Integration administrative act without a hearing — § 24 SGB X and what you can do now

You open your mail and hold a decision in your hand: "Integration agreement replacing administrative act" or "Cooperation plan set by administrative act". It contains duties, deadlines, application numbers. But: you never had a conversation about it beforehand. No appointment, no call, no letter asking what you have to say about the planned points. In exactly such situations there is often a formal defect — and that makes the decision open to challenge.

The essentials in 30 seconds

• Before an adverse administrative act (Verwaltungsakt, VA), the Jobcenter has to hear (anhören) you — that is set out in § 24 SGB X.
• An "EGV-replacing VA" (old, § 15 SGB II old version) or a cooperation plan set by VA (§ 15a SGB II new version) is adverse — so a hearing is mandatory.
• No hearing, too short a deadline or only pro forma: that is a formal defect that grounds a right to revocation.
• Objection deadline: one month from delivery (§ 84 SGG). After that the decision becomes final.
• The defect can be healed (geheilt) during the objection procedure (§ 41 SGB X) — only if the Jobcenter does it properly.

We review your decision within 5 minutes. Free and non-binding.

Why does this happen?

An administrative act is a unilateral, sovereign order of the Jobcenter. If it contains duties, the authority is interfering with your rights. That is precisely why the law requires: before the Jobcenter imposes duties on you, it must give you a hearing (Anhörung) on the facts relevant to the decision (§ 24 Abs. 1 SGB X). You should have the chance to present the facts from your point of view before the stamp comes down.

In practice, this often does not work. Caseworkers are overburdened, measures should be "off the table fast". A conversation is short, one-sided, or never happens. Then the decision lands in your mailbox — and you read for the first time what you are supposed to do starting next week.

Concrete example: Frau B. is unemployed and has been receiving Bürgergeld since February 2026. She had a brief appointment at the Jobcenter at the beginning of March. Content: personal details, hand in sick note, "we will get back to you". On 14 April a letter arrives: cooperation plan set by administrative act. Content: 8 applications per month, a four-week application workshop, reporting duty every two weeks. She was never asked about these specific points. That is the classic hearing defect — and the basis for a successful objection.

Your rights in concrete terms

1. Hearing duty under § 24 SGB X

§ 24 Abs. 1 SGB X is clear: before an administrative act is issued that interferes with your rights, you must be given the opportunity to comment on the facts relevant to the decision. The integration VA and the cooperation plan set by VA both fall under this — because they impose duties whose breach can later trigger sanctions.

A hearing (Anhörung) means concretely: you must know that an adverse decision is imminent, you must know which duties are envisaged, and you must have time to comment on them. Brief small talk during the appointment is not enough. A standard clause "have been heard" in the decision is even less enough.

2. Typical hearing defects

In practice we see four patterns:

• No hearing at all: you receive the decision without any prior notice.
• Too short a deadline: you are heard but only have two or three days to respond. Case law: as a rule, at least two weeks are appropriate, more for complex matters.
• Formal but empty: a sentence like "you may comment until …" — without saying about what. You cannot defend yourself meaningfully like that.
• Unilateral imposition without conversation: for the cooperation plan (Kooperationsplan), § 15 SGB II expressly requires joint development. If the plan is set unilaterally without you ever having been involved in its creation, this too is defective.

3. Legal consequence: right to revocation

The hearing defect is a formal flaw. It does not make the VA void from the outset — but it grounds a right to revocation. If you file an objection, the Jobcenter must revoke the decision unless it heals the defect. The neat thing: in this case the courts do not even have to examine the content. The formal defect is enough.

4. Healing under § 41 SGB X

The Jobcenter may make up the defect until the conclusion of the objection procedure (§ 41 Abs. 1 Nr. 3, Abs. 2 SGB X). Concretely: it can subsequently hear you during the objection procedure, explain the planned duties to you and set a deadline. Important: the make-up must be functionally equivalent. A two-liner "please comment" is not enough. The Jobcenter has to set out concretely which facts form the basis — and then visibly engage with your objections.

5. Distinction: cooperation plan vs. EGV-VA

The difference matters in practice:

• The cooperation plan (Kooperationsplan) under § 15 SGB II new version is designed to be cooperative. It is jointly developed and is not an administrative act. If it really emerges jointly, there is no classic hearing problem.
• The EGV-replacing VA (old law, § 15 Abs. 3 SGB II old version) or a cooperation plan content set by VA under § 15a SGB II is, by contrast, unilateral. Exactly here the hearing duty applies — and exactly here it is often violated.

Rule of thumb: as soon as the decision says "Verwaltungsakt" and contains duties, you must have been heard beforehand. Content is not the focus here — that is examined on our sister page on the integration agreement by administrative act. This page is about the form.

6. Objection deadline and suspensive effect

Against the integration VA you can file an objection within one month of delivery (§ 84 SGG). The objection generally has suspensive effect (aufschiebende Wirkung) (§ 86a SGG). This means: until the decision, you do not have to fulfil the duties; sanctions are excluded in the meantime.

Current case law

Case law on the hearing has been settled for decades. The Federal Social Court (Bundessozialgericht, BSG) regularly emphasises that the hearing under § 24 SGB X is not a formality, but a central procedural right of the affected person. Its complete omission generally leads to revocability of the decision unless one of the narrow exceptions of § 24 Abs. 2 SGB X applies [URTEIL-REFERENZ].

For healing under § 41 SGB X the courts are strict: a mere reference in the objection decision that the affected person could "have commented at any time" is not enough. What is required is an independent, visible make-up of the hearing with presentation of the decision-relevant facts and serious engagement with the response [URTEIL-REFERENZ].

Specifically on integration administrative acts and cooperation-plan contents set by VA, there is now a growing number of social court decisions that expressly recognise hearing defects as grounds for revocation [URTEIL-REFERENZ]. Further relevant decisions will be added as soon as the editorial team has verified them.

How to act now

1. Read the decision carefully. Does it say "Verwaltungsakt" at the top and impose duties on you? Then the hearing duty applies. Check: was there an appointment or letter before the decision in which exactly these duties were announced?
2. Gather documents. Collect all invitations, conversation notes and letters of the past months. The more seamlessly you can show that no real hearing took place, the better.
3. Note the deadline. One month from delivery — the date at the top of the letter is your starting point. Mark the end of the deadline in your calendar in red.
4. File an objection. Informally and in writing. Example: "I file an objection against the administrative act of [date], file no. [no.]. Reasons to follow." By registered mail or in person against a stamp of receipt.
5. Submit reasoning. Within a few weeks send detailed reasoning — with the clear pointer: hearing under § 24 SGB X was not properly conducted. Describe chronologically what happened (and what did not).
6. Have the decision reviewed. The line between "proper hearing" and "merely formal" is tricky in individual cases. A trained outside view recognises faster whether the objection on the formal defect alone already has prospects of success.

Avoid these typical mistakes

• Treating "I was asked in the appointment" as a hearing. Small talk in which you did not know that exactly these duties were to be set by VA is not a hearing within the meaning of § 24 SGB X. Test rigorously: did you know that an adverse decision was imminent? Did you receive a deadline for written comments?
• Attacking only the content, not the form. Many concentrate in the objection only on whether the duties are substantively correct. The formal defect is, however, often the stronger lever — because it leads on its own to revocation, without the substantive discussion even being opened.
• Accepting the healing although it is incomplete. If the Jobcenter sends you in the objection procedure a sentence like "you may still comment", that is not proper healing. Insist on a real hearing with concrete factual presentation and a deadline.
• Giving up after the deadline. If you have missed the one-month deadline, the VA becomes final — but you can still file a review application under § 44 SGB X (Überprüfungsantrag). The chances of success are then lower, but not zero.

Frequently asked questions

Is it enough if I gave my "OK" during the Jobcenter appointment?

No, not automatically. A hearing under § 24 SGB X requires that the decision-relevant facts be specifically named to you and that you had a serious opportunity to comment on them. A short oral appointment in which you did not know that an adverse VA was imminent generally does not suffice. Check the conversation note or protocol if there is one.

What if the Jobcenter makes up the hearing in the objection procedure?

That is generally possible under § 41 SGB X ("healing"). What matters is that the make-up is serious: the Jobcenter has to set out the supporting facts in writing, give you a reasonable deadline for comments and engage with your response. If it remains a form letter, the defect persists — and revocation is again possible.

Do I have to fulfil the duties until the decision?

No. The objection against an integration VA generally has suspensive effect (§ 86a SGG). As long as your objection has not been decided, no sanctions can be derived from the duties of the decision. If the Jobcenter claims otherwise, you should have it reviewed.

Does the hearing duty also apply to the cooperation plan?

The genuine, jointly developed cooperation plan is not an administrative act — there the classic hearing question does not arise, because it precisely emerges from the joint process. If, however, individual contents are set by administrative act (§ 15a SGB II, e.g. after the joint creation has failed), § 24 SGB X applies fully again — then there must be a proper hearing before the VA is issued.

What does the objection cost me?

Nothing. The objection against a Jobcenter decision is free of charge. The later lawsuit before the social court is also free for benefit recipients under § 183 SGG. Counselling aid (Beratungshilfe) and legal aid (Prozesskostenhilfe) are generally available without difficulty for Bürgergeld recipients.

Have your decision reviewed now

An integration administrative act without a clean hearing is a classic among formal defects — and one of the most rewarding, because it can lead to revocation without substantive discussion. The deadline is short, memories fade.

We review your decision within 5 minutes. Free and non-binding.

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