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Back Germany's Pension Mandate for the Self-Employed: What Recommendation 22 Actually Says

Germany's Pension Mandate for the Self-Employed: What Recommendation 22 Actually Says

€735.63 a month, no opt-out for new freelancers, from 2027. What the pension commission really wants, and who can still say no.

Marc Clemens
Marc Clemens

Aug 30, 2026

Insurance Finances Legal studie
TL;DR

Germany's pension commission wants newly self-employed people, from a still-undetermined cutoff date likely 1 January 2027, folded into the statutory pension with no opt-out, at a standard rate of €735.63 a month, half that for the first three years. Anyone already self-employed keeps an unconditional opt-out. The contribution base runs at least 20% higher than an employee's, and identifying who is self-employed means a data exchange with the tax offices, raising the risk of more false self-employment cases. Run the €735.63 through your own numbers now, and check which group you fall into.

€735.63 a month. That is what a self-employed person in Germany pays in 2026 if they are covered by the statutory pension insurance at the standard rate. Whether that number is about to apply to you comes down to a single recommendation in a report almost nobody has read.

On 23 June 2026, Germany's pension commission handed over its final report with 33 recommendations. On 2 July, the coalition committee decided to implement them "fully and swiftly", and the legislation is meant to be finished by the end of 2026. Recommendation 22 is the one that decides your cash flow.

What Recommendation 22 actually says

The whole thing turns on two sentences, and the line they draw is not between rich and poor. It is between new and existing.

The labour ministry quotes the wording like this: the commission recommends including "all self-employed people without mandatory cover who start their activity from a cut-off date, compulsorily and without an opt-out" in the statutory pension insurance. Anyone already self-employed is included too, but can leave again through what the report calls an unconditional opt-out. No proof, no assessment, a declaration is enough.

No cut-off date appears anywhere. In its analysis, the VGSD assumes 1 January 2027 at the earliest, and says openly that this is an assumption. If you go freelance in 2027, that date is the difference between an obligation with no way out and a form you fill in once. It is the most important number in the debate, and it has not been set.

What it costs

The amount does not come from the report either. It comes from the VGSD's reading, which uses the standard contribution: 18.6% of the reference value. Both inputs are official. The Deutsche Rentenversicherung puts the 2026 reference value at €3,955 a month and the contribution rate at 18.6%. That gives €735.63. In the first three years after starting up it would be half, so €367.83. Anyone earning much less should be able to pay an income-based amount instead.

The catch sits in the assessment base. The VGSD's calculation is that contributions are levied on profit, which makes the base and every contribution on it "at least 20 percent higher" than for an employee on comparable income once the employer share is counted. The BAGSV statement of 6 August 2026, backed by 25 associations, turns that into a full picture: effectively 25.1% for health and care insurance, 22.3% for pensions, and for part-time self-employed people near the minimum thresholds already more than 60% combined.

What that does to a working month is easiest to see in a rule of thumb Lars Siegert gave beginners in his session. VAT goes straight into a second account, then:

"Set aside 30% for the income tax and 15 to 20% for the health insurance. At some point there is payday, and we need to have the money ready." (Lars Siegert)

Whatever is left, Lars says, is "more than 50%, and this is the money you can use freely". Add a standard pension contribution and that half stops being a half. Which is why this reform is not really a pension story. It is a liquidity story.

93% or 72%? Both numbers are right

The argument has run for months on two figures that look like they contradict each other.

In March 2026 the DIW checked who actually saves: 93% of self-employed people use at least one form of retirement provision, 7% none at all. On average they put more than a fifth of their net income into it, which is above the 18.6% the statutory system charges. Kritikos, Priem and Sohrweide therefore argue against a blanket mandate and for targeted support aimed at the small group on low incomes.

The pension insurance measures something else and lands somewhere else. Its Rentenupdate counts around 2.6 million self-employed people with no mandatory old-age cover, or 72%. And almost 18% of formerly self-employed people over 65 end up in the bottom income decile, against around 10% of former employees.

The gap is not a statistical trick. One number describes whether people save. The other describes whether they are required to. Politically the second one is winning, because old-age poverty among the self-employed is real even when 93% do something about it. A third number matters more for you: the DIW puts the poverty risk rate of the self-employed at 16.9% against 12.4% for employees. The spread is wide, and the average says very little about any individual case.

The Freelancer-Kompass 2026 shows how that lands in people's heads. 55% of respondents worry about their finances in retirement, up from 49% the year before. They put aside €1,167 a month on average, with a median of €800. And 80% can imagine working past retirement age. Worth noting on the side: the Aktivrente, which since 1 January 2026 lets people earn up to €2,000 a month tax free past retirement age, applies only to employees in social-insurance-liable jobs. More than 102,000 people have signed against that exclusion.

What was said on stage

Lilian Tschan, State Secretary in the Federal Ministry of Labour and Social Affairs, came to Freelance Unlocked 2026 and explained the government's logic without hedging. She cites Germany's 3.5 million people who are self-employed as their main occupation, more than half of them solo, and then the sentence the entire reform hangs on:

"Belonging to public social insurance cannot rest on what the working person feels like. It cannot be decisive whether someone believes they don't need the protection of a solidarity community." (Lilian Tschan)

Tschan points to the Covid support payments as evidence that self-employed people can misjudge their own exposure, and to the fact that the system needs reliable financing. Anyone who hears the applause in the room when the question of the statutory pension comes up understands why the argument does not land well in this community.

The sharpest framing came in the expert panel straight afterwards, from Professor Rainer Schlegel, former President of the Federal Social Court. He considers the question of principle long settled:

"For three legislative terms the coalition agreements have said we will build an insurance for all working people. That means all self-employed people are obliged to provide for old age. Everyone agrees on that, and I think it is coming. The only question is what form that provision has to take." (Rainer Schlegel)

His counter-proposal is the most pragmatic thing in the panel. The state may demand that nobody falls back on basic income support in old age, and should define a target to match, something like a reliable retirement income of around €1,000, or €1,300 with health cover included. How you hit that target is your business. Anything beyond it is not the state's job.

Jörn Freynick, General Secretary of the BAGSV, objects above all to pulling in people who are already self-employed. Every previous expert commission and the coalition agreement itself, Jörn says, treated this as a rule for future self-employed people. Charging everyone else on top of the contracts, property and other provision they are already paying into is, in his words, a punch in the stomach. That is exactly why the unconditional opt-out is in the recommendation. It is the compromise that makes the reform passable at all.

The part almost everyone misses: the data exchange

To enforce a duty, the state has to know who is self-employed. The VGSD points out that identification would run through a data exchange with the tax offices, and warns about the side effect: more prosecutions of self-employed people for alleged false self-employment. It wants the status determination rules reformed at the same time.

That worry is not theoretical. Silke Becker, Director Legal & Compliance at Etengo, walked the audience through what can happen under the leaked draft on "new self-employment": the client withholds and pays the pension contributions, then the tax office looks at integration and instruction, and suddenly payroll tax is on the table and input VAT is supposed to come back. Her verdict was short.

"In a lot of places this has not been thought through to the end. We get a completely new legal category that only applies to social insurance law. For a practitioner like me, that is a disaster." (Silke Becker)

Schlegel did the arithmetic on stage: 18.6% on 90% of the agreed fee up to the contribution ceiling, withheld and paid over by the client, exactly as it works for employees. That is the draft, not the law. But it shows the direction of travel, and how tightly the pension duty and the status question are now bolted together.

If your own setup is borderline, this is the moment to sort it out, not the moment after the data starts flowing. 9am's free false self-employment self-check follows the same logic auditors use and shows you in a few minutes which parts would draw attention. For how an audit actually runs and what contracts are worth in one, see our piece on false self-employment, pension insurance and contracts.

What to do on Monday

  1. Run your own standard contribution. €735.63 a month is €8,827.56 a year, half of that in the first three years. Put the number into your annual plan and look at what is left underneath it.
  2. Work out which group you are in. Anyone self-employed before the cut-off date gets an opt-out with no conditions as things stand. Anyone starting after it does not. If you were planning to go freelance anyway, that is an argument for sooner.
  3. Pull together the evidence for the provision you already have. Contracts, property, portfolios, professional pension schemes. An opt-out will probably need only a declaration, but any hardship rule will need numbers.
  4. Do the status check before the data routes exist. A clean contract, real client diversity and documented entrepreneurial activity protect you against both reforms at once.
  5. Make some noise. The associations are collecting positions for the next draft round right now. The advice from the expert panel was refreshingly unbureaucratic: pester your local member of parliament until they do something about it. For who is fighting for what, see our overview of the political landscape for freelancers in Germany, and for the ministry's own plans, our piece on the BMAS reforms for self-employment.

You cannot negotiate away a statutory duty. You can negotiate away a thin project pipeline. If your contributions become fixed costs, the number of billable project days matters more than ever: create a free profile on 9am and let companies across DACH match against what you actually do.

Freelance Unlocked is co-organized by 9am together with Uplink and freelancermap. This article draws on the sessions of Lilian Tschan and the expert panel on the false self-employment reform at Freelance Unlocked 2026. Watch the full talks above, and join us at the next edition: freelanceunlocked.com.

Marc Clemens

Founder & Product Builder

Marc has spent more than a decade building recruiting and job marketplaces. He founded 9am to make freelance work simpler for both sides, and organizes the Freelance Unlocked conference.

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