Integration agreement by administrative act — and what your objection can achieve now

You are holding a multi-page decision that prescribes applications, counselling appointments and measures — at the top it says "Eingliederungsvereinbarung ersetzender Verwaltungsakt" (integration agreement by substituting administrative act). It sounds technical, feels strict, and at the end a sanction (Sanktion) looms. Many of these decisions do not stand up to closer scrutiny.

This page explains what a Widerspruch (objection) against an Eingliederungsvereinbarung Verwaltungsakt actually does, why such legacy decisions still exist although the integration agreement was replaced by the cooperation plan (Kooperationsplan) in 2023, and where the most common errors lie.

The most important points in 30 seconds

• Since the Bürgergeld-Gesetz of 2023 there are no new integration agreements (Eingliederungsvereinbarung, EGV) — they have been replaced by the cooperation plan (Kooperationsplan) (§ 15 SGB II new version).
• The cooperation plan (Kooperationsplan) does not trigger direct sanctions (Sanktion) — unlike the old EGV by administrative act (Verwaltungsakt).
• Old EGV decisions from before July 2023 partly remain in force and are sometimes still used in 2026 as a basis for sanctions.
• An administrative act (Verwaltungsakt) must be concrete, definite and individual — blanket duties like "10 applications per month" without individual-case examination can be challenged.
• Objection deadline: one month from service (§ 84 SGG). After that the decision becomes final.
• An objection (Widerspruch) against the EGV by administrative act has suspensive effect — until a decision is reached you do not have to fulfil the duties and no sanctions threaten.

We review your decision within 24 hours. Free and non-binding.

Why does this happen at all?

Until 30 June 2023, benefit recipients had to conclude an integration agreement (Eingliederungsvereinbarung, EGV) with the Jobcenter — a kind of contract setting out duties on both sides. If no agreement could be reached, the Jobcenter was allowed to replace the agreement unilaterally by administrative act (Verwaltungsakt) (§ 15 Abs. 3 SGB II old version). This "substituting administrative act" was the core mechanism with which Jobcenters could enforce duties if the claimant did not sign the contract.

The Bürgergeld-Gesetz fundamentally changed this system. Since 1 July 2023 the rule is: the Jobcenter draws up a cooperation plan (Kooperationsplan) together with you (§ 15 SGB II new version). This plan records what suits you professionally, which steps you want to take and what support the Jobcenter offers. The cooperation plan is not an administrative act — and if you do not sign it, there is no automatic replacement decision any more. Sanctions (Sanktionen) cannot follow directly from the cooperation plan but only from specific individual requests.

A concrete example: Herr R. has been receiving Bürgergeld since 2022. His case worker handed him an integration agreement by administrative act in May 2023 — that is, still under the old law — limited to twelve months. Among other things it states: "You will apply to at least ten positions subject to social security contributions each month and submit proof unrequested." In April 2024 the Jobcenter asks for the application evidence — Herr R. has only six applications. The Jobcenter announces a sanction for breach of duty (Pflichtverletzung). But the blanket ten-applications duty is exactly the type of clause that Social Courts keep striking down.

Your rights in concrete terms

An administrative act that imposes duties on you must meet several formal and substantive requirements. If even one is violated, the decision can be partially or fully unlawful — and with it any sanction derived from it.

1. Definiteness (§ 33 SGB X)

An administrative act must be substantively sufficiently definite. You must know exactly what is required of you, by when and in what form. Phrasings like "You make intensive efforts to find work" or "regular applications" are too vague. Likewise too indefinite: a number with no link to your specific placement situation — that is, "ten applications per month" without any check on how many suitable positions even exist in your region.

2. Individual focus (§ 15 SGB II old version)

The old EGV had to be tailored to you personally: qualifications, health, family situation, mobility. A decision with text modules that could be swapped onto any other benefit recipient does not meet that standard. Copied duty catalogues without individual case reference are a classic point of attack.

3. Suitability and reasonableness

Every duty must be suitable to advance your integration into work, and reasonable (zumutbar). Ten applications per month for a 55-year-old with a back condition and no driving licence in a structurally weak region are generally neither suitable nor reasonable. Equally problematic: duties to take part in measures for which there is no free place, or in trainings that do not take your health into account.

4. Legal consequences notice (Rechtsfolgenbelehrung)

The decision must clearly explain what sanction (Sanktion) threatens if you do not fulfil the duties. The legal consequences notice (Rechtsfolgenbelehrung) must be concrete, understandable and tailored to your case. A blanket hint like "In case of breach, benefit reductions threaten" is not sufficient according to settled case law [URTEIL-REFERENZ].

5. Objection and suspensive effect (§ 84, § 86a SGG)

You can file an objection (Widerspruch) within one month against the administrative act (§ 84 SGG). The objection against an EGV by administrative act usually has suspensive effect (aufschiebende Wirkung) (§ 86a Abs. 1 SGG) — meaning: as long as the objection has not been decided, you cannot be sanctioned on the basis of the EGV. That is one of the most important differences to the sanction decision itself, where suspensive effect is excluded.

6. Transition into the new law

Legacy decisions from before July 2023 do not automatically lose their force. They often continue until the originally intended end date, usually six or twelve months. Many have expired by now — but not all. If a legacy decision was extended or reissued, that is problematic from today's perspective: under the new § 15 SGB II, this legal figure no longer exists in that form. A "substituting administrative act" newly issued in 2024 or later is usually unlawful.

Current case law

On the old integration agreement by administrative act there is extensive case law — which also remains relevant for legacy decisions still in force today.

The Federal Social Court (Bundessozialgericht, BSG) has repeatedly stressed that an EGV must be tailored to the individual situation and that blanket duty catalogues do not meet the requirements for an administrative act [URTEIL-REFERENZ]. State Social Courts (Landessozialgerichte) have also set aside decisions in numerous rulings that did not contain a sufficiently definite legal consequences notice (Rechtsfolgenbelehrung) or imposed duties whose fulfilment was hopeless from the outset [URTEIL-REFERENZ].

Important for the transition: the Bürgergeld-Gesetz recast the entire sanction system in § 31 ff. SGB II. A sanction (Sanktion) based on a duty derived from an old EGV by administrative act must today meet both the old requirements for the EGV and the new sanction provisions. In practice this produces many sources of error — and often makes objections successful.

Further relevant BSG and LSG decisions will be added as soon as the editorial team has verified them: [URTEIL-REFERENZ].

How to proceed now

1. Classify the decision. Read the top of the document: does it say "Eingliederungsvereinbarung", "Verwaltungsakt" or "Kooperationsplan"? Only the first two directly give rise to sanction risks. A cooperation plan (Kooperationsplan) on its own is harmless.
2. Note the deadline. An administrative act has a Rechtsbehelfsbelehrung (instructions on legal remedies) at the end. From service you have one month to file an objection. Write the deadline down in a clearly visible way.
3. Go through the duties. Mark every single duty. Check: is it concrete? Is it tailored to your situation? Is it feasible? Blanket application quotas, undefined "cooperation" or unsuitable measures are suspicious.
4. File an objection (Widerspruch). Informally, in writing: "I file an objection against the administrative act of [date], file number [number]. The reasoning will follow." By post with registered delivery or in person against a receipt stamp.
5. Submit the reasoning. Send a detailed reasoning within a few weeks — with the concrete points you consider unlawful. Definiteness (Bestimmtheit), individuality, suitability, legal consequences notice (Rechtsfolgenbelehrung).
6. Have the decision reviewed. Many legacy decisions fall apart under detailed scrutiny — laypeople often cannot see the formal errors. An outside perspective recognises more quickly whether an objection has prospects of success.

Typical mistakes to avoid

• Accepting blanket duties. "You apply ten times per month" without reference to your qualifications, your labour market or your health is a classic point of attack. Do not be intimidated — such wordings often do not hold up.
• Confusing the cooperation plan with the EGV. The new cooperation plan (Kooperationsplan) is a joint agreement, not a decision. Anyone who does not sign it cannot be directly sanctioned for that. Only if the Jobcenter subsequently sends you a concrete individual request (appointment, application, measure) can a sanction result from non-compliance.
• Missing the deadline. After one month the administrative act becomes final (bestandskräftig) — even if it is clearly unlawful. A brief informal objection is enough to preserve the deadline; the reasoning can be submitted later.
• "Voluntarily" signing too quickly. Some Jobcenters present old EGVs for signature as if they were a contract. If you sign, the EGV becomes a real contract — an objection is then harder. Better to have it reviewed first, then decide.

Frequently asked questions

Do I have to fulfil the duties from the old EGV despite an objection?

No. An objection (Widerspruch) against an integration agreement by administrative act usually has suspensive effect (aufschiebende Wirkung) (§ 86a SGG). As long as no decision has been reached, no sanctions may be derived from the duties. That applies even if the Jobcenter claims otherwise.

Can the Jobcenter still serve an EGV by administrative act on me today?

No — for new cases this legal figure has not existed since 1 July 2023. It was replaced by the cooperation plan (Kooperationsplan). If you now receive a decision labelled as "Verwaltungsakt" that imposes integration duties on you, that is a strong indication of an error — an objection is then particularly worthwhile.

What is the difference between the cooperation plan and the EGV by administrative act?

The cooperation plan (Kooperationsplan) is drawn up jointly and is not a unilateral order. It is not an administrative act and does not create direct sanctions — neither on failure to sign nor on non-fulfilment of individual points. The old EGV by administrative act, by contrast, was a unilateral imposition of duties that the Jobcenter could enforce directly with sanctions. The switch to the cooperation plan was consciously a softening of the system.

What happens if I do not sign the cooperation plan?

No sanction follows from that. However, the Jobcenter can require specific duties of you separately — such as an appointment, a particular application or a measure. Only if you receive a concrete individual request with a correct legal consequences notice (Rechtsfolgenbelehrung) and do not comply without an important reason, can a benefit reduction (Leistungsminderung) follow.

How long do old EGVs from before July 2023 still apply?

Until the end date set out in the decision — usually six or twelve months after issue. Most old EGVs have now expired. If you still receive a sanction decision today based on an old EGV, it is worth closely checking both levels: was the EGV actually still in force during the sanction period? And was it formally correct?

Have your decision reviewed now

The integration agreement by administrative act is a discontinued model — but a persistent one. Many legacy decisions still have effect, some Jobcenters issue new ones despite the legislative change. Definiteness (Bestimmtheit), individual focus, legal consequences notice (Rechtsfolgenbelehrung) and the clean transition into the new law: these are four adjusting screws where many of these decisions can be overturned.

We review your decision within 24 hours. Free and non-binding.

Send us a photo of your decision — and we will get back to you with a clear assessment.