Arbeitszeugnis: Decoding a German Reference

Key takeaways

• Your final grade is usually in the satisfaction sentence. Per the Federal Labor Court, stets zu unserer vollsten Zufriedenheit is very good, stets zu unserer vollen Zufriedenheit good and zu unserer vollen Zufriedenheit only satisfactory, the middle grade.
• Only those three grades come from the Federal Labor Court. Every lower grade rests on lower-court rulings, mainly one regional court’s table from 2000, or on chamber guides.
• You have a right to a reference that matches your work, not to a good one as such. In court, you must prove better work to get more than satisfactory, and your employer must prove anything below average.
• Coded wording is banned by German law (§ 109 of the Trade Regulation Code, GewO), and the rulings we found back only a few negative readings, such as bemüht (made an effort) with no word on success. In 2011 the Federal Labor Court said that code lists in books and online mostly repeat court examples out of context.
• The statute of limitations runs out three years after the end of the year the claim arose. IHK Dresden’s guide counts from the end of the year you leave. Cutoff periods in collective bargaining agreements or your contract can be far shorter, so ask for corrections early.

Contents

1. What grade does each phrase mean?
2. What does stets (always) mean?
3. What do the conduct and closing sentences say about you?
4. Are there secret codes in an Arbeitszeugnis?
5. Can you demand a good grade?
6. How to check your Arbeitszeugnis
7. What to do if your Arbeitszeugnis is bad
8. Frequently asked questions

Dieser Artikel auf Deutsch: Arbeitszeugnis-Formulierungen und ihre Noten

German law requires an Arbeitszeugnis to be truthful first and kind only as far as the truth allows, as the Federal Labor Court (Bundesarbeitsgericht, BAG) puts it¹. The pull between truth and kindness produced a jargon of its own, the Zeugnissprache, as the Dresden Chamber of Industry and Commerce (IHK Dresden) explains². Its stock phrases map onto a school-style scale¹. Our advice: judge yours by German reference practice, where good grades are common, not by what “satisfactory” would mean on a report card.

This guide covers German law only. It does not apply to Swiss or Austrian references. For each phrase you can see who backs the reading: a court, or only a chamber guide.

What grade does each phrase mean?

In most references, your final grade sits in a stock sentence about how satisfied your employer was. At the top of the scale it reads Sie hat die ihr übertragenen Aufgaben stets zu unserer vollsten Zufriedenheit erledigt (she always completed her assigned tasks to our fullest satisfaction)^3,4. Employers may use another system, but in 2003 the BAG cited a study of 1,000 references that found the satisfaction sentence, in one grade or another, in about 88 percent of them⁵. “Satisfied” here does not describe your employer’s feelings. It measures your work against what is usually expected of someone in a comparable job¹. In its 2000 ruling, one panel of the Regional Labor Court (LAG) Hamm, an appeals court below the BAG, said it had applied this scale of standard phrases in its rulings since 1992⁴. IHK Dresden and IHK München, the Munich chamber, publish guides, which are not law^2,3.

Notes on the table:

• A: The chambers disagree: IHK Dresden rates it good, IHK München lists it under very good^2,3. In 2005 the BAG linked vollste satisfaction with very good work without addressing stets⁶.
• B: The BAG calls it the middle grade and notes that some read it as an in-between grade, voll befriedigend¹. LAG Hamm took that reading in 2000: vollbefriedigend, slightly above the average stets zu unserer Zufriedenheit⁴. IHK Dresden and IHK München both list it as satisfactory^2,3.
• C: The BAG read Zufriedenheit as satisfactory in 1976, LAG Hamm reported in 2002, adding that the lower courts mostly read it as sufficient⁷.
• D: The BAG reads bemüht as censure if success goes unmentioned and gives it no grade⁸. LAG Hamm also read it as censure in 2000⁴.

Only the grades very good, good and satisfactory were assigned by the BAG itself¹. Every grade below satisfactory comes from LAG Hamm’s 2000 table, other lower courts (note C) or the chambers. The LAG Hamm panel behind that table called the scales essentially settled. Guidebooks read the phrases slightly differently, it added, and which reading is right is ultimately more a matter of taste than of law⁴.

For individual ratings, such as expertise or working style, we found no court-backed scale. They must still fit the final grade, because a reference may not contradict itself⁵. A better final grade follows from the individual ratings only if they compel it, and an occasional “good” was not enough for the BAG in 2003⁵.

What does stets (always) mean?

Stets lifts a grade, but it does not claim you never made a mistake. The BAG explained in 2014 that stets and immer (always) signal more than could normally be expected, not that no error ever happened¹. The BAG gives durchgehend (consistently) the same grade-lifting effect¹. Without such a time word, zu unserer vollen Zufriedenheit drops from good to satisfactory, the BAG says¹. The BAG names stets, immer and durchgehend. LAG Hamm also counted jederzeit (at all times) in 2000 and 2002, and IHK München lists it for both good and very good^3,4,7. In LAG Hamm’s 2000 table, dropping stets likewise costs one grade: stets zu unserer Zufriedenheit is satisfactory, zu unserer Zufriedenheit sufficient⁴. For vollsten with no time word at all, the chambers disagree (see note A).

What do the conduct and closing sentences say about you?

The conduct sentence rates how you dealt with supervisors and colleagues and how you fit into the workflow⁹. LAG Hamm’s 2000 table and IHK München’s guide turn it into a second grade, and they grade it differently, starting at the top^3,4.

For war stets einwandfrei, the BAG said in 2005 that the rating is usually seen as above average⁶. In the same ruling, the BAG said that conduct with no cause for complaint at all must show in words like immer, durchweg (throughout) or ausnahmslos (without exception)⁶.

Check who is named, and in what order. In 2000, LAG Hamm said that whether all three or four groups (supervisors, colleagues, subordinates, customers) appear usually matters more than the conduct wording itself, since a missing group can hint at trouble⁴. A peer-reviewed 2018 study of 800 references by researchers at the University of Erlangen-Nuremberg (Sende, Moser and Galais; we could read only its abstract) found signs that reordering supervisors and colleagues, or leaving certain parts out, is used on purpose as a negative signal¹⁰.

The closing sentence (Schlussformel) with thanks and good wishes is optional. The BAG ruled in 2012 and 2022 that you have no claim to one^11,12. In 2022 it left open whether that also holds when your employer routinely ends its references with such a closing¹². If you dislike yours, you can demand a reference without it, not a better wording¹¹.

In 2000, LAG Hamm read closings as grades: it said a closing, if used, must match the grades, and rated a bare Wir wünschen ihr für die Zukunft viel Glück (we wish her good luck for the future) as poor, while noting that such readings were not yet widely known⁴. The BAG has since held that your employer has no duty to write a closing that matches your grade, and that the rule against leaving out expected praise does not apply to closing sentences, even when a closing leaves out a supposedly usual part¹¹. In 2012 the BAG left open whether an ill-fitting closing counts as a banned code. Either way, you can have it removed¹¹. The court also said that a missing thank-you says more about the writer than about you¹¹.

Are there secret codes in an Arbeitszeugnis?

Hidden codes (Geheimcodes) are banned. Section 109(2) of the Trade Regulation Code (Gewerbeordnung, GewO) demands clear, understandable wording and bans marks or phrases meant to say something about you other than what the reference’s form and wording show¹³.

In 2011 the BAG took one supposed code apart: kennen gelernt (got to know), as in “we got to know him as a very interested and highly motivated employee,” does not signal that those qualities were missing⁸. The court saw no empirical evidence that the phrase had taken on a generally understood coded meaning, and said the so-called code lists in books and online mostly repeat court examples out of context⁸. That code reading came from the same LAG Hamm panel whose table supplies the lower grades above. The BAG called it an isolated view that never caught on⁸.

Readings a court has backed:

• Bemüht (made an effort) with no word on success reads as censure, per the BAG⁸.
• Silence where a reader expects praise: a reference must be true and may not leave out what readers in your line of work expect to see praised, per the BAG^9,11.
• An offer to answer future employers’ questions about the quality of your work was struck in 2009 by the Herford Labor Court (ArbG Herford), a first-instance court, as a coded signal that the grades do not reflect your performance¹⁴.

The same 2018 study suggests the advice books are not all folklore. According to its abstract, most of the techniques they discuss were used to a notable extent and on purpose, and shorter references carried worse ratings¹⁰. In our reading, a single word is rarely a banned code, and context decides. Even bemüht reads as censure only when the reference is silent on success, per the BAG⁸. Look for patterns instead, like a missing group, an unusual order or a short, thin text.

Can you demand a good grade?

Only if your work earned it, and in court you must prove it. Section 109 GewO gives you a right to a reference that matches your performance, not to a “good” or “very good” one as such, the BAG ruled in 2014^1,13. An employee whose work earned a “good” can claim that grade and enforce it, the court said in 2003⁵. Your employer still has some discretion in grading, and courts review it only in a limited way. It exceeds that discretion if, for example, the grade was clearly driven by improper motives^1,5. The middle grade decides who must prove what:

• For anything better than zu unserer vollen Zufriedenheit, you must present and prove the facts in court¹.
• For anything below average, the burden is on your employer, a split the BAG endorsed in 2003⁵.
• How common good grades are in your industry has no direct influence on this¹.

Nor can you claim a better grade because others get inflated ones. Final grades that do not match the performance are untrue and therefore unlawful, the BAG said, and there is no duty to follow such a practice¹.

Good grades do seem common. The BAG quoted the legal authors Düwell and Dahl, who in 2011, drawing on the studies the lower court had relied on, put the share of “(very) good” ratings at 86.6 percent¹. The court stressed that such studies are neither expert evidence nor official statistics¹. One of them, by the University of Erlangen-Nuremberg, covered 802 references, one per person, that Manpower GmbH & Co. KG employees had received from their previous employers. Only about 13 came from health care and nursing, the employer’s field in that case¹. Whether it is the same sample as the 2018 study’s 800 references is not documented. According to its abstract, that 2018 study found that references, despite a trend toward better ratings, are not uniformly positive¹⁰.

Employers with a pile of applications often just skim references for the final grade, the BAG noted in 2003, so its wording can decide whether you are invited to an interview⁵. If good grades are that common, a legally average befriedigend carries less weight than the English word “satisfactory” suggests. If yours says zu unserer vollen Zufriedenheit and you can show better work, ask in writing for stets zu unserer vollen Zufriedenheit. A bonus beyond your contract can help. The BAG said it could suggest that your employer, too, thought you deserved special recognition¹.

How to check your Arbeitszeugnis

Check the German original for these points:

• Signature by someone who ranks above you, with their position shown. If a typed name appears under it, that person must sign^15,16. An electronic reference carries the issuer’s name and qualified electronic signature instead^13,17.
• Letterhead, if your employer uses company stationery, per IHK Dresden’s chamber guide².
• A full, precise job description that gives an outside reader, such as a future employer, a clear picture of your work⁹.
• Prose, not a grade table styled like a report card. As a rule, such a table does not satisfy your claim⁹.
• No isolated incidents, good or bad, that do not characterize your work^6,9.
• Parental leave mentioned only if it was a substantial interruption of your work, per the BAG¹⁸.
• No gaps where praise is usual in your line of work. If such a statement is missing although it applies to you, and its absence could hurt your job search, you can demand that it be added, per the BAG^1,5,11.
• Supervisors and colleagues both named in the conduct part⁹.
• Standard business format, and your employer may fold it twice to fit a standard business envelope if the original can still be copied without the folds showing¹⁶.
• Reason for leaving only at your request, per IHK München’s chamber guide³.
• The original date on a corrected reference, if the delay was not your fault, per IHK Dresden’s chamber guide².
• Electronic only with your consent, the issuer’s name and a qualified electronic signature^13,17.

What to do if your Arbeitszeugnis is bad

Ask your employer in writing for a corrected or completed reference (Berichtigung or Ergänzung), naming the lines you dispute or the statement that is missing, and keep a copy. You cannot demand particular wording as long as the reference is clear and contains nothing false⁸. A wrong grade counts as something false, though. The final grade must be true as well, and a grade your work earned can be enforced, within the discretion your employer has⁵. If your employer refuses, you can take the claim to court⁵. A certified employment-law specialist (Fachanwalt für Arbeitsrecht) or your union can check your case and deadlines first.

As a rule, your employer is bound by what it already certified. If it wrote vollste Zufriedenheit in an interim reference and later objects to the grammar, it must still certify very good performance in other words⁶. In a corrected reference, it cannot rate your conduct worse unless new circumstances justify that, the BAG said in 2005⁶. Your employer can depart from an earlier rating only if it later learns of circumstances that justify a different one⁶. A final reference covers your whole employment, though, so in our reading it can rate the time after an interim reference differently¹⁹.

Several deadlines can run against you:

• Statute of limitations: three years under § 195 of the Civil Code (Bürgerliches Gesetzbuch, BGB), from the end of the year the claim arose (§ 199(1) BGB)^20,21. IHK Dresden counts from the end of the year you leave, so the claim expires at the end of the third full calendar year after your job ends².
• Cutoff periods (Ausschlussfristen) in collective bargaining agreements or in your employment contract can also cut the claim short, per IHK Dresden. For collective bargaining agreements, the BAG has confirmed they apply to references^2,15. In a 2005 case, the cutoff clause in § 70 of the BAT, the public-sector collective bargaining agreement that applied, required only a written demand within six months¹⁵. A written objection demanding a new reference, sent within six months of receiving it, was enough¹⁵. Check your own clause for any further step, such as a deadline to sue.
• Forfeiture (Verwirkung) can end the claim earlier if you do nothing for a long time, your inaction leads your employer to believe you have dropped it, and holding it to the claim would then be unfair. The BAG sets no fixed number of months¹⁵.

Frequently asked questions

What is a qualified Arbeitszeugnis?

A qualified reference (qualifiziertes Zeugnis) states the type and duration of your work and also rates your performance and conduct. A simple one (einfaches Zeugnis) states only the type and duration. Under § 109(1) GewO you are entitled to a written reference when your job ends and can demand the qualified kind¹³. Your employer can only meet the claim once you have chosen, IHK Dresden’s chamber guide says, so ask for the qualified kind explicitly².

Can I get my Arbeitszeugnis in English?

We found no German statute or court ruling that gives you a right to an English version, or that rules one out: § 109 GewO, the statute on references, says nothing about language¹³. If you need one for jobs abroad, ask your employer for an English version alongside the German original, or have the original translated. A word-for-word translation can mislead. “To our full satisfaction” sounds like praise in English, but in German practice it marks the middle grade¹. We would make sure any translation conveys the grade, not just the words.

Is an electronic Arbeitszeugnis valid?

Yes, since January 1, 2025, if you consent and the issuer adds their name and a qualified electronic signature (§ 109(3) GewO, § 126a BGB)^2,13,17,22. Our reading: a plain PDF by email without that signature does not qualify. IHK Dresden says a corrected reference must carry the original issue date if the delay was not your fault². Because a qualified electronic signature stamps the real date, the government bill says such references must be issued on paper²³.

Why does the English translation of the Civil Code still ban electronic references?

Because that translation, published on gesetze-im-internet.de, includes amendments only up to an Act of August 10, 2021²⁴. Its Section 630 still reads: “The reference may not be provided in electronic form.”²⁵ The Fourth Bureaucracy Relief Act of 2024 has since replaced the ban in § 630 BGB with a rule that a reference may be issued electronically with consent^22,23. For employees, § 630 points to § 109 GewO, which the same Act changed the same way^22,26.

What is an interim reference (Zwischenzeugnis)?

An interim reference (Zwischenzeugnis) rates you while you are still employed. You can claim one if you have a valid reason. A new supervisor, a transfer or notice of termination with a long notice period can qualify, LAG Hamm explained in 2007¹⁹. If you are contesting a dismissal, the same court said you can choose between an interim and a final reference. In the court’s view, once you have asked for and received a final reference during that dispute, you have no valid reason left for an interim one until a final judgment establishes that the dismissal did not end your job¹⁹. No statute covers the interim reference. The right exists only as an exception, grounded in your employer’s secondary duties under the employment contract¹⁹.

Does my employer have to mail my Arbeitszeugnis?

Usually not. The BAG said in 1999, citing its own 1995 ruling, that your employer normally only has to keep it ready for pickup at the workplace, though in individual cases it can be obliged to mail it to you in your interest¹⁶. If you have already left Germany, say so when you ask for it to be mailed.

How bad can an Arbeitszeugnis be?

The statute sets no minimum grade¹³. A reference must be truthful first, and final grades that do not match the performance are untrue, the BAG says¹. Within the truth, it must still be kind: it must not make your next job search needlessly harder, and isolated incidents that do not characterize your work stay out^1,6. If your employer rates your work below average, it must prove the facts behind that in court⁵.

How quickly must my employer issue my Arbeitszeugnis?

Section 109 GewO sets no fixed period¹³. LAG Hamm, following the BAG, ruled in 2007 that the statute’s bei Beendigung (at the end) means you can ask while your job is ending, not only after. Your employer cannot refuse to issue it just because your lawsuit over the dismissal has not been finally decided, the court added¹⁹. IHK Dresden’s guide recommends issuing it within a month of the request or departure, which is guidance, not law². If your employer is to blame for a delay, or for a reference that does not do your work justice, you may be owed damages, the BAG noted in 2003⁵.

Sources

All sources are in German except the English translation of the Civil Code.

1. Federal Labor Court (Bundesarbeitsgericht, BAG), judgment of November 18, 2014, 9 AZR 584/13. bundesarbeitsgericht.de/entscheidung/9-azr-584-13 (retrieved September 29, 2026)
2. IHK Dresden (Chamber of Industry and Commerce): Arbeitszeugnis: Rechte, Fristen & Formulierungen. Fact sheet. ihk.de/dresden/hauptnavigation/recht-steuern/merkblaetter-von-a-bis-z/arbeitszeugnis-rechte-fristen-formulierungen-6717034 (retrieved September 29, 2026)
3. IHK für München und Oberbayern (Chamber of Industry and Commerce): Arbeitszeugnis verfassen. Guide. ihk-muenchen.de/ratgeber/recht/arbeitsrecht/bestehende-arbeitsverhaeltnisse-kuendigung-sozialversicherung/arbeitszeugnis (retrieved September 29, 2026)
4. Regional Labor Court (LAG) Hamm, judgment of March 28, 2000, 4 Sa 1578/99. Justiz NRW (NRWE). nrwe.justiz.nrw.de/arbgs/hamm/lag_hamm/j2000/4_Sa_1578_99_Urteil_20000328.html (retrieved September 29, 2026)
5. Federal Labor Court (BAG), judgment of October 14, 2003, 9 AZR 12/03. Full text via lexetius.com (unofficial host). lexetius.com/2003,3626 (retrieved September 29, 2026)
6. Federal Labor Court (BAG), judgment of June 21, 2005, 9 AZR 352/04. Full text via lexetius.com (unofficial host). lexetius.com/2005,2294 (retrieved September 29, 2026)
7. Regional Labor Court (LAG) Hamm, judgment of May 22, 2002, 3 Sa 231/02. Justiz NRW (NRWE). nrwe.justiz.nrw.de/arbgs/hamm/lag_hamm/j2002/3_Sa_231_02urteil20020522.html (retrieved September 29, 2026)
8. Federal Labor Court (BAG), judgment of November 15, 2011, 9 AZR 386/10. bundesarbeitsgericht.de/entscheidung/9-azr-386-10 (retrieved September 29, 2026)
9. Federal Labor Court (BAG), judgment of April 27, 2021, 9 AZR 262/20. bundesarbeitsgericht.de/entscheidung/9-azr-262-20 (retrieved September 29, 2026)
10. Sende, C. C., Moser, K. & Galais, N. (2018). Die Leistungs- und Verhaltensbeurteilung in Arbeitszeugnissen. Zeitschrift für Arbeits- und Organisationspsychologie, 62(4), 169-187. Abstract. doi:10.1026/0932-4089/a000270 (retrieved September 29, 2026)
11. Federal Labor Court (BAG), judgment of December 11, 2012, 9 AZR 227/11. bundesarbeitsgericht.de/entscheidung/9-azr-227-11 (retrieved September 29, 2026)
12. Federal Labor Court (BAG), judgment of January 25, 2022, 9 AZR 146/21. bundesarbeitsgericht.de/entscheidung/9-azr-146-21 (retrieved September 29, 2026)
13. Section 109, German Trade Regulation Code (Gewerbeordnung, GewO): the employment reference. Consolidated text, gesetze-im-internet.de. gesetze-im-internet.de/gewo/__109.html (retrieved September 29, 2026)
14. Labor Court (ArbG) Herford, judgment of April 1, 2009, 2 Ca 1502/08. Justiz NRW (NRWE). nrwe.justiz.nrw.de/arbgs/hamm/arbg_herford/j2009/2_Ca_1502_08urteil20090401.html (retrieved September 29, 2026)
15. Federal Labor Court (BAG), judgment of October 4, 2005, 9 AZR 507/04. Full text via lexetius.com (unofficial host). lexetius.com/2005,3414 (retrieved September 29, 2026)
16. Federal Labor Court (BAG), judgment of September 21, 1999, 9 AZR 893/98. Full text via lexetius.com (unofficial host). lexetius.com/1999,1209 (retrieved September 29, 2026)
17. Section 126a BGB: electronic form. Consolidated text, gesetze-im-internet.de. gesetze-im-internet.de/bgb/__126a.html (retrieved September 29, 2026)
18. Federal Labor Court (BAG), judgment of May 10, 2005, 9 AZR 261/04. Full text via lexetius.com (unofficial host). lexetius.com/2005,2189 (retrieved September 29, 2026)
19. Regional Labor Court (LAG) Hamm, judgment of February 13, 2007, 19 Sa 1589/06. Justiz NRW (NRWE). nrwe.justiz.nrw.de/arbgs/hamm/lag_hamm/j2007/19_Sa_1589_06urteil20070213.html (retrieved September 29, 2026)
20. Section 195, German Civil Code (Bürgerliches Gesetzbuch, BGB): standard limitation period. Consolidated text, gesetze-im-internet.de. gesetze-im-internet.de/bgb/__195.html (retrieved September 29, 2026)
21. Section 199 BGB: start of the standard limitation period. Consolidated text, gesetze-im-internet.de. gesetze-im-internet.de/bgb/__199.html (retrieved September 29, 2026)
22. Fourth Bureaucracy Relief Act (Viertes Bürokratieentlastungsgesetz, BEG IV) of October 23, 2024, Federal Law Gazette (BGBl.) 2024 I No. 323, Articles 14, 36 and 74. recht.bund.de/bgbl/1/2024/323/regelungstext.pdf?__blob=publicationFile&v=1 (retrieved September 29, 2026)
23. German Bundestag, printed paper (Drucksache) 20/11306 of May 8, 2024: Federal Government bill for BEG IV, explanatory memorandum. dserver.bundestag.de/btd/20/113/2011306.pdf (retrieved September 29, 2026)
24. gesetze-im-internet.de: German Civil Code (BGB), English translation, version note. gesetze-im-internet.de/englisch_bgb/index.html (retrieved September 29, 2026)
25. gesetze-im-internet.de: German Civil Code (BGB), English translation, Section 630. gesetze-im-internet.de/englisch_bgb/englisch_bgb.html#p3066 (retrieved September 29, 2026)
26. Section 630 BGB: duty to issue a reference. Consolidated text, gesetze-im-internet.de. gesetze-im-internet.de/bgb/__630.html (retrieved September 29, 2026)

Published October 10, 2026 · Last updated October 10, 2026 · Wild Garden Editorial Team · Last verified October 10, 2026 · 189 of 189 source citations confirmed against the primary source · Our editorial standards · Spotted an error? redaktion@wildgarden.io

Not legal advice. German law only; statutes and case law as of September 29, 2026. Collective bargaining agreements and employment contracts can differ.

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