made within three months after final recognition, and family life must be impossible in a non-EU country to which the sponsor or family has special ties. Timeliness alone does not guarantee the exemption; discretionary waiver may also be available under the statute outside that case. This does not reopen the suspended subsidiary-protection route.
Hardship reporting and its limits alongside statutory exceptions
- First establish your relative's status in GermanySubsidiary protection or refugee recognition? The difference decides whether this route concerns you at all. Ask for a copy of the decision of the Federal Office for Migration and Refugees before taking any step.
- Check the hardship ground and applicable exceptionSections 22 and 23 remain unaffected. The Foreign Office particularly identifies international-law or urgent humanitarian grounds under section 22 sentence 1, assessed by individual circumstances; group membership alone does not establish the exception.
- Explain hardship to IOM under the noticeThe notice identifies [email protected] from 26 July 2025 and requires reasons. We do not declare a reasonless email legally void, but it fails to explain why hardship applies. Follow the authority’s evidence instructions.
- Wait for the preliminary inspection and the referralThe IOM forwards the report to the Federal Office of Administration for preliminary inspection, and thereafter to the competent mission abroad for review and decision. The decision therefore rests with the mission, not with the IOM.
- If hardship is identified: a priority appointmentThe Foreign Office says the mission contacts you to arrange a visa-application appointment. This permits application, not final approval; conditions, checks and a subsequent decision remain.
- Distinguish hardship-report rejection from visa refusalIf the report does not establish hardship, the notice says a visa application remains possible. If the visa application itself is refused, promptly read its remedy instructions and get specialised advice. Preliminary-report rejection is not the same visa decision.
Three points to check before making a decision
1) Do not confuse refugee status with subsidiary protection orassume a guaranteed waiting period. Check the current permit, protection decision and family category.
2) Sending a hardship report without reasons. The official text requires the reasons why a case of hardship exists — a general message is assessed on what it contains.
3) Do not assume every deadline is a month or a year. Notification date, proper remedy instructions and statutory exceptions matter; obtain prompt specialist review.
What the position was before the suspension — and why it matters
Before the suspension, section 36a provided the ordinary subsidiary-protection family route: discretionary humanitarian admission, no entitlement under that route, and a cap of 1, 000 national visas monthly. Its published text does not open the ordinary route during section 104(14)’s suspension orremove sections 22/23.
Under the current law, absent amendment or extension, the rules resume after the end of 23 July 2027, from 24 July 2027. Published section 36a rules do not automatically entitle every family to admission; no decision or appointment on that date is guaranteed.
Official sources
The Federal Foreign Office notice on the suspension of family reunification · Section 36a AufenthG — reunification with beneficiaries of subsidiary protection · Section 22 — admission on urgent humanitarian grounds · Scope and dates, section 104(14) · Refugee exemption conditions, section 29(2) · Claim deadline, section 74 VwGO · Remedy instructions and exception, section 58 VwGO
Please note: this page is general guidance, not legal advice. Reunification cases are assessed individually — consult a lawyer specialising in immigration law or a migration advice centre before any decision concerning your family.
Frequently asked questions
Has family reunification in Germany been stopped?
Family reunification under section 36a to subsidiary-protection beneficiaries is suspended through the end of 23 July 2027; sections 22 and 23 remain unaffected. Refugee status alone is outside this particular suspension, but the route retains its requirements and individual assessment.
Does the suspension cover recognised refugees?
Refugee status, work/study/BlueCard permits orreunification to a German national are not subject to this specific section 36a suspension merely on that basis. Each route retains its conditions; being outside the suspension does not automatically mean approval.
What remains possible despite the suspension?
Sections 22 and 23 of the Residence Act are unaffected, and hardship cases can still be claimed under them — particularly reasons of international law and urgent humanitarian grounds within the meaning of Section 22, which relate to the circumstances of the individual case.
How do I report a case of hardship?
By email to [email protected] under the Family Assistance Programme run by the International Organization for Migration, since 26 July 2025, stating the reasons why a case of hardship exists. The IOM forwards the report to the Federal Office of Administration for preliminary inspection and then to the competent mission.
What happens if hardship is established?
The notice provides a priority visa-application appointment if review identifies hardship; that appointment is not approval. If the report does not establish hardship, a visa application remains possible and is then assessed under its requirements.
What do I do if the visa application is refused?
After visa refusal, a claim at the Berlin Administrative Court is normally due within one month of notification under section 74 with a proper remedy instruction under section 58(1) VwGO. Where instructions are missing or incorrect, section 58(2) sets a general one-year period from service/announcement, subject to its exceptions. This page calculates no start or last day for your case. Get prompt specialised review and do not assume you may wait a year.
Will the suspension end automatically in 2027?
Current law suspends the section 36a route through 23 July 2027. Without amendment or extension, previous rules resume from 24 July 2027, including section 36a discretion and a cap of 1, 000 visas monthly. That is no automatic approval or appointment guarantee.