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I mainly work in Germany, but recently I had a little project for an US company. They were satisfied with my work and are ready to give me a Letter of Recommendation. I can make suggestions about structure and content of this LoR. They know that it is much more important in Germany than it is in the US.

But, as I work mainly in Germany, I want to use this document mainly instead of the "Arbeitszeugnis" (work certificate, essentially it is the German LoR).

But, the common structure of the German AZs and the US LoRs differs a lot, both in content and in the form. The major differences I know until now:

  1. AZs always contain the time interval of the working for the named company, while LoRs might not.
  2. AZs always contain the technologies used, LoRs might not.
  3. German companies are forced by law to give a positive AZ to every ex-employee. This can be enforced in court, so normally, AZs contain only positive wording, and negative items are only mentioned in a roundabout way.
    I know that, in the US, a LoR is only written when the employee's work was satisfactory, so it will usually only contain positive things.
  4. And, of course, AZs are written on German, while the LoRs are on English. :-) (But it is not a problem, every IT leader is a nearly native level English speaker in Germany.)

They won't make a German AZ for me (not even in English), because it would highly contradict their company and country standards. They don't know anything about the German system and customs, they don't and won't understand it. But they are open for my suggestions regarding structure and content of their US-style recommendation letter.

What should I suggest to them? If a German boss in the future checks my US LoR, what will be important for him in it?

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    Don't lose track of the purpose of those AZ/LoR. It's not Pokemon, collecting isn't a goal by itself. They exist to help you get a new job, period. This LoR too should be judged on that criterium, and that criterium alone. Not on how much it resembles an AZ.
    – MSalters
    Jan 19, 2016 at 20:19
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    @MSalters I hope, all of my employers in the future will also share your opinion. :-) Especially the Germans, they are relative traditionalists (f.e. they prefer paper documents) and more rigorous for the formalities.
    – Gray Sheep
    Jan 26, 2016 at 13:20
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    @MSalters That's precisely what the question is about and the reason why it might be very important for that letter of recommendation to meet German expectations. I don't know how much experience you have over there but I have many anecdotes illustrating this.
    – Relaxed
    Mar 13, 2019 at 22:48

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They won't make a German AZ for me (even not on English), because it would highly contradict their company and country standards.

That's pretty obvious I think. They would be unable to do so without hiring a lawyer with knowledge in German labour law and I personally think it would provide no use for you anyway.

The German Arbeitszeugnis is - as you already pointed out yourself - more of a formality. Due to legal restrictions they wouldn't be able to write the truth in there and that's also the reason, why it wouldn't provide any benefit for you having an Arbeitszeugnis from them in my opinion.

Actually I think you overestimate the importance of a Arbeitszeugnis in Germany a bit. Atleast for knowledge workers I wouldn't say it is important at all. Clearly it's important to have one. If your previous job was a fulltime employment at a German company - it would be weird if you had no Arbeitszeugnis from them. But as they are 95% the same (containing the same phrases agreed upon by hundreds of judges and lawyers) it's not actually important what's written inside of it.

What should I suggest to them?

In your position I would just suggest them to write a proper letter of recommendation and make sure that it contains;

  • the achievements you made in this position and which benefits resulted for the company,
  • the technologies you used,
  • some sentences about your work ethics.

Also try to make sure it looks official (written on company letterhead and with personal signature).

If a German boss in the future checks my US LoR, what will be important for him in it?

International project experience is generally well received. As an LoR is pretty obvious not the same as an Arbeitszeugnis, German HR won't be looking for formalities inside of it, but rather see it as a personal reference letter. These are also common in Germany (especially for freelancers) and are free of any formal requirements.

Expanding on the point "Is the Arbeitszeugnis a formality?"

@mart Actually this may of course be a relative and debated opinion and may very well depend on company size/culture and industry sector (the OP is in IT, where I think my claim is especially valid). In my opinion (and I think I'm not alone with that one) the Arbeitszeugnis is worthless for the assesment of an individual applicant based on the following facts:

  • As the OP already pointed out in his answer the employer is forced by law to write a generally positive Arbeitszeugnis, which limits his ability to do an actual assessment of the person, which the Arbeitszeugnis should be supposed to deliver.
  • Still there are over 30.000 lawsuits over the contents of Arbeitszeugnisse in Germany every year. Law suits in which the employer has nothing to gain, but only to loose (time & money).
  • The above points result in the fact that most companies nowadays tend to just hand out a templated Arbeitszeugnis not specific to the actual performance, or an overly positive on. A recent study (from the university Erlangen-Nürnberg) showed that the average grade was 1.9 in 2014 (while it was at 2.4 in 1994). Obviously if the average grade is already that high, there is not much of a possibility to actually compare applicants based on this gradings. If everybody left school with an A-grade, that grades would be pretty useless to find the intellectually gifted ones.

TLDR; The Arbeitszeugnis is on a slow way to meaninglessness since a few decades. Nowaday it's just a formality to have (if your previous employer was a German company - that's why the OP doesn't really need one), but in most of the cases you are likely to gain nothing by having an very good one.

If you don't trust my judgement here, here, here and here is some further reading (in German).

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    I doubt that the Arbeitszeugnis is a formality in the eyes of a recruiter. Can you back that statement up?
    – mart
    Jan 20, 2016 at 12:38
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    dubious statement backed up enough for the scope of the answer IMO, +1
    – mart
    Jan 20, 2016 at 16:04
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    Warning: This answer does not reflect current reality in Germany, regardless of what some newspapers write (and in fact some of these articles explicitly contradict this answer). Many HR departments do not consider the Arbeitszeugnis a formality if you have worked for a German company and don't have one. Furthermore, they know how and do decipher the code. However, recruiters often are aware that companies outside Germany may not provide an equivalent document.
    – Roland
    Aug 25, 2016 at 12:53
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    Yes, I think we agree. But I think your answer is still dangerous because as written one could think that the content is not important as long as you have one. And the reality is that you need at least a reasonably good on (after decoding it). If you have that (and usually they are good) other aspects of your application become more important.
    – Roland
    Aug 25, 2016 at 13:14
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    The more positive they are in general, the more suspicious it is not to have one or not to have an extremely positive one. It's certainly true it's not a very useful predictor of job performance (just like unstructured interviews btw) but it does not follow that it is a mere formality. And I am not convinced all German recruiters (even in IT and even for relatively internationally oriented companies) are as aware of international customs and as flexible as you imply. Thinking of all this in terms of school grades is another example of this mindset and it's not so easy to shake cultural habits.
    – Relaxed
    Mar 13, 2019 at 22:59
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How can I formulate an USA-style recommendation letter to be used as an Arbeitszeugnis (German Work Certificate)?

Don't.

The Arbeitszeugnis is a legal minefield and no foreign company will be capable of providing one. As far as I know, the strict requirements of the Arbeitszeugnis mean that there is not one "true" translation for all the different phrases used in German. I'm not sure whether an English LoR can ever have the same legal value as a German one from a German employer, but that's largely a legal matter.

This page has details on translating your German Arbeitszeugnis into English, and even they recommend not trying to translate it yourself but hiring a professional translator. And that's for converting it to the English version which has no legal value or restrictions. An excerpt:

Ein deutsches Zeugnis ist stark normiert, rechtlich genau geregelt und sogar einklagbar. Es erfasst die Arbeit und die Leistung eines Arbeitnehmers umfassend und detailliert. Deutsche Praktikanten und Arbeitnehmer erwarten das oft auch von englischsprachigen Zeugnissen. Ein englisches oder US-amerikanisches Arbeitszeugnis ist aber weder rechtlich vorgeschrieben noch formell wie ein deutsches.

Ein Beispiel: In Deutschland lautet die Gesamtbewertung für ein sehr gutes Zeugnis immer: "Er/sie arbeitete stets zu unserer vollsten Zufriedenheit". Zwar kann man diese Formel problemlos mit "He always worked to our fullest/utmost satisfaction" übersetzten. Allerdings bevorzugt man im Englischen meist andere Beschreibungen (siehe unten). Grundsätzlich hat ein Arbeitszeugnis im Englischen eher den Charakter eines Empfehlungsschreibens.

Wer nur ein deutsches Arbeitszeugnis bekommt, sollte stets beachten: Arbeitszeungisse immer professionell übersetzen lassen

Source: Englische Arbeitszeugnisse, e-fellows.net

Just ask your company to provide you with a typical Letter of Recommendation. Because the interpretations of specific phrases are so strict, I would avoid using direct translations of typical Arbeitszeugnis statements like "She/he carried out every aspect of her work to the highest possible standard" at all costs. Instead, go with a basic and enthusiastic English recommendation. An Arbeitszeugnis is just ticking a box in an application anyway and since you were working for a foreign company, not having a "real" one should not be an issue.

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  • No, I won't use it as a legal AZ, I only want to show it between my legal documents (Bewerbungsunterlagen) I use to apply for a project/job. Of course it wouldn't be a legally bound AZ, but I only want to include it in the folder of my AZs.
    – Gray Sheep
    Jan 19, 2016 at 13:24
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I think that a letter of recommendation is a positive sign for a prospective employer in any way. The fact that a former employer takes the time to write something up like this is never a bad sign. In regards to the german system there are some red flags companies might use to communicate "bad behavior". I'd be on the lookout for these when you try to hand your letter of recomendation to a german firm. I'd ask for a rewrite if I found one of those but other than that you are probably fine.

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