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Digital compulsory on jobcenter.digital causes significant problems for those receiving citizens' benefit
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dossier
“Many recipients of citizen's benefit use the jobcenter.digital portal to communicate more easily and quickly with their job center and to be informed in advance about invitations, notices, etc. without having to forgo sending them by post, as experience has shown that postal delivery is not always reliable and punctual. However, since November 18, 2024, anyone who wants to use jobcenter.digital must declare that they will forego the delivery of all documents by post. Without this general waiver it is no longer possible to use jobcenter.digital…”Post by Ottokar from March 14, 2025 on gegen-hartz.de
with information on the legal situation and practical problems and:
- Further approval applications no longer in paper form: de facto compulsion to use Jobcenter.digital as an illegal access barrier?
“The Bremen job center and other jointly-established job centers explain in information letters to benefit recipients that “no further approval applications will be sent by post in the future”. At the same time, it is pointed out that the application for further approval can be submitted “simple and uncomplicated” via Jobcenter.digital.The relevant information letter is available here:https://t1p.de/wmk4v
Other job centers also announce this, see e.g. B. the Kaiserslautern job center:https://t1p.de/zacxj
Comment: I consider this administrative practice to be unlawful. Section 37 SGB II stipulates that there is freedom of form when submitting an application. This means: Applications can still be submitted in paper form. By stopping sending application forms, the job centers initially want to save postage costs. At the same time, they apparently hope that benefit recipients will forget to apply for continued approval and thus stop receiving benefits.
On the other hand, the job centers are obliged to provide comprehensive advice to SGB II benefit recipients. The duty to provide advice is an official duty. According to case law, this includes:"In social law, social service providers have special obligations to provide advice and support. Comprehensive advice to the insured person is the basis for the functioning of the increasingly complicated social benefit system. The focus is no longer just on answering questions or requests for advice, but rather the understanding support of the insured person, i.e. the attentive examination by the clerk to determine whether there is reason to point out to the insured person, even ex officio, options for shaping the situation or disadvantages that are related to his concerns, rather than specific ones Questions require expertise that the insured often does not have.” BGH, judgment of August 2, 2018 – III ZR 466/16
This obligation to provide information is referred to as spontaneous advice. It is mandatory according to Section 14 SGB I. This means: The job center must point out an impending non-payment of benefits, see also:https://t1p.de/4n8k7
The job centers systematically attempt to circumvent this obligation to provide advice with this procedure.
At the same time, the paper application forms will disappear from the BA websites and the job centers of the joint institutions. This effectively forces people to only submit applications via Jobcenter.digital. As long as the analogous application is not legally excluded, this is illegal.
Alternatively, the current application forms can be downloaded from Tacheles:https://t1p.de/rttgs
In addition, according to Section 17 Paragraph 1 SGB I, job centers have a legal obligation to ensure that access to social benefits is organized without unnecessary access barriers. However, the actual obligation to use Jobcenter.digital creates precisely such access barriers.
By stopping sending paper documents, the job centers want to urge those entitled to benefits to use Jobcenter.digital. If Jobcenter.digital is actually offered as the only communication channel and the paper applications disappear, this amounts to forced use of this communication channel.
The BA must understand that there will always be people who cannot cope with digital access, who do not have the appropriate devices or data volume or who cannot read and write sufficiently. Therefore there must always be an analogue access. There is also a need for citizens' offices where people with difficulties can go to receive support - and not rejection.” From theThomé Newsletter 33/2026 from September 27, 2026
(“Subsequent authorization applications are no longer on paper”) - Analogue access routes to job centers should be retained
“The Federal Government is in favor of maintaining analogue access to basic security benefits for jobseekers on a permanent basis. Those entitled to benefits should not suffer any legal disadvantages if they do not use the digital offerings. This is evident from the Federal Government's response (Printed matter 21/7276
) in response to a small question from the Die Linke faction (Printed matter 21/6621
) out. At the same time, the federal government admits that there have been repeated difficulties with registration and authentication in the online portal of the Federal Employment Agency (BA). In particular, the mandatory multi-factor authentication introduced after a security incident caused additional challenges. In order to make access easier, the Federal Employment Agency says it has expanded technical support and created another option for registration with the “BA-Secure app”..” From theThomé Newsletter 28/2026 from August 23, 2026
, see also:
- Basta Unemployed Initiative: “Why we advise against only communicating digitally with the #Jobcenter:
The central point for us why we reject digital contact with the job center is that the digitalization of all areas of life should make people and human actions unnecessary.
We have something against that. There are also some practical problems with the digital platform of the #Jobcenter: Using “Jobcenter digital” often requires new devices (computers, cell phones or laptops). They are expensive and many of us cannot afford them. And if I take part in digital communication with the #Jobcenter, then I have to agree to only communicate digitally with the authority. The thing is neither multilingual nor barrier-free. Encryption doesn't work, it doesn't exist. Uploading documents often doesn't work
The whole story is prone to disruption. The status of the application process cannot be properly understood and documents continue to disappear, but then I don't have any witnesses. We therefore recommend that you continue to communicate via paper.”Thread by bastaberlin from August 18, 2026 on bsky
- Basta Unemployed Initiative: “Why we advise against only communicating digitally with the #Jobcenter:
See also our dossierDigitalcourage campaign: Report digital compulsory measures (not just at the railways)!and the entire sectionThe employment agency and its “customer data”
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