Opening a psychology practice in Germany without an Approbation: counselling, coaching, Heilpraktiker licence

What you may offer in a psychology practice without an Approbation

The line is drawn by the Heilpraktikergesetz (Alternative Practitioners Act): anyone who professionally diagnoses, cures or alleviates illness practises Heilkunde (the healing professions) and needs a licence for it (§ 1 HeilprG). Practising Heilkunde without a licence is a criminal offence (§ 5 HeilprG). Activities that only concern social conflicts or purposes outside Heilkunde are not included (§ 1(2) sentence 3 PsychThG). This results in four types of service:

Many combine several services: counselling and coaching for people in crises, separations or under stress, diagnostics for schools or companies and, with a Heilpraktikererlaubnis, the treatment of anxiety or depression. What matters is that your clients can tell from your website and the first session what you are offering in their case.

Professional title: what you may call yourself

• Academic degree: You may use “Diplom-Psycholog:in” or “M.Sc. Psychologie” with the corresponding degree. Academic degrees are protected under criminal law (§ 132a StGB).
• “Psycholog:in”: No professional law regulates the title. But it is considered misleading if there is no completed degree in psychology behind it (§ 5 UWG; OLG Schleswig, judgment of 21 July 2016, 6 U 16/15).
• With a Heilpraktikererlaubnis: for example “Heilpraktiker:in für Psychotherapie” or “Heilpraktiker:in, beschränkt auf das Gebiet der Psychotherapie”, ideally combined with your degree.
• What is not allowed: Without an Approbation, you may not use the title “Psychotherapeut:in” or one that could be confused with it (§ 1(1) PsychThG, § 132a StGB).
• Free to choose: descriptions of your activity such as “Psychologische Beratung” (psychological counselling), “Coaching” or “Psychologische Diagnostik” (psychological diagnostics).

Heilpraktiker für Psychotherapie: the limited licence

Since a 1993 ruling by the Federal Administrative Court (3 C 34.90), the Heilpraktikererlaubnis can be limited to psychotherapy. The responsible body is the Gesundheitsamt (public health office) or the authority at your place of residence or future practice location. The requirements are set out in § 2 of the implementing regulation to the Heilpraktikergesetz:

For psychologists, the assessment is often shortened: if you have a Diplom or master’s degree in psychology in which clinical psychology was an examination subject, many authorities decide based on your records, that is, without an exam. Practice differs between federal states and authorities; the city of Munich, for example, grants the licence to Diplom psychologists with clinical psychology without a separate exam. Before applying, ask which documents your authority requires.

Psychological counselling, coaching and diagnostics without Heilkunde

Without a Heilpraktikererlaubnis, your services stay outside Heilkunde. That is a large field, but it requires a clear line in everyday work:

• Counselling and coaching: questions about life, relationships and parenting, career changes, stress, conflicts. You don’t make ICD diagnoses and don’t promise a cure.
• Suspected illness: If a client seems depressed, suicidal or traumatised, refer them to their GP, a psychiatrist or 116117 (the on-call medical service) and document this. Without a licence, you may not treat the disorder.
• Diagnostics and expert reports: aptitude and performance testing, personnel selection or expert reports commissioned by courts and authorities. Some fields, such as driving aptitude assessment, require their own accreditation.
• Supervision, training, workshops: for teams, clinics, schools and companies; here references and clear offers count for more than the website alone.

Fees and billing: self-paying clients, private insurance, Beihilfe

• Statutory health insurance: It pays neither for counselling nor for treatment by psychologists without an Approbation, not even with a Heilpraktikererlaubnis. Reimbursement under § 13(3) SGB V (Fifth Book of the Social Code) is not available to your clients either.
• Private health insurance: Some policies reimburse services by Heilpraktiker:innen (alternative practitioners), often with caps; psychotherapy by Heilpraktiker:innen is frequently limited or excluded. Your clients should check with their insurer beforehand.
• Beihilfe (state allowance for civil servants): Psychotherapy by Heilpraktiker:innen is usually not eligible.
• Self-paying clients: The norm for most practices. You set your fee freely; many use the Gebührenverzeichnis für Heilpraktiker (GebüH, fee schedule for alternative practitioners) as a guide, but it is not a binding fee scale.
• Transparency: State your fee, the length of a session and your cancellation rules on the website and in writing before you start. People who know that no insurer will pay make a more conscious decision.

Freelance profession or trade? Taxes and insurance

You register with the tax office using the Fragebogen zur steuerlichen Erfassung (tax registration questionnaire). Two questions decide how much effort is involved: whether you work as a freelancer and whether your services are subject to VAT.

• Freelance profession: With a Heilpraktikererlaubnis, you belong to the listed professions under § 18(1) No. 1 EStG (Income Tax Act). For counselling, coaching, training or diagnostics, it depends on the specific activity; the tax office may also classify it as a trade, with trade registration, IHK (chamber of commerce) membership and possibly trade tax.
• VAT: Treatments under a Heilpraktikererlaubnis are exempt (§ 4 No. 14(a) UStG). Counselling without treatment, coaching, supervision and most expert reports are usually taxable at 19%.
• Small business exemption: Since 2025, it applies if your turnover was at most €25,000 in the previous year and does not exceed €100,000 in the current year (§ 19 UStG). Your exempt treatments don’t count towards this.
• Pension insurance: If you mainly give courses, training or seminars and have no employees, you may be subject to compulsory pension insurance as a self-employed teacher (§ 2 sentence 1 No. 1 SGB VI). Clarify this early with the Deutsche Rentenversicherung (German pension insurance).
• No chamber: Without an Approbation, you are not a member of a chamber and have no professional code. Professional associations such as the BDP voluntarily offer ethical guidelines, advice and group contracts.
• Professional liability insurance: Not required by law, but strongly recommended. Make sure that counselling, diagnostics and, where applicable, Heilkunde under the Heilpraktikergesetz are expressly covered.

Confidentiality, premises and data protection

As a psychologist with a Diplom or master’s degree, you are bound by confidentiality under criminal law: § 203(1) No. 2 StGB expressly names “Berufspsychologen mit staatlich anerkannter wissenschaftlicher Abschlußprüfung” (professional psychologists with a state-recognised academic final examination) – regardless of whether you counsel or treat under a Heilpraktikererlaubnis. Data on mental health is specially protected under Art. 9 GDPR. For your practice, this means:

A website that clearly defines your services

Without access to the statutory insurance funds, almost all clients come through recommendations and their own online search. Your website therefore has to do two things: build trust and state unmistakably what you offer. Advertising involving Heilkunde is also subject to the Heilmittelwerbegesetz (Therapeutic Products Advertising Act).

Which details belong in the Impressum (legal notice) is explained in the post on mandatory information for psychology practices; you can create a complete legal notice with the legal notice generator. Which advertising is allowed is covered in the post on advertising rules for psychologists. How to get found in your city is shown in the posts on the Google Business Profile and local SEO.

Checklist: seven steps to your psychology practice

How to plan location, financing and the steps of starting a practice in general is described in the guide to opening a practice in Germany.