The Act on the Suspension of Family Reunification with Beneficiaries of Subsidiary Protection (Gesetz zur Aussetzung des Familiennachzugs zu subsidiär Schutzberechtigten) entered into force on 24 July 2025. Following the entry into force of this law, no family reunification with persons with subsidiary protection status will be granted before 24 July 2027. The aim of the Act is to relieve the burden on admission and integration systems in Germany.

A review will be conducted in good time before the end of the suspension period to consider whether it can and should be extended. If the Act is not extended or otherwise amended, the rules applicable prior to the suspension will automatically regain their validity.

This new legal situation does not affect sections 22 and 23 of the Residence Act. It will still be possible to claim cases of hardship pursuant to these provisions, which contain exceptions to the general rules. Particularly relevant are reasons of international law and urgent humanitarian grounds within the meaning of section 22 sentence 1 of the Residence Act, which relate above all to the circumstances of each individual case.

The International Organization for Migration (IOM) provides support for processing cases of hardship as part of its Family Assistance Programme (FAP), which has been operating successfully for many years. From 26 July 2025, cases of hardship must be reported by email to info.fap.hardship@iom.int, stating the reasons why a case of hardship exists.

IOM will forward the report of the case of hardship to the Federal Office of Administration for a preliminary review and then to the competent mission abroad.

The mission abroad will inform the person who reported the case of hardship of the outcome of its review.

• If the report shows that a case of hardship exists, the mission abroad will contact the person concerned to arrange a priority appointment to apply for a visa.
• If the report has not shown that a case of hardship exists, the person concerned will receive a written notification that the claim has been rejected. If the person does not agree with the decision, they are free to submit a visa application nonetheless. If a visa application is rejected, the rejection notice contains official information regarding legal remedies, including details on the form of remedy (filing an appeal), where this should be done (Berlin Administrative Court) and the deadline (one month from the date on which the notice is served).