Should nurses pay recruitment fees? How to spot recruitment scams
Quick answer: No. For UK and German nursing jobs, you should not pay a recruiter any fee to find you a job. The employer pays the recruiter. You may have to pay some of your own costs, such as English tests, regulator fees or a visa fee, and a fair contract may ask you to repay some costs if you leave early. But anyone who asks for a "placement fee", "processing fee" or money for a "visa slot" is breaking the rules or scamming you.
This guide explains the rules in the UK, Germany and the USA, which countries are on the UK "red list", what repayment clauses are legal, and how to check a recruiter before you send money or documents.
The UK rules: no fees to nurses
The Department of Health and Social Care's Code of Practice for the international recruitment of health and social care personnel (last updated 27 March 2025) applies to NHS employers, local authorities, private health and care providers, and the agencies that supply them in England.
The key rules for you:
- No fees to candidates. Recruitment agencies must not charge candidates for recruitment services. Employers must not use agencies that charge candidates fees.
- Use of ethical recruiters. Employers should only use recruiters on the NHS Employers Ethical Recruiters List.
- Clear information. You should get clear details of the job, pay and contract before you commit.
- Fair repayment clauses only (see below).
Separately, Home Office sponsor guidance says employers must not recover the sponsor licence fee or the certificate of sponsorship fee from workers. If they do, they will normally lose their licence. UK employment agency law also generally stops agencies charging work-seekers for finding them work.
What you may still pay yourself
| Cost | Can you be asked to pay? | Notes |
|---|---|---|
| Recruiter's placement or "service" fee | No | Against the Code; a strong red flag |
| Certificate of sponsorship (CoS) fee | No | Employer must pay; cannot recover it from you |
| Immigration Skills Charge | No | Employer cost; cannot be reclaimed through a repayment clause |
| Interview costs | No (cannot be reclaimed) | Listed in the Code as non-recoverable |
| IELTS/OET, CBT, NMC fees | Yes, often | Paid to official bodies, not to an agent. Many employers refund some costs |
| Visa fee | Yes, often | Paid to the Home Office on GOV.UK. Some employers refund it |
| Flights, first accommodation, OSCE fee | Depends on employer | Often paid by the employer, sometimes with a repayment clause |
A simple test: money should go to official bodies (the test provider, the NMC, the Home Office), never to an agent's personal bank account. See our Health and Care Worker visa guide for the official fees.
Repayment clauses and "training bonds": what is legal
Many UK employers pay for your flights, OSCE, visa or accommodation. In return, your contract may say you must repay some of these costs if you leave early. This is allowed, but the Code says repayment clauses must be transparent, proportionate, time-limited and flexible.
| If you leave within… | Maximum you should repay (Code example) |
|---|---|
| 0–12 months | Up to 100% of itemised costs |
| 13–24 months | Up to 50% |
| 25–36 months | Up to 25% |
| After 36 months | Nothing |
The Code also says:
- Costs must be itemised – real costs, listed one by one, not a round "penalty" number.
- Employers must not reclaim agency fees, the Immigration Skills Charge, sponsor licence fees, certificate of sponsorship costs or interview costs.
- No interest can be added, and payment in cash is not acceptable.
The red list and amber list (UK)
The UK does not actively recruit health workers from countries with severe health worker shortages. These countries are based on the WHO Health Workforce Support and Safeguards List.
| List | Countries (examples) | What it means |
|---|---|---|
| Red (54 countries) | Nigeria, Ghana, Zimbabwe, Pakistan, Bangladesh, Ethiopia, Uganda, Tanzania, Zambia, Cameroon and others | No active recruitment by UK employers or agencies |
| Amber | Kenya, Nepal | Active recruitment only through the government-to-government agreements |
| Green (not on either list) | India, the Philippines, Sri Lanka, Malaysia and others | Ethical recruitment allowed. India, Malaysia, the Philippines and Sri Lanka also have government-to-government agreements |
See the full red and amber list on NHS Employers. The list depends on where you live, not your nationality.
What this means for you
- If you live in a red list country such as Nigeria or Ghana, you can still apply directly to a job advertised by a UK employer, on your own. What is not allowed is an agency or employer targeting you.
- So if an agent in Lagos or Accra says "pay us and we will get you an NHS job", this breaks the Code. Ethical agencies in the UK are not allowed to recruit you actively.
- If you live in Kenya or Nepal, look for recruitment run under the official government agreement.
Germany: "Faire Anwerbung Pflege Deutschland"
Faire Anwerbung Pflege Deutschland (Fair Recruitment Nursing Germany) is a state quality seal owned by the German Federal Ministry of Health. It is awarded to recruitment agencies and employers that recruit nurses from outside the EU and pass independent audits.
- Employer-pays principle: recruitment must be free for nurses. Recruitment costs are not passed on to you.
- Transparency: you get clear information about the process and who to contact.
- Your rights in writing, in a language you understand.
The seal is voluntary, so not every honest agency has it. But you can check certified agencies on the seal website. German law (Section 38 of the Employment Ordinance) also says that only the Federal Employment Agency may recruit health and care workers from countries on the WHO list.
In Germany, some contracts ask you to repay language course costs if you leave early. If you are unsure whether a clause is fair, Faire Integration gives free, anonymous advice on work issues to migrants from outside the EU. See our Germany nurse visa guide for more.
USA: ethical recruitment and breach fees
The USA has no single national rule like the UK Code. Key points:
- The Alliance for Ethical International Recruitment Practices, run by TruMerit (formerly CGFNS), has a Health Care Code for ethical recruitment and certifies recruiters as "Certified Ethical Recruiters". Ask any US recruiter whether they are certified, then check with TruMerit.
- For green card cases, US rules require the employer to pay the costs of the labour certification step. See our EB-3 green card guide.
- Some US contracts include large breach fees ("liquidated damages") if you leave early. In Paguirigan v. Prompt Nursing Employment Agency (2019), a US federal court ruled that one agency's breach clauses were unenforceable penalties and that its threats broke US anti-trafficking law. This does not mean every breach fee is illegal. Rules depend on the state and the contract, so get advice before you sign.
Red flags checklist
Stop and check if you see any of these:
- You are asked to pay a placement, registration, processing or "visa slot" fee to an agent.
- Payment must go to a personal bank account, UPI ID, crypto wallet or cash.
- A "guaranteed" job or visa. No honest recruiter can guarantee a visa.
- You get a job offer without an interview, or after a short chat on WhatsApp only.
- The employer's emails come from Gmail, Yahoo or Outlook addresses, not the employer's own domain (for NHS trusts, usually nhs.net or nhs.uk).
- You are told you can skip the NMC, CBT, OSCE or English test, or are offered a certificate for money.
- The "nurse" job has a care worker occupation code (6135 or 6136), or the salary is below Band 5 with no explanation.
- Pressure to pay or sign today.
- They ask for your original passport or certificates to "keep safe".
- A contract with a huge fixed penalty, interest, or costs that never reduce.
- The agency says it recruits nurses from red list countries for UK jobs.
- The company is not on Companies House, or its registered address does not match.
How to verify a recruiter: step by step
- UK: search the NHS Employers Ethical Recruiters List (updated monthly; last update 30 October 2026). Being on the list is not a recommendation, but being missing is a warning sign for UK health jobs.
- Check the company on Companies House (UK) or the official company register of the country where it says it is based.
- Check the employer is a licensed sponsor. GOV.UK publishes a "Register of worker and temporary worker licensed sponsors". Search for the employer's exact name.
- Confirm the job directly with the employer. Find the NHS trust's phone number or email on its own official website (not from the agent), and ask if the offer is real.
- India: recruiting agents must be registered with the Ministry of External Affairs. Ask for the registration number and check it on the eMigrate portal. Indian rules also cap what a registered agent may charge a worker (the Emigration Rules say ₹30,000 plus GST; some older MEA pages show ₹20,000). For UK and German jobs, though, the ethical codes say you should pay the agent nothing.
- Germany: check the Faire Anwerbung Pflege Deutschland list of certified agencies.
- USA: ask TruMerit whether the recruiter is a Certified Ethical Recruiter.
Illustrative example (not a real person): a nurse in Hyderabad gets a WhatsApp message offering "NHS Band 5, visa guaranteed, ₹3 lakh processing fee, pay 50% now". She searches the agency name on the Ethical Recruiters List and finds nothing. She looks up the NHS trust named in the offer, emails its international recruitment team from the address on the trust's own website, and is told they have never heard of the agent. She does not pay, saves the chat, and reports it on the MADAD portal and to Report Fraud.
Where to report scams and unfair treatment
| Problem | Where to report |
|---|---|
| Fraud or scam (England, Wales, Northern Ireland) | Report Fraud (replaced Action Fraud): reportfraud.police.uk or 0300 123 2040 |
| Fraud or scam (Scotland) | Police Scotland on 101 |
| Forced work, threats, passport taken, unsafe housing in the UK | Modern Slavery and Exploitation Helpline 08000 121 700; 999 in an emergency |
| UK recruiter breaking the Code | NHS Employers international recruitment team (Internationalrecruitment@nhsconfed.org) – they can investigate and remove recruiters from the list |
| Indian recruiting agent (registered or illegal) | Protector General of Emigrants / Protector of Emigrants office, via eMigrate; the MADAD portal; or the Indian embassy or high commission. See MEA guidance |
| Germany – work rights, pay, contract problems | Faire Integration advice centres (free) |
Before you report, save everything: chats, emails, payment receipts, bank details you were given, phone numbers and the agent's social media pages.
Common mistakes
- Paying "just a small deposit". Scammers often start small, then ask for more.
- Trusting a logo. NHS and government logos are easy to copy. Verify through official contact details.
- Thinking a fee means a better service. In the UK and Germany, ethical recruitment is free for nurses.
- Not reading the repayment clause until after you arrive.
- Sharing your NMC, OET or IELTS login with an agent. Keep control of your own accounts.
- Not reporting. Reporting helps protect the next nurse, even if you did not lose money.
Nurse Pathways Abroad is free for nurses. We never charge you, and we cannot promise jobs or visas. If you want an honest view of your route, use our "Check your route" form on the home page.
Frequently asked questions
Is it legal for a recruiter to charge a nurse a fee for a UK job?
UK health and social care employers must not use recruiters that charge candidates fees, under the Code of Practice for international recruitment. UK law also generally stops employment agencies charging work-seekers for finding them work. You may still pay your own costs such as English tests, NMC fees or the visa fee, but never a placement fee to an agent.
Can a UK employer make me repay costs if I leave early?
Yes, if the contract has a clear repayment clause that is fair and reduces over time. The Code of Practice example is up to 100% of itemised costs if you leave in the first year, up to 50% in the second year, up to 25% in the third, and nothing after 3 years. Employers must not reclaim agency fees, the Immigration Skills Charge, sponsor licence or certificate of sponsorship costs, and must not charge interest.
Which countries are on the UK red list for nurse recruitment?
The UK red list follows the WHO Health Workforce Support and Safeguards List and has 54 countries, including Nigeria, Ghana, Zimbabwe, Pakistan and Bangladesh. Kenya and Nepal are on the amber list. India and the Philippines are not on either list. Nurses living in red list countries can still apply directly to an advertised job themselves.
How do I check if a UK nurse recruiter is genuine?
Search the NHS Employers Ethical Recruiters List, which was last updated on 30 October 2026. Then check the company on Companies House, confirm the job directly with the NHS trust or employer using contact details from their official website, and check the employer is on the Home Office register of licensed sponsors.
Where can I report a nurse recruitment scam?
In England, Wales and Northern Ireland, report fraud to Report Fraud (which replaced Action Fraud) online or on 0300 123 2040. In Scotland, call Police Scotland on 101. In India, complain to the Protector General of Emigrants through the eMigrate or MADAD portals. If you are being forced to work or are in danger, call the UK Modern Slavery and Exploitation Helpline on 08000 121 700, or 999 in an emergency.
Do nurses pay fees to go to Germany?
Agencies with the German state seal 'Faire Anwerbung Pflege Deutschland' follow the employer-pays principle, so recruitment costs are not passed on to nurses. German law also says only the Federal Employment Agency may recruit health workers from countries on the WHO list.
What is a breach fee in US nursing contracts?
Some US recruiters put a large 'liquidated damages' or breach fee in the contract if a nurse leaves early. In 2019 a US federal court ruled that the breach clauses used by one New York agency were unenforceable penalties and that threats to enforce them broke US anti-trafficking law. Get any US contract checked before you sign.
Official sources we checked
- DHSC: Code of practice for the international recruitment of health and social care personnel in England
- NHS Employers: Code of Practice red and amber list of countries
- NHS Employers: Ethical recruiters list
- NHS Employers: Code of Practice frequently asked questions
- WHO: Health workforce support and safeguards list 2023
- WHO: Global Code of Practice amended (29 May 2026)
- Home Office: Sponsor a Skilled Worker guidance (version 04/26)
- German Federal Ministry of Health: Faire Anwerbung Pflege Deutschland
- Faire Anwerbung Pflege Deutschland (seal website)
- Germany: Section 38 Employment Ordinance (BeschV)
- Faire Integration (free advice for migrant workers in Germany)
- TruMerit: Ethical international recruitment
- Paguirigan v. Prompt Nursing Employment Agency (E.D.N.Y. 2019)
- MEA India: Complaints against recruiting agents
- City of London Police: Report Fraud service
This guide is general information, not legal or immigration advice. Rules, fees and waiting times change, so always confirm on the official sites linked above before you pay or apply.