EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 990 final

2026/0275 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on the recognition of qualifications of third-country nationals

{SEC(2026) 990 final} - {SWD(2026) 989 final} - {SWD(2026) 990 final} - {SWD(2026) 991 final}

(Text with EEA relevance)

EN 1 EN

EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The Treaties, the Charter of Fundamental Rights of the European Union and the European

Pillar of Social Rights establish a broad framework supporting access to employment, skills

development and participation in the Union labour market. While the free movement of

workers, freedom of establishment and freedom to provide services enshrined in the Treaties

are rights of Union citizens, third-country nationals who are legally resident in the Union can

also benefit from this broader framework, in accordance with the conditions and within the

scope laid down in Union law. The European Pillar of Social Rights, proclaimed in 2017,

emphasises the importance of skills and employability in its first chapter on equal

opportunities and access to the labour market. In particular, Principle 1 on education, training

and lifelong learning recognises everyone’s right to maintain and acquire skills enabling full

participation in society and the labour market, and Principle 4 provides for the right to active

support to find or change jobs, including through re-skilling and job-search assistance.

This long-standing framework is reflected in the Commission’s Political Guidelines for 2024–

2029, which emphasise the importance of skills portability and of enabling people to make

effective use of their skills in the Union. In her Political Guidelines for 2024–2029, the

President of the Commission underlined the need to ensure that the Union benefits from high-

quality skills, irrespective of where and how they were acquired, and to facilitate the

recognition of skills acquired in one country in another. These objectives are also reflected in

the ‘One Europe, One Market’ roadmap, launched in April 2026 with the objective of further

deepening and completing the Single Market by the end of 2027, including by removing

remaining barriers, reducing administrative burden and strengthening the Union’s

competitiveness.

While the EU labour market has reached record-high employment levels, it faces widespread

and structural skilled labour shortages, particularly in sectors such as healthcare, ICT,

construction, energy, and transport, driven in part by an ageing population and a shrinking

working-age workforce. These shortages coexist with persistent 'skills waste',

overqualification and the underutilisation of skills being significantly more pronounced

among third-country nationals than among the domestic workforce. This mismatch also

depresses earnings for those working below their qualification level and risks contributing to

downward wage pressure and reducing the return on skills for employers and represents a loss

of overall productivity for the Union economy at a time of skills shortages. Whether already

residing in a Member State or seeking to migrate to the Union, third-country nationals face

recognition procedures for their qualifications that are fragmented, complex and lacking in

transparency, leading to uncertain and inconsistent outcomes. Two distinct but often

interconnected types of procedure are concerned: formal recognition for access to a regulated

profession, and qualification or skills checks carried out as part of a procedure to obtain a

long-stay visa or a residence permit (for instance under the EU Blue Card or national highly-

skilled-worker schemes). The average recognition procedure is estimated to cost EUR 1,500

and to take 14.2 months, with 70.4% of third-country nationals surveyed considering the

length of the process a 'big' or 'very big' problem. Nearly half of third-country nationals who

initiated recognition procedures were seeking access to a regulated profession in healthcare, a

sector facing acute shortages across the Union. Unlike EU nationals, who benefit from the

mutual recognition mechanisms of Directive 2005/36/EC (the Professional Qualifications

Directive), third-country nationals have no comparable EU framework. This gap undermines

EN 2 EN

the effectiveness of the Union's talent-attraction ecosystem — including the EU Blue Card,

the EU Talent Pool, Talent Partnerships with priority third countries and the European Legal

Gateway Office pilot — whose value for employers and jobseekers depends on recognition

systems functioning adequately. Procedures for recognition of qualifications for access to

further learning are outside the scope of this proposal.

This proposal responds to a clear and repeated political mandate. The Political Guidelines of

Commission President von der Leyen committed to a Skills Portability Initiative 'to ensure a

skill acquired in one country is recognised in another' and to 'make it easier to attract the right

talent with harmonised rules on the recognition of qualifications'. The March 2025

Communication on the Union of Skills confirmed this commitment, and the Letta report on

the Single Market highlighted the need to extend automatic recognition of qualifications to

help address persistent labour shortages. The European Council, meeting on 19 March 2026,

called for a Commission proposal on the portability of qualifications and skills, including

third-country nationals, by autumn 2026. The proposal is part of the Skills Portability

Initiative and its general objective is to facilitate the recognition of qualifications of third-

country nationals in order to address labour and skills shortages in the Union. Three specific

objectives are pursued: (i) streamlined recognition systems within and between Member

States; (ii) reduced legal and administrative complexity for third-country national applicants,

employers and authorities; and (iii) increased trust in, and understanding of, qualifications

obtained in third countries.

• Consistency with existing policy provisions in the policy area

The proposal is complementary to, and does not overlap with, existing EU instruments. The

Professional Qualifications Directive provides a robust framework for the recognition of

professional qualifications, but its Single Market legal basis confines its personal scope to EU

nationals; it does not, and cannot, extend to third-country nationals. Existing EU migration

instruments contain only limited provisions on recognition, generally limited to equal

treatment with nationals of the Member State concerned. None of these instruments regulate

the organisation, structure or functioning of recognition procedures as such, or require

Member States to simplify or coordinate such procedures. Commission Recommendation

(EU) 2023/2611 is the only EU-level instrument specifically addressing recognition of

qualifications of third-country nationals and is non-binding and therefore cannot ensure

consistent outcomes across the Union. The proposal is one of three interlinked actions under

the Skills Portability Initiative. Action 1 addresses improving the availability of reliable,

comparable and verifiable digitalised information on qualifications and skills in the EU.

Action 2 modernises recognition procedures under the Professional Qualifications Directive

for EU citizens. Action 3 — the subject of this proposal — addresses the gap in the EU legal

and policy framework covering recognition of qualifications of third-country nationals (and is

based on Article 79(2), points (a) and (b), TFEU).

The procedural guarantees in this proposal are aligned with those applicable to Union citizens

under Directive 2005/36/EC as amended by Action 2 of the Skills Portability Initiative, and

do not place third-country nationals in a more favourable position than Union citizens

exercising free movement. The differences between the two frameworks reflect the practical

challenges of assessing qualifications from third countries, which justifies the need for an

extensive prior review of the learning programmes concerned benefitting from automatic

recognition.

• Consistency with other Union policies

The proposal forms part of the Fair Labour Mobility Package. It responds to the

Competitiveness Compass's identification of skilled labour shortages as a structural

EN 3 EN

competitiveness risk, to the Union of Skills and to the Single Market Strategy's call for

digitalisation and procedural simplification of recognition. It complements and reinforces the

effectiveness of the EU Talent Pool (established by Regulation (EU) 2026/1047), Talent

Partnerships with priority third countries, the European Legal Gateway Office pilot, the EU's

Visa Strategy, the Commission Recommendation on attracting talent for innovation, and the

Action Plan on Integration and Inclusion, all of which rely on well-functioning recognition

systems to deliver their intended results. The proposal also contributes to the objectives of the

European Asylum and Migration Strategy adopted in January 2026 which aims at making the

EU the most attractive place in the global race for talent in the next five years. The proposal is

consistent with the Union's policy on trade, in particular as regards the framework on Mutual

Recognition Agreements established in EU free trade agreements.The initiative also

contributes to the 2030 Agenda for Sustainable Development, in particular SDG 1 (No

poverty), SDG 8 (Decent work and economic growth), SDG 9 (Industry, innovation and

infrastructure) and SDG 10 (Reduced inequalities).

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The proposal is based on Article 79(2), points (a) and (b), TFEU, which empowers the

European Parliament and the Council, acting in accordance with the ordinary legislative

procedure, to adopt measures in the area of the conditions of entry and residence of third-

country nationals and the definition of their rights, including the conditions governing

freedom of movement and of residence in other Member States and access to employment.

Recognition of qualifications is directly linked to the conditions of entry and residence within

the meaning of Article 79(2)(a) TFEU, since access to employment — and therefore to

residence for work purposes — often depends on whether qualifications obtained in a third

country can be recognised. The proposal also supports the effective exercise of the rights of

third-country nationals legally residing in the Union under Article 79(2)(b) TFEU, by

facilitating access to employment corresponding to their qualifications and reducing the

underutilisation of their skills. This legal basis is distinct from the Single Market legal bases

(Articles 46, 49, 53 and 62 TFEU) used for Actions 1 and 2 of the Skills Portability Initiative,

which are confined in personal scope to EU nationals exercising free movement rights. In

accordance with Article 79(5) TFEU, the proposal does not affect Member States' right to

determine the volumes of third-country nationals admitted to their territory to seek work,

whether employed or self-employed.

• Subsidiarity (for non-exclusive competence)

Article 79 TFEU falls within Title V TFEU (the Area of Freedom, Security and Justice),

which Article 4(2)(j) TFEU identifies as a shared competence between the Union and the

Member States. The objectives of streamlined, simple and trusted recognition procedures for

third-country nationals cannot be sufficiently achieved by Member States acting alone.

Divergent national systems, combined with the absence of any legal framework comparable to

Directive 2005/36/EC, generate cross-border uncertainty and burden that individual Member

States cannot resolve alone; recognition procedures interact structurally with EU migration

instruments whose effectiveness depends on their functioning adequately; and the lack of trust

in third-country qualifications would best be addressed through EU-level tools that generate

economies of scale which would be inefficient to replicate separately across 27 national

systems. This necessity was confirmed in the Public Consultation, in which 95.3% of

respondents considered EU-level action very or somewhat necessary. Action at Union level is

more effective than action at national level and delivers clear added value: it would allow

EN 4 EN

third-country nationals to better understand requirements, prepare applications and anticipate

outcomes; it would lower the administrative burden faced by employers, particularly SMEs,

in navigating divergent national systems; and it would strengthen the EU's position in the

global competition for talent by supporting instruments such as the EU Blue Card, the EU

Talent Pool and Talent Partnerships. The preferred policy option is estimated to generate

aggregate administrative savings for competent authorities, employers and third-country

nationals amounting to approximately EUR 22.3 million per year, monetised time savings for

applicants of approximately EUR 300 million per year, and a reduction in employer-borne

administrative costs of approximately EUR 20 million per year — benefits that could not be

achieved as efficiently through 27 separate national approaches. The proposal does not

transfer Member States' competence over the definition of regulated professions, national

education and training systems, or migration and admission decisions.

• Proportionality

The Impact Assessment examined three policy options: a non-binding option based on soft

measures and guidance (PO1); a binding option establishing common procedural rules,

including an EU authenticity-verification service and interoperable national databases (PO2);

and a binding option combining these common rules with automatic recognition for a defined

set of professions, grounded in prior verification of third-country learning programmes (PO3,

the preferred option). Each option was assessed against the principles of subsidiarity and

proportionality: PO1 imposes no new obligations on Member States; PO2 addresses

procedural requirements without harmonising substantive assessment standards; and PO3,

while going further, remains grounded in the existing framework of minimum training

requirements under the Professional Qualifications Directive, preserves Member States'

competence over qualification standards and admission decisions, and makes participation by

third-country institutions in the automatic-recognition register voluntary. PO3 was identified

as the preferred option because it generates aggregate net benefits substantially larger than the

alternatives (an overall comparative score of 9, against 6 for PO2 and 3 for PO1, across the

criteria of effectiveness, efficiency and coherence), while remaining limited to what is

necessary: it does not create a 'once-only' EU-wide validity of recognition, does not

harmonise which professions are regulated, and does not alter or interfere with Member

States' competence over migration and admission decisions. Implementation obligations are

proportionate to the improvements it delivers and sit within the established EU legislative

tradition of minimum harmonisation in the field of recognition of qualifications. The

measures in the proposal are directly linked to the scale and persistence of the problems

associated with recognition of qualifications in the wider context of talent attraction. The

general system simplifies procedures without harmonising substantive assessment standards.

The automatic recognition system is grounded in prior programme verification. The system

preserves Member State competence over qualification standards and admission decisions;

participation by third-country institutions is voluntary and the system will expand based on

demonstrated interest by the institutions, limiting the risk of unintended effects on origin

country skills systems. The proposal does not affect Member State competence to take

recognition decisions or manage migration and admissions. Further detail on the comparative

assessment of policy options and their proportionality is set out in Sections 6 and 7 and the

Preferred Option section of the Impact Assessment (SWD) accompanying this proposal.

• Choice of the instrument

The proposal takes the form of a Directive laying down minimum requirements for the

recognition of qualifications of third-country nationals. A Directive is considered the most

appropriate instrument, as it establishes binding common rules while leaving Member States

the discretion to organise their competent authorities and to integrate the new rules within

EN 5 EN

their own administrative and procedural traditions, consistent with the degree of

harmonisation traditionally applied in this field (including under Directive 2005/36/EC). A

Regulation was considered disproportionate and unsuitable given that the proposal lays down

only a harmonised minimum set of rights and guarantees, leaving Member States free to

introduce or maintain more favourable systems; the common rules must be integrated into the

highly diverse recognition and migration procedures currently in place across Member States;

and the common rules would not regulate the matter exhaustively.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

There is no existing EU legislation specifically addressing the recognition of qualifications of

third-country nationals, and therefore no ex-post evaluation or fitness check of such

legislation exists. The only EU-level instrument in this field, Commission Recommendation

(EU) 2023/2611, is non-binding and has not been subject to formal ex-post evaluation. The

problem analysis underpinning this proposal is instead based on extensive desk research,

primary fieldwork and stakeholder consultation, described in the Impact Assessment, which

quantifies the practical consequences of the current fragmented landscape, including the

average cost (EUR 1,500) and duration (14.2 months) of recognition procedures for third-

country nationals.

• Stakeholder consultations

A Call for Evidence covering the Skills Portability Initiative, its three actions and envisaged

policy options was published on 5 December 2025 and remained open until 27 February 2026.

A Public Consultation ran in parallel from October 2025 to April 2026. Targeted

consultations were conducted between October 2025 and April 2026 with national competent

authorities, healthcare professional organisations (including CPME, EFN and UEMO),

employers, civil society organisations and third-country national applicants, including a

dedicated third-country national survey, together with bilateral meetings and written

contributions from Member State governments. Employer, third-country national, civil-

society and professional-organisation respondents were broadly supportive of binding

common procedural rules; Member State positions were more nuanced. Some Member

States explicitly supported common rules modelled on the general system of Directive

2005/36/EC; others offered conditional support tied to avoiding new administrative burden

and maintaining alignment with existing national frameworks. These positions, and the

Commission's assessment of how they have been reflected in the preferred option, are

summarised in Annex 2 (Stakeholder consultation synopsis report) of the Impact Assessment.

• Collection and use of expertise

The Impact Assessment draws on a study conducted by an external contractor (a consortium

led by EY Italy in collaboration with the Istituto Ricerca Sociale, IRS). The call for tenders

was launched on 25 July 2025 and the study was awarded on 16 October 2025, with a kick-off

meeting on 24 October 2025, an inception report delivered on 16 December 2025, a draft

interim report on 3 March 2026 and a final report on 30 April 2026. An Inter-Service Steering

Group, comprising more than twenty Commission services, met three times to steer the

preparation of the Skills Portability Initiative, complemented by a dedicated steering group for

the external study and other bilateral meetings.

EN 6 EN

• Impact assessment

This proposal is supported by an Impact Assessment. The draft Impact Assessment was

submitted to the Regulatory Scrutiny Board on 15 June 2026 and examined by the Board on

15 July 2026. The Regulatory Scrutiny Board issued a positive opinion with comments on the

draft Impact Assessment on 17 July 2026.Three policy options were compared against a 'do-

nothing' baseline: PO1 (non-binding soft measures), PO2 (common binding procedural rules)

and PO3 (common binding procedural rules with automatic recognition for a defined set of

regulated professions, the preferred option). PO3 scored highest across all three comparative

criteria (effectiveness, efficiency and coherence), generating aggregate administrative savings

estimated at EUR 22.3 million per year, monetised time savings for applicants of

approximately EUR 300 million per year, and a reduction in employer-borne administrative

costs of approximately EUR 20 million per year, against implementation costs of EUR 28.7–

50.7 million one-off and EUR 3.7–6.0 million per year, borne mainly at EU level. The final

policy proposal reflects the preferred option identified in the Impact Assessment.

• Regulatory fitness and simplification

While this is not a REFIT initiative in the strict sense, the proposal is designed to reduce,

rather than add to, the administrative burden currently faced by third-country nationals,

employers and competent authorities. Common procedural rules are estimated to reduce

certified translation needs by around one third, while the new support services for assessment

of authenticity will reduce the burden associated with verifying documents. Mandatory

coordination between recognition and migration authorities eliminates duplicate qualification

assessments across parallel administrative procedures. In line with the simplicity by design

principles applied to this proposal, the following elements were assessed and addressed: (i)

digital-by-default delivery, (ii) the "once-only" principle for organisation of recognition

procedures, and (iii) proportionality for small administrations and employers. For the

professions covered by automatic recognition, processing times are projected to fall from 14.2

months to approximately 4 months freeing competent authority capacity for more complex

cases. Employers stand to benefit from faster recruitment and more predictable timelines, with

administrative costs for hiring a recognised professional estimated to fall by 35–50% for

sectoral professions, generating indicative aggregate savings of EUR 14–30 million per year.

No new administrative costs are expected for citizens or businesses, consistent with the 'one

in, one out' approach; the proposal does not impose compliance obligations on economic

operators, notably SMEs and micro-enterprises, and therefore does not require a specific

exemption for micro-enterprises. A dedicated SME panel survey captured the specific

experiences and views of SMEs to gather their understandings of the costs, administrative

burden and expected benefits associated with EU-level action. The SME Panel Survey (2026,

n=159) found that 68% of respondents identify reduced administrative burden during

recruitment as the primary anticipated benefit of a more common EU recognition framework,

61% identify faster recruitment processes, and 70% identify faster and more transparent

procedures as a structural factor in attracting qualified third-country professionals. Faster,

more predictable procedures are expected to generate monetised time savings for employers

of around EUR 20 million per year. The proposal is designed to be internet-ready: it requires

that all requirements, procedures and formalities in recognition procedures may also be

completed remotely and by electronic means and that relevant information is made available

on existing EU digital tools and platforms.

• Fundamental rights

The proposal reduces procedural barriers to recognition, enhancing access to occupations and

employment rights (Articles 15 and 20 of the Charter of Fundamental Rights of the European

EN 7 EN

Union; Principle 4 of the European Pillar of Social Rights). It introduces enforceable

procedural guarantees — binding timelines, defined documentation requirements and appeal

rights — giving third-country nationals an effective remedy against procedural failures

(Article 47 of the Charter) and supporting the right to good administration (Article 41). By

enabling access to regulated professions commensurate with qualifications of third-country

nationals, it improves fair and just working conditions (Article 31 of the Charter; Pillar

Principles 5 and 6). A common procedural baseline applicable irrespective of nationality

reinforces compliance with the principle of non-discrimination and promotes equal

opportunities (Articles 21 and 23 of the Charter; Pillar Principles 2 and 3); the automatic

recognition channel addresses the risk of undeclared work disproportionately borne by women

in care and nursing professions, with a direct gender-equality dimension, and tailored

information and support are provided for refugees and other vulnerable applicants. The

proposal also gives effect to the requirement of a high level of human health protection

(Article 35 of the Charter), as recognition of medical qualifications remain conditional on

meeting the applicable minimum training requirements, compensation measures and language

controls. Processing of personal data by Member States' competent authorities under this

Directive is carried out in accordance with Regulation (EU) 2016/679 (GDPR); processing by

the Commission, including for the support services for assessment of authenticity, is carried

out in accordance with Regulation (EU) 2018/1725 (EUDPR).

4. BUDGETARY IMPLICATIONS

The proposal entails budgetary implications for the Union, principally linked to the

establishment and operation of the support services for assessment of authenticity (Article

28), to be procured externally, the review architecture underpinning automatic recognition

(trusted review bodies and the associated delegated-act framework under Articles 12, 14 and

16), and the secretariat of the group of coordinators for the recognition of qualifications of

third-country nationals (Article 33).

The resources needed may be provided in the Commission’s proposal for the next MFF 2028-

2034, in particular the EU Facility under the National and Regional Partnership Plans. The

Commission assesses that part of the existing staff can be redeployed to meet the needs

generated by this proposal, and an additional three full-time equivalents will be necessary to

complement the overall needs.

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next Multiannual Financial Framework.

The source of financing and scope of Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and

thereafter shall be determined through the annual budgetary procedure. All appropriations and

staffing allocations as of 2028 are indicative.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

A group of coordinators for the recognition of qualifications of third-country nationals is

established as an advisory group to the Commission (Article 33), tasked with facilitating

cooperation between Member States and the Commission, supporting implementation, and

ensuring coordination with other relevant expert groups. The existing network of national

contact points designated under Article 57 of Directive 2005/36/EC will also cover matters

arising under this Directive (Article 34). Monitoring will be based on headline indicators for

each specific objective. From the date of application, Member States will submit annual

EN 8 EN

statistics on applications, processing times, information exchanges and use of the automatic

recognition channel and the authenticity-verification service (Article 35); operational data

from the support services for assessment of authenticity will feed directly into this monitoring

without additional national reporting obligations. Member States will submit implementation

reports to the Commission, and the Commission will report to the European Parliament and

the Council no sooner than seven years after the date of transposition (Article 37), covering

processing times, outcomes, user experience and identified bottlenecks. A formal evaluation

of the Directive's effectiveness, efficiency, coherence and EU added value is envisaged no

sooner than seven years after the date of transposition, examining in particular whether

processing times and administrative costs have fallen, the uptake of the automatic recognition

channel, and whether trust in third-country qualifications has increased.

• Detailed explanation of the specific provisions of the proposal

Title I — General provisions (Articles 1–3)

Article 1 sets out the subject matter: minimum requirements for the recognition of

qualifications obtained in a third country or another Member State, held by third-country

nationals, where recognition facilitates access to a regulated profession or is part of a

procedure to obtain a long-stay visa or a residence permit. Article 2 defines the personal and

material scope, covering third-country nationals already legally residing in a Member State

and those seeking entry and residence who demonstrate a clear intention to migrate (for

instance through an ongoing procedure to obtain a long-stay visa or a residence permit, a job

offer, or registration on the EU Talent Pool). Article 3 sets out the definitions used throughout

the Directive, including 'recognition of professional qualifications', 'recognition in the context

of a procedure to obtain a long-stay visa or a residence permit', and 'digital credential'.

Title II — Recognition to access a regulated profession (Articles 4–20)

Chapter 1 (Articles 4 to 6) sets out the general effects of recognition for access to regulated

professions, the conditions for partial access, and the processing of qualifications already

obtained within the Union. Chapter 2 (Articles 7 to 10) establishes a general system for the

recognition of evidence of training issued in third countries, modelled on the general system

of Directive 2005/36/EC, including the conditions for recognition (Article 8), the

compensation measures that may be imposed where substantial differences exist (Article 9),

and the minimum training requirements applicable to certain sectoral professions (Article 10).

Chapter 3 (Articles 11 to 15) establishes the automatic recognition mechanism for a defined

set of professions (doctors, nurses responsible for general care, dental practitioners, midwives,

veterinary surgeons, pharmacists and architects) obtained in a third country, on the basis of

training programmes reviewed by a 'trusted review body' against the applicable quality-

assurance and minimum-training frameworks.Article 13 sets out the review criteria, Article

14 the methodology and the composition of the review team; Article 15 provides a right to

appeal review decisions and a Member State challenge mechanism; Article 12 defines which

bodies may act as trusted review bodies; and Article 16 empowers the Commission to

recognise third countries whose education and training systems provide sufficient guarantees,

simplifying or waiving the review requirement for institutions established there. Chapter 4

(Articles 17 to 20) sets out rules for pursuing the profession once recognised, covering

language requirements, use of academic and professional titles, and approval by health

insurance funds.

Title III — Recognition in the context of a procedure to obtain a long-stay visa or a

residence permit (Articles 21 to 26)

EN 9 EN

This Title applies where recognition or assessment of a qualification is a condition for, or

influences the outcome of a procedure to obtain a long-stay visa or a residence permit. Article

22 establishes the right to assessment of qualifications where this is part of a procedure to

obtain a long-stay visa or a residence permit. Article 23 requires that recognition procedures

under this Title be limited to what is necessary and be integrated into the relevant procedure

to obtain a long-stay visa or a residence permit wherever possible, avoiding duplicate

assessments, separate applications or additional fees. Article 24 requires that qualification

levels be assessed using the European Qualifications Framework; Article 25 sets out a

learning-outcomes approach for cases going beyond a simple level comparison, including the

compensation measures available where substantial differences are identified. Article 26 gives

applicants the option of an integrated procedure combining migration-related recognition with

recognition of qualifications for access to a regulated profession, avoiding duplication of

effort.

Title IV — Common provisions (Articles 27 to 32)

Article 27 limits the documents and formalities that competent authorities may require to

those listed in Annex VII of Directive 2005/36/EC, and provides for alternative methods of

verification where confirmation from a third country is unfeasible within the applicable

deadline. Article 28 establishes support services for assessment of authenticity, provided by

the Commission to Member States as advisory (non-binding) assessments of the authenticity

of qualifications submitted by applicants, operating in accordance with Regulation (EU)

2018/1725. Article 29 sets binding procedural deadlines for recognition decisions (in principle

three months from the submission of a complete application), together with information and

appeal rights. Article 30 requires that recognition procedures under Title II and III can be

completed remotely and electronically, and provides safeguards on residence permits during

the procedure. Article 31 sets criteria for any fees charged. Article 32 requires Member States

to provide third-country nationals with timely, comprehensive and user-friendly information

on recognition procedures, including tailored information for refugees and other vulnerable

applicants.

Title V — Reporting and final provisions (Articles 33 to 42)

Article 33 establishes a group on the recognition of qualifications of third-country nationals as

an advisory group to the Commission. Article 34 extends the role of existing assistance

centres designated under Directive 2005/36/EC to matters covered by this Directive. Article

35 extends the application of the alert mechanism of Directive 2005/36/EC to third-country

nationals. Article 36 sets out the conditions for the exercise of the delegated powers conferred

on the Commission. Article 38 sets out the conditions for the exercise of the implementing

powers conferred on the Commission. Article 39 establishes implementation and reporting

obligations. Articles 40 to 42 contain the standard final provisions on transposition, entry into

force and addressees.

EN 10 EN

2026/0275 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on the recognition of qualifications of third-country nationals

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular

Article 79(2), points (a) and (b), thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national Parliaments,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) To enhance labour market efficiency, foster fair integration, and strengthen the

Union's economic resilience and competitiveness, it is necessary to establish a clear,

common and predictable framework for the recognition of the qualifications of third-

country nationals, obtained in another Member State or in a third country, for the

purposes of access to a regulated profession in a Member State and of obtaining a

long-stay visa or a residence permit.

(2) Third-country nationals, whether already legally residing in a Member State or seeking

to enter and reside in the Union, encounter recognition procedures for their

qualifications that are often fragmented, overly complex, and lacking transparency,

resulting in uncertainty, delays, and inconsistent outcomes across Member

States. Member States have taken commitments under the Lisbon Recognition

Convention1 and the Global Convention on Higher Education2, yet national rules still

present varying requirements, procedures, and outcomes depending on the Member

State, the profession concerned, and the competent authority. Those disparities and

complexity create unnecessary barriers to labour market integration, contribute to

skills waste, and undermine the Union's ability to attract and retain the talent needed to

address persistent skills shortages.

(3) This Directive forms part of a package together with [Regulation xxxx/xx/EU

establishing a framework for portability of skills and qualifications and amending

Regulation (EU) 2018/1724 ('Skills Portability Act')] s and [Directive xx/xxx

amending Directive 2005/36]. Digital qualification attestations issued under that

Regulation should be accepted as digital credentials for the purposes of this Directive.

1 Council of Europe and UNESCO, "Convention on the Recognition of Qualifications concerning Higher

Education in the European Region", ETS No. 165, Lisbon, 11 April 1997. coe.int. 2 UNESCO, "Global Convention on the Recognition of Qualifications concerning Higher Education",

Paris, 25 November 2019. https://www.unesco.org/en/legal-affairs/global-convention-recognition-

qualifications-concerning-higher-education.

EN 11 EN

Where a third-country national holds a qualification obtained in the Union, recognition

should take place under this Directive by applying the rules of Directive 2005/36/EC

accordingly, in order to avoid parallel procedures.

(4) The Union's ability to attract and retain skilled third-country nationals is a key

determinant of its long-term competitiveness. The Union currently competes at a

disadvantage in the global market for talent, with skilled third-country nationals often

favouring other destinations, among others, due to the fragmented, complex and

unpredictable procedures they face in seeking recognition of their qualifications in the

Union.

(5) Existing Union instruments on migration, such as Council Directive 2003/109/EC3,

Directives 2014/36/EU4, 2014/66/EU5, (EU) 2016/8016, (EU) 2021/18837, and (EU)

2024/12338 of the European Parliament and of the Council, do not establish rules on

the organisation, structure or functioning of recognition systems, nor rules for Member

States to simplify, harmonise or coordinate recognition procedures, in cases where

recognition is required for migration purposes. Consequently, divergences in national

approaches persist, and the structural misalignment between migration systems and

qualification recognition frameworks remains unaddressed. Faster and more effective

recognition of qualifications would also strengthen the effectiveness of the EU Talent

Pool established by Regulation (EU) 2026/1047 of the European Parliament and of the

Council9. Once operational, the EU Talent Pool will provide the first Union-wide

platform addressing labour shortages at the Union level by facilitating the recruitment

of third-country nationals. In that regard, it is key to support employers' understanding

of the qualifications of third-country nationals, and the confidence of Member States'

competent authorities that the qualifications presented correspond to recognised levels

of skills. Streamlined and reliable recognition of qualifications therefore supports the

functioning of the EU Talent Pool by providing the necessary assurance to employers

and host Member States, and by reducing the administrative burden on third-country

nationals. By reducing the mismatch between the qualifications held by third-country

nationals and the level of employment they actually obtain, this Directive also

3 Council Directive 2003/109/EC of 25 November 2003 concerning the status of third-country nationals

who are long-term residents (OJ L 16, 23.1.2004, p. 44, ELI: http://data.europa.eu/eli/dir/2003/109/oj). 4 Directive 2014/36/EU of the European Parliament and of the Council of 26 February 2014 on the

conditions of entry and stay of third-country nationals for the purpose of employment as seasonal

workers (OJ L 94, 28.3.2014, p. 375, ELI: http://data.europa.eu/eli/dir/2014/36/oj). 5 Directive 2014/66/EU of the European Parliament and of the Council of 15 May 2014 on the conditions

of entry and residence of third-country nationals in the framework of an intra-corporate transfer (OJ L

157, 27.5.2014, p. 1, ELI: http://data.europa.eu/eli/dir/2014/66/oj). 6 Directive (EU) 2016/801 of the European Parliament and of the Council of 11 May 2016 on the

conditions of entry and residence of third-country nationals for the purposes of research, studies,

training, voluntary service, pupil exchange schemes or educational projects and au pairing (OJ L 132,

21.5.2016, p. 21, ELI: http://data.europa.eu/eli/dir/2016/801/oj). 7 Directive (EU) 2021/1883 of the European Parliament and of the Council of 20 October 2021 on the

conditions of entry and residence of third-country nationals for the purpose of highly qualified

employment, and repealing Council Directive 2009/50/EC (OJ L 382, 28.10.2021, p. 1, ELI:

http://data.europa.eu/eli/dir/2021/1883/oj). 8 Directive (EU) 2024/1233 of the European Parliament and of the Council of 24 April 2024 on a single

application procedure for a single permit for third-country nationals to reside and work in the territory

of a Member State and on a common set of rights for third-country workers legally residing in a

Member State (OJ L, 2024/1233, 30.04.2024, ELI: http://data.europa.eu/eli/dir/2024/1233/oj). 9 Regulation (EU) 2026/1047 of the European Parliament and of the Council of 29 April 2026

establishing an EU Talent Pool (OJ L, 2026/1047, 12.5.2026, ELI:

http://data.europa.eu/eli/reg/2026/1047/oj).

EN 12 EN

contributes to strengthening the labour market participation of disadvantaged groups

within the Union.

(6) For the purposes of this Directive, recognition of qualifications should be understood

as covering both recognition for the purpose of access to a regulated profession and

recognition in the context of a procedure to obtain a long-stay visa or a residence

permit. This Directive should therefore apply to third-country nationals seeking either

form of recognition, independently of whether their qualifications were obtained in a

Member State or a third country, and irrespective of whether they are already legally

residing in the Union or are seeking to migrate to it with a demonstrated intention to

do so, such as through the EU Talent Pool.

(7) The provisions of this Directive should be without prejudice to the competence of

Member States to regulate professions or determine the requirements for issuing a

long-stay visa or a residence permit regulated under national law, and, in accordance

with Article 79(5) TFEU, to their right to determine the volume of third-country

nationals admitted to their territory for the purpose of seeking work.

(8) Access to regulated professions depends on the possession of the required professional

qualifications or of professional qualifications that can be recognised as equivalent to

those qualifications required to practise in the host Member State. Third-country

nationals face significant disparities in recognition procedures across Member States.

Differences in required documentation, compensation measures and assessment

methods risk encouraging applicants to target jurisdictions with more lenient

procedures before relocating, which undermines fairness and places the Union at a

competitive disadvantage in attracting global talent.

(9) In order to ensure equal treatment and non-discriminatory access to the profession,

recognition of professional qualifications should enable third-country nationals to

access and pursue in the host Member State the same profession as that for which they

are qualified in another Member State or in a third country, under the same conditions

as nationals of the host Member State. For third-country nationals, access to the

profession should remain subject to applicable requirements relating to residence,

employment and other legal conditions, and should not create new entry or residence

rights. Access under the same conditions should also mean that, where nationals of the

host Member State are required, in order to pursue the profession, to satisfy additional

requirements, such as providing evidence of a clear criminal and professional record,

the host Member State may apply the same requirements to third-country nationals.

(10) In order to avoid imposing disproportionate requirements on applicants, where the

regulated profession in the host Member State covers activities going beyond those for

which the applicant is qualified, and full compensatory measures would in practice

amount to requiring completion of an entire training programme, the host Member

State should be able to grant partial access, provided that the relevant activity can

objectively be separated from other activities covered by the profession and subject to

the case-law of the Court of Justice of the European Union on overriding reasons of

general interest.

(11) In order to ensure the consistent treatment of qualifications obtained within the Union,

while respecting the distinction with the freedom to provide services under Article 56

TFEU, where third-country nationals hold attestations of competence, evidence of

formal qualifications or professional experience acquired in a Member State that

would enable a Union citizen to access a regulated profession under Title III of

EN 13 EN

Directive 2005/36/EC of the European Parliament and of the Council10, the relevant

provisions of that Directive concerning the right of establishment should apply mutatis

mutandis to them.

(12) To enable third-country nationals to make full use of those qualifications obtained in a

third country, while ensuring that recognition is subject to appropriate safeguards, two

complementary recognition systems should be established. First, a general system,

closely mirroring Title III, Chapter I of Directive 2005/36/EC and adapted to the

context of third-country qualifications; and, second, a system for the automatic

recognition of selected qualifications that meet Union minimum training and quality

standards, also adapted to reflect the specific challenges of assessing qualifications

obtained outside the Union.

(13) In order to ensure that all applicants have access to an appropriate assessment

pathway, qualifications acquired in a third country that do not benefit from automatic

recognition should be assessed under the general system, modelled on the general

system established by Directive 2005/36/EC but adapted to reflect the specific

difficulties of assessing qualifications and professional experience acquired outside the

Union.

(14) This Directive should also allow Member States to rely on alternative, reliable

methods of verification where the necessary documentation cannot reasonably be

obtained from a third country, so that recognition procedures are not obstructed by

circumstances outside the applicant's control.

(15) In order to prevent compensation measures from being used as a disguised or

disproportionate barrier to recognition, under the general system, compensation

measures should remain limited to cases of substantial differences between the

applicant's qualification and domestic requirements, and of justified doubts about the

quality of the third country's education system. In light of the difficulties of assessing

third-country qualifications, including variable training standards and legitimate

doubts as to the quality of education systems, Member States should be afforded

greater flexibility than under Article 14 of Directive 2005/36/EC in determining

whether and which compensation measures to impose. To ensure that doubts

concerning the quality of education and training systems of third countries are not

invoked arbitrarily or without justification, Member States should notify the

Commission of the country and profession concerned and explain the nature of the

doubts. Moreover, any compensation measure should comply with the principle of

proportionality, take due account of relevant knowledge, skills and competences

already demonstrated by the applicant, and be applied in a manner that safeguards

applicants' procedural rights and supports their effective integration into the

profession.

(16) A system of automatic recognition speeds up recognition processes by removing the

need for individual assessments, reducing administrative burdens and ensuring greater

consistency in outcomes across Member States. It also has the potential to incentivise

the development of third-country training programmes aligned with Union standards,

expanding the pool of qualified professionals eligible to practise in the Union.

10 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the

recognition of professional qualifications (OJ L 255, 30.9.2005, p. 22, ELI:

http://data.europa.eu/eli/dir/2005/36/oj).

EN 14 EN

(17) The automatic recognition system should initially cover professions for which

Directive 2005/36/EC has already established harmonised minimum training

requirements, namely doctors, nurses responsible for general care, dental practitioners,

midwives, veterinary surgeons, pharmacists and architects, given their importance for

public health and safety and the persistent labour shortages affecting them. Its scope

should also extend to any profession for which a Common Training Framework is

adopted pursuant to Article 49a of Directive 2005/36/EC, ensuring the system remains

adaptable over time.

(18) To ensure the trustworthiness of the automatic recognition system, evidence of formal

qualifications benefiting from it should be issued following completion of a training

programme reviewed by a trusted independent body and should be issued as a digital

credential ensuring authenticity, security and ease of verification. The review process,

including any negative outcome, and the underlying review report should be made

public to ensure full transparency.

(19) A training programme should be regarded as ‘reviewed’ only where a trusted review

body has confirmed its compliance with the applicable quality and content standards,

including alignment with the minimum training conditions set out in Directive

2005/36/EC or the relevant common training framework. Given the greater variability

in oversight and transparency across third-country education systems compared with

the Union, such review requires more extensive scrutiny than in the context of

qualifications obtained within the Union, so as to ensure that only qualifications

meeting Union standards are eligible for automatic recognition.

(20) In order to ensure the rigour, credibility and transparency of the automatic recognition

system, the review process should be carried out by a multidisciplinary team of

independent experts with relevant subject-matter and quality assurance expertise,

including through an on-site assessment of the training environment, delivery methods

and quality assurance practices for the training programme. The 'reviewed' status

granted to a training programme should be time-limited and subject to periodic

renewal, to ensure that training standards continue to be met over time and that any

subsequent changes to applicable minimum training requirements are properly

reflected.

(21) In order to ensure the scalability and sustainability of the review system, a review

should take place at the request of, and be funded by, the individual third-country

training institution concerned, with results published. To ensure fairness and

accountability, training institutions should have the right to appeal review decisions

under the national law of the Member State where the trusted review body is

established, which have to be resolved promptly and fairly.

(22) To further strengthen trust in the automatic recognition system, Member States should

have a means of contesting a review decision where they have justified doubts as to its

correctness, subject to appropriate safeguards against misuse of that mechanism.

(23) To ensure the reliability, independence, expertise and accountability of the review

process, only quality assurance agencies established in the Union and meeting certain

eligibility criteria should be recognised as trusted review bodies, and their authority

should be limited to specified professions.

(24) In order to facilitate the recognition procedure for qualifications obtained in third

countries whose education and training systems offer sufficient guarantees of quality,

EN 15 EN

oversight and administrative cooperation, the review requirement should be

adjusted for the institutions established in those third countries.

(25) While applicants should have the language knowledge necessary to practise their

profession in the host Member State, language controls should only be carried out after

recognition of the qualification, to avoid creating unnecessary barriers within the

recognition process itself, and should be proportionate to the profession and activity

concerned.

(26) In the context of procedures for obtaining long-stay visas and residence permits for

work purposes, Member States routinely assess the qualifications of third-country

nationals as part of the applications, yet assessment criteria and approaches vary across

Member States and legal pathways, often creating uncertainty for applicants and

disparities in outcomes. To address those challenges, a common framework for

recognition in the context of such procedures should be established, complementing

and aligning with existing Union legal migration instruments and national rules,

without adding procedural burdens or conflicting with more favourable provisions.

(27) This Directive should establish a right for third-country nationals to obtain the

assessment of their qualifications where such recognition constitutes a prerequisite or

material factor for a positive outcome of the procedures to obtain long-stay visas and

residence permits, ensuring access to a fair, efficient and non-discriminatory

procedure. Where a Member State already treats a foreign qualification as equivalent

to a domestic one without requiring formal recognition, this Directive should not

oblige that Member State to introduce an additional procedure.

(28) Formal recognition requirements should be avoided to access professions that are not

regulated, in favour of transparency and comparability tools, such as the European

Qualifications Framework11 and Europass12, which enable third-country nationals,

employers and competent authorities to understand and compare qualifications and

skills. Where a procedure to obtain a long-stay visa or a residence permit concerns

access to a profession that is not regulated, Member States should rely on such tools

rather than impose formal recognition requirements, and nothing in this Directive

should be construed as requiring Member States to introduce such requirements for

that purpose.

(29) In order to prevent gaps in the protection of applicants, a common set of minimum

procedural rules should apply to all recognition processes carried out in the context of

procedures for obtaining a long-stay visa or a residence permit, whatever their scope,

depth or complexity. Those rules should always be applied proportionately to their

purpose. Where a check is intended only to confirm that qualifications are genuine and

relevant, or to verify a qualification's level, Member States should apply simpler and

faster procedures than those used for recognition for access to regulated professions.

Nothing in this Directive should be constructed as requiring Member States to

establish new or standalone recognition procedures where the necessary assessment

can be carried out within existing migration procedures.

11 Council recommendation of 22 May 2017 on the European Qualifications Framework for lifelong

learning and repealing the recommendation of the European Parliament and of the Council of 23 April

2008 on the establishment of the European Qualifications Framework for lifelong learning (OJ C 189,

15.6.2017, p. 15). 12 Decision (EU) 2018/646 of the European Parliament and of the Council of 18 April 2018 on a common

framework for the provision of better services for skills and qualifications (Europass) and repealing

Decision No 2241/2004/EC.

EN 16 EN

(30) In order to ensure a consistent and objective basis for assessing qualification levels

across Member States, where procedures for obtaining a long-stay visa or a residence

permit require an assessment of an applicant's qualification level, that assessment

should be based on the descriptors and levels of the European Qualifications

Framework, having regard to national qualifications frameworks and, where available,

existing comparisons between third-country frameworks and the European

Qualifications Framework. Where a more detailed assessment is required, going

beyond a comparison of levels or a general classification of the field of study, a

learning outcomes approach should be applied, comparing the applicant's acquired

skills against those required in the host Member State. To avoid applicants

unnecessarily completing compensation measures before a final decision on entry or

residence, qualifications assessed under a learning outcomes approach should be

provisionally recognised for the purposes of the procedure for obtaining a long-stay

visa or a residence permit, with any compensation measure required only once entry or

residence has been granted.

(31) To avoid that third-country nationals undergo parallel and duplicative procedures,

Member States should offer applicants seeking both a long-stay visa or a residence

permit and access to a regulated profession an integrated recognition procedure, and,

where applicants do not choose that option, ensure effective coordination between the

separate procedures, including referral mechanisms and reuse of prior verifications.

(32) Recognition procedures often impose significant administrative and financial burdens

on applicants, in particular due to extensive documentation requirements, including

diplomas, transcripts and evidence of professional experience, and the associated costs

of translation. To alleviate this burden, Member States should limit the documents and

certificates they require to the types of documents listed in Annex VII of Directive

2005/36/EC. Where the procedure to obtain a long-stay visa or a residence permit does

not require recognition or assessment of qualifications that would give access to a

regulated profession in its territory, Member States should limit documentary

requirements to those directly related to the applicant’s qualifications. Since there may

be exceptional reasons, such as non-cooperation, non-responsiveness or administrative

dysfunction of a third-country authority, an applicant should be able to show that

despite reasonable efforts, they were unable to obtain the requested documents.

Member States should be able to employ reliable alternative methods to assess

qualifications, skills or other evidentiary elements.

(33) In cases of justified doubts regarding the authenticity of submitted documents, or

regarding an applicant's professional conduct or criminal record, Member States

should be able to seek confirmation from the competent authorities of the third country

or Member State where the qualification was awarded. However, in view of their

inherent security and verification mechanisms, digital credentials should be presumed

authentic, and their validity should not be challenged. Since third countries may

nonetheless fail to provide such confirmation in a timely manner due to, for example,

non-cooperation, non-responsiveness or administrative dysfunction, and in order to

ensure that recognition procedures are not delayed or obstructed by circumstances

outside the applicant's control, Member States should be able to rely on reliable

alternative methods of attestation.

(34) Doubts about the authenticity of qualifications are a major obstacle to efficient

recognition procedures. Verifying third-country qualifications often proves complex

and resource-intensive for Member States, leading to delays, administrative burdens,

and legal uncertainties. These challenges are particularly acute for documents issued in

EN 17 EN

countries with less strong institutional frameworks or conflicts, where verification is

difficult. This problem is further compounded by the prevalence of fraudulent

credentials and diploma mills, which undermine trust in qualification recognition

procedures. While Member States have introduced stringent verification measures –

such as certified translations, notarised copies, and legalisation – those measures,

though aimed at ensuring authenticity, prolong processing times and increase costs for

applicants and authorities alike. To support Member States in verifying the

authenticity of qualifications obtained in third countries, the Commission will provide

support services for the assessment of authenticity, by pooling expertise, digital tools

and through cooperation with third countries and relevant educational and professional

bodies. Since responsibility for the underlying recognition decision remains with the

competent authorities of the Member States, in providing these services the

Commission shall only have an advisory role, providing reasoned technical support

rather than binding conclusions.

(35) The exchange of requests and responses between the Commission and the competent

authorities of the Member States for the assessment of authenticity entails cross-border

exchanges of data in support of the recognition of qualifications obtained in third

countries. The authentication support services constitute a trans-European digital

public service within the meaning of Regulation (EU) 2024/903 (the Interoperable

Europe Act), given that their operation entails cross-border exchanges of data to

support the recognition of qualifications of third-country nationals. Their operation

should therefore be subject to an interoperability assessment as referred to in that

Regulation, to be carried out through a delegated act.

(36) The processing of personal data by the Commission is necessary for the performance

of a task carried out in the public interest, namely supporting Member States in

assessing the authenticity of qualifications obtained in third countries, that task being

laid down in this Directive. Such processing should therefore be based on Article 5(1),

point (a), of Regulation (EU) 2018/1725.

(37) The duration and unpredictability of qualification recognition procedures constitute

major obstacles for third-country nationals seeking to enter or integrate into the Union

labour market. Beyond decision-making times, the overall duration is further

prolonged by document collection, translation, legalisation and compensation

measures, hampering individuals' professional integration and disrupting employers'

recruitment processes. To enhance legal certainty and procedural efficiency, clear time

limits for the acknowledgement of applications and the completion of recognition

procedures should be set. Competent authorities should be required to keep applicants

informed of the progress of their application. Recognition procedures should remain

fully accessible to beneficiaries of international protection unable to provide

documentary evidence of their qualifications, in accordance with Article 30(2) of

Regulation (EU) 2024/1347 of the European Parliament and of the Council13, while

respecting the minimum training requirements provided for in Article 2(2) of Directive

2005/36/EC.

13 Regulation (EU) 2024/1347 of the European Parliament and of the Council of 14 May 2024 on

standards for the qualification of third-country nationals or stateless persons as beneficiaries of

international protection, for a uniform status for refugees or for persons eligible for subsidiary

protection and for the content of the protection granted, amending Council Directive 2003/109/EC and

repealing Directive 2011/95/EU of the European Parliament and of the Council (OJ L, 2024/1347,

22.05.2024, ELI: http://data.europa.eu/eli/reg/2024/1347/oj).

EN 18 EN

(38) The time limits applicable to the recognition procedure should be without prejudice to,

and should not extend, suspend or otherwise affect, deadlines laid down under national

or Union law for examining applications for long-stay visas or residence permits.

Member States should organise the recognition procedure so as not to undermine the

timely processing of such applications.

(39) To safeguard applicants' rights, decisions on recognition, or failures to meet prescribed

deadlines, should be subject to appeal under national law. Member States should also

allow applicants to receive communications in either an official language of the host

Member State or another language commonly used by third-country nationals there.

(40) Access to recognition procedures remains a significant challenge for third-country

nationals residing outside the Union or lacking a legal pathway to enter a Member

State solely for this purpose, particularly where procedures rely on in-person

verification or national electronic identification is unavailable prior to entry. Member

States should therefore enable applicants not yet residing in their territory but with a

demonstrated intention to do so to complete the process remotely.

(41) Since recognition may be a precondition for the issuance or renewal of a residence or

work permit, and since a residence permit may itself expire before an applicant

completes a required compensation measure, Member States should ensure that third-

country nationals already legally residing in their territory are not deprived of their

residence status as a result of undergoing a recognition procedure, including by issuing

or extending residence permits for the duration of any compensation measure.

(42) To further simplify recognition procedures, Member States should allow their

completion remotely and by electronic means, without prejudice to the ability of

competent authorities to request certified copies at a later stage where justified doubts

arise.

(43) Recognition procedures often impose significant and unpredictable financial burdens

on applicants, including application fees, translation and legalisation costs, and

charges linked to compensation measures, with particularly high costs observed in

some healthcare professions. Member States should ensure that any fees charged are

transparent, justified and proportionate.

(44) Access to clear, comprehensive and user-friendly information is essential for third-

country nationals seeking recognition of their qualifications, yet current information

mechanisms across Member States often fall short of applicants' needs. Member States

should ensure timely, accurate and user-friendly information on recognition

procedures, including through digital platforms and national assistance centres, with

particular attention to the needs of refugees, beneficiaries of international protection,

and other applicants unable to access or understand such information autonomously.

(45) Member States should take into account the risk that facilitated recognition of

qualifications obtained in third countries may contribute to the loss of skilled

personnel from sectors or regions already affected by workforce shortages, in

particular in the health sector. Member States should cooperate with third countries of

origin, including through knowledge-sharing, support for skills development, and

circular migration opportunities, so as to mitigate the risk of such losses while

facilitating the fair recognition of qualifications for third-country nationals already

present in, or seeking to move to, the Union. In the health sector specifically, Member

States should have regard to the principles set out in the World Health Organization

Global Code of Practice on the International Recruitment of Health Personnel, and to

EN 19 EN

the WHO Health Workforce Support and Safeguards List, when engaging in the

recruitment of health personnel qualified in third countries identified in that List as

facing critical health workforce shortages.

(46) To ensure effective and consistent implementation of this Directive, a group on the

recognition of qualifications of third-country nationals should be established to

support cooperation between Member States and the Commission and the exchange of

experience and best practices. The assistance centres designated by Member States

pursuant to Article 57b of Directive 2005/36/EC should also assume responsibility for

matters relating to the recognition of qualifications of third-country nationals under

this Directive, without prejudice to the responsibilities of other competent authorities

under Union or national law.

(47) In order to achieve the objectives of this Directive, the power to adopt acts in

accordance with Article 290 TFEU should be delegated to the Commission to establish

and amend a list of trusted review bodies. It is of particular importance that the

Commission carry out appropriate consultations during its preparatory work, including

at expert level, and that those consultations be conducted in accordance with the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making14. In particular,

to ensure equal participation in the preparation of delegated acts, the European

Parliament and the Council receive all documents at the same time as Member States'

experts, and their experts systematically have access to meetings of Commission

expert groups dealing with the preparation of delegated acts.

(48) In order to ensure uniform conditions for the implementation of this Directive,

implementing powers should be conferred on the Commission. Those powers should

be exercised in accordance with Regulation (EU) No 182/2011 of the European

Parliament and of the Council.15

(49) To enable effective monitoring of the implementation and impact of this Directive, and

to support its continuous improvement, Member States should provide the

Commission with annual statistics on the number of applications and decisions taken,

and should report periodically on the practical application of the provisions of this

Directive, including processing times, outcomes and stakeholder feedback, on the

basis of which the Commission should report to the European Parliament and the

Council.

(50) In accordance with Articles 1 and 2 of Protocol No 21 on the position of the United

Kingdom and Ireland in respect of the area of freedom, security and justice, annexed

to the Treaty on European Union (TEU) and to the TFEU, and without prejudice to

Article 4 of that Protocol, Ireland is not taking part in the adoption of this Directive

and is not bound by it or subject to its application. [Or: In accordance with Article 3 of

Protocol No 21 on the position of the United Kingdom and Ireland in respect of the

area of freedom, security and justice, annexed to the TEU and to the TFEU, Ireland

has notified, by letter of XXX, its wish to take part in the adoption and application of

this Directive.]

14 OJ L 123, 12.5.2016, p. 1, http://data.europa.eu/eli/agree_interinstit/2016/512/oj. 15 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

laying down the rules and general principles concerning mechanisms for control by the Member States

of the Commission's exercise of implementing powers (OJ L 55, 28.2.2011, p. 13, ELI:

http://data.europa.eu/eli/reg/2011/182/oj).

EN 20 EN

(51) In accordance with Articles 1 and 2 of Protocol No 22 on the position of Denmark,

annexed to the TEU and to the TFEU, Denmark is not taking part in the adoption of

this Directive and is not bound by it or subject to its application.

(52) Since the objectives of this Directive, namely, to establish a streamlined and trusted

framework for the recognition of third-country nationals' qualifications, cannot be

sufficiently achieved by Member States but can, by reason of scale and effects, be

better achieved at Union level, the Union may adopt measures in accordance with the

principle of subsidiarity under Article 5 of the Treaty on the European Union. In

accordance with the principle of proportionality, this Directive does not go beyond

what is necessary to achieve those objectives.

(53) The processing of personal data under this Directive by the competent authorities of

the Member States should be carried out in accordance with Regulation (EU)

2016/679 of the European Parliament and of the Council16. The processing of personal

data under this Directive by the Commission, including for the support services for

assessment of authenticity, should be carried out in accordance with Regulation (EU)

2018/1725 of the European Parliament and of the Council17.

(54) The European Data Protection Supervisor was consulted in accordance with Article

42(1) of Regulation (EU) 2018/1725 and delivered an opinion on (…) ],

HAVE ADOPTED THIS DIRECTIVE:

Title I

General provisions

Article 1

Subject matter

1. This Directive lays down minimum requirements for the recognition of qualifications

held by third-country nationals.

2. This Directive shall not affect provisions of Union law and national law which are

more favourable to third-country nationals, including provisions regarding

procedures to obtain long-stay visas or residence permits where recognition forms

part of such procedures. This Directive shall also apply without prejudice to relevant

international instruments, including future or existing mutual recognition agreements

for qualifications with third countries.

Article 2

Scope

16 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data and on the free movement of

such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016,

p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj). 17 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

protection of natural persons with regard to the processing of personal data by the Union institutions,

bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No

45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI:

http://data.europa.eu/eli/reg/2018/1725/oj).

EN 21 EN

1. This Directive shall apply to the recognition of qualifications held by third-country

nationals:

(a) legally residing in a Member State;

(b) seeking entry to and residence in a Member State, and that are undergoing a

procedure to obtain a long-stay visa or a residence permit in accordance with

Title III;

(c) seeking entry and residence in a Member State, and that apply for recognition

remotely in accordance with Article 30, and who meet one of the following

conditions:

(i) they have obtained a job offer in that Member State;

(ii) they are registered as a jobseeker on the EU Talent Pool established by

Regulation EU(2026)1047 and have been selected for a job vacancy or

have been contacted by an employer to start the recruitment process for a

job in that Member State, where recognition of qualifications is required

for the role.

It does not apply to the recognition of qualifications for the purpose of access to

further learning.

2. For the purposes of paragraph 1, this Directive shall apply where the recognition of

those qualifications, whether obtained in another Member State or in a third country:

(a) is a precondition to access and pursue a regulated profession within a Member

State, on either self-employed or employed basis; or

(b) constitutes a factor determining the outcome of a procedure to obtain a long-

stay visa or a residence permit for work purposes.

3. This Directive shall not apply to third-country nationals who, under agreements

between the Union and its Member States, on the one hand, and third countries, on

the other hand, enjoy rights of free movement equivalent to those of Union citizens.

4. This Directive shall not apply to notaries who are appointed by an official act of

government.

Article 3

Definitions

For the purposes of this Directive, the following definitions apply:

(a) ‘applicants’ means third-country nationals who apply to a host Member State for the

recognition of their qualifications and/or to obtain long-stay visas or residence

permits;

(b) ‘regulated profession’ means a regulated profession as defined in Article 3(1), point

(a), of Directive 2005/36/EC;

(c) ‘professional qualifications’ means qualifications attested by evidence of formal

qualifications, an attestation of competence and/or professional experience;

(d) ‘recognition of professional qualifications’ means the recognition by the host

Member State of a professional qualification obtained in another Member State or in

a third country for the purposes of access to or pursuit of a regulated profession in

the territory of the host Member State;

EN 22 EN

(e) ‘evidence of formal qualifications’ means diplomas, certificates and other evidence

issued by an authority in a Member State or a third country designated pursuant to

legislative, regulatory or administrative provisions of that Member State or that third

country and certifying successful completion of professional training;

(f) ‘attestation of competence’ means documentation issued by the competent authority

in a Member State or third country designated in accordance with relevant

legislative, regulatory, or administrative provisions, on the basis of one or more of

the following:

(i) A training course not forming part of a certificate or diploma;

(ii) a specific examination without prior training;

(iii) full-time pursuit of the profession in a Member State or third country for three

consecutive years or for an equivalent duration on a part-time basis during the

previous 10 years;

(iv) general primary or secondary education attesting that the holder has acquired

general knowledge;

(g) ‘recognition in the context of a procedure to obtain a long-stay visa or a residence

permit’ means the recognition or assessment, by a Member State, of qualifications or

skills obtained in a third country or in another Member State, and held by a third-

country national, where it constitutes a factor determining the outcome of a

procedure to obtain a long-stay visa or a residence permit, including within a points-

based immigration system;

(h) ‘third-country national’ means a person who is not a citizen of the Union within the

meaning of Article 20(1) TFEU;

(i) ‘competent authority’ means any authority or body empowered by a Member State or

a third country specifically to issue or receive training diplomas and other documents

or information, to receive applications, and take the decisions referred to in this

Directive;

(j) ‘professional experience’ means the actual and lawful full-time or equivalent part-

time pursuit of the profession concerned in a Member State or a third country;

(k) ‘adaptation period’ means an adaptation period as defined in Article 3(1), point (g),

of Directive 2005/36/EC;

(l) ‘aptitude test’ means a test tailored to the applicant as defined in Article 3(1), point

(h), of Directive 2005/36/EC;

(m) ‘test of professional competence’ means a standardised test, designed for a specific

profession in order to evaluate an applicant’s knowledge and skills that are essential

to pursue that profession in the host Member State;

(n) ‘bridging course’ means a targeted course designed for a defined target group of

already qualified professionals to address specific typical gaps in professional

knowledge, skills and competences and enable them to practise the regulated

profession in the host Member State;

(o) ‘quality assurance agency’ means an independent body carrying out external quality

assurance in higher education or in vocational education and training (VET);

(p) ‘European Quality Assurance Register for Higher Education (EQAR)’ means the

register of quality assurance agencies that have demonstrated substantial compliance

EN 23 EN

with the Standards and Guidelines for Quality Assurance in the European Higher

Education Area, in the applicable version at the relevant time;

(q) ‘digital credential’ means a credential issued in electronic form which provides

information on qualifications, qualification levels, skills or learning outcomes, and

which can be used to demonstrate that information in a reliable and verifiable

manner.

Title II

Recognition to access a regulated profession

Chapter 1

General provisions

Article 4

Effects of recognition

1. The recognition of professional qualifications by the host Member State shall allow

beneficiaries to gain access in that Member State to the same profession as the one

for which they are qualified in the third country or in the other Member State where

they obtained their qualifications under the same conditions as the nationals of the

host Member State, provided the beneficiaries meet all necessary legal requirements

for employment and residency.

2. For the purposes of this Directive, the profession which the applicant wishes to

pursue in the host Member State shall be considered the same as the one for which

they are qualified in a third country or in another Member State if the activities

covered are comparable.

3. By way of derogation from paragraph 1 of this Article, partial access to a profession

in the host Member State shall be granted under the conditions laid down in Article

5.

Article 5

Partial access

1. The competent authority of the host Member State shall grant partial access, on a

case-by-case basis, to a professional activity in its territory only when all the

following conditions are fulfilled:

(a) the professional is fully qualified to exercise in a third country or another

Member State the professional activity for which partial access is sought in the

host Member State;

(b) differences between the professional activity legally exercised in the third

country or in the other Member State and the regulated profession in the host

Member State as such are so large that the application of compensation

measures would amount to requiring the applicant to complete the full

programme of education and training required in the host Member State to

have access to the full regulated profession in the host Member State;

(c) the professional activity can objectively be separated from other activities

falling under the regulated profession in the host Member State.

EN 24 EN

For the purpose of the first subparagraph, point (c), the competent authority of the

host Member State shall take into account whether the professional activity can be

pursued autonomously in the third country or in the other Member State.

2. Partial access may be rejected if such rejection is justified by overriding reasons of

general interest, suitable for securing the attainment of the objective pursued, and

does not go beyond what is necessary to attain that objective.

3. Applications for the purposes of establishment in a Member State shall be examined

in accordance with Chapter 2 of this Title and with Title IV.

4. By way of derogation from Article 19, the professional activity shall be exercised

under the professional title of the third country or of the other Member State once

partial access has been granted. The host Member State may require use of that

professional title in the languages of the host Member State. Professionals benefiting

from partial access shall clearly indicate to the service recipients the scope of their

professional activities.

5. This Article shall not apply to professionals benefiting from automatic recognition of

their professional qualifications under Chapter 3 of this Title, and in cases where

Chapter II, III or IIIa of Title III of Directive 2005/36/EC have been applied to third-

country nationals in accordance with Article 6 of this Directive.

Article 6

Evidence of professional qualifications obtained in the Union

Where third-country nationals hold an attestation of competence, evidence of formal

qualifications, or professional experience obtained in the Union, and such qualifications or

experience would allow a Union citizen to access or pursue a regulated profession in the host

Member State pursuant to Title III of Directive 2005/36/EC, the provisions of that Directive

shall apply to those third-country nationals accordingly when they seek recognition to access

and pursue that profession in the host Member State.

Chapter 2

General system for the recognition of evidence of training issued

in third countries

Article 7

Scope

This Chapter applies to situations which are not covered by Article 6, or by Chapter 3 of this

Title or where the applicant does not satisfy the conditions laid down in Chapter 3 of this

Title.

Article 8

Conditions for recognition

1. If access to or pursuit of a regulated profession in a host Member State is contingent

upon possession of specific professional qualifications, the competent authority of

that Member State shall permit applicants to access and pursue that profession, under

the same conditions as apply to its nationals, if they possess an attestation of

competence or evidence of formal qualifications, issued by a competent authority in

EN 25 EN

a third country, and required by a third country in order to gain access to and pursue

that profession on that country’s territory.

2. Access to, and pursuit of, a profession as referred to in paragraph 1 shall also be

granted to applicants who have pursued the profession concerned on a full-time basis

for one year or for an equivalent overall duration on a part-time basis during the

previous 10 years in a third country which does not regulate that profession, and who

possess one or more attestations of competence or evidence of formal qualifications

issued by that third country which does not regulate the profession.

Attestations of competence and evidence of formal qualifications shall satisfy both of

the following conditions:

(a) they are issued by a competent authority in a third country;

(b) they attest that the holder has been prepared for the pursuit of the profession

concerned.

3. By way of derogation from paragraphs 1 and 2 of this Article, the competent

authority of the host Member State may refuse access to, and pursuit of, the regulated

profession to applicants who only possess an attestation of competence, where access

to or pursuit of that regulated profession in the host Member State requires a diploma

certifying successful completion of a post-secondary course of at least four years, or

for an equivalent duration on a part-time basis, which may in addition be expressed

with an equivalent number of ECTS credits, at a university or establishment of

higher education or another establishment of equivalent level.

4. When the applicant duly documents that, despite reasonable efforts, they were unable

to obtain the attestation of competence referred to in paragraphs 1, 2 and 3, the host

Member State shall assess the feasibility of, and where appropriate, employ

alternative methods to assess qualifications, skills or other evidentiary elements.

Those methods may include affidavits, third-party assessments, professional

interviews or reputable evaluation frameworks like qualifications passports, designed

for refugees and vulnerable migrants. The host Member State shall ensure that

applicants are not unduly disadvantaged due to those circumstances and shall base its

decisions on available and reasonable evidence.

Article 9

Compensation measures

1. Article 8 shall not preclude the host Member State from imposing on the applicant a

compensation measure among those listed in paragraph 2 of this Article in one of the

following cases:

(a) the training that the applicant has received covers substantially different

matters from those covered by the evidence of formal qualifications required in

the host Member State;

(b) the regulated profession in the host Member State comprises one or more

regulated professional activities which do not exist in the corresponding

profession in the third country where the applicant obtained the attestation of

competence or evidence of formal qualifications, and the training required in

the host Member State covers substantially different matters from those

covered by the applicant’s attestation of competence or evidence of formal

qualifications;

EN 26 EN

(c) the Member State has justified doubts as to the quality of the education,

training or qualification system under which the evidence of formal

qualifications has been awarded.

For the purpose of this Article, ‘substantially different matters’ means matters in

respect of which knowledge and skills acquired are essential for pursuing the

profession and with regard to which the training received by the applicant shows

significant differences in terms of content from the training required by the host

Member State.

In case a Member State decides to impose compensation measures on the basis of

justified doubts according to point (c), it shall notify the Commission of the country

and profession concerned and the nature of the doubts.

2. If the host Member State makes use of the option provided for in paragraph 1, it shall

indicate to the applicant which of the following compensation measures they are

required to complete:

(a) an adaptation period, not exceeding three years, where the applicant undergoes

supervised practice and, if necessary, additional training;

(b) an aptitude test;

(c) a test of professional competence;

(d) a bridging course, with a duration of up to one year.

3. Paragraphs 1 and 2 shall be applied with due regard to the principle of

proportionality. In particular, if the host Member State intends to require the

applicant to complete a compensation measure, it shall first ascertain whether the

knowledge, skills and competences acquired by the applicant in the course of the

applicant’s professional experience or through lifelong learning, and formally

validated to that end by a relevant body, in any Member State or in a third country, is

of such nature as to cover, in full or in part, the substantially different matters.

4. The decision imposing a compensation measure shall be duly justified. In particular,

the applicant shall be provided with the reasons for the compensation measure,

information on the substantial differences, and, where relevant, why those

differences cannot be compensated by knowledge, skills and competences acquired

in the course of prior experience or other qualifications through lifelong learning

formally validated to that end by a relevant body.

5. Member States shall ensure that an applicant who fails the aptitude test or test of

professional competence referred to in paragraph 2, points (b) and (c), or one or more

tests forming part of a bridging course or adaptation period, referred to in paragraph

2, points (a) and (d), is given the opportunity to retake the respective tests. Member

States shall ensure that feedback detailing assessment results and areas for

improvement is provided to applicants, and ensure that applicants are entitled to at

least two further attempts to pass each test that they have failed.

6. Member States shall ensure that an applicant has the possibility of taking the aptitude

test or the test of professional competence referred to in paragraph 2, points (b) and

(c), not later than six months after the initial decision imposing an aptitude test or test

of professional competence on the applicant. Member States shall also ensure that an

applicant has the possibility to start a bridging course referred to in paragraph 2,

point (d), no later than six months after the initial decision imposing the completion

of a bridging course on the applicant.

EN 27 EN

Article 10

Minimum training requirements for certain professions

Where Articles 24, 25, 28, 31, 34, 35, 38, 40 and 44 of Directive 2005/36/EC set out

minimum conditions on the training for certain professions, under this Chapter any

recognition of evidence of formal qualifications in one of those professions shall be

contingent upon fulfilment of those minimum conditions.

Chapter 3

Recognition on the basis of reviewed training programmes in

accordance with minimum training conditions

Article 11

Principle of automatic recognition based on reviewed training programmes in third

countries

1. Each Member State shall recognise evidence of formal qualifications giving access to

the professional activities of doctor with basic training or specialised doctor, as nurse

responsible for general care, as dental practitioner, as specialised dental practitioner,

as midwife, as veterinary surgeon, as pharmacist, and as architect, obtained in a third

country, and shall for the purposes of access to and pursuit of those professional

activities, give such evidence the same effect on its territory as the evidence of

formal qualifications which it itself issues, provided that all of the following

conditions are met:

(a) the evidence of formal qualifications has been obtained following successful

completion of a training programme which has been reviewed in accordance

with Articles 13 and 14 by a trusted review body within the meaning of Article

12;

(b) the trusted review body has publicly disclosed the result of the review process

and a review report;

(c) the evidence of formal qualifications is issued as a digital credential.

2. Each Member State shall, for the purpose of access to and pursuit of a regulated

profession that is covered by a common training framework pursuant to Article 49a

of Directive 2005/36/EC, and where that Member State is not exempted from the

obligation of introducing a common training framework in accordance with Article

49a(5) of Directive 2005/36/EC, give evidence of formal qualifications acquired in

third countries the same effect in its territory as the evidence of formal qualifications

which it itself issues, provided that all of the following conditions are met:

(a) the evidence of formal qualifications has been obtained following successful

completion of a training programme which has been reviewed in accordance

with Articles 13 and 14 by a trusted review body as referred to in Article 12;

(b) the trusted review body has publicly disclosed the result of the review process

and a review report;

(c) the evidence of formal qualifications is issued as a digital credential.

EN 28 EN

Article 12

Trusted review bodies

1. A quality assurance agency established in the Union may apply to the Commission to

be listed as a trusted review body for higher education programmes if it fulfils all of

the following criteria:

(a) it is registered in the European Quality Assurance Register for Higher

Education (EQAR) without interruption for a period of at least 10 years;

(b) it has documented prior experience in conducting external quality assurance

reviews, as a quality assurance agency, in at least three different third

countries.

2. A quality assurance agency established in the Union may apply to the Commission to

be listed as a trusted review body for vocational education and training (VET)

programmes if it fulfils all of the following criteria:

(a) it is competent, under national law, in the Member State in which it is

established, for the quality assurance of VET programmes;

(b) it has documented prior experience in conducting external quality assurance

reviews, as a quality assurance agency, in at least three different third

countries.

3. The Commission is empowered to adopt a delegated act supplementing this Directive

by listing the trusted review bodies in accordance with Article 36. It shall list all

quality assurance agencies that applied to be listed in accordance with paragraphs 1

and 2, and that comply with the requirements set out in those paragraphs.

4. Only trusted review bodies listed in the delegated act referred to in paragraph 3 shall

be considered trusted review bodies for the purposes of this Directive, and only in

relation to the professions indicated therein.

Article 13

Reviewed training programmes

For the purposes of Article 11, only training programmes that have been reviewed in

accordance with Article 14 and found to fulfil the following criteria shall be considered as

reviewed training programmes:

(a) The training programme is compliant with the Standards and Guidelines for Quality

Assurance in the European Higher Education Area (ESG), in the version applicable

at the relevant time, in case the training programme is delivered through a higher

education institution;

(b) Quality assurance measures comprising independent assessment, a competence-

based assessment methodology, transparent outcomes, periodic external review, and

an appeal or complaint mechanism have been implemented for the delivery of the

programme, in case the training programme is delivered through vocational training;

(c) The institution delivering the programme is lawfully established in the third country

concerned and authorised under the law of that country to award the qualification in

question;

EN 29 EN

(d) For the professions listed in Article 11(1), the training programme is compliant with

the minimum conditions on the training applicable to the relevant profession as set

out in Articles 24, 25, 28, 31, 34, 35, 38, 40, 44, and 46 of Directive 2005/36/EC;

(e) In the cases of Article 11(2), the training programme is compliant with the applicable

common training framework.

Article 14

Review of training programmes in third countries

For the purposes of Article 11, Member States shall ensure that the review of training

programmes is carried out as follows:

(a) Upon request by a training institution in higher education or in vocational training

outside the Union, a trusted review body pursuant to Article 12 assesses compliance

with the criteria set out in Article 13.

(b) To this end, the trusted review body forms a review team which carries out the

assessment of the training programme. For that purpose, the review team shall

consist of:

(i) between five and nine reviewers selected by the trusted review body. Those

reviewers shall include subject matter experts of the relevant discipline or

disciplines, and specialists in quality assurance and evaluation methodologies;

and

(ii) up to three reviewers that Member States appoint for the review following an

invitation to all Member States by the trusted review body. For that purpose,

each Member State shall appoint only one reviewer. Where more than three

Member States intend to appoint a reviewer, a randomised process shall apply

for the selection of the three reviewers.

Each of the reviewers selected pursuant to points (i) and (ii) shall declare, prior to

participating in the review, the absence of any conflict of interest in relation to the

institution under review, including any consultancy, advisory or other remunerated

relationship with that institution within the preceding three years. A reviewer unable

to make that declaration shall not participate in the review of the institution

concerned.

(c) The trusted review body organises at least one on-site visit of the review team as an

integral part of the assessment of the training programme.

(d) The trusted review body communicates its decision on the outcome of the assessment

to the institution organising the reviewed training programme and to the

Commission.

(e) Following a positive assessment of a training programme, the trusted review body

grants the status of ‘reviewed’ on the basis that the applicable requirements laid

down in Article 13 are satisfied. The status of ‘reviewed’ shall be valid for a period

of five years or until the transposition deadline of any Commission delegated act,

adopted pursuant to Article 21(6), second subparagraph of Directive 2005/36/EC,

which updates the knowledge and skills referred to in Articles 24(3), 31(6), 34(3),

38(3), 40(3), 44(3), or 46(4) of Directive 2005/36/EC.

(f) After each assessment the trusted review body makes the result of the review process

publicly available in a dedicated, clearly identifiable and easily accessible section of

EN 30 EN

its website or other publicly accessible online interface, no matter if the outcome of

the review was positive or negative.

(g) If requested by the training institution with a reviewed programme, the trusted

review body carries out a new review following the submission of a renewal

application at least six months before the expiration of the current status of

‘reviewed’. The training institution shall present detailed reports demonstrating

continuous compliance with the training standards since the last review, alongside

documentation outlining enhancements in training methodologies, assessment

processes, and quality assurance practices. The trusted review body shall review the

renewal application and communicate its decision to the institution organising the

reviewed training programme and to the Commission within three months of

application submission. The review team under point (b)(i) shall not be the same as

the review team for the institution's immediately preceding review.

(h) Any fee or charge levied by the trusted review body for the review shall be

transparent and proportionate to the costs of the service provided, and shall be

commensurate with the complexity, scope and duration of the review carried out by

the trusted review body. This shall not preclude the trusted review body from

including in its fees a reasonable margin over its costs, provided that such margin

does not render the fee disproportionate to the service provided.

Article 15

Right to appeal or contest review decisions

1. Training institutions whose training programmes received a negative result

following the review in accordance with Article 14 shall be allowed to appeal that

result under the national law of the Member State where the trusted review body is

established. Member States shall establish procedures ensuring that such appeals are

resolved fairly and promptly.

2. If a Member State has justified doubts on the review carried out pursuant to Article

14, that Member State may communicate its concerns in writing to the Commission.

Within 15 working days after receipt of that communication, the Commission shall

provide its views and invite the other Member States to express their views. In case

at least 5 Member States express support for this concern to the Commission within

two months following that invitation, the Commission shall inform all Member

States in writing that they shall only consider the given training programme as

reviewed once a second review has been carried out pursuant to Article 14.

3. If following the second review pursuant to paragraph 2 the training programme is

granted the status of ‘reviewed’, the validity period referred to in Article 14, point (e)

shall start from the date of that result.

4. If the result of the second review is negative, the programme shall not be considered

as a reviewed training programme in the meaning of Article 13 and cannot benefit

from recognition pursuant to Article 11.

Article 16

Listed third countries

1. For qualifications obtained in a third country listed in the delegated acts referred to in

paragraph 2 of this Article, Member States shall ensure that trusted review bodies

EN 31 EN

automatically consider the criteria laid down in Article 13, points (a) and (b) as being

fulfilled.

2. The Commission is empowered to adopt delegated acts in accordance with Article 36

to supplement this Directive by establishing and amending a list of third countries for

which the learning quality assurance systems provide guarantees as regards all of the

following elements:

(a) public oversight or equivalent supervision of qualifications;

(b) quality assurance or accreditation of the relevant institutions or training

programmes;

(c) authenticity, reliability and verifiability of the qualifications issued;

(d) comparability and consistency of the intended learning outcomes or

qualification standards relevant to the application of this Directive;

(e) administrative cooperation with the competent authorities of the Member

States and the Commission.

3. The Commission shall monitor whether the third countries listed in the delegated acts

referred to in paragraph 2 continue to fulfil the conditions laid down in paragraph 2,

points (a) to (e). Where the Commission has well-founded concerns that the

conditions for the inclusion of a third country in the list are no longer fulfilled, it may

adopt a decision suspending the application of paragraph 1 in respect of that third

country. The Commission shall inform the third country concerned and the Member

States of the suspension and the reasons without delay.

4. The suspension referred to in paragraph 3 of this Article shall apply until the

Commission, following its assessment, either lifts it or adopts a delegated act in

accordance with Article 36 removing the third country concerned.

Chapter 4

Rules for pursuing the profession

Article 17

Knowledge of languages

1. Professionals benefiting from the recognition of professional qualifications shall

have a knowledge of languages necessary for practising the profession in the host

Member State.

2. A Member State shall ensure that any controls carried out by, or under the

supervision of, the competent authority for controlling compliance with the

obligation under paragraph 1 shall be limited to the knowledge of one official

language of the host Member State, or one administrative language of the host

Member State provided that it is also an official language of the Union.

3. Controls carried out in accordance with paragraph 2 may be imposed if the

profession to be practised has patient safety implications. Controls may be imposed

in respect of other professions in cases where there is a serious and concrete doubt

about the sufficiency of the professional’s language knowledge in respect of the

professional activities that that professional intends to pursue.

Controls may be carried out only after the recognition of a professional qualification.

EN 32 EN

4. Any language controls shall be proportionate to the activity to be pursued. The

professional concerned shall be allowed to appeal such controls under national law.

Article 18

Use of academic titles

Without prejudice to Article 19, the host Member State shall ensure that the right shall be

conferred on the persons concerned to use academic titles awarded to them in another

Member State or in a third country, and possibly an abbreviated form thereof, in the language

of that other Member State or that third country. The host Member State may require that title

to be followed by the name and address of the establishment or examining board which

awarded it. Where an academic title of another Member State or of a third country is liable to

be confused in the host Member State with a title which, in the latter Member State, requires

supplementary training not acquired by the beneficiary, the host Member State may require

the beneficiary to use the academic title of the Member State or third country where it has

been issued in an appropriate form, to be laid down by the host Member State.

Article 19

Use of professional titles

1. If, in a host Member State, the use of a professional title relating to one of the

activities of the profession in question is regulated, third-country nationals who are

authorised to practise a regulated profession on the basis of this title shall use the

professional title of the host Member State, which corresponds to that profession in

that Member State, and make use of any associated initials.

2. Where a profession is regulated in the host Member State by an association or

organisation within the meaning of Article 3(2) of Directive 2005/36/EC, third-

country nationals shall not be authorised to use the professional title issued by that

organisation or association, or its abbreviated form, unless they furnish proof that

they are members of that association or organisation.

If the association or organisation makes membership contingent upon certain

qualifications, it may do so only under the conditions laid down in this Directive, in

respect of third-country nationals who possess professional qualifications.

Article 20

Approval by health insurance funds

Member States which require persons who acquired their professional qualifications in their

territory to complete a preparatory period of in-service training and/or a period of professional

experience in order to be approved by a health insurance fund, shall waive this obligation for

the holders of evidence of professional qualifications of doctor and dental practitioner

acquired in other Member States or in other third countries.

EN 33 EN

Title III

Recognition in the context of a procedure to obtain a long-stay

visa or a residence permit

Article 21

Scope

This Title applies where the recognition by the host Member State of a qualification or skills

obtained in another Member State or in a third country, and held by a third-country national,

constitutes a factor determining the outcome of a procedure to obtain a long-stay visa or a

residence permit for work purposes, including within a points-based immigration system.

Article 22

Right to assessment of qualifications and skills in the context of a procedure to obtain a

long-stay visa or a residence permit

1. Member States shall ensure that, where the recognition or assessment of

qualifications or skills constitutes a factor determining the outcome of a procedure to

obtain a long-stay visa or a residence permit for work purposes, applicants have the

right to have assessed and taken into account the following for the purposes of that

procedure:

(a) their formal qualifications obtained in another Member State or in a third

country;

(b) their skills acquired through professional or other experience.

2. Where relevant to that procedure, that assessment may take into account information

provided by a current or prospective employer of the applicant, in particular

concerning the tasks, responsibilities and skills required for the position offered.

3. Member States shall ensure that qualifications and skills referred to in paragraph 1

are not refused solely on the ground that they were obtained in another Member State

or in a third country.

4. Member States shall ensure that the recognition and assessment procedure is fair,

does not impose unnecessary burdens on applicants, and is designed to facilitate the

efficient processing of applications for a long-stay visa or a residence permit.

5. Member States shall ensure that the recognition or assessment results are presented

to the applicant in a reasoned decision. That decision shall determine whether the

qualifications or skills of the third-country national are:

(a) recognised and thus treated as equivalent to the qualification level or other

qualification requirements applicable in the context of the procedure to obtain a

long-stay visa or a residence permit;

(b) recognised provisionally, contingent upon the applicant completing

compensation measures in accordance with Article 25(3);

(c) not recognised.

Article 23

Procedural requirements

EN 34 EN

1. Member States shall ensure that any recognition or assessment referred to in Article

22 is carried out within the procedure to obtain a long-stay visa or a residence permit

and in accordance with the principles of necessity, proportionality and simplification.

2. Where the procedure to obtain a long-stay visa or a residence permit does not require

recognition or assessment of qualifications that would give access to a regulated

profession in its territory, the host Member State shall assess qualifications or skills

within the procedure to obtain a long-stay visa or a residence permit and shall not

require a separate recognition or assessment procedure outside that procedure. In

particular, that Member State shall:

(a) not duplicate previous assessments or the requirement to submit evidence that

is already available to, or capable of being obtained by, the competent

authorities of that Member State;

(b) integrate any request for information or supporting evidence to carry out the

recognition or assessment in the application to obtain a long-stay visa or a

residence permit, and not require a separate application for recognition of

qualifications;

(c) limit documentary requirements to those that are necessary for the assessment

and reasonably available to the applicant or, with the applicant’s consent, to a

current or prospective employer submitting evidence on the applicant’s behalf;

(d) not charge any separate or additional fees for the assessment or recognition of

qualifications or skills, other than fees that may be charged for the procedure to

obtain a long-stay visa or a residence permit;

(e) ensure that the assessment or recognition of qualifications or skills is carried

out within the time limits of the procedure to obtain a long-stay visa or a

residence permit and does not cause delay in the processing of the relevant

long-stay visa or residence permit application.

Article 24

Recognition of qualification levels

1. Where, for the purposes of recognition in the context of a procedure to obtain a long-

stay visa or a residence permit, Member States establish the level of a qualification,

they shall apply the levels and descriptors of the European Qualifications Framework

(EQF) as set out in [Annex III of Regulation xxxx/xx/EU establishing a framework

for portability of skills and qualifications and amending Regulation (EU) 2018/1724

('Skills Portability Act')].

For that purpose, Member States shall take into account any relevant existing

comparison of qualification levels or frameworks of third countries to the EQF.

2. The level of the qualification shall not constitute the only element of the assessment

but shall be considered together with the qualification’s intended learning outcomes,

duration, content, workload, practical training, professional experience and, where

relevant, the scope of professional activities to which it gives access in another

Member State or the third country in which it was awarded.

Article 25

Recognition of qualifications without access to regulated professions

EN 35 EN

1. Where Member States evaluate qualifications for the purpose of recognition in the

context of a procedure to obtain a long-stay visa or a residence permit, and where

that evaluation goes beyond a comparison of qualification levels as provided for in

Article 24 and a general classification of the field of study, they shall ensure that a

learning outcomes approach is applied, focusing primarily on comparing the

applicant’s acquired skills to the relevant reference qualification. Where possible, the

assessment shall also consider experiences gained through non-formal learning and

skills acquired through professional or other experience. Where provided, and with

the applicant’s consent, information from a current or prospective employer relevant

to the skills required for the position offered may also be taken into account.

2. Member States shall recognise a qualification in the context of a procedure to obtain

a long-stay visa or a residence permit if all of the following conditions are met:

(a) there are no substantial differences in qualification level;

(b) there are no substantial differences in the intended learning outcomes;

(c) there are no justified doubts on the quality of the education, training or

qualification system under which the evidence of formal qualifications has

been awarded in a third country.

3. If substantial differences in intended learning outcomes or levels of qualification are

established, or if the Member State has justified doubts on the quality of the

education, training or qualification system under which the evidence of formal

qualifications has been awarded in a third country, provisional recognition shall be

granted, contingent upon the applicant completing suitable compensation measures

within a clearly defined timeframe laid down by the host Member State. For the

purpose of the procedure to obtain a long-stay visa or a residence permit, the

provisionally recognised qualification shall be treated as finally recognised. The host

Member State shall, at the time provisional recognition is granted, inform the

applicant in writing of the compensation measures required, the timeframe within

which they shall be completed, and the consequences of failing to complete them

within that timeframe. The successful completion of the compensation measures

shall only be required if the applicant is subsequently granted a long-stay visa or a

residence permit.

4. The compensation measures shall be designed to address identified gaps and shall be

selected from one of the following:

(a) an aptitude test;

(b) a test of professional competence;

(c) a bridging course, with a duration of up to one year.

5. By way of derogation from paragraph 3, if substantial differences in the learning

outcomes or the level of qualification cannot be adequately remedied through

compensation measures, Member States may refuse recognition of qualifications for

the purpose of the procedure to obtain a long-stay visa or a residence permit. A

decision to refuse recognition of qualifications shall not automatically result in the

rejection of the application for a long-stay visa or a residence permit.

6. For the purposes of paragraphs 2, 3 and 4:

(a) 'substantial difference in intended learning outcomes' means instances where

the essential knowledge and skills, necessary for practising a given profession,

EN 36 EN

are not among the intended learning outcomes of the third-country

national’s training, resulting in significant differences in terms of the essential

knowledge and skills obtained compared with those required by the host

Member State;

(b) ‘substantial difference in qualification levels’ means instances where the

qualification level of a third-country national is assessed to be two or more

levels below the level of the training required by the host Member State, as

determined by the descriptors of the EQF.

Article 26

Integrated procedure with the recognition of professional qualifications

1. Member States shall offer applicants seeking recognition of qualifications in the

context of a procedure to obtain a long-stay visa or a residence permit, who also wish

to access a regulated profession, the possibility of choosing an integrated recognition

procedure. That procedure shall satisfy the requirements laid down in this Title and

in Title II. Upon successful completion of the integrated recognition procedure, the

applicant shall receive a recognition of qualifications for the purposes of the

procedure to obtain a long-stay visa or a residence permit as referred to in Article

22(5), point (a), and for the access to the regulated profession, as provided for in

Article 4.

2. For applicants not opting for an integrated recognition procedure, Member States

shall ensure that recognition procedures in the context of the procedure to obtain a

long-stay visa or a residence permit, and recognition procedures for access to

regulated professions are coherent. Authorities shall take into account all prior

assessments and verifications of the provided evidence that have already been carried

out in previous procedures and shall not require applicants to resubmit documents

that have already been provided in those procedures.

3. Member States shall ensure that information on both integrated and separate

recognition procedures is readily available to applicants to support informed

decision-making.

4. With the applicant’s consent, Member States may inform a current or prospective

employer of the outcome of the recognition or assessment referred to in paragraph 1,

in particular where that outcome is relevant to a procedure for employment-based

admission.

Title IV

Common provisions

Article 27

Documentation and formalities

1. Where the competent authorities of the host Member State decide on the recognition

of a qualification by virtue of Title II or Article 26, those authorities may require

solely the types of documents and certificates listed in Annex VII of Directive

2005/36/EC. Where the competent authorities of the host Member State decide on

the recognition of a qualification by virtue of Articles 24 and 25 as part of a

procedure to obtain a long-stay visa or a residence permit, for the purpose of the

EN 37 EN

recognition of the qualification those authorities may demand solely the types of

documents listed in Annex VII of Directive 2005/36/EC, point 1(b). This limitation

on the documents that can be required for the purpose of recognising a qualification

is without prejudice to any other document requirements applicable under Union or

national law for the part of the examination of the application for a long-stay visa or

a residence permit that is unrelated to the recognition of the qualification.

2. For the purposes of this Directive, where the documents requested are to be provided

by another Member State or a third country, the references to “home Member State”

or “the Member State from which the foreign national comes” in Annex VII of

Directive 2005/36/EC shall be understood as referring to the other Member State or

the third country, as applicable.

3. Where the host Member State imposes requirements as to the date of issue of the

documents referred to in Annex VII of Directive 2005/36/EC, point 1(d), (e) and (f),

it shall accept documents issued within the three months preceding the date on which

they are submitted.

The Member States, bodies and other legal persons involved in the process shall

guarantee the confidentiality of the information which they receive.

4. In cases of justified doubts, the host Member State may, after obtaining agreement

from the applicant, require from the competent authorities of a Member State or a

third country confirmation of the authenticity of the attestations and evidence of

formal qualifications awarded in that other Member State or the third country.

5. Where a digital credential is issued under a trusted framework provided in

Regulation (EC) No 910/2014 it shall be presumed authentic unless the competent

authority has concrete and specific indications that the credential is not authentic.

6. In cases of justified doubt, where evidence of formal qualifications, as defined in

Article 3(e), has been issued by a competent authority in a Member State and

includes training received in whole or in part in an establishment legally established

in the territory of another Member State, the host Member State shall be entitled to

verify with the competent body in the Member State of origin of the award all of the

following:

(a) whether the training course at the establishment which gave the training has

been formally certified by the educational establishment based in the Member

State of origin of the award;

(b) whether the evidence of formal qualifications issued is the same as that which

would have been awarded if the course had been followed entirely in the

Member State of origin of the award;

(c) whether the evidence of formal qualifications confers the same professional

rights in the territory of the Member State of origin of the award.

7. In cases of justified doubts, the host Member State may require from the competent

authorities of a third country or of a Member State confirmation of the fact that the

applicant is not suspended or prohibited from the pursuit of the profession as a result

of serious professional misconduct or conviction of criminal offences relating to the

pursuit of any of their professional activities.

8. Where the applicant duly documents that, despite reasonable efforts, he was unable

to obtain the documents referred to in paragraph 1, or the host Member State cannot

obtain the confirmations referred to in paragraph 4 or paragraph 7 of this Article,

EN 38 EN

from the third country, the host Member State shall assess the feasibility of, and

where appropriate, employ alternative methods to assess qualifications, skills or

other evidentiary elements. Those methods may include affidavits, third-party

assessments, professional interviews, or reputable evaluation frameworks, like

qualifications passports designed for refugees and vulnerable migrants. The host

Member State shall ensure that applicants are not unduly disadvantaged due to those

circumstances and shall base its decisions on available and reasonable evidence.

9. Where a host Member State requires its nationals to swear a solemn oath or make a

sworn statement in order to gain access to a regulated profession, and where the

wording of that oath or statement cannot be used by a third-country national, the host

Member State shall ensure that the person concerned can use an appropriate

equivalent wording.

10. Member States shall accept the documents referred to in paragraph 1 in any of the

official languages of the Union.

Article 28

Support Services for the Assessment of Authenticity

1. The Commission shall provide support services for the assessment of authenticity.

2. In providing these services, the Commission shall support Member States in the

recognition of qualifications obtained in a third country by offering assessments on

the authenticity of submitted evidence of formal qualifications.

3. At the request of a competent authority of a Member State, the Commission shall

assess the authenticity of qualifications, diplomas, certificates or other evidence of

formal qualifications issued in a third country and submitted in the context of an

application falling within the scope of this Directive, in particular by utilising digital

tools, international databases and through cooperation with third countries and

educational and professional bodies. Requests shall be submitted electronically and

be accompanied by the documents necessary for the assessment and proof of

payment of any applicable fee referred to in paragraphs 7 and 8.

4. The Commission shall provide the requesting Member State with a substantiated

assessment of authenticity, including detailed explanations of the evaluation process

and findings. That assessment shall be advisory in nature and shall not be binding on

competent authorities of the Member States who shall remain solely responsible for

the recognition decision.

5. For the purposes of paragraph 3, the Commission is empowered to conclude

administrative arrangements, aimed at facilitating the exchange of information

necessary for the assessment of authenticity, with the competent authorities of third

countries and with international or professional bodies responsible for the issuance or

accreditation of qualifications. The Commission shall cooperate, where relevant,

with Union delegations to third countries and EU agencies. Such arrangements shall

not create binding obligations under international law on the Union.

6. The Commission shall respond to a request submitted pursuant to paragraph 3 within

three weeks of receipt of the complete documentation referred to in that paragraph.

Where the Commission is unable to provide an assessment within that period, in

particular due to the need to obtain information from a third-country authority or

body referred to in paragraph 3, it shall inform the requesting competent authority

EN 39 EN

without delay, indicating the reasons for the delay and the anticipated timeframe for

completion.

7. The Commission may charge a cost-recovery fee to the requesting competent

authority for the provision of the assessment referred to in paragraph 3.

8. The Commission shall, by means of implementing acts, adopt uniform rules

regarding:

(a) the calculation methodology for determining cost recovery;

(b) the applicable fee amounts and payment modalities;

(c) specific cases where fee exemptions or reductions apply, in particular for

beneficiaries of international protection or applicants in demonstrably

vulnerable situations.

Those implementing acts shall be adopted in accordance with the examination

procedure referred to in Article 38.

9. In relation to personal data processed for the provision of support services for the

assessment of authenticity, the Commission shall act as controller within the

meaning of Article 3(8) of Regulation (EU) 2018/1725 and shall ensure, in

accordance with Article 33 of that Regulation, the security of the processing by

implementing appropriate technical and organisational measures, taking into account

the nature of the personal data processed, including where submitted documents may

incidentally contain special categories of personal data, referred to in paragraph 10.

10. For the purpose of carrying out the tasks referred to in paragraph 3, the Commission

may process the following categories of personal data, to the extent strictly necessary

for a given assessment:

(a) the applicant's identification data as contained in the evidence of formal

qualifications submitted;

(b) data relating to the submitted qualifications, diplomas, certificates or other

evidence of formal qualifications issued in a third country, including the

awarding institution, date of issue, field and level of study, and any identifiers

or security features of the document.

The Commission shall not process special categories of personal data within the

meaning of Article 10 of Regulation (EU) 2018/1725. Where documentation

submitted by a competent authority incidentally contains such data, the Commission

shall ensure that those data are not retained and are deleted without delay.

11. Personal data processed for the purpose of assessing authenticity shall be retained

only for as long as necessary for that purpose and, in any event, for no longer than

12 months from the date on which the assessment is provided to the requesting

competent authority, unless a longer period is necessary for the purposes of an

ongoing appeal, audit or investigation, in which case the data shall be erased without

delay thereafter.

12. The Commission shall periodically report on the support services for the assessment

of authenticity to ensure transparency and continued improvement. Member States

are encouraged to provide feedback to facilitate enhancements in service delivery.

13. The Commission is empowered to adopt delegated acts in accordance with Article 36

laying down the organisational and technical measures necessary for the provision of

EN 40 EN

the support services, and for the security of processing of personal data, including as

regards the systems used for the exchange of requests and supporting documents

between the Commission and the competent authorities of the Member States, access

to such systems, the interfaces made available to competent authorities of the

Member States, the data sources to be consulted and arrangements for keeping them

up to date, and the administrative and operational management of these services.

Article 29

Recognition procedure

1. For procedures under Title II and under Article 26, the host Member State shall

ensure that:

(a) the competent authority acknowledges receipt of the application for recognition

of professional qualifications within one month of receipt and informs the

applicant of any missing document;

(b) the procedure for examining an application for the recognition of professional

qualifications is completed as quickly as possible and leads to a duly

substantiated decision by the competent authority in the host Member State

within three months after the date on which the applicant submitted the

complete application with the required evidence.

The deadline provided for in the first subparagraph, point (b), may be extended by

one month except in cases falling under Title II, Chapter 3.

2. For procedures under Title III, except those covered by Article 26, recognition shall

not extend, suspend or otherwise affect, any time limits or procedural deadlines

applicable under Union or national law to the examination of and decision on the

application for a long-stay visa or a residence permit. Member States shall ensure

that the organisation of the recognition procedure does not undermine the effective

processing of the application for a long-stay visa or a residence permit within the

applicable time limits.

3. The decision on the application for recognition of professional qualifications, or

failure to reach a decision, within the deadline, shall be subject to appeal under

national law.

4. Applicants shall receive regular updates regarding the progress and current status of

their application, including information on the specific stage within the procedural

process.

5. The host Member State shall offer applicants the choice to receive communications,

such as acknowledgments of receipt, decisions and any other information related to

the procedure, in an official language of that Member State, or in at least one other

language commonly spoken by incoming third-country nationals or third-country

nationals already legally residing in that Member State.

Article 30

Access to recognition procedures

1. The host Member State shall ensure that recognition procedures can be completed

remotely and by electronic means, and that third-country nationals who are not

residing in that Member State can access and complete recognition under Titles II

EN 41 EN

and III remotely from their country of residence. Such a possibility shall not prevent

the competent authorities of the host Member State from requesting certified copies

at a later stage in the event of justified doubts and where strictly necessary.

2. The host Member State shall grant or extend the validity of residence permits to

third-country nationals who fulfil all of the following conditions:

(a) they are legally residing in the host Member State;

(b) they can demonstrate an ongoing effort to secure employment in the profession

concerned, such as registration with a public employment service, submission

of job applications, or a conditional offer of employment;

(c) they have applied for recognition of their professional qualifications under

Title II or Article 26 at least four months before their long-stay visa or

residence permit expires.

Member States shall ensure that the residence permit remains valid during the

recognition procedure, including where procedural delays occur that are not

attributable to the applicant.

3. Member States shall grant or extend the validity of residence permits for the period

needed for completing compensation measures required pursuant to Article 9 to

third-country nationals legally residing in the Member State, unless it can be

established at the time of the application for recognition of their professional

qualifications that the third-country national does not satisfy the other conditions for

the issuance of such a permit.

Article 31

Fees and charges

1. A host Member State shall either waive fees for recognition procedures and

compensation measures or, except for the cases referred to in Article 23(2), point (d),

ensure that any fees charged do not exceed the actual cost incurred in providing the

service to applicants.

2. By way of derogation from paragraph 1, Member States may impose flat-rate charges

if they can be justified by the average cost of providing the service to applicants.

3. Member States shall ensure that detailed information on the structure of the fee and

justification for any charges imposed as part of the recognition process is publicly

available and easily accessible and shall actively inform applicants of this

information before the recognition process begins.

Article 32

Information provision

1. Member States shall ensure that third-country nationals, irrespective of whether they

reside within or outside their territory, have access to timely, comprehensive and

user-friendly information and support concerning procedures for the recognition of

qualifications under this Directive.

2. The information referred to in paragraph 1 shall cover the following aspects:

(a) applicable legal and administrative requirements;

EN 42 EN

(b) procedural steps, expected timelines and applicable costs;

(c) the rights and obligations of applicants;

(d) available remedies, appeal mechanisms and complaint procedures.

3. Member States shall ensure that the information they provide in accordance with

paragraph 2 clearly distinguishes and explains the different procedures laid down

in Titles II and III.

4. Where applicable, Member States shall provide comprehensive information on

compensation measures, including adaptation periods, aptitude tests, tests of

professional competence and bridging courses, as referred to in Articles 9 and 25,

covering their organisation, conditions, obligations for applicants, and other relevant

practical arrangements.

5. Where applicable, Member States shall provide comprehensive information on any

complementary measures available to third-country nationals, including language

courses and integration support, reskilling or upskilling pathways, and links to

employment services.

6. Member States shall ensure that refugees, beneficiaries of subsidiary protection in

accordance with Regulation (EU) 2024/1347 have access to tailored information,

assistance and support services, considering their specific legal status, needs and

vulnerabilities.

7. To facilitate a coherent and user-friendly experience, Member States shall, where

appropriate, organise information provision through coordinated or streamlined

arrangements, including digital platforms, and activities of the national assistance

centres as laid down in Article 34.

8. Member States shall ensure that the information referred to in this Article is also

made available on existing Union tools and platforms.

9. Member States shall ensure that the information provided pursuant to this Article is

regularly reviewed and kept up to date. They shall put in place mechanisms to collect

and analyse feedback from third-country nationals, with a view to improving the

quality, clarity, accessibility and coherence of the information and of the support

services.

10. Member States and the competent authorities involved shall ensure the

confidentiality of personal and sensitive information obtained in the context of

information provision and assistance, in accordance with applicable Union and

national law.

Title V

Reporting and final provisions

Article 33

Group on the recognition of qualifications of third-country nationals

1. Member States shall assist one another in the implementation of this Directive.

2. A group on the recognition of qualifications of third-country nationals (‘the Group’)

is established as an advisory group to the Commission.

3. The Group's tasks shall be the following:

EN 43 EN

(a) promoting uniform application of this Directive;

(b) contributing to the effective cooperation between Member States’ authorities

and the Commission with regards to matters covered by this Directive;

(c) advising the Commission, as appropriate, in the early preparations of draft

implementing acts to be adopted pursuant to this Directive;

(d) contributing to the smooth cooperation with other relevant expert groups;

(e) facilitating the exchange of experience and best practices for an efficient and

effective organisation of recognition of qualifications of third-country

nationals, including through outreach to professionals, their representative

organisations and social partners, quality assurance agencies and qualifications

recognition networks.

4. Each Member State shall appoint one representative and one alternate representative

to the Group.

5. The Group shall be chaired by the Commission. The Commission shall provide the

Group’s Secretariat.

On a proposal by the Commission, the Group shall adopt its rules of procedure.

6. The Group shall meet at regular intervals that allow the Group to effectively perform

its tasks provided for in this Directive.

Article 34

Assistance centres

The assistance centres designated by Member States pursuant to Article 57b of Directive

2005/36/EC shall provide assistance on the recognition of qualifications relating to third-

country nationals provided for in this Directive, for the benefit of third-country nationals

including through cooperation, where appropriate, with employers, other contact points, and

authorities in other Member States and third countries.

The assistance centres shall operate without prejudice to the responsibilities of other

competent authorities under Union or national law.

Article 35

Alert mechanism

Where a third-country national is restricted or prohibited, including on a temporary basis, by a

national authority or court from pursuing, in whole or in part, on the territory of a Member

State, any of the professional activities referred to in Article 56a(1) of Directive 2005/36/EC,

the competent authority of that Member State shall inform the competent authorities of all

other Member States. For this purpose Article 56a of Directive 2005/36/EC shall apply

mutatis mutandis.

Article 36

Exercise of the delegation

EN 44 EN

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts referred to in Article 12(3) and Article 16(2) shall

be conferred on the Commission for a period of five years from the entry into force

of this Directive. The Commission shall draw up a report in respect of the delegation

of power not later than nine months before the end of the five-year period. The

delegation of power shall be tacitly extended for periods of an identical duration,

unless the European Parliament or the Council opposes such an extension not later

than three months before the end of each period.

3. The delegation of power referred to in Article 12(3) and Article 16(2) may be

revoked at any time by the European Parliament or by the Council. A decision to

revoke shall put an end to the delegation of the power specified in that decision. It

shall take effect on the day following the publication of the decision in the Official

Journal of the European Union or at a later date specified therein. It shall not affect

the validity of any delegated acts already in force.

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. A delegated act adopted pursuant to Article 12(3) and Article 16(2) shall enter into

force only if no objection has been expressed either by the European Parliament or

the Council within a period of two months of notification of that act to the European

Parliament and the Council or if, before the expiry of that period, the European

Parliament and the Council have both informed the Commission that they will not

object. That period shall be extended by two months at the initiative of the European

Parliament or the Council.

Article 37

Statistics

1. By [31 May of the year following the third year of entry into force], and annually

thereafter, Member States shall report to the Commission statistics on the

implementation of this Directive. Those statistics shall cover the previous calendar

year and include the following information:

(a) the number of applications received and handled, and decisions taken,

disaggregated by:

(i) citizenship;

(ii) occupation;

(iii) status (i.e. the residence or migration status under which the third-

country national is present or seeking to be present in the Union);

(iv) type of procedure (procedures under Article 6; Title II, Chapter 2; Title

II, Chapter 3; Article 24, Article 25 and Article 26);

(v) outcome of the decision (positive, positive with partial access; positive

with compensation measure, broken down by type of compensation

measure; negative);

EN 45 EN

(b) the proportion of applications that are complete at first submission;

(c) the average duration of processing applications;

(d) the average number of information exchanges per case;

(e) the number of authenticity checks requested.

2. The Commission shall make a summary of the information provided in accordance

with paragraph 1 publicly available.

Article 38

Committee procedure

1. The Commission shall be assisted by the Committee on the Recognition of

Professional Qualifications established by Article 58(1) of Directive 2005/36/EC.

That committee shall be a committee within the meaning of Regulation (EU) No

182/2011.

2. Where reference is made to this paragraph, Article 5 of Regulation (EU) No

182/2011 shall apply.

Article 39

Reports

1. By 31 May [of the year following the third year of entry into force], and every

five years thereafter, Member States shall submit a report to the Commission on the

application of this Directive. The report shall contain the following information

regarding the recognition of qualifications in the context of procedures for access to

regulated professions and for obtaining a long-stay visa or residence permit:

(a) processing times of applications;

(b) outcomes;

(c) user experience;

(d) results of the review of the procedures, including constraints and areas

requiring improvement identified.

As part of preparing the report, Member States shall collect feedback from

employers, professional bodies, third-country nationals, and other stakeholders.

2. No sooner than seven years after the date of transposition of this Directive,

the Commission shall carry out an evaluation of this Directive and present a report

on the main findings to the European Parliament and the Council. Member States

shall provide the Commission with the information necessary for the preparation of

that report.

Article 40

Transposition

1. Member States shall bring into force the laws, regulations and administrative

provisions necessary to comply with this Directive by [2 years after entry into force]

at the latest. They shall forthwith communicate to the Commission the text of those

provisions.

EN 46 EN

When Member States adopt those provisions, they shall contain a reference to this

Directive or be accompanied by such a reference on the occasion of their official

publication. Member States shall determine how such reference is to be made.

2. Member States shall communicate to the Commission the text of the main provisions

of national law which they adopt in the field covered by this Directive.

Article 41

Entry into force

This Directive shall enter into force on the twentieth day following that of its publication in

the Official Journal of the European Union.

Article 42

Addressees

This Directive is addressed to the Member States in accordance with the Treaties.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

[...] [...]

EN 47 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Directive of the European Parliament and of the Council on the

recognition of qualifications of third-country nationals

1.2. Policy area(s) concerned

Employment, social affairs and inclusion. The initiative is also relevant to the

internal market policy area (recognition of professional qualifications) and to the

migration and home affairs policy area (legal migration and integration of third-

country nationals), given its interaction with Directive 2005/36/EC and with the

Union's legal migration acquis.

1.3. Objective(s)

1.3.1. General objective(s)

To facilitate the recognition of qualifications held by third-country nationals so as to

help address labour and skills shortages in the Union.

1.3.2. Specific objective(s)

Specific objective No

1. Streamlined recognition systems within and between Member States: Improved

alignment and consistency between national recognition systems across the EU, and

coherence within Member States, between recognition procedures for access to

regulated professions and those embedded in migration regimes.

2. Reduced legal and administrative complexity for recognition of qualifications of

third-country nationals: Clearer and less burdensome requirements, documentation

and procedural steps for third-country national applicants, employers and authorities,

including, reduced administrative steps and enhanced user-friendliness.

3. Increased trust and understanding of qualifications obtained in third countries:

Improved transparency, comparability and trust of third-country qualifications within

the EU, through enhanced information availability and mechanisms that support the

assessment of foreign qualifications and skills.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the

beneficiaries/groups targeted.

For third-country national applicants: shorter and more predictable recognition

procedures, clearer information on requirements, and a genuine prospect of

recognition for qualifications obtained outside the Union, with an associated increase

in the probability of employment matched to their qualification level and a reduction

in the incidence of overqualification. For employers, including SMEs: faster access

to recognised professionals, reduced administrative costs linked to hiring, and

improved ability to fill vacancies in sectors facing structural shortages, including

healthcare. For competent authorities and Member States: reduced administrative

burden and duplication of effort, more consistent decision-making, and stronger

evidence and cooperation channels through which to identify and act on fraudulent

documentation. For the Union as a whole: a measurable contribution to addressing

EN 48 EN

labour and skills shortages and to the coherence of the Union's approach to legal

migration.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

General objective

(a) Share of third-country nationals in qualification-matched employment within 12

months of arrival

(b) Number of recognition procedures initiated and completed per year by third-

country nationals

Specific objective 1

(a) Share of cases requiring parallel submissions (duplicate qualification checks

across recognition and migration procedures)

(b) Number of cases requiring re-submission or additional information, as a share of

total applications

(c) Share of recognition applications submitted digitally

Specific objective 2

(a) Average end-to-end processing time per recognition procedure, by Member States

and procedure type

(b) Average number of documents requested per application, including certified

translations

(c) Estimated applicant-side cost per recognition procedure Share of complete

applications at first submission

Specific objective 3

(a) Number of authenticity checks processed via the EU-level service per year

(b) Share of CA reporting sufficient information on third-country qualification

systems to make timely decisions without requesting additional documentation or

compensation measures

(c)Processing time for sectoral professions under automatic recognition channel

1.4. The proposal/initiative relates to:

☑ a new action

☐ a new action following a pilot project/preparatory action (1)

☐ the extension of an existing action

☐ a merger or redirection of one or more actions towards another/a new

action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

(1) As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 49 EN

In the short term, Member States will need to transpose the Directive's common

procedural rules (timeframes, information requirements, single points of contact)

within the transposition deadline of 2 years. The Commission will need to establish

the authentication service and make it operational and adopt any implementing

measures needed to specify the professions eligible for automatic recognition. In the

longer term, full-scale operation of the automatic recognition channel and of the

authentication service will require ongoing coordination with Member States,

competent authorities and third countries, periodic review of the list of professions

covered, and monitoring of implementation.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante) Recognition of third-country qualifications

is currently handled through divergent national procedures, with no common Union

framework equivalent to Directive 2005/36/EC for intra-EU mobility. This

fragmentation generates duplicated authenticity checks across Member States,

inconsistent outcomes for applicants with comparable qualifications, and an absence

of the trust infrastructure needed to support automatic recognition for professions

facing acute shortages. Individual Member States acting alone cannot replicate the

economies of scale of a shared authenticity-verification service, nor secure the cross-

border consistency needed to build mutual trust between competent authorities.

Expected generated EU added value (ex-post) A common Union framework is

expected to reduce duplication and verification costs across Member States, increase

the consistency and speed of recognition decisions, and strengthen the Union's

collective ability to address labour and skills shortages, in a manner that no

individual Member State could achieve acting alone.

1.5.3. Lessons learned from similar experiences in the past

The experience of Directive 2005/36/EC demonstrates that a common Union

framework for recognition, combined with structured administrative cooperation

(competent authority networks, the Internal Market Information system), can

substantially reduce recognition timeframes and improve consistency, while showing

that purely voluntary cooperation (as tested under Policy Option 1 in the impact

assessment) is insufficient to achieve comparable results at Union level. The

Directive's existing minimum training requirements for a number of professions offer

a further lesson, showing that agreement on common substantive standards, and not

only procedural rules, can itself be a basis for building trust and cooperation between

competent authorities, a precedent relevant to the design of the automatic recognition

channel under this initiative. The Council Recommendation of 22 December 2020 on

a comprehensive approach to the recognition of qualifications of third-country

nationals offers a related lesson, in that its non-binding, voluntary approach has not

resulted in the level of convergence or consistency needed across Member States,

reinforcing the case for the more binding measures proposed under this initiative.

The German Federal Recognition Act experience shows that formalised recognition

procedures for foreign qualifications are associated with a measurable increase in the

probability of qualification-matched employment.

EN 50 EN

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

This proposal is compatible with the Commission’s proposal for the Multiannual

Financial Framework 2028-2034. It generates synergies with Action 1 of the Skills

Portability Initiative, with Directive 2005/36/EC as amended under Action 2, and

with instruments under the Fair Labour Mobility Package and the EU Talent Pool.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The preferred financing option is direct financing from the Union budget, as the

initiative requires the development, deployment and operation of a common

European authentication system that will be used across all Member States. A

centrally financed solution ensures economies of scale, avoids duplication of costs,

and guarantees interoperability and consistent implementation across the Union.

Alternative approaches based on separate national developments or decentralised

financing would require multiple parallel investments, increase integration costs and

create risks of fragmentation and inconsistent implementation. Financing through

existing Union programmes and budgetary resources allows the initiative to build on

existing digital infrastructure and expertise while ensuring efficient use of Union

funds. Where appropriate, existing resources will be redeployed to support the

implementation of the initiative.

The current proposal entails additional staff costs under Heading 4 of the proposal

for the 2028-2034 multiannual financial framework, as it is a new action. For

operational costs, it builds on the Commission proposal for National and Regional

Partnership Plans and its EU Facility under Heading 1 of the 2028-2034 multiannual

financial framework, subject to its adoption, and the EU annual budgetary procedure.

1.6. Duration of the proposal/initiative and of its financial impact

☐ limited duration

☐ in effect from [DD.MM]YYYY to [DD.MM]YYYY

☐ financial impact from YYYY to YYYY for commitment appropriations

and from YYYY to YYYY for payment appropriations.

☑ unlimited duration

Implementation with a start-up period from YYYY to YYYY,

followed by full-scale operation.

1.7. Method(s) of budget implementation planned(2)

☐ Direct management by the Commission

☑ by its departments, including by its staff in the Union delegations;

☐ by the executive agencies

☐ Shared management with the Member States

(2) Details of budget implementation methods and references to the Financial Regulation may be found on

the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 51 EN

☐ Indirect management by entrusting budget implementation tasks to:

☐ third countries or the bodies they have designated;

☐ international organisations and their agencies (to be specified);

☐ the European Investment Bank and the European Investment Fund;

☐ bodies referred to in Articles 70 and 71 of the Financial Regulation;

☐ public law bodies;

☐ bodies governed by private law with a public service mission to the

extent that they are provided with adequate financial guarantees;

☐ bodies governed by the private law of a Member State that are entrusted

with the implementation of a public-private partnership and that are

provided with adequate financial guarantees;

☐ bodies or persons entrusted with the implementation of specific actions in

the common foreign and security policy pursuant to Title V of the Treaty

on European Union, and identified in the relevant basic act

☐ bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance

with sector-specific rules, with the implementation of Union funds or

budgetary guarantees, to the extent that such bodies are controlled by

public law bodies or by bodies governed by private law with a public

service mission, and are provided with adequate financial guarantees in

the form of joint and several liability by the controlling bodies or

equivalent financial guarantees and which may be, for each action,

limited to the maximum amount of the Union support.

Comments

[...]

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

The Commission will monitor implementation on a continuous basis through the

indicators set out in section 1.3.4, drawing on administrative data reported by

Member States' competent authorities, authentication service caseload and

processing-time data, and periodic surveys of competent authorities. Member States

will report on transposition and on the functioning of national recognition procedures

in accordance with the reporting obligations set out in the Directive. The

Commission will carry out an evaluation in accordance with the Better Regulation

Guidelines within 7 years of the deadline for transposition, assessing effectiveness,

efficiency, coherence, relevance and EU added value against the general and specific

objectives.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

Direct management, as per article 62.1(a) of the Financial Regulation, is the

preferred mode of implementation, as the actions will be carried out by the European

EN 52 EN

Commission, specifically Directorate-General for Employment, Social Affairs and

Inclusion (DG EMPL), which will ensure the coordination with Member States and

the various stakeholders.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The controls are part of the internal control system of DG EMPL. The new activities

will be subject to the same risk identification and mitigation approach.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The controls are integrated into the internal control system of DG EMPL. The new

activities will generate negligeable additional control costs at DG level.

2.3. Measures to prevent fraud and irregularities

The Commission shall ensure that, when actions financed are implemented, the

financial interests of the Union are protected by the application of preventive

measures against fraud, corruption and any other illegal activities, by effective

checks and by the recovery of the amounts unduly paid and, if irregularities are

detected, by effective, proportional and dissuasive penalties. The Commission is

authorised to carry out checks and verifications in situ under this Decision, in

compliance Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996

concerning on-the-spot checks and inspections carried out by the Commission in

order to protect the European Communities financial interests against fraud and other

irregularities. If need be, investigations shall be carried out by the European Anti-

Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the

European Parliament and of the Council of 25 May 1999 concerning investigations

conducted by the European Anti-Fraud Office.

EN 53 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s) affected

Existing budget lines

In order of multiannual financial framework headings and budget lines.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and

does not pre-judge the next Multiannual Financial Framework. The source of financing and scope of Union financial

commitment in the post-2027 period remain subject to the outcome of interinstitutional negotiations on the MFF

2028-2034 and thereafter shall be determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

Heading of multiannual

financial framework

Budget line

Type of

expendit

ure

Contribution

Number Diff./No

n-diff. (3)

from

EFTA

countries (4)

from

candidat

e

countries

and

potential

candidat

es (5)

from

other

third

countrie

s

other assigned

revenue

1

To be determined after the

adoption of the MFF and

in the context of the

annual budgetary

Diff./No

n-diff. YES/NO YES/NO YES/NO NO

(3) Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. (4) EFTA: European Free Trade Association. (5) Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 54 EN

procedure for the EU

Facility – Successor of 07

02 04 00 – ESF+ EaSI

strand

New budget lines requested

In order of multiannual financial framework headings and budget lines.

Heading

of

multiannu

al

financial

framework

Budget

line

Type of

expenditur

e

Contribution

Number Diff./non-

diff.

from

EFTA

countries

from

candidate

countries

and

potential

candidates

from other

third

countries

other

assigned

revenue

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

☐ The proposal/initiative does not require the use of operational appropriations

EN 55 EN

☑ The proposal/initiative requires the use of operational appropriations, as explained below:

3.2.1.1. Appropriations from voted budget

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the

next Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the

annual budgetary procedure. All appropriations and staffing allocations as of 2028 are indicative

EUR million (to three decimal places)

Heading of multiannual financial framework Number 1 - Economic, social and territorial cohesion,

agriculture, rural and maritime prosperity and security

DG: EMPL Year

2028

Year

2029

Year

2030

Year

2031

Yea

r 2

032

Year 2

033

2034

and

subsequ

ent

years

TOTAL MFF

2028-2034

Operational appropriations

Budget line – successor 07

02 04

Commit

ments (1a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s (2a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Appropriations of an administrative nature financed from the envelope of specific programmes (6)

Budget line (3) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

(6) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 56 EN

TOTAL appropriations

for DG EMPL

Commit

ments

=1a+1

b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s

=2a+2

b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Heading 1 Year

2028

Year

2029

Year

2030

Year

2031

Yea

r 203

2

Year

2033

2034

and

subsequ

ent

years

TOTAL MFF

2028-2034

TOTAL operational

appropriations

Commit

ments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(6) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING 1

of the multiannual financial

framework

Commit

ments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Heading of multiannual financial

framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

EN 57 EN

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes (7)

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

(7) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 58 EN

Appropriations of an administrative nature financed from the envelope of specific programmes (8)

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Heading 1 Year

2028

Year

2029

Year

2030

Year

2031

Yea

r 2

032

Year 2

033

2034

and

subsequ

ent

years

TOTAL MFF

2021-2027

TOTAL operational

appropriations

Commit

ments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(6) 0 0 0 0 0 0 0 0

TOTAL appropriations

under HEADING 1

of the multiannual financial

framework

Commit

ments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

(8) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 59 EN

Year

2028

Year

2029

Year

203

0

Year

2031

Year

2032

Year

2033

2034

and

subsequ

ent

years

TOTAL MFF

2021-2027

TOTAL operational

appropriations (all

operational headings)

Com

mitme

nts

(4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Paym

ents (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from

the envelope for specific

programmes (all operational

headings)

(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

TOTAL appropriations

Under Heading 1 to 3

of the multiannual financial

framework

(Reference amount)

Com

mitme

nts

=4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Paym

ents =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Heading of multiannual financial framework 4 ‘Administrative expenditure’ (9)

DG: EMPL Year

2028

Year

2029 Year

203

Year

2031

Year

2032

Year

2033 2034

and

TOTAL MFF

2021-2027

(9) The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 60 EN

0 subsequ

ent

years

Human resources 0.582 0.582 0.58

2 0.582 0.582 0.582 0.582 4.074

Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG EMPL Appropriations 0.582 0.582 0.58

2 0.582 0.582 0.582 0.582 4.074

TOTAL appropriations under HEADING

4 of the multiannual financial framework

(Total

commitme

nts = Total

payments)

0.582 0.582 0.582 0.582 4.074

EUR million (to three decimal places)

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

2034

and

subs

eque

nt

year

s

TOTAL MFF

2021-2027

TOTAL appropriations under

HEADINGS 1 to 4

of the multiannual financial

framework

Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

EN 61 EN

The staff needed to implement this proposal has been assessed at 3 full time equivalent (FTE), of which 1 are redeployed from existing

staff in the DG and 2 are to be covered by the redeployment pool of the Commission.

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indi

cate

obje

ctive

s

and

outp

uts

⇓

Year

2028

Year

2029

Year

2030

Year

2031

Enter as many years as necessary to show

the duration of the impact (see Section 1.6) TOTAL

OUTPUTS

Type (10)

Aver

age

cost

No Cost No Cost No Cost No Cost No Cost No Cost No Cost Total

No

Total

Cost

SPECIFIC

OBJECTIVE No 1 (11): [...]

Outp

ut p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Outp

ut

Outp

ut

(10) Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.). (11) As described in point 1.4.2. 'Specific objective(s)...'

EN 62 EN

Subtotal for specific

objective No 1 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

SPECIFIC

OBJECTIVE No 2

...

Outp

ut

Subtotal for specific

objective No 2

SPECIFIC

OBJECTIVE No. 3

Outp

ut p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Subtotal for specific

objective No. 3

TOTALS p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.2.3. Summary of estimated impact on administrative appropriations

☐ The proposal/initiative does not require the use of appropriations of an administrative nature

☑ The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033 2034 and

subsequent

TOTAL MFF

2021-2027

EN 63 EN

years

HEADING 4

Human resources 0.582 0.582 0.582 0.582 0.5

82

0.5

82

0.5

82 4.074

Other administrative expenditure 0.000 0.000 0.000 0.000 0.0

00

0.0

00

0.0

00 0.000

Subtotal HEADING 4 0.582 0.582 0.582 0.582 0.5

82

0.5

82

0.5

82 4.074

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0

00

0.0

00

0.0

00 0.000

Other expenditure of an administrative

nature 0.000 0.000 0.000 0.000

0.0

00

0.0

00

0.0

00 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.0

00

0.0

00

0.0

00 0.000

TOTAL 0.582 0.582 0.582 0.582

0.582

0.5

82

0.5

82 4.074

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure

and the steering mechanism. All appropriations and staffing allocations as of 2028 are indicative.

EN 64 EN

3.2.3.3. Total appropriations

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative

purposes only and does not pre-judge the next Multiannual Financial Framework. The source of

financing and scope of Union financial commitment in the post-2027 period remain subject to the

outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined

through the annual budgetary procedure and the steering mechanism. All appropriations and staffing

allocations as of 2028 are indicative.

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from

the DG that are already assigned to management of the action and/or have been redeployed within the DG, together, if necessary, with

any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary

constraints.

3.2.4. Estimated requirements of human resources

☐ The proposal/initiative does not require the use of human resources

☑ The proposal/initiative requires the use of human resources, as explained below

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs) (12)

VOTED APPROPRIATIONS Year

2028

Year

2029

Year

2030

Year

2031

Year

203

2

Year 2033 2034 and

subsequent years

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's

Representation Offices) 3 3 3 3 3 3 3

(12) Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed within

your DG and what are your net needs.

EN 65 EN

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

External staff (in FTEs)

20 02 01 (AC, END from the 'global envelope') 0 0 0 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU

Delegations) 0 0 0 0 0 0 0

Admin.

support line

[XX.01.YY.Y

Y]

at Headquarters 0 0 0 0 0 0 0

in EU Delegations 0 0 0 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0 0 0 0

TOTAL 3 3 3 3 3 3 3

This proposal is a new action and no current staff is assigned to this new task. The three FTE mentioned above are additional staff needed to

implement the proposal, to be covered by the redeployment pool of the Commission.

3.2.4.2. Financed from external assigned revenues

EN 66 EN

3.2.4.3. Total requirements of human resources

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading

7 or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts 3 0 N/A N/A

External staff

(CA, SNEs,

INT)

0 0 N/A N/A

The staff needed to implement this proposal has been assessed at 3 full time equivalent (FTE), of which 1 are redeployed from existing

staff in the DG and 2 are to be covered by the redeployment pool of the Commission.

Description of tasks to be carried out by:

Officials and temporary staff

Outsource the authentication services to an external entity by public

procurement, writing the specifications for the tendering procedure;

monitor the work of the selected entity; ensure the functioning of the

authentication services.

External staff

3.2.5. Overview of estimated impact on digital technology-related investments

EN 67 EN

Compulsory: the best estimate of the digital technology-related investments entailed by the proposal/initiative should be included in the

table below.

Exceptionally, when required for the implementation of the proposal/initiative, the appropriations under Heading 7 should be presented

in the designated line.

The appropriations under Headings 1-6 should be reflected as "Policy IT expenditure on operational programmes". This expenditure

refers to the operational budget to be used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation of the

initiative and their associated investments (e.g. licences, studies, data storage etc). The information provided in this table should be

consistent with details presented under Section 4 "Digital dimensions".

TOTAL Digital and IT

appropriations

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-2027

HEADING 4

IT expenditure (corporate) 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 4 0.000 0.000 0.000 0.000 0.000

Outside HEADING 4

Policy IT expenditure on

operational programmes 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING

4 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

EN 68 EN

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

☑ can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF).

☐ requires use of the unallocated margin under the relevant heading of the MFF

and/or use of the special instruments as defined in the MFF Regulation.

☐ requires a revision of the MFF.

EN 69 EN

3.2.7. Third-party contributions

The proposal/initiative:

☑ does not provide for co-financing by third parties

☐ provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034 Total

Specify the co-financing

body (EFTA, (potential)

candidate countries, third

countries)

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations co-

financed p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.3. Estimated impact on revenue

☑ The proposal/initiative has no financial impact on revenue.

☐ The proposal/initiative has the following financial impact:

☐ on own resources

☐ on other revenue

☐ please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

EN 70 EN

Budget revenue line:

Appropriations

available for the

current financial year

Impact of the proposal/initiative (13)

Year

2024

Year

2025

Year

2026

Year

2027

Article ..........

For assigned revenue, specify the budget expenditure line(s) affected.

[...]

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

[...]

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

If the policy initiative is assessed as having no requirement of digital relevance:

Justification of why digital means cannot be used to enhance policy implementation and why the ‘digital by default’ principle is not

applicable

[...]

Otherwise:

High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital

solutions and/or digital public services)

Reference to the

requirement

Requirement

description

Actors affected or

concerned by the

requirement

High-level Processes Categories

(13) As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20% for

collection costs.

EN 71 EN

Article 11

Paragraph 1c: Member

States shall recognise

evidence of formal

qualifications for

doctors (with basic and

specialised training),

nurses responsible for

general care, dental

practitioners, specialised

dental practitioners,

midwives, veterinary

surgeons, pharmacists,

and architects obtained

in a third country,

provided the following

conditions are met: (c)

The evidence of formal

qualifications is issued

as a digital credential,

ensuring authenticity,

security, and ease of

verification.

Member States Third

countries’ institutions

Issuance of

qualifications Data/ Digital solutions

Article 28 (1-3)

The Commission shall

provide support services

for the assessment of

authenticity.

1. In providing

these services, the

Commission shall shall

support Member States

in the recognition of

European Commission

provides the system for

Member States upload

evidence provided by

the applicant in the

system

Processing, assessment

and recognition of

evidence authenticity

Data/Digital

Solutions/Digitalisation-

automation of

activities/Digital Public

Services

EN 72 EN

qualifications obtained

in a third country by

offering assessments on

the authenticity of

submitted evidence of

formal qualifications.

2. At the request of

a competent authority of

a Member State, the

Commission shall assess

the authenticity of

qualifications, diplomas,

certificates or other

evidence of formal

qualifications issued in a

third country and

submitted in the context

of an application falling

within the scope of this

Directive, in particular

by utilising digital tools,

international databases

and through cooperation

with third countries and

educational and

professional bodies.

Requests shall be

submitted electronically

and be accompanied by

the documents necessary

for the assessment and

proof of payment of any

EN 73 EN

applicable fee referred

to in paragraph 8.

3. The Commission

shall provide the

requesting Member

State with a

substantiated assessment

of authenticity,

including detailed

explanations of the

evaluation process and

findings. That

assessment shall be

advisory in nature and

shall not be binding on

competent authorities of

the Member States who

shall remain solely

responsible for the

recognition decision.

Article 28 (8-11)

The processing of

personal data by the

Commission for the

purposes of the support

services for assessment

of authenticity shall

comply with Regulation

(EU) 2018/1725 and be

limited to what is

necessary and

proportionate for the

European Commission Processing of personal

data Data/ Digital solutions

EN 74 EN

performance of a task

carried out in the public

interest as laid down in

Article 5(1)(a) of

Regulation (EU)

2018/1725. The

Commission shall

ensure that personal data

is processed lawfully,

securely, and with the

necessary safeguards to

protect individuals’

privacy rights, including

data minimisation,

transparency, and access

rights for data subjects.

The Commission shall

periodically report on

the activities and

effectiveness of support

services to ensure

transparency and

continual improvement.

Member States are

encouraged to provide

feedback to facilitate

enhancements in service

delivery.

Article 30

Access to recognition

procedures Member

States shall ensure that

all requirements,

Member States

Applicants professionals

(users)

Recognition procedure Data/Digital public

services/Digital

Solutions/Digitalisation-

EN 75 EN

procedures and

formalities in

recognition procedures

may be easily

completed, remotely and

by electronic means.

This shall not prevent

competent authorities of

Member States from

requesting certified

copies at a later stage in

the event of justified

doubts and where

strictly necessary.

automation of activities

Article 36

Statistics Member States

shall communicate to

the Commission

statistics on the

implementation of this

Directive. Those

statistics shall cover the

previous calendar year

and include information

on the number of

applications received

and handled and

decisions taken, and

shall be disaggregated

by citizenship, by

occupation, status

(beneficiaries of

international protection,

European Commission

Member States

Statistics on the

recognition processes

Data/Digital

Solutions/Digitalisation-

automation of activities

EN 76 EN

beneficiaries of the right

to free movement, etc),

type of procedure

(Article 6; Title II,

Chapter 2; Title II,

Chapter 3; Article 23;

Article 24 or Article 25),

and outcome of the

decision (positive,

positive with partial

access; positive with

compensation measure,

broken down by type of

compensation measure;

negative). They shall

also include the share of

complete applications at

first submission, average

processing times,

average information

exchanges per case, and

number of authenticity

checks requested.

Article 38

Reports Member States

shall send a report to the

European Commission

on the application of this

Directive. To this end,

Member States shall

collect data on

processing times,

outcomes, and user

European Commission

Member States

Reporting on the

recognition processes

Data/Digital public

services/Digital

Solutions

EN 77 EN

experience across both

procedures for access to

regulated professions

and for migration

purposes, and include

this information in the

report. They shall also

review the procedures to

report on identified

bottlenecks and

opportunities for

improvement. Member

States shall collect

feedback from

employers, professional

bodies, third-country

nationals, and other

stakeholders as part of

this exercise.

4.2. Data

High-level description of the data in scope

Type of data Reference to the requirement(s) Standard and/or specification (if

applicable)

Digital qualification attestations

Article 11 – Formal qualifications issued

as digital credentials by Third country

institutions/Article 28 – Support services

for assessment of authenticity, provided by

the Commission

N/A

Non-digital evidence of formal Article 28 – Support Services for Documents listed in Annex VII of

EN 78 EN

qualification and other supporting

evidence

Assessment of Authenticity Directive 2005/36/EC; accepted in any

official language of the Union

Personal information used for the support

services for assessment of authenticity,

provided by the Commission

Article 28 – Processing of personal data

by the Commission to provide support

services for assessment of authenticity

EUDPR (Reg. (EU) 2018/1725); data

minimisation, transparency and data-

subject access rights (Art. 28)

Annual statistical summary of recognition

procedures (includes number of

applications received and decisions,

breakdowns, outcomes, processing times

and delays)

Article 36

Report on the application of the Directive.

Member States shall send a report to the

European Commission with data regarding

the processing times, outcomes,

procedures on the recognition processes.

Moreover, this report should also include

the identification of bottlenecks and

opportunities for improvement. The

European Commission shall submit a

report to the European Parliament and the

Council on the application of the

Directive.

Article 38

Alignment with the European Data Strategy

Explanation of how the requirement(s) are aligned with the European Data Strategy

[...]

Alignment with the once-only principle

Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored

EN 79 EN

[...]

Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

[...]

Data flows

High-level description of the data flows

Type of data Reference(s) to the

requirement(s)

Actors who

provide the data

Actors who receive

the data

Trigger for the

data exchange

Frequency (if

applicable)

Type of data #1

Type of data # 2

4.3. Digital solutions

High-level description of digital solutions

Digital solution

Reference(s) to

the

requirement(s)

Main mandated

functionalities

Responsible

body

How is

accessibility

catered for?

How is

reusability

considered?

Use of AI

technologies (if

applicable)

Digital solution

#1

Digital solution

#2

EN 80 EN

For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments

Digital solution #1

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI Act

EU Cybersecurity framework

eIDAS

Single Digital Gateway and IMI

Others

Digital solution #2

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI Act

EU Cybersecurity framework

EN 81 EN

eIDAS

Single Digital Gateway and IMI

Others

4.4. Interoperability assessment

High-level description of the digital public service(s) affected by the requirements

Digital public service

or category of digital

public services

Description Reference(s) to the

requirement(s)

Interoperable Europe

Solution(s)(NOT

APPLICABLE)

Other interoperability

solution(s)

Support services for

assessment of

authenticity

The support services

will be tasked with

supporting Member

States in the recognition

of qualifications

obtained outside the

Union by offering

assessments on the

authenticity of

submitted evidence of

formal qualifications.

Requests to the service

shall be submitted

electronically. The

service might use digital

tools and international

databases to perform its

tasks.

Article 28 (1-3)

EN 82 EN

As mentioned in Article

28(12), delegated acts

will be prepared by the

Commission to set out

the organisational and

technical measures

required for the

operation of the service.

The interoperability

assessment of the

service will be carried

out in the context of

these delegated acts.

Impact of the requirement(s) as per digital public service on cross-border interoperability

Digital public service #1

Assessment Measure(s) Potential remaining barriers (if

applicable)

Alignment with existing digital and

sectorial policies. Please list the

applicable digital and sectorial policies

identified

Digital or sectorial policy #1 Digital or

sectorial policy #2 Digital or sectorial

policy #3

Barrier #1 Barrier #2 Barrier #3

Organisational measures for a smooth

cross-border digital public services

delivery. Please list the governance

measures foreseen

Governance measure #1 Governance

measure #2 Governance measure #3 Barrier #1 Barrier #2 Barrier #3

EN 83 EN

Measures taken to ensure a shared

understanding of the data. Please list

such measures

Measure #1 Measure #2 Measure #3 Barrier #1 Barrier #2 Barrier #3

Use of commonly agreed open technical

specifications and standards. Please list

such measures

Measure #1 Measure #2 Measure #3 Barrier #1 Barrier #2 Barrier #3

4.5. Measures to support digital implementation

High-level description of measures supporting digital implementation

Description of the

measure

Reference(s) to the

requirement(s) of

digital relevance that it

supports

Commission role (if

applicable)

Actors to be involved

(if applicable)

Expected timeline (if

applicable)

Measure #1

Measure #2

Measure #3

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 995 final

2026/0273 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and Regulation (EU)

No 1024/2012

{SEC(2026) 995 final} - {SWD(2026) 995 final} - {SWD(2026) 996 final} -

{SWD(2026) 997 final}

(Text with EEA relevance)

EN 1 EN

EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The free movement of workers, freedom of establishment and freedom to provide services are

fundamental freedoms enshrined in the Treaties, underpinning the ability of Union citizens to

pursue professional and economic activities across the Union. These Treaty freedoms are

complemented by the Charter of Fundamental Rights of the European Union, which

recognises the right to engage in work and to pursue a freely chosen or accepted occupation,

as well as the freedom of Union citizens to seek employment, work, exercise the right of

establishment and provide services in any Member State. They are further supported by the

European Pillar of Social Rights, proclaimed in 2017, whose first chapter on equal

opportunities and access to the labour market emphasises the importance of skills and

employability. In particular, Principle 1 on education, training and lifelong learning

recognises everyone’s right to maintain and acquire skills enabling full participation in society

and successful transitions in the labour market, while Principle 4 provides for the right to

active support to find or change jobs, including re-skilling and job-search assistance.

This long-standing framework is reflected in the Commission’s Political Guidelines for 2024–

2029, which place skills portability and the effective use of skills acquired across borders

among the priorities for strengthening labour mobility and enabling people to make full use of

their skills throughout the Union. In her Political Guidelines for 2024–2029, the President of

the Commission underlined the need to ensure that the Union benefits from high-quality

skills, irrespective of where and how they were acquired, and to facilitate the recognition of

skills acquired in one country in another. These objectives are also reflected in the ‘One

Europe, One Market’ roadmap, launched in April 2026 with the objective of further

deepening and completing the Single Market by the end of 2027, including by removing

remaining barriers, reducing administrative burden and strengthening the Union’s

competitiveness.

This proposal forms part of the Skills Portability Initiative (SPI), which is a key component of

the Fair Labour Mobility Package (FLMP). The SPI was announced under the Union of

Skills, adopted in March 2025 as the Commission’s strategy to strengthen Europe’s human

capital and competitiveness, including by improving the portability of skills and qualifications

across the Union. The present proposal implements Action 2 of the SPI. It aims at further

facilitating and modernising the recognition of professional qualifications in regulated

professions by leveraging digital tools to streamline, accelerate and make recognition

procedures more efficient, while strengthening administrative cooperation between competent

authorities and improving the monitoring of the implementation and functioning of the

recognition system.

By amending the Directive, this proposal aims to reduce the time and cost required to have a

professional qualification recognised in another Member State, making recognition more

transparent and digital.

For regulated professions, Directive 2005/36/EC on the recognition of professional

qualifications (‘the Directive’) is a cornerstone of the Union framework for professional

mobility. It facilitates the free movement of professionals by establishing rules for the

recognition of professional qualifications, while taking account of Member States’

EN 2 EN

competence to regulate professions and to lay down requirements for their pursuit in order to

safeguard relevant public interests.

The need for action is supported by the Commission's report on the implementation of the

Directive covering the period 2020–2024, as well as by the studies and stakeholder

consultations underpinning the impact assessment accompanying this proposal. This evidence

points to persistent shortcomings in the availability and quality of information provided to

applicants, inefficiencies and unnecessary burdens in recognition procedures, and challenges

affecting administrative cooperation between competent authorities.

The proposal therefore introduces targeted amendments to simplify and accelerate recognition

procedures, to improve the availability, completeness and reliability of information on

recognition requirements and procedures, and to strengthen administrative cooperation

between competent authorities. Across these areas, it promotes the use of interoperable digital

tools to support more efficient, transparent and user-friendly recognition processes throughout

the Union. The proposal does not alter the conditions under which Member States regulate

professions or the national arrangements for taking recognition decisions.

The other two legislative initiatives under the Skills Portability Initiative concern digital

qualification attestations and recognition of professional qualifications obtained outside the

EU (in a third country). The former relies on the measures developed under the proposal for

the Regulation establishing a framework for portability of skills and qualifications (SPI

Action 1, “Skills Portability Act”). The latter refers to a proposal of the Directive establishing

a framework for the recognition of third-country qualifications held by third-country

nationals, to ensure that holders of such qualifications who are EU nationals are not treated

less favourably than third country nationals (SPI Action 3). When applicable, all three

proposals under the SPI refer to each other to avoid repetitions and ensure coherence.

• Consistency with existing policy provisions in the policy area

This proposal is fully consistent with the existing EU framework governing the recognition of

professional qualifications. Directive 2005/36/EC remains the central Union instrument in this

area, without prejudice to the limited number of sector-specific rules laid down in other Union

legal acts. It also continues to govern both establishment and the temporary and occasional

provision of services in regulated professions. As recognised by Article 3 of Directive

2006/123/EC on services in the internal market, where the provisions of the two Directives

overlap, Directive 2005/36/EC prevails. This proposal does not affect that relationship.

• Consistency with other Union policies

This proposal is consistent with the Union's broader policy and legislative framework on the

digital transformation of public administration. In particular, it complements the Single

Digital Gateway Regulation (EU) 2018/1724 and the Once-Only Technical System

established thereunder, Regulation (EU) No 910/2014 (eIDAS) as amended by Regulation

(EU) 2024/1183 establishing the European Digital Identity framework, and the Interoperable

Europe Regulation (EU) 2024/903 in particular as regards the principle of interoperability by

design and the requirements applicable to binding requirements affecting cross-border

interoperable digital public services. By promoting interoperable digital credentials, trusted

electronic exchanges of information and interoperable public services, the proposal

contributes to the common objective of delivering more efficient, user-friendly and seamless

cross-border administrative procedures across the Union.

EN 3 EN

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The proposal is based on the same legal basis as Directive 2005/36/EC, namely, Articles 46,

53(1) and 62 of the Treaty on the Functioning of the European Union (TFEU). These

provisions empower the Union to adopt measures facilitating the free movement of workers,

the freedom of establishment and the freedom to provide services, including through the

mutual recognition of diplomas, certificates and other evidence of formal qualifications and

the coordination of national provisions governing access to and the pursuit of regulated

professions.

• Subsidiarity (for non-exclusive competence)

The initiative concerns the functioning of the internal market, an area of shared competence

between the Union and the Member States pursuant to Article 4(2)(a) TFEU. Accordingly, the

principle of subsidiarity applies.

EU-level action is this area has been established as necessary and appropriate since the

adoption of the original framework in 2005, and subsequent updates to this common

framework can only be achieved through action at Union level.

Coordinated action is necessary because professional recognition inherently requires cross-

border interaction between competent authorities, including information exchange,

qualification validation, and document verification. Because these challenges are structural

and transnational, isolated national measures cannot ensure reciprocity, establish common

operational rules, or eliminate heterogeneous practices. Furthermore, integrating digital tools

to streamline these procedures requires a unified approach; developing such solutions

independently at the national level risks fragmentation, duplication, and lack of

interoperability.

Union action is also essential to strengthen transparency and enforcement. Current monitoring

relies heavily on complaints by individual applicants and Member States’ self-reported data,

which fail to provide a comprehensive basis for identifying systematic non-compliance.

Action at EU level is required to establish consistent, comparable data to enable more timely

and more accurate monitoring, supporting targeted corrective measures. By streamlining

information requirements, deadlines, and cooperation practices, a coordinated framework

reduces administrative effort, lowers reporting costs, and minimizes divergent assessments.

Ultimately, only coordinated national systems can achieve this level of transparency; Union

intervention is necessary to resolve persistent administrative burdens and legal uncertainty,

ensuring the existing framework operates as intended and Treaty-conferred rights can be

effectively exercised in practice.

EU-level action also offers clear economies of scale. A single, streamlined framework is

significantly more cost-effective than multiple, parallel national systems requiring complex

technical interfaces. While national administrations will incur initial adaptation costs, these

will be well offset by long-term efficiency gains, reduced reporting burdens, and lower error

rates. Ultimately, uncoordinated national approaches cannot achieve the required consistency

or scale, making Union intervention the most effective way to ensure Treaty rights are able to

be meaningfully exercised.

EN 4 EN

• Proportionality

The proposal concerns the revision of Directive 2005/36/EC, an area where the need for

Union action is already established. The proposed amendments are limited to addressing

specific implementation shortcomings, namely fragmented information, unnecessarily

burdensome recognition procedures, uneven levels of digitalisation and inefficiencies in

administrative cooperation between competent authorities.

The proposal does not harmonise the substantive rules governing regulated professions or the

conditions for the recognition of professional qualifications. Member States remain fully

responsible for regulating professions, determining professional qualifications, assessing

applications and taking recognition decisions. Rather, the focus of the proposed measures is

on procedural improvements, such as clarifying certain procedural obligations, strengthening

administrative cooperation and facilitating the use of interoperable digital tools.

The proportionality of these measures was thoroughly evaluated across all policy options in

the impact assessment, balancing expected benefits against implementation effort.

Proportionality was assessed in the comparison of the policy options considered in the impact

assessment. The assessment also examined whether the scope, intensity and implementation

requirements of the proposed measures were commensurate with the objectives pursued. The

preferred option was selected as the most effective response while remaining strictly

necessary and proportionate. Although it entails a greater degree of intervention than

alternative options, this reflects the magnitude and persistence of the problems addressed and

remains confined to procedural aspects of the recognition framework, fully respecting

Member States' competence over the regulation of professions or substantive recognition

decisions as well as their competence in safeguarding public health, safety and the quality of

services.

• Choice of the instrument

As this proposal amends Directive 2005/36/EC, the appropriate legal instrument is a directive.

A coordinating amendment concerning Regulation 1024/2012 is ancillary to the amendment

of Directive 2005/36/EC.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

No ex-post evaluation was carried out specifically for the preparation of this proposal. The

most recent evaluation of the Directive was conducted in the context of its 2013 revision.

Subsequently, the main innovations introduced by Directive 2013/55/EU, namely the

European Professional Card and the Alert Mechanism, were subject to a dedicated assessment

in 2018. The decision not to undertake a further evaluation was based on the availability of a

recent and comprehensive implementation report for the years 2020-20241, published only a

few months before the preparation of this proposal. That report and the accompanying Staff

Working Document (SWD)2 provide an extensive assessment of the functioning of the

Directive, drawing on a broad range of evidence, including data from the Regulated

Professions Database, targeted surveys of competent authorities, national coordinators and

professional organisations, as well as other stakeholder input. It offers a detailed analysis of

1 COM(2026) 86 final 2 SWD(2026)64 final

EN 5 EN

the implementation of the existing framework, identifies the main challenges encountered in

practice and provides a robust evidence base for the preparation of this proposal.

• Stakeholder consultations

As detailed in the impact assessment accompanying this proposal, the preparation of the

initiative was supported by extensive stakeholder consultation activities.

In addition to the consultations carried out in the context of the recent implementation report,

the Commission conducted an open public consultation as part of the Skills Portability

Initiative as well as a series of targeted stakeholder consultations. Furthermore, a range of

targeted consultation activities were organised with competent authorities, national

coordinators, professional organisations and representatives of regulated professions, as well

as targeted surveys of competent authorities and citizens who had undergone recognition

procedures.

These consultation activities provided valuable evidence on the practical functioning of the

current framework, the challenges encountered by applicants and competent authorities, and

stakeholders' views on possible policy responses. Together with the other sources of evidence

supporting the impact assessment, they informed both the identification of the problems the

development of the measures included in this proposal.

The consultation activities revealed broad agreement among stakeholders on the main

challenges affecting the functioning of the current recognition system. In particular,

stakeholders consistently identified shortcomings in the information available to applicants,

inefficiencies in recognition procedures and scope for improving administrative cooperation

between competent authorities. There was also broad support for further digitalisation and

simplification of recognition procedures as a means of reducing administrative burden and

improving efficiency. Stakeholders further emphasised the need to support competent

authorities in implementing the Directive through common tools, clearer rules and

strengthened cooperation.

These views are reflected in the proposal, which addresses both shortcomings in the design of

the current framework and challenges relating to its implementation. On the one hand, it

introduces new common structural elements, most notably a mandatory European digital

workflow supporting recognition procedures across the Union. On the other hand, it

strengthens the implementation of the existing framework by clarifying procedural rules to

apply the Directive more consistently. Together, these measures are intended to remove the

main obstacles identified by stakeholders and improve the efficiency, predictability and

consistency of recognition procedures across the Union.

• Collection and use of expertise

The Impact assessment accompanying this legislative proposal was support by an external

study commissioned from EY Advisory Services S.p.A and Istituto per la Ricerca Sociale.

• Impact assessment

An impact assessment was carried out in support of this proposal and was informed by an

external study prepared for the Commission.

The impact assessment examined three policy options aimed at improving the consistent

implementation and effectiveness of the Directive. The first option focused on promoting

EN 6 EN

greater administrative convergence through non-legislative measures, such as guidance,

recommendations, peer learning and the exchange of good practices. The second option

combined targeted legislative amendments with increased digitalisation by proposing a

common European digital solution while allowing Member States to continue using

interoperable national systems. The third and preferred option complemented the digital

transformation of recognition procedures with a broader package of legislative measures

addressing additional sources of administrative burden and inefficiency, including the quality

of information provided to applicants, administrative cooperation between competent

authorities, document requirements, fees, paper-based procedures and procedural deadlines.

The third option was selected as the preferred one because it is expected to achieve the

objectives of the initiative most effectively while ensuring cost-effectiveness. It combines a

common European digital recognition solution, developed and financed by the Commission,

with legislative amendments designed to improve the operation of the recognition system. By

providing a common digital infrastructure at Union level, the preferred option reduces

implementation costs for Member States, creates economies of scale, and supports a more

consistent implementation of the Directive.

The impact assessment concludes that the preferred option will generate significant economic

and social benefits. It is expected that the preferred option will reduce the administrative costs

incurred by applicants and competent authorities in recognition procedures, while shortening

processing times and enabling professionals to enter the labour market more quickly.

Employers are also expected to benefit from faster and less cumbersome recruitment, reduced

vacancy durations and improved access to skilled workers.

Beyond these direct benefits, the proposal is expected to improve the functioning of the

internal market for professional services by facilitating the more efficient allocation of skills

across Member States. This is expected to contribute to addressing labour and skills shortages,

improving labour market matching, increasing labour productivity and strengthening the

resilience and competitiveness of the European economy. The proposal is also expected to

generate positive social impacts by improving employment opportunities, supporting upward

career mobility and enhancing income security for professionals seeking to exercise their

profession in another Member State.

• Regulatory fitness and simplification

The proposal contributes to the objectives of regulatory fitness by simplifying the recognition

of professional qualifications and reducing administrative burdens for applicants, competent

authorities and employers. It directly addresses the procedural complexities and inefficiencies

identified in the current framework, while preserving the core principles of the Directive and

Member States' responsibility for recognition decisions.

For applicants, the proposal makes it simpler to request and quicker to obtain a recognition

decision. Reducing reliance on paper-based processes, promoting the use of digital

attestations, limiting documentary requirements and providing more complete and

standardised information on recognition procedures should make recognition procedures more

predictable, reduce the number of incomplete applications and requests for additional

information, and lower the time and costs associated with preparing and submitting

applications.

For competent authorities, the proposal introduces a common digital workflow, integrating

artificial intelligence support, strengthens administrative cooperation and provides clearer

EN 7 EN

procedural rules. These measures are expected to reduce administrative effort, avoid

duplication of work, streamline the handling of recognition procedures and improve the

consistency and efficiency of decision-making across Member States.

For employers, faster and more predictable recognition procedures are expected to facilitate

recruitment, improve workforce planning and accelerate access to qualified professionals,

including in sectors experiencing labour and skills shortages.

The proposal contributes to the Union’s competitiveness by shortening the time needed to fill

vacancies in regulated professions. Small and medium enterprises are expected to benefit

proportionately more, while no new obligations are imposed on businesses.

Although the implementation of the new digital infrastructure will require initial investment

in IT systems, training and organisational adjustments, these transitional costs are expected to

be outweighed by lasting reductions in administrative burden, shorter processing times and a

more efficient and coherent recognition system across the Union.

• Fundamental rights

By facilitating the recognition of professional qualifications across Member States, the

proposal supports the effective exercise of the freedoms of movement, namely establishment

and the provision of services within the internal market and freedom of movement for

workers. By reducing administrative and regulatory barriers, the proposal enables mobile

professionals to pursue their profession on the basis of their qualifications and merits,

irrespective of their nationality and the Member State in which they obtained their

qualifications. In doing so, it contributes to the principles of equal treatment and non-

discrimination, as enshrined in Article 21 of the Charter of Fundamental Rights, and

facilitates the effective exercise of the rights conferred by the Treaties. It also promotes the

right to engage in work and to pursue a freely chosen occupation, as enshrined in Article 15 of

the Charter of Fundamental Rights, in particular paragraph 2, which guarantees Union citizens

the freedom to seek employment, to work, to exercise the right of establishment and to

provide services in any Member State.

4. BUDGETARY IMPLICATIONS

The proposal has budgetary implications for the Union budget related to the development,

deployment and operation of the European Digital Recognition Solution (EDRS), which will

be developed, financed and operated by the Commission, within three years after entry into

force of this Directive.

The EDRS will provide a common digital workflow for the recognition of professional

qualifications across the Union and will include interfaces for applicants and competent

authorities, AI-assisted functionalities to support the processing of recognition applications,

interoperability with relevant Union systems, including the Single Digital Gateway Once-

Only Technical System and the European Digital Identity Wallet, analytical and statistical

functionalities, and integration with the enhanced Regulated Professions Database.

For 2027, the resource of the deployment of the system will come from EaSI. This initiative

should be financed within the agreed envelope of the programme For the following years, the

resources needed may be provided in the Commission’s proposal for the next MFF 2028-

2034, in particular the EU Facility under the National and Regional Partnership Plans. The

Commission assesses that the HR needs will be covered by redeployment to meet the needs

EN 8 EN

generated by this proposal. The estimated impact on expenditure and staffing for 2028 and

beyond is added for illustrative purposes only and does not pre-judge the next Multiannual

Financial Framework. The source of financing and scope of Union financial commitment in

the post-2027 period remain subject to the outcome of interinstitutional negotiations on the

MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

The Commission will keep Member States informed about the development of EDRS,

allowing them to prepare for its deployment. In any case, the EDRS must be made operational

ahead of the date for the transposition of the corresponding procedural obligations of the

Member States under this proposal. Member States are not required to bear costs for

developing or adapting national solutions supporting recognition processes, as the EDRS

together with other EU solutions such as IMI will fully cover the functionality that competent

authorities need to process applications for recognition of professional qualifications.

By providing and financing a common Union-wide digital infrastructure, the proposal avoids

the need for Member States to develop and maintain separate national solutions, thereby

reducing implementation costs, creating economies of scale and supporting the consistent

implementation of the Directive across the Union. The detailed budgetary implications of the

proposal are set out in the accompanying financial statement.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

The Commission will monitor implementation in close cooperation with the national

coordinators and competent authorities. Monitoring will focus on the extent to which the

proposal succeeds in simplifying recognition procedures, reducing administrative burden and

costs, and improving administrative cooperation.

Monitoring will be based on two complementary sources: biennial reporting by Member

States, coordinated by the national coordinators, and annual data generated through the

EDRS. The first data collection will take place before the deployment of the new system to

establish a baseline, followed by regular monitoring after implementation.

The monitoring framework includes indicators measuring the quality and completeness of

information provided to applicants, the efficiency and timeliness of recognition procedures,

the administrative burden associated with recognition applications, and the effectiveness of

administrative cooperation between competent authorities. A detailed set of indicators,

together with the data sources and collection methods, is set out in the Impact Assessment

accompanying this proposal. The Commission will carry out an evaluation of the Directive

approximately five years after the expiry of the transposition deadline.

• Explanatory documents (for directives)

Pursuant to Article 3 of this Directive, Member States are required to transpose its provisions

into national law and to notify the Commission of the corresponding national measures. When

notifying those measures, Member States should provide sufficient information to enable the

Commission to assess the completeness and correctness of transposition. This information

should clearly indicate how the provisions of the Directive have been implemented in national

law.

EN 9 EN

• Detailed explanation of the specific provisions of the proposal

Article 1 sets out the amendments to Directive 2005/36/EC. Article 2 contains an amendment

of the provisions referred to in the annex of Regulation (EU) No 1024/2012 on administrative

cooperation through the Internal Market Information System (‘the IMI Regulation’). Article 3

contains the provisions on transposition, Article 4 concerns the entry into force of the

amending Directive, and Article 5 specifies its addressees.

The substantive amendments introduced by Article 1 are organised around the following main

themes:

Digitalisation of recognition procedures: The proposal replaces the existing European

Professional Card framework with a European Digital Recognition Solution established by

new Article 56b. While recognition decisions remain the responsibility of Member States, the

entire administrative workflow will be carried out through a common digital infrastructure

used by all competent authorities. The proposal also introduces a digital-only principle

through Article 56c.

Faster and more predictable recognition procedures: The proposal introduces, through

Article 56d, deadlines for each key procedural step, creating a structured workflow from the

submission of an application to the final recognition decision. This replaces the current

approach, under which only the overall duration of the procedure is defined, and substantially

reduces the maximum duration of recognition procedures under both the automatic

recognition system and the general system. For temporary and occasional provision of

services, Article 7(4) similarly shortens the duration of prior checks. To reinforce compliance,

the new Article 56e introduces a financial compensation mechanism for applicants affected by

excessive delays in the administrative handling of their recognition applications.

Simplification of procedural requirements: The proposal further harmonises the procedural

framework by clarifying, through amendments to Article 50, that competent authorities may

request only the documents expressly provided for by the Directive. Article 50(8) requires

Member States to accept those documents in any official language of the Union, while Article

56c(3) establishes rules on communication with applicants. A new Article 51a introduces

common principles governing recognition fees. Together, these measures reduce unnecessary

administrative burdens, improve legal certainty and promote more consistent application of

the Directive.

Modernisation of notifications and reporting: The proposal modernises the notification

framework by amending Article 59(1), requiring Member States to submit notifications

concerning regulated professions through the Internal Market Information System. It also

strengthens the Commission's role in monitoring the implementation of the Directive through

amendments to Article 60, enabling reporting to rely on statistical information generated by

the European Digital Recognition Solution and thereby improving the quality, comparability

and availability of implementation data.

Strengthened cooperation and governance: The proposal introduces a more structured

governance framework through new Article 60a, strengthening cooperation between the

Commission and the Member States within the Group of Coordinators on the Recognition of

Professional Qualifications. Annual work programmes will provide a clearer framework for

monitoring implementation, identifying common challenges, exchanging good practices and

preparing future developments of the recognition system. The strengthened governance

EN 10 EN

framework is also intended to facilitate and streamline the use of the Directive's delegated

powers, in particular with regard to the establishment of Common Training Frameworks.

Equal treatment of EU nationals and third-country nationals: Amendments to Articles

2(2), 3(3) and 10(g) of Directive 2005/36/EC align the Directive with [Directive xxxx/xxx/EU

on the recognition of qualifications of third-country nationals], which establishes a framework

for the recognition of third-country qualifications held by third-country nationals. The

existing provisions are replaced by new rules on recognition of qualifications obtained outside

the Union in Title Va, ensuring coherence between the two legal frameworks while preserving

the distinction between the general system and automatic recognition under Directive

2005/36/EC as well as the main features underlying each of those systems.

EN 11 EN

2026/0273 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and Regulation (EU)

No 1024/2012

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular

Article 46, Article 53(1) and Article 62 thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national parliaments,

Having regard to the opinion of the European Economic and Social Committee3,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) The Single Market is a cornerstone of European integration and a key driver of the

Union’s competitiveness, prosperity and resilience. Its full potential depends, inter

alia, on enabling people to move freely across the Union and to put their skills and

qualifications to use wherever they are needed. Facilitating mobility contributes to a

better allocation of skills across the Union, helps address labour and skills shortages

and strengthens the capacity of the Union economy to respond to changing economic

and demographic needs. Therefore, remaining barriers to the mobility of professionals

should be reduced. This is particularly important in the field of regulated professions,

where access to or pursuit of a professional activity is subject to the possession of

specific professional qualifications. Differences in national qualification requirements

may raise obstacles to the mobility of qualified professionals between Member States.

(2) Directive 2005/36/EC of the European Parliament and of the Council4 sets out the

rules governing the recognition of professional qualifications for access to and pursuit

of regulated professions and is a crucial instrument supporting the mobility of workers

and services within the Single Market. It establishes a Union framework for the

recognition of professional qualifications and thereby plays a central role in enabling

professionals to exercise their right to free movement while ensuring that the

requirements governing access to regulated professions in the host Member State are

appropriately taken into account. In order to further facilitate professional mobility

within the Single Market, that framework should be modernised and made simpler,

3 OJ C […], […], p. […]. 4 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the

recognition of professional qualifications, OJ L 255, 30.9.2005, p. 22, ELI:

http://data.europa.eu/eli/dir/2005/36/oj

EN 12 EN

faster and more efficient, in particular by making better use of digital tools,

streamlining recognition procedures and strengthening administrative cooperation

between competent authorities.

(3) Directive 2005/36/EC, which lays down rules governing the recognition of

professional qualifications of Union citizens, already contains specific rules

concerning qualifications obtained in third countries. In particular, its Article 2(2)

provides that each Member State may, in accordance with its national rules, permit

Member State nationals holding evidence of professional qualifications obtained in a

third country to pursue a regulated profession on its territory and that, in the case of

professions covered by Title III, Chapter III, that recognition is to respect the

minimum training conditions laid down in that Chapter. In addition, Article 3(3) of

Directive 2005/36/EC, first sentence, read in conjunction with Article 10, point (g),

ensures that, where a Member State national has obtained recognition of their third-

country qualification in one Member State and has three years of certified professional

experience in that profession within the same Member State, their third-country

qualification is to be regarded as evidence of formal qualifications under that

Directive, which should entitle them to recognition of their evidence of professional

qualifications under the general system when seeking access to the profession in

another Member State. With the adoption of [Directive xxxx/xxx/EU on the

recognition of qualifications of third-country nationals5], establishing a framework for

the recognition, for the purpose of establishment, of third-country qualifications held

by third-country nationals, it is appropriate to ensure that Directive 2005/36/EC also

establishes a coordinated approach to the recognition of qualifications obtained by

Member State nationals outside the Union.

(4) To that end, the necessary adjustments should be made to Directive 2005/36/EC to

ensure coherence between the two legal acts. It is therefore necessary to include a new

Title Va of Directive 2005/36/EC so as to ensure that each Member State develops

appropriate procedures for the recognition of professional qualifications obtained

outside the Union held by nationals of a Member State. Such procedures should ensure

that nationals of a Member State seeking recognition of their professional

qualifications in a host Member State for the purposes of establishment are not subject

to rules that are less favourable than those applicable to the third-country nationals

seeking recognition of their professional qualifications in that Member State.

(5) The distinction between, and underlying logic of, the general system of recognition

and the system of automatic recognition established by Directive 2005/36/EC should

be preserved, while taking due account of the specificities of qualifications awarded

outside the Union to ensure that the conditions required for access to and pursuit of the

profession in the host Member State are met.

(6) In its Special Report 10/24 on the recognition of professional qualifications in the

Union,6 the European Court of Auditors considered that, while Directive 2005/36/EC

is an essential mechanism, it is used sparsely and inconsistently. To improve the

system of recognition of professional qualifications, it notably recommended annual

updating of Annex V to that Directive, reducing the deadline for recognition through

the automatic system that benefits professions for which mandatory minimum training

5 […] 6 Special report 10/2024: The recognition of professional qualifications in the EU – An essential

mechanism, but used sparsely and inconsistently

EN 13 EN

requirements are set under the Directive, as well as ensuring reliable and consistent

information for citizens.

(7) Procedures for the recognition of professional qualifications can come with a high

burden for applicants. Professionals seeking recognition of qualifications acquired in

another Member State are required to submit multiple supporting documents,

including certified copies and translations, sometimes in paper form, and to bear fees

which vary considerably between Member States. Such requirements may discourage

professionals from pursuing opportunities in other Member States. Reducing the

reliance on physical documents while ensuring access to underlying information is

therefore key to facilitate the free movement of professionals within the Union.

(8) While most procedures for the recognition of professional qualifications under

Directive 2005/36/EC are completed within the applicable timeframes, persistent

delays in some cases continue to affect applicants and may hinder the timely access to

regulated professions. Such delays can entail significant costs or lost opportunities for

applicants while also affecting employers awaiting the recruitment of qualified

professionals, particularly in sectors facing labour and skills shortages. It is therefore

necessary to modernise, simplify and improve the efficiency of procedures for the

recognition of professional qualifications by laying down precise deadlines for the

exchange of information and for mutual assistance between the competent authorities

of the host Member State and those of the home Member State.

(9) To be able to submit complete recognition applications, applicants should be provided

with reliable information to support them in the process of recognition of their

qualifications. They should be able to understand, at an early stage, whether and under

which conditions they may access a regulated profession in another Member State. It

is therefore necessary to ensure that clear, trustworthy and up-to-date information is

available for applicants before starting a procedure and that they are appropriately

guided towards the relevant profession, applicable national rules and required

supporting documents.

(10) The European Professional Card introduced by Directive 2013/55/EU of the European

Parliament and of the Council7 has remained confined to a limited number of

professions and, given its case-specific design, has not proven capable of being scaled

up into a broader or more comprehensive solution for the recognition of professional

qualifications. To ensure a smooth and orderly transition to that solution, the European

Professional Card (EPC) should therefore be phased out gradually. To that end,

Member States should, during a limited transitional period, continue issuing the EPC.

(11) To facilitate the recognition of professional qualifications, a common Union IT

solution, the European Digital Recognition Solution, should be established at Union

level to support the digitalisation of procedures for the recognition of professional

qualifications. That system should provide a common digital infrastructure enabling

applicants to submit applications and supporting documents, including by reusing

relevant data from national identity or credential systems, and to receive information

on the status and outcome of their applications. It should facilitate secure and efficient

cooperation between competent authorities, reduce administrative burden and undue

7 Directive 2013/55/EU of the European Parliament and of the Council of 20 November 2013 amending

Directive 2005/36/EC on the recognition of professional qualifications and Regulation (EU)

No 1024/2012 on administrative cooperation through the Internal Market Information System ( ‘the IMI

Regulation’ ) OJ L 354, 28.12.2013, pp. 132–170,ELI: http://data.europa.eu/eli/dir/2013/55/oj

EN 14 EN

delays, and simplify procedures for applicants and competent authorities. It should

also contribute to the consistent application and uniform implementation of Directive

2005/36/EC across Member States, while fully respecting data protection requirements

and the organisation and functioning of national administrative systems.

(12) The introduction of stricter procedural timeframes for the exchange of information and

mutual assistance between the competent authorities should be accompanied with

measures that support Member States in making that cooperation more efficient

through a common digital workflow. The European Digital Recognition Solution

should therefore support secure communication, full traceability of procedural steps,

legal certainty and the timely handling of applications.

(13) The use of digital solutions should contribute to the more efficient organisation of

procedures for the recognition of professional qualifications. To that end, based on the

digital qualification attestations made available under [Regulation(EU)XXX

establishing a framework for portability of skills and qualifications and amending

Regulation (EU) 2018/1724]8, applicants should be able to obtain, by digital means,

formal evidence of qualifications issued by the competent authorities of the home

Member State and to verify, prior to submission, whether their application is complete,

including as regards the adequacy of supporting documents and translations. Digital

tools should also support competent authorities in the assessment of applications,

including the examination of supporting evidence, facilitate the secure exchange of

information with authorities in other Member States, and improve communication

with the applicants. These improvements should contribute to shorter processing times

for applications and to a reduction in the applicable deadlines.

(14) The Internal Market Information System (‘IMI’), established by Regulation (EU) No

1024/2012 of the European Parliament and of the Council9, is a tool supporting

administrative cooperation between competent authorities in the recognition of

professional qualifications under Directive 2005/36/EC. The European Digital

Recognition Solution established under Directive 2005/36/EC should build on and

interoperate with IMI, avoiding duplication of communication channels and preserving

the accumulated functionality of the existing tool. The Annex to that Regulation

should be amended in accordance with the amendments to the provisions of this

Directive.

(15) Regulation (EU) 2018/1724 of the European Parliament and of the Council10

established the Single Digital Gateway and the Once-Only Technical System, enabling

the cross-border exchange of evidence between competent authorities without

requiring users to resubmit documents already held by another public authority. Its

continued implementation can support more efficient recognition procedures by

allowing supporting documents exchanged through the Once-Only Technical System

to be used within the European Digital Recognition Solution, reducing the burden on

applicants to obtain and submit certified copies of evidence already available through

public registers or authorities in another Member State.

8 […] 9 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on

administrative cooperation through the Internal Market Information System and repealing Commission

Decision 2008/49/EC, OJ L 316, 14.11.2012, p.1, ELI: http://data.europa.eu/eli/reg/2012/1024/oj 10 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

establishing a single digital gateway to provide access to information, to procedures and to assistance

and problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p.

1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj

EN 15 EN

(16) The publicly available database of regulated professions referred to in Article 59(1) of

Directive 2005/36/EC set up and maintained by the Commission provides a centralised

overview of professions that are regulated in each Member State, the applicable legal

provisions, and the competent authorities responsible. To ensure legal certainty and

consistency, that database should constitute the single authoritative source of

information on the regulatory status of professions across the Union, and Member

States should keep the information they notify complete, accurate and up to date.

(17) Language barriers can complicate and delay recognition procedures. Recent advances

in machine translation, including the Commission's eTranslation service, make it

possible to process documents submitted in another official language of the Union by

facilitating understanding of their content. The continuous improvement in the quality

of machine translation is steadily increasing confidence in translated documents and is

reshaping the contribution of human translators towards quality assurance and

verification. Competent authorities should therefore be able to rely on machine

translation integrated into the European Digital Recognition Solution to facilitate the

handling of applications, while preserving the possibility of requesting a certified

human translation where appropriate.

(18) To support the digitalisation of procedures under Directive 2005/36/EC, the European

Digital Recognition Solution, which would be built on a Union-wide infrastructure for

digital qualification attestations should allow applicants to use and share trusted digital

evidence across borders more efficiently. The European Digital Recognition Solution

established by this Directive constitutes a cross-border digital public service within the

meaning of Regulation (EU) 2024/903 of the European Parliament and of the Council

(Interoperable Europe Act)11 and is subject to the requirements laid down in that

Regulation, including the obligation to carry out an interoperability assessment. In

accordance with the requirements applicable to European Digital Identity Wallets

under Regulation (EU) 910/2014 of the European Parliament and of the Council12, the

European Digital Recognition Solution should be interoperable with the EU Digital

Identity Wallet so that applicants can submit, reuse and securely share, under their

control, pre-authenticated digital documents stored therein, including evidence of

formal qualifications. By relying on standardised digital qualification attestations and

interoperable systems, such a framework should help competent authorities access

reliable and up-to-date information more quickly, accelerate verification, reduce

repeated requests for the same evidence, and support faster, more consistent

recognition decisions across Member States.

(19) To support the digitalisation of recognition procedures under Directive 2005/36/EC,

Member States should ensure the secure receipt and verification of credentials, as well

as their use in the digital processing of recognition requests and the issuance of

recognition decisions. The European Digital Recognition Solution should further

reinforce confidence of applicants and employers in the use of digital evidence in

cross-border recognition procedures for regulated professions. Digital qualification

attestations issued in accordance with [Regulation(EU)XXX establishing a framework

11 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying

down measures for a high level of public sector interoperability across the Union (Interoperable Europe

Act), OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj 12 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on

electronic identification and trust services for electronic transactions in the internal market and

repealing Directive 1999/93/EC, OJ L 257, 28.8.2014, p. 73, ELI:

http://data.europa.eu/eli/reg/2014/910/oj

EN 16 EN

for portability of skills and qualifications and amending Regulation (EU) 2018/1724]

should enable competent authorities to rely on their authenticity without carrying out

further checks. For other documents submitted in support of recognition requests,

where checks of authenticity are necessary, greater digitalisation should enable

competent authorities to carry out such checks more efficiently and consistently,

helping to detect irregularities and prevent fraudulent submissions.

(20) To guarantee equal treatment and effective access, applicants who are unable to

undergo the procedure by electronic means only, including due to limited digital skills,

should not be disadvantaged in the exercise of their rights under Directive

2005/36/EC. Member States should make appropriate arrangements to enable such

applicants to pursue the relevant procedures by non-electronic means, while ensuring

that their applications are handled with the same diligence, without undue delay and

subject to the same procedural safeguards as applications submitted through the digital

solution. In this context, documents submitted in the course of such procedures may be

provided in different formats, including paper documents that have been scanned and

converted into electronic form, as well as electronic documents including electronic

attestations of attributes set out in Commission Implementing Regulation (EU)

2024/297913. The use of different formats should not lead to discrimination against the

applicant provided that the authenticity, integrity and, where relevant, origin of the

documents can be appropriately assessed. Where an applicant makes use of non-

electronic means for justified reasons, Member States should ensure that the

competent authority, or another designated body, enters the necessary data and

documents into the digital system without undue delay and keeps the applicant

appropriately informed of the progress of the procedure. Member States should also

provide adequate technical and digital support to applicants using the digital solution,

in particular to those with limited digital skills, to ensure effective access on an equal

basis.

(21) Competent authorities may, in the examination of applications for the recognition of

professional qualifications, be assisted by the European Digital Recognition Solution.

Such assistance could entail the assessment of the completeness of applications with

respect to the appropriate information and relevant evidence provided, the authenticity

of documents submitted, the identification of substantial differences between the

training evidenced by the applicant and the national training requirements, the

indication of possible compensation measures (aptitude tests or adaptation periods) in

accordance with Directive 2005/36/EC, and the identification of similar previously

assessed cases with a view to promoting consistency in decision-making.

(22) The Commission and Member States, in their respective capacities as processor and

controllers, within the meaning of Article 29(3) of Regulation (EU) 2018/1725 of the

European Parliament and of the Council14 and Article 28(3) of Regulation (EU)

13 Commission Implementing Regulation (EU) 2024/2979 of 28 November 2024 laying down rules for the

application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards

the integrity and core functionalities of European Digital Identity Wallets, OJ L, 2024/2979, 4.12.2024,

ELI:http://data.europa.eu/eli/reg_impl/2024/2979/oj 14 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

protection of natural persons with regard to the processing of personal data by the Union institutions,

bodies, offices and agencies and on the free movement of such data, OJ L 295, 21.11.2018, p. 39, ELI:

http://data.europa.eu/eli/reg/2018/1725/oj

EN 17 EN

2016/679 of the European Parliament and of the Council15, should implement

appropriate technical and organisational measures to safeguard personal data against

unauthorised access, accidental loss, or unlawful processing.

(23) Where an excessive delay is attributable to the competent authority and not to the

applicant, it should entitle the latter to an appropriate and proportionate compensation

for the economic disadvantage caused by the delay.

(24) The benefits of automatic recognition could be further extended to additional

professions through fuller use of the mechanism established by Directive 2005/36/EC

for the development of common training frameworks. Where a common set of

minimum knowledge, skills and competences necessary for the pursuit of a specific

profession can be identified and is shared by at least one third of the Member States,

common training frameworks can provide an effective means of promoting

professional mobility while respecting national regulatory approaches and training

systems. To attain this objective, a strengthened cooperation among competent

authorities is needed through the Group of Coordinators established by Commission

Decision 2007/172/EC16. While contributing to the overall consistent and effective

implementation of Directive 2005/36/EC, including through the preparation of annual

work programmes and the exchange of experience and best practices, the Group

should also serve as a forum for outreach to and exchange with professionals, their

representative organisations and social partners, including on labour market needs,

quality standards and professional autonomy. In particular, it should contribute to

identifying emerging common sets of knowledge, skills and competences, assessing

needs and expectations in the professions, and exploring opportunities for the

development of common training frameworks in accordance with this Directive.

(25) To ensure coherence, transparency and proportionality, and to avoid duplicative

reporting obligations, the additional monitoring and evaluation requirements linked to

the digitalisation and simplification measures introduced by this Directive should be

integrated into the reporting framework established by Article 60 of Directive

2005/36/EC. Evaluation should in particular assess the functioning of the European

Digital Recognition Solution, its effect on administrative burdens and procedure

duration, and its impact on the mobility of professionals and addressing labour and

skills shortages in the internal market.

(26) Directive 2005/36/EC and Regulation (EU) 1024/2012 should therefore be amended

accordingly.

(27) The European Data Protection Supervisor was consulted in accordance with Article

42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council

and delivered its opinion on [date]17.

15 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data and on the free movement of

such data, OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj

16 Commission Decision 2007/172/EC of 19 March 2007 setting up the group of coordinators for the

recognition of professional qualifications, OJ L 79, 20.3.2007, pp. 38–39 (BG, ES, CS, DA, DE, ET,

EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, RO, SK, SL, FI, SV), OJ L 219M, 24.8.2007, pp. 367–368

(MT), ELI: http://data.europa.eu/eli/dec/2007/172/oj 17 OJ C , , p. .

EN 18 EN

HAVE ADOPTED THIS DIRECTIVE:

Article 1

Amendments to Directive 2005/36/EC

Directive 2005/36/EC is amended as follows:

(1) Article 1 is replaced by the following:

'Article 1

Subject matter

1. This Directive establishes rules according to which a Member State which makes access to

or pursuit of a regulated profession in its territory contingent upon possession of specific

professional qualifications (‘the host Member State’) shall recognise professional

qualifications obtained in one or more other Member States (‘the home Member State’) and

which allow the holder of the said qualifications to access and pursue the said profession in

the host Member State.

2. This Directive also establishes rules concerning partial access to a regulated profession and

recognition of professional traineeships pursued in another Member State.

3. This Directive also lays down rules under which a host Member State shall recognise

professional qualifications obtained in a third-country for the purpose of establishment in that

Member State and which allow the holder of the said qualifications to access and pursue the

profession in that Member State under conditions that are not less favourable than those for

third-country nationals.';

(2) Article 2 is amended as follows:

(a) the first subparagraph of paragraph 1 is replaced by the following:

'1. This Directive shall apply to all nationals of a Member State wishing to pursue a

regulated profession in a Member State, including those belonging to the liberal

professions, on either a self-employed or employed basis, and who obtained their

professional qualifications in another Member State or in a third country';

(b) paragraph 2 is deleted;

(3) Article 3 is amended as follows:

(a) paragraph 1 is amended as follows:

(i) point k is deleted;

(ii) the following point o is added:

'(o) ‘digital qualification attestation’ an attestation of a qualification that is

awarded in a digital format in accordance with Regulation (EU) xxxx/xxx on

portability of skills and qualifications and amending Regulation (EU)

2018/172418';

(b) paragraph 3 is deleted;

18 […]

EN 19 EN

(4) Article 4 is amended as follows:

'Article 4

Effects of recognition

1. The recognition of professional qualifications by the host Member State shall allow

beneficiaries to gain access in that Member State to the same profession as the one for which

they are qualified in the home Member State or in the third country where they obtained their

qualifications under the same conditions as its nationals.

2. For the purposes of this Directive, the profession which the applicant wishes to pursue in

the host Member State shall be considered the same as the one for which they are qualified in

their home Member State or in the third country if the activities covered are comparable.

3. By way of derogation from paragraph 1 of this Article, partial access to a profession in the

host Member State shall be granted under the conditions laid down in Article 4f.';

(5) Articles 4a, 4b, 4c, 4d and 4e are deleted;

(6) Article 4f is amended as follows:

'Article 4f

Partial access

1. The competent authority of the host Member State shall grant partial access, for the purpose

of establishment, on a case-by-case basis, to a professional activity in its territory only when

all the following conditions are fulfilled:

(a) the professional is fully qualified to exercise in the home Member State or in

the third country the professional activity for which partial access is sought in

the host Member State;

(b) differences between the professional activity legally exercised in the home

Member State or in the third country and the regulated profession in the host

Member State as such are so large that the application of compensation

measures would amount to requiring the applicant to complete the full

programme of education and training required in the host Member State to

have access to the full regulated profession in the host Member State;

(c) the professional activity can objectively be separated from other activities

falling under the regulated profession in the host Member State.

For the purpose of the first subparagraph, point (c), the competent authority of the

host Member State shall take into account whether the professional activity can be

pursued autonomously in the home Member State or in the third country.

2. The competent authority of the host Member State shall grant partial access, for the purpose

of temporary and occasional services in the host Member State, on a case-by-case basis, to a

professional activity in its territory only when all the following conditions are fulfilled:

(a) the professional is fully qualified to exercise in the home Member for the

professional activity for which partial access is sought in the host Member

State;

(b) differences between the professional activity legally exercised in the home

Member State and the regulated profession in the host Member State as such

are so large that the application of compensation measures would amount to

requiring the applicant to complete the full programme of education and

EN 20 EN

training required in the host Member State to have access to the full regulated

profession in the host Member State;

(c) the professional activity can objectively be separated from other activities

falling under the regulated profession in the host Member State.

For the purpose of the first subparagraph, point (c), the competent authority of the

host Member State shall take into account whether the professional activity can be

pursued autonomously in the home Member State or in the third country.

3. Partial access may be rejected if such rejection is justified by overriding reasons of general

interest, suitable for securing the attainment of the objective pursued, and does not go beyond

what is necessary to attain that objective.

4. Applications for the purposes of establishment in a Member State shall be examined in

accordance with Chapters I and IV of Title III for professionals seeking partial access based

on professional qualifications obtained in their home Member State and in accordance with

Title Va for professionals seeking partial access based on the professional qualifications

obtained in a third country.

5. Applications for the purposes of providing temporary and occasional services in the host

Member State concerning professional activities that have public health or safety implications

shall be examined in accordance with Title II.

6. By way of derogation from Article 52 of this Directive, the professional activity shall be

exercised under the professional title of the third country or of the other Member State once

partial access has been granted. The host Member State may require use of that professional

title in the languages of the host Member State. Professionals benefiting from partial access

shall clearly indicate to the service recipients the scope of their professional activities.

7. This Article shall not apply to professionals benefiting from automatic recognition of their

professional qualifications under the provisions referred to under Title Va of this Directive.';

(7) Article 7 is amended as follows:

(a) paragraph 1 is replaced by the following:

'1. Member States may require that, where the service provider first moves from one

Member State to another in order to provide services, the service provider shall inform

the competent authority in the host Member State in a written declaration to be made

in advance including the details of any insurance cover or other means of personal or

collective protection with regard to professional liability. Such declaration shall be

renewed once a year if the service provider intends to provide temporary or occasional

services in that Member State during that year.';

(b) in paragraph 4, the second subparagraph is replaced by the following:

'Within two weeks of informing the applicant that the declaration referred to in

paragraphs 1 and 2 of this Article is complete, as stipulated in Article 56d(4), the

competent authority shall notify the service provider of its decision which may be one

of the following:

(a) not to check the professional qualifications;

(b) where the professional qualifications have been checked:

(i) to require the service provider to take an aptitude test; or

(ii) to allow the provision of services';

EN 21 EN

(8) in Article 8, paragraph 1 is replaced by the following:

'1. The competent authorities of the host Member State may ask the competent authorities of

the Member State of establishment, in the event of justified doubts, to provide any

information relevant to the legality of the service provider’s establishment and good conduct,

as well as the absence of any disciplinary or criminal sanctions of a professional nature. In the

event that the competent authorities of the host Member State decide to check the service

provider’s professional qualifications, they may ask the competent authorities of the Member

State of establishment for information about the service provider’s training courses to the

extent necessary to assess substantial differences likely to be harmful to public health or

safety. The competent authorities of the Member State of establishment shall provide that

information in accordance with Articles 56 and 56d. In the case of non-regulated professions

in the home Member State, the assistance centres referred to in Article 57b may also provide

such information.';

(9) in Article 10, point (g) is deleted;

(10) Article 14 is amended as follows:

(a) in paragraph 3, the second subparagraph is replaced by the following:

'This applies also to the cases provided for in Article 10 points (b) and (c), in Article

10 point (d) concerning medical doctors and dental practitioners, in Article 10 point (f)

when the migrant seeks recognition in another Member State where the relevant

professional activities are pursued by nurses responsible for general care or specialised

nurses holding evidence of formal qualifications as a specialist who have taken part in

the training leading to the possession of the titles listed in Annex V, point 5.2.2.';

(b) the following paragraph 8 is added:

'8. Member States shall ensure that applicants who fail an aptitude test, or one or more

tests forming part of an adaptation period, are given the opportunity to retake the

respective tests. Member States shall ensure that feedback detailing assessment results

and areas for improvement is provided to applicants, and that applicants are entitled to

at least two further attempts to pass each test that they have failed.';

(11) in Article 21, paragraph 1 is replaced by the following:

'1. Each Member State shall recognise evidence of formal qualifications as doctor giving

access to the professional activities of doctor with basic training and specialised doctor, as

nurse responsible for general care, as dental practitioner, as specialised dental practitioner, as

veterinary surgeon, as pharmacist and as architect, listed in Annex V, points 5.1.1, 5.1.2,

5.2.2, 5.3.2, 5.3.3, 5.4.2, 5.6.2 and 5.7.1 respectively, which satisfy the minimum training

conditions referred to in Articles 24, 25, 31, 34, 35, 38, 44 and 46 respectively, and shall, for

the purposes of access to and pursuit of the professional activities, give such evidence the

same effect on its territory as the evidence of formal qualifications which it itself issues.

Such evidence of formal qualifications shall be issued by the competent bodies in the Member

States and accompanied, where appropriate, by the certificates listed in Annex V, points 5.1.1,

5.1.2, 5.2.2, 5.3.2, 5.3.3, 5.4.2, 5.6.2 and 5.7.1 respectively.

Member States shall ensure that any person to whom they award the evidence of formal

qualifications in that Member State referred to in Annex V, points 5.1.1, 5.1.2, 5.2.2, 5.3.2,

5.3.3, 5.4.2, 5.6.2, and 5.7.1, may request that the relevant certificate accompanying that

evidence of formal qualification, listed in Annex V, be issued as a digital qualification

attestation in accordance with [Regulation(EU)XXX establishing a framework for portability

of skills and qualifications and amending Regulation (EU) 2018/1724]. Any person holding

EN 22 EN

such evidence of formal qualifications and, where appropriate, the relevant certificate listed in

Annex V, which was issued in a non-digital form, may request from the issuing Member State

a digital qualification attestation of that certificate in accordance with [Regulation(EU)XXX

establishing a framework for portability of skills and qualifications and amending Regulation

(EU) 2018/1724].

The provisions of the first and second subparagraphs shall not affect the acquired rights

referred to in Articles 23, 27, 33, 37, 39 and 49.

The provisions of the third and fourth subparagraphs are without prejudice to the provisions

of [Regulation(EU)XXX establishing a framework for portability of skills and qualifications

and amending Regulation (EU) 2018/1724] concerning digital qualification attestation.';

(12) in Article 25, the following paragraph 6 is inserted:

'6. In order to reflect generally acknowledged changes in the medical terminology across the

Union, the Commission is empowered to adopt delegated acts in accordance with Article 57c

in order to update the generic name of specialties in points 5.1.3 and 5.3.3 of Annex V. ';

(13) Articles 50 and 51 are replaced by the following:

'Article 50

Documentation and formalities

1. Where the competent authorities of the host Member State decide on an application for

authorisation to pursue the regulated profession by virtue of this Title, those authorities may

require solely the documents and certificates listed in Annex VII.

Where the host Member State decides to impose a requirement as to the date of issue of the

documents referred to in Annex VII, points 1(d), (e) and (f), it shall accept documents issued

within a specific period that may not be shorter than the three months preceding the date on

which they are submitted.

The Member States, bodies and other legal persons shall guarantee the confidentiality of the

information which they receive.

2. In cases of justified doubts, the host Member State may require from the competent

authorities of a Member State confirmation of the authenticity of the attestations and evidence

of formal qualifications awarded in that other Member State, as well as, where applicable,

confirmation of the fact that the beneficiary fulfils, for the professions referred to in Chapter

III of this Title, the minimum training conditions set out respectively in Articles 24, 25, 28,

31, 34, 35, 38, 40, 44 and 46.

3. By way of derogation from paragraph 2, Member States shall not require confirmation of

authenticity where evidence of formal qualifications is submitted as a digital qualification

attestation or where attestations or evidence are obtained through the technical system for the

cross-border automated exchange of evidence, as established under Regulation (EU)

2018/1724 of the European Parliament and of the Council19. This shall be without prejudice to

the possibility for Member States to verify compliance with the minimum training

requirements applicable under Chapter III of this Title.

19 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

establishing a single digital gateway to provide access to information, to procedures and to assistance

and problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p.

1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj

EN 23 EN

4. In cases of justified doubt, where evidence of formal qualifications has been issued by a

competent authority in a Member State and includes training received in whole or in part in an

establishment legally established in the territory of another Member State, the host Member

State shall be entitled to verify with the competent body in the Member State of origin of the

award:

(a) whether the training course at the establishment which gave the training has

been formally certified by the educational establishment based in the Member

State of origin of the award;

(b) whether the evidence of formal qualifications issued is the same as that which

would have been awarded if the course had been followed entirely in the

Member State of origin of the award;

(c) whether the evidence of formal qualifications confers the same professional

rights in the territory of the Member State of origin of the award.

5. In cases of justified doubts, the host Member State may require from the competent

authorities of a Member State confirmation of the fact that the applicant is not suspended or

prohibited from the pursuit of the profession as a result of serious professional misconduct or

conviction of criminal offences relating to the pursuit of any of their professional activities.

6. Exchange of information between competent authorities of different Member States under

this Article shall take place through the Internal Market Information system (IMI) established

by Regulation (EU) 1024/2012 of the European Parliament and of the Council20.

7. Where a host Member State requires its nationals to swear a solemn oath or make a sworn

statement in order to gain access to a regulated profession, and where the wording of that oath

or statement cannot be used by nationals of the other Member States, the host Member State

shall ensure that the persons concerned can use an appropriate equivalent wording.

8. Member States shall accept the documents referred to in paragraph 1 in any of the official

languages of the Union.

Article 51

Procedure for the mutual recognition of professional qualifications

1. The competent authority in the host Member State shall examine an application for

authorisation to practise a regulated profession without undue delay and shall adopt a duly

substantiated decision within two weeks after the date on which the applicant is informed in

accordance with Article 56d(4) that the application is complete and no additional information

is required. That deadline may be extended by four weeks in cases falling under Chapters I

and II of this Title.

2. The decision of the competent authority, or failure to reach a decision within the period

laid down in paragraph 1, shall be subject to appeal under national law.';

(14) the following Article 51a is inserted:

'Article 51a

Fees and charges

20 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on

administrative cooperation through the Internal Market Information System and repealing Commission

Decision 2008/49/EC, OJ L 316, 14.11.2012, p.1, ELI: http://data.europa.eu/eli/reg/2012/1024/oj

EN 24 EN

1. A host Member State shall either waive fees for recognition procedures and compensation

measures or ensure that any fees charged do not exceed the actual costs incurred in providing

the service to applicants.

2. By way of derogation from paragraph 1, Member States may impose flat-rate charges if

they can be justified by the average cost of providing the service to applicants.

3. Any potential or actual damage claims or compensations that could be derived from the

non-respect of the deadlines laid down in Article 56d shall not be considered in the

calculation of costs of service or costs of processing applications.

4. Member States shall ensure that detailed information on the structure of the fee and

justification for any charges imposed as part of the recognition process is publicly available

and easily accessible.

5. Through IMI or another electronic interface that the Commission shall make available for

that purpose, each Member State shall notify the Commission of the fees charged for

recognition procedures and for compensation measures for each profession. Through the same

interface, each Member State shall notify any changes to these fees before these changes take

effect.';

(15) in Article 53(3), the second subparagraph is replaced by the following:

'Controls may be carried out only after the recognition of a professional qualification.';

(16) in Article 56, paragraph 2 is replaced by the following:

'2. The competent authorities of the home and the host Member States shall exchange

information regarding disciplinary action or criminal sanctions taken or any other serious,

specific circumstances which are likely to have consequences for the pursuit of activities

under this Directive.

The competent authorities of the home Member State shall examine the veracity of the

circumstances and shall decide on the nature and scope of the investigations which need to be

carried out and shall inform the competent authorities of the host Member State of the

conclusions which the competent authorities of the home Member State draw from the

information available to them.';

(17) the following Articles 56b, 56c, 56d, 56e and 56f are inserted:

'Article 56b

European Digital Recognition Solution

1. The Commission shall establish and maintain a comprehensive European Digital

Recognition Solution ('the EDRS'), available in all official languages of the Union, which

shall provide a platform for the submission of declarations made in accordance with Article 7

and for applications for recognition of professional qualifications under Title III.

2. The EDRS shall provide the following functions:

(a) allow competent authorities to configure the evidence that a professional is

required to provide when applying for the recognition of professions notified

pursuant to Article 59(1), and the evidence that a professional must provide for

prior checks pursuant to Article 7(4);

(b) allow applicants to create, edit, withdraw, and monitor any declarations made

in accordance with Article 7 or any applications for recognition under Title III;

EN 25 EN

(c) allow applicants to provide all required supporting evidence from a range of

sources and in various formats, including scanned paper documents, electronic

attestations of attributes stored in a European Digital Identity Wallet in

accordance with Regulation (EU) No 910/2014 of the European Parliament and

of the Council21, and documents requested through the technical system for the

cross-border automated exchange of evidence established under Regulation

(EU) 2018/1724 of the European Parliament and of the Council;

(d) perform an initial automated assessment of the completeness of the application

and accompanying supporting evidence before the applicant submits the

declaration or application;

(e) make applications and declarations with supporting evidence accessible to the

host Member State;

(f) acknowledge receipt of the application to the applicant.

For the purposes of the first subparagraph, point (a), the solution shall allow

competent authorities to configure the required supporting evidence for each

procedure type and profession. It shall also ensure that, for applications under Title

III, the required evidence does not exceed that set out in Article 50 read in

conjunction with Annex VII, and that, for the declarations made in accordance with

Article 7, the required evidence does not exceed that specified in that Article.

3. The EDRS shall build on and interoperate with IMI. It shall allow direct use of the

functionality of IMI for secure communication between competent authorities, and it shall

facilitate secure communication of competent authorities with the applicant.

4. In the development and operation of EDRS the Commission shall ensure that it is designed

to support competent authorities in their work to assess applications and to take decisions on

recognition, including through machine translation of documents, and to support the

verification of authenticity of evidence.

5. The EDRS shall ensure that the applicant is informed without undue delay of the

completion of each stage of the procedure, and of any compensation that is due in accordance

with Article 56d.

6. The Commission shall publish on its website the formats and standards the EDRS uses for

the issuance, in the form of digital qualification attestations, of recognition decisions taken by

Member States.

Article 56c

Digital processing of applications

1. Member States shall ensure that declarations made under Article 7 and requests for

recognition under Title III are submitted through EDRS.

In cases where the applicant is not able to use EDRS, Member States shall provide the

applicant with the option to submit declarations and applications in non-electronic format. In

such exceptional circumstances, the Member State shall upload without undue delay the

submitted information into EDRS, ensuring all submissions are processed within this EDRS,

21 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on

electronic identification and trust services for electronic transactions in the internal market and

repealing Directive 1999/93/EC, OJ L 257, 28.8.2014, p. 73, ELI:

http://data.europa.eu/eli/reg/2014/910/oj

EN 26 EN

and regularly informing the applicant on the progress of the processing of the application or

declaration.

2. Competent authorities shall use IMI and EDRS to exchange information that is needed for

the processing of applications and declarations with the competent authorities of other

Member States or with applicants.

3. Member States shall ensure that any official communication to applicants is made in all

official languages of that Member State that are also official languages of the Union, and at

least one other official language of the Union. Member States shall ensure that any official

communication to applicants, such as acknowledgement of receipts, decisions and any other

information related to the procedure, shall be transmitted through EDRS.

Article 56d

Procedure for the digital processing of applications

1. Competent authorities of the host Member State shall assess the completeness of the

application and of the evidence provided and inform the applicant through EDRS of any

missing documents no later than one week after submission of the application or declaration.

2. Competent authorities of the host Member State shall communicate to the home Member

State any justified doubts they have on the supporting evidence issued by that Member State

and identify any need for information or attestations to be provided by that Member State.

To this end, no later than one week after the submission of the complete file of the application

or declaration, the host Member State shall request the home Member State to provide

through EDRS the required information, confirmation or attestations needed to proceed with

the application or to dispel any justified doubts.

3. Competent authorities of the home Member State shall provide any evidence or attestations

that are requested through EDRS within two weeks. For procedures under Article 7(4), and

Chapters I and II of Title III, this period may be extended by two additional weeks upon

request of the home Member State.

4. After having access to the complete file, and having received, if required, any other

supporting evidence in accordance with paragraphs (1) to (3), the host Member State shall

without undue delay inform the applicant through EDRS that the application file for

recognition made in accordance with Title III or the declaration made in accordance with

Article 7(4) is complete and no additional information is required from the applicant or the

home Member State to process the application or to perform the required prior checks.

5. For declarations made under Article 7, with the exception of those requiring a prior check

pursuant to paragraph 4 of that Article, the host Member State shall inform the applicant via

EDRS without undue delay after receipt of the declaration that the execution of services in its

territory may start immediately.

6. In relation to procedures under Title III and to the outcome of prior checks carried out in

accordance with Article 7(4), point (b), the final decision taken by the host Member State

shall be issued in the form of a digital qualification attestation through EDRS.

EN 27 EN

Article 56e

Non-respect of deadlines

1. If the home Member State exceeds the deadlines set out in Article 21(1) or Article 56d(3)

by more than five calendar days, it shall ensure that applicants are entitled to claim and

receive compensation for the delay. The compensation shall take the form of a lump sum for

each day of non-respect of the deadline, starting on the first day after the expiry of the

relevant deadline and ending on the date the home Member State treated all open requests for

evidence or attestations related to the application.

2. If the host Member State exceeds the deadlines set out in Article 51 or Article 56d by more

than ten calendar days, it shall ensure that applicants are entitled to claim and receive

compensation for the delay. The compensation shall take the form of a lump sum for each day

of non-respect of the deadline, starting on the first day after the expiry of the relevant deadline

and ending on the date of receipt of the final decision by the applicant. No compensation shall

accrue in respect to any period between a request made by the host Member State and the date

on which the home Member State or, under Title Va, the third country issuing the

qualification provides the evidence or the attestations requested. Such periods shall be taken

into account for the purposes of paragraph 1.

3. Member States may set a maximum amount for the total compensation payable under

paragraphs 1 and 2 expressed as a specific number of daily lump sum compensations.

4. At the request of the applicant and without prejudice to paragraph 5, Member States shall

pay the compensation referred to in paragraphs 1 and 2 as soon as the recognition procedure

or the processing of the declaration is completed.

5. Member States shall ensure that applicants have the right to seek, in accordance with

national law, compensation in respect of any damage or loss suffered exceeding the lump sum

compensation due to the non-respect of deadlines by that Member State.

Article 56f

Processing of personal data

1. Processing of personal data through the EDRS shall be carried out only to the extent that is

necessary for for carrying out tasks laid down in paragraphs 3, 4, 5 and 6.

2. Each Member State shall designate one or more competent authorities responsible for

operating its connection to the EDRS.

3. Where the competent authorities of the home and host Member States exchange personal

data through the EDRS for the purposes of this Directive, they shall act as joint controllers,

within the meaning of Article 26 of Regulation (EU) 2016/679 of the European Parliament

and of the Council22, solely in respect of the cross-border processing operations that are

strictly necessary for that exchange, including the transmission, routing, receipt, consultation

and technical provision of the personal data concerned through the EDRS, as well as the

management of related access rights, logging, security measures and incident handling.

22 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data and on the free movement of

such data, OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj

EN 28 EN

4. The Commission shall act as a processor, within the meaning of Article 3, point (12), of

Regulation (EU) 2018/1725 of the European Parliament and of the Council23, on behalf of the

joint controllers referred to in paragraph 3 of this Article, for the processing of personal data

carried out through the EDRS. In that capacity, it shall provide, technically maintain and

operate the solution, and ensure its interoperability, security, and supervision in accordance

with this Directive. The processing operations carried out by the Commission on behalf of the

joint controllers and the respective responsibilities of the Commission and those joint

controllers shall be governed by arrangements concluded in accordance with Article 29(3) of

Regulation (EU) 2018/1725 and, where applicable, Article 28(3) of Regulation (EU)

2016/679. This paragraph is without prejudice to the responsibilities of the competent

authorities of the Member States, acting as controllers or joint controllers, for processing

operations falling within their respective competence under this Directive.

5. The competent authority of the host Member State shall be the controller, within the

meaning of Article 4, point (7), of Regulation (EU) 2016/679 for the processing of personal

data necessary for the following:

(a) the handling of applications for recognition of professional qualifications;

(b) the assessment of applications, including the verification of supporting

information;

(c) the adoption of decisions and the management of redress procedures;

(d) the handling of personal data related to declarations for provision of services.

6. The competent authority of the home Member State shall be the controller, within the

meaning of Article 4 point (7), of Regulation (EU) 2016/679 for the processing of personal

data necessary for the following:

(a) verifying qualifications or confirming the authenticity of documents;

(b) providing supporting information or documents to the applicant or to the host

Member State;

(c) responding to requests for information made by the applicant and/or the host

Member State, pursuant to this Directive.

7. Where the processing of personal data by the competent authorities of the host or the home

Member State involves automated individual decision-making concerning the applicant,

including profiling, within the meaning of Article 22 of Regulation (EU) 2016/679 of the

European Parliament and of the Council, Member States shall ensure appropriate safeguards

ensuring that decisions affecting the recognition of professional qualifications are taken in a

lawful, fair and transparent manner. These safeguards shall at least include:

(a) the right of the data subject (applicant) to obtain meaningful information on the

use of automated processing in the examination of the application;

(b) the right of the data subject (applicant) to request that the decision be reviewed

by a natural person competent to assess the application;

(c) the right of the data subject (applicant) to express his or her point of view and

to submit observations or additional evidence;

23 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

protection of natural persons with regard to the processing of personal data by the Union institutions,

bodies, offices and agencies and on the free movement of such data, OJ L 295, 21.11.2018, p. 39, ELI:

http://data.europa.eu/eli/reg/2018/1725/oj

EN 29 EN

(d) the right of the data subject (applicant) to contest the decision by means of the

remedies available under national law.

8. Access to personal data processed pursuant to this Directive shall be limited to:

(a) the Commission, to the extent necessary for the operation, maintenance,

security and supervision of the solution;

(b) the competent authorities of the host and home Member States, to the extent

necessary for the performance of their tasks under paragraphs 3, 5 and 6 of this

Article.

9. Personal data shall be shared between the Commission and the competent authorities of the

Member States, or between the competent authorities of the host and home Member States,

only to the extent necessary for the purposes of paragraphs 3, 5 and 6 of this Article. Such

sharing shall not affect the responsibility of each controller for the processing operations

falling within its competence.

10. Each controller referred to in paragraphs 5 and 6 shall determine, within the limits of

applicable Union and national law, the retention periods for personal data applicable to the

processing operations for which it is responsible. Those periods shall be proportionate and

limited to what is necessary for the purposes of processing. The Commission shall ensure the

automatic deletion, 36 months after the completion of the recognition procedure, of the record

of that procedure and of the documents used therein from the solution, without affecting the

availability of those documents through the technical system for the cross-border automated

exchange of evidence established under Regulation (EU) 2018/1724 of the European

Parliament and of the Council, for their subsequent reuse.

11. The Commission and the competent authorities of the Member States shall cooperate,

within the scope of their respective responsibilities, to ensure the secure and lawful processing

of personal data under this Directive, including as regards:

(a) access management and logging;

(b) incident handling and personal data breach notification;

(c) data quality and accuracy;

(d) the handling of requests from data subjects and supervisory authorities.';

(18) in Article 57(1), point (b) is deleted;

(19) Article 57a is deleted;

(20) Article 57c is amended as follows:

(a) paragraph 2 is replaced by the following:

'2. The power to adopt delegated acts referred to in the third subparagraph of Article

3(2), Article 20, the second subparagraph of Article 21(6), Article 21a(4), Article

25(5), Article 25(6), the second paragraph of Article 26, the second subparagraph of

Article 31(2), the second subparagraph of Article 34(2), Article 35(4) and (5), the

second subparagraph of Article 38(1), the third subparagraph of Article 40(1), the

second subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) shall be

conferred on the Commission for a period of five years from 17 January 2014. The

Commission shall draw up a report in respect of the delegation of power not later than

nine months before the end of the five-year period. The delegation of power shall be

tacitly extended for periods of an identical duration, unless the European Parliament or

EN 30 EN

the Council opposes such extension not later than three months before the end of each

period.';

(b) paragraph 3 is replaced by the following:

'3. The power to adopt delegated acts referred to in the third subparagraph of Article

3(2), Article 20, the second subparagraph of Article 21(6), Article 21a(4), Article

25(5), Article 25(6), the second paragraph of Article 26, the second subparagraph of

Article 31(2), the second subparagraph of Article 34(2), Article 35(4) and (5), the

second subparagraph of Article 38(1), the third subparagraph of Article 40(1), the

second subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) may be

revoked at any time by the European Parliament or by the Council. A decision to

revoke shall put an end to the delegation of the power specified in that decision. It

shall take effect the day following the publication of the decision in the Official

Journal of the European Union or at a later date specified therein. It shall not affect

the validity of any delegated acts already in force.';

(c) paragraph 5 is replaced by the following:

'5. A delegated act adopted pursuant to the third subparagraph of Article 3(2), Article

20, the second subparagraph of Article 21(6), Article 21a(4), Article 25(5), Article

25(6), the second paragraph of Article 26, the second subparagraph of Article 31(2),

the second subparagraph of Article 34(2), Article 35(4) and (5), the second

subparagraph of Article 38(1), the third subparagraph of Article 40(1), the second

subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) shall enter into force

only if no objection has been expressed either by the European Parliament or the

Council within a period of two months of notification of that act to the European

Parliament and the Council or if, before the expiry of that period, the European

Parliament and the Council have both informed the Commission that they will not

object. That period shall be extended by two months at the initiative of the European

Parliament or of the Council.';

(21) Article 59 is replaced by the following:

'Article 59

Transparency

1. Member States shall notify to the Commission a list of existing regulated professions,

specifying the activities covered by each profession, and a list of regulated education and

training, and training with a special structure, referred to in Article 11, point (c)(ii), in their

territory. Any change to those lists shall also be notified to the Commission via IMI before its

entry into force. The Commission shall set up and maintain a publicly available database of

regulated professions, including a general description of activities covered by each profession.

2. By 18 January 2016, Member States shall notify to the Commission the list of professions

for which a prior check of qualifications is necessary under Article 7(4). Member States shall

provide the Commission with a specific justification for the inclusion of each of those

professions on that list. Member States shall notify any changes to that list to the Commission

via IMI.

3. Member States shall examine whether requirements under their legal system restricting the

access to a profession or its pursuit to the holders of a specific professional qualification,

including the use of professional titles and the professional activities allowed under such title,

are compatible with the following principles:

EN 31 EN

(a) they shall not directly nor indirectly discriminate on the basis of nationality or

residence;

(b) they shall be justified by overriding reasons of general interest;

(c) they shall be suitable for securing the attainment of the objective pursued and

shall not go beyond what is necessary to attain that objective.

4. Paragraph 1 of this Article shall also apply to professions regulated in a Member State by

an association or organisation within the meaning of Article 3(2) and any requirements for

membership of those associations or organisations.

5. Before introducing any new requirements referred to in paragraph 3, Member States shall

inform the Commission and shall indicate the reasons for considering that those requirements

comply with points (a), (b) and (c) of that paragraph.';

(22) the following Title Va is inserted:

'TITLE Va

RECOGNITION OF QUALIFICATIONS OBTAINED IN A THIRD COUNTRY

Article 59a

Applicable provisions

1. Member States shall establish procedures for the recognition of professional qualifications

obtained in a third country. For that purpose, Chapter 2 of Title II, Article 11, Article 27,

Article 29(1) and (3) to (5), Article 30(1), Article 31, Article 32(1), (2), (4) and (7) to (10) and

Article 37 of [Directive xxxx/xxx/EU on the recognition of qualifications of third-country

nationals 24] shall apply mutatis mutandis.

2. For the purposes of this Title, Article 3(1) point (c) of this Directive shall be understood as

referring to diplomas, certificates and other evidence, issued by an authority in a third country

designated pursuant to legislative, regulatory or administrative provisions of that third

country, certifying successful completion of professional training.

3. For the purposes of paragraph 1 of this Article, Title III of this Directive shall not apply,

except Article 52(1) and (2), as provided in paragraph 4 of this Article.

4. For the purposes of paragraph 1 of this Article, Article 52(1) and (2), Title IV and Title V

of this Directive shall apply mutatis mutandis to the recognition of professional qualifications

obtained in a third country , with the exception of Article 55a.

Article 59b

Minimum training requirements for certain professions

Where Articles 24, 25, 28, 31, 34, 35, 38, 40 and 44 of this Directive set out minimum

conditions on the training for certain professions, the recognition of professional

qualifications under this Title shall be contingent upon fulfilment of those minimum

conditions.

Article 59c

Use of services for the assessment of authenticity

24 […]

EN 32 EN

For the purposes of assessing an application within the scope of this Directive, the competent

authority of a Member State may request from the Commission to assess the authenticity of

qualifications, diplomas, certificates or other evidence of formal qualifications issued in a

third country, pursuant to Article 28 of [Directive xxxx/xxx/EU on the recognition of

qualifications of third-country nationals].';

(23) Article 60 is replaced by the following:

'Article 60

Evaluation, statistics and reporting

1. From [the date falling 4 years after the adoption of this Directive] Member States shall,

every two years, send a report to the Commission on the application of the system. The report

shall contain general observations and a description of the main problems arising from the

application of this Directive.

2. The Commission shall, every year, provide the Group of Coordinators established under

Commission Decision 2007/172/EC with a statistical summary of the processing of

applications through the solution referred to in Article 56b. This summary shall include the

number of decisions taken, broken down by Member State, by profession, by type of

procedure and by outcome, as well as statistics on processing times and delays. This statistical

summary shall not include any personal data.

3. Every five years from [the date falling 8 years after the adoption of this Directive] the

Commission shall publish a report on the implementation of this Directive.

4. With a view to evaluating the functioning of EDRS referred to in Article 56b of this

Directive, the first report published in accordance with paragraph 3 of this Article shall carry

out an evaluation of this Directive. The Commission shall present a report on the main

findings of that evaluation to the European Parliament, the Council, the European Economic

and Social Committee and the Committee of the Regions regarding the use of digital tools, the

reduction of administrative burden and costs, the availability of relevant information to

applicants, and the duration of recognition procedures.

5. Member States shall provide all the necessary information for the preparation of the reports

referred to in paragraph 3 and 4.';

(24) the following Article 60a is inserted:

'Article 60a

Cooperation between the Commission and the Member States

1. The Commission shall cooperate with the Group of Coordinators established under

Decision 2007/172/EC25, on matters related to the implementation of this Directive with a

view to sharing best practices, identifying the need for guidance and promoting convergence

among Member States.

2. The Commission shall adopt an annual work programme for the Group of Coordinators. It

shall make that work programme, together with the relevant preparatory documents, publicly

available.

25 Commission Decision 2007/172/EC of 19 March 2007 setting up the group of coordinators for the

recognition of professional qualifications, OJ L 79, 20.3.2007, pp. 38–39 (BG, ES, CS, DA, DE, ET,

EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, RO, SK, SL, FI, SV), OJ L 219M, 24.8.2007, pp. 367–368

(MT), ELI: http://data.europa.eu/eli/dec/2007/172/oj

EN 33 EN

3. The annual work programme shall include:

(a) priority topics and issues to be addressed;

(b) appropriate tools and methods to be applied;

(c) expected outputs and deliverables, including those deriving from potential

work on common training frameworks in accordance with Article 49a, together

with indicative timelines, where appropriate;

(d) the subgroups to be established, maintained or discontinued, together with their

mandates.

4. The Commission shall submit the draft annual work programme to the Group of

Coordinators for endorsement no later than at the final meeting of the preceding year.

5. The Group of Coordinators shall establish a subgroup for the digitalisation of recognition

procedures. The subgroup’s tasks shall be the following:

(a) to establish cooperation between Member States’ authorities and the

Commission on questions relating to the digitalisation of procedures for the

recognition of professional qualifications;

(b) to facilitate the implementation of Articles 56b(4), 56c to 56e of this Directive;

(c) to liaise with other relevant recognition networks and expert groups on

digitalisation, in particular the Digitalisation Group established on the basis of

[Regulation(EU)XXX establishing a framework for portability of skills and

qualifications and amending Regulation (EU) 2018/1724], to ensure synergies

are fully exploited.

6. The Commission may adopt work programmes for the subgroups of the Group of

Coordinators upon submitting the draft work programme for endorsement by the subgroup

concerned. It shall make those work programmes, together with the relevant preparatory

documents, publicly available.';

(25) Annex VII is amended in accordance with the Annex to this Directive.

Article 2

Amendment to Regulation (EU) No 1024/2012

Point 2 of the Annex to Regulation (EU) No 1024/2012 is replaced by the following:

‘2. Directive 2005/36/EC of the European Parliament and of the Council on the

recognition of professional qualifications: Article 8, Article 21a, Article 50, Article

51a(5), Article 56, Article 56a to 56f and Article 59(1), (2) and (5) and Article 60(1)

of Directive 2005/36/EC, and in Article 11(1) of Directive (EU) 2018/958.’

Article 3

Transposition

1. Member States shall bring into force the laws, regulations and administrative provisions

necessary to comply with this Directive by 2 years after entry into force at the latest. They

shall forthwith communicate to the Commission the text of those provisions.

EN 34 EN

When Member States adopt those provisions, they shall contain a reference to this Directive

or be accompanied by such a reference on the occasion of their official publication. Member

States shall determine how such reference is to be made.

2. Member States shall apply the measures referred to in paragraph 1:

(a) from 2 years after entry into force of this Directive as regards Article 1,

paragraphs 3(a)(i), 5, 12, 15, 18, 20 and 24;

(b) from [the date of application of Directive xxxx/xxx/EU on the recognition of

qualifications of third-country nationals] as regards Article 1, paragraphs 1, 2,

3(b), 4, 6, 9, 10, 22 and 25;

(c) from [3 years after entry into force] of this Directive as regards Article 1,

paragraphs 3(a)(ii), 7, 8, 11, 13, 14, 15, 16, 17, 19, 21, 23 and Art. 2.

3. Member States shall communicate to the Commission the text of the main provisions of

national law which they adopt in the field covered by this Directive.

Article 4

Entry into force

This Directive shall enter into force on the […] day following that of its publication in the

Official Journal of the European Union.

Article 5

Addressees

This Directive is addressed to the Member States.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ...................................................................................... 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 3

1.3.4. Indicators of performance ............................................................................................ 3

1.4. The proposal/initiative relates to: ................................................................................. 4

1.5. Grounds for the proposal/initiative .............................................................................. 4

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 4

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 4

1.5.3. Lessons learned from similar experiences in the past .................................................. 4

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 5

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 5

1.6. Duration of the proposal/initiative and of its financial impact .................................... 6

1.7. Method(s) of budget implementation planned ............................................................. 6

2. MANAGEMENT MEASURES................................................................................... 8

2.1. Monitoring and reporting rules .................................................................................... 8

2.2. Management and control system(s) ............................................................................. 8

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed .................. 8

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them............................................................................................................ 8

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ........................................... 8

2.3. Measures to prevent fraud and irregularities ................................................................ 9

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 10

EN 2 EN

3.2. Estimated financial impact of the proposal on appropriations ................................... 12

3.2.1. Summary of estimated impact on operational appropriations.................................... 12

3.2.1.1. Appropriations from voted budget ............................................................................. 12

3.2.1.2. Appropriations from external assigned revenues ....................................................... 17

3.2.2. Estimated output funded from operational appropriations......................................... 22

3.2.3. Summary of estimated impact on administrative appropriations ............................... 24

3.2.3.1. Appropriations from voted budget .............................................................................. 24

3.2.3.2. Appropriations from external assigned revenues ....................................................... 24

3.2.3.3. Total appropriations ................................................................................................... 24

3.2.4. Estimated requirements of human resources.............................................................. 25

3.2.4.1. Financed from voted budget....................................................................................... 25

3.2.4.2. Financed from external assigned revenues ................................................................ 26

3.2.4.3. Total requirements of human resources ..................................................................... 26

3.2.5. Overview of estimated impact on digital technology-related investments ................ 28

3.2.6. Compatibility with the current multiannual financial framework.............................. 28

3.2.7. Third-party contributions ........................................................................................... 28

3.3. Estimated impact on revenue ..................................................................................... 29

4. DIGITAL DIMENSIONS .......................................................................................... 29

4.1. Requirements of digital relevance .............................................................................. 30

4.2. Data ............................................................................................................................ 30

4.3. Digital solutions ......................................................................................................... 31

4.4. Interoperability assessment ........................................................................................ 31

4.5. Measures to support digital implementation .............................................................. 32

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Directive of the European Parliament and of the Council amending

Directive 2005/36/EC on the recognition of professional qualifications as regards the

digitalisation of recognition procedures and recognition of professional qualifications

issued outside the Union and Regulation (EU) No 1024/2012.

1.2. Policy area(s) concerned

People, society and social model, Free movement of persons, labour mobility

Freedom of establishment, freedom to provide services

Digitalisation of public administrations

1.3. Objective(s)

1.3.1. General objective(s)

Improve the functioning of the EU system for the recognition of professional

qualifications by amending Directive 2005/36/EC

1.3.2. Specific objective(s)

Improve the availability, completeness and reliability of information on recognition

requirements and procedures.

Simplify and accelerate recognition procedures.

Strengthen administrative cooperation between competent authorities.

These objectives will be pursued through the increased use of interoperable digital

tools and workflows, supporting more efficient, transparent and user-friendly

recognition processes across the Union.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.

Professionals seeking recognition of their qualifications will benefit from faster,

simpler and more predictable recognition procedures, improved access to

information on recognition requirements and procedures, and quicker access to

employment in another Member State.

Competent authorities will benefit from more efficient and interoperable digital

workflows, reduced administrative burden and costs, improved administrative

cooperation, and more consistent implementation of the Directive across the Union.

Employers will benefit from faster recruitment processes, shorter vacancy durations

and improved access to skilled workers, helping to address labour and skills

shortages.

The economy is expected to benefit from a better-functioning internal market for

professional services, supported by a common European digital recognition solution

that creates economies of scale, reduces implementation costs, facilitates a more

efficient allocation of skills across Member States, improves labour market matching

and productivity, and strengthens resilience and competitiveness.

EN 4 EN

Society is expected to benefit from enhanced labour mobility, improved employment

opportunities, greater upward career mobility and increased income security for

professionals exercising their profession in another Member State. By improving the

allocation of skills across the Union, the proposal will also help address labour and

skills shortages and reinforce the delivery of services in sectors of particular

importance to society, including healthcare and education.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

Progress towards the specific objectives will be monitored through the following

indicators:

Availability and quality of information for applicants:

Presence and completeness of the information required under the Directive on

national portals.

Consistency between information provided through national portals and the RegProf

database.

Share of incomplete or incorrectly prepared applications attributable to information

gaps.

User satisfaction with the clarity and accessibility of information provided on

recognition procedures.

Efficiency of recognition procedures:

Average processing time for recognition procedures.

Average number of documents, translations and certified copies requested per

application.

Administrative effort required by competent authorities to process applications.

Share of recognition decisions adopted within the deadlines laid down in the

Directive.

Administrative cooperation between competent authorities:

Average response time to requests for administrative cooperation.

Average number of information requests and confirmation exchanges required per

recognition case.

Satisfaction of competent authorities with the quality and usefulness of the

information received from their counterparts.

1.4. The proposal/initiative relates to:

✓a new action

a new action following a pilot project / preparatory action26

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

26 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 5 EN

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

The Commission will start developing and testing the European Digital Recognition

Solution during the transposition period. Member States will have to transpose the

Directive and initiate the necessary legal, administrative and technical preparations.

After the expiry of the transposition deadline, the European Digital Recognition

Solution should be operational and Member States should have completed the

implementation and technical preparations necessary to apply the revised recognition

framework.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante)

The initiative concerns the functioning of the internal market, an area of shared

competence. Since the recognition of professional qualifications inherently involves

cross-border interactions between competent authorities, including the exchange of

information, validation of qualifications and verification of documents, effective

action requires a common Union framework. Member States acting individually

cannot establish common operational rules, ensure reciprocity or prevent divergent

administrative practices. Likewise, the deployment of interoperable digital solutions

cannot be achieved through isolated national initiatives without creating

fragmentation, duplication and a lack of interoperability. Union action is therefore

necessary to improve the functioning of the existing framework, enhance

transparency and monitoring, strengthen administrative cooperation, and ensure that

professionals can effectively exercise their Treaty rights to free movement.

Expected generated EU added value (ex-post)

The proposal is expected to generate EU added value by improving the legal

framework for the recognition of professional qualifications across the Union and

supporting it with unified digital tools. It will increase legal certainty and the

consistency of implementation, reduce administrative burdens and compliance costs

for both competent authorities and applicants, and improve the efficiency and

transparency of cross-border recognition procedures. The common European digital

recognition solution will create significant economies of scale by replacing the need

for multiple parallel national solutions and facilitating interoperability across

Member States. The proposal will also strengthen monitoring and enforcement

through the availability of comparable Union-wide data, enabling the Commission

and Member States to identify implementation problems more effectively and

support the consistent application of Union law. Together, these benefits will

contribute to a better-functioning internal market, more efficient labour mobility and

a more effective exercise of the Treaty rights of citizens and professionals

1.5.3. Lessons learned from similar experiences in the past

The experience gained from the implementation of the 2013 revision of Directive

2005/36/EC demonstrates the benefits of introducing digital elements into

EN 6 EN

recognition procedures, while also highlighting the limitations of an approach based

primarily on voluntary and decentralised implementation. Although digital tools have

improved certain aspects of administrative cooperation and information exchange,

their uptake has been uneven across Member States and they have not resulted in a

scalable, end-to-end digital recognition process. These lessons point to the need for a

more integrated and interoperable approach based on a common digital workflow at

Union level, while preserving Member States' competence for decisions on the

recognition of professional qualifications.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

The proposal is compatible with the current Multiannual Financial Framework. The

development, deployment and operation of the European Digital Recognition

Solution will be financed from existing Union programmes and budgetary resources

dedicated to digital public administration and the functioning of the internal market,

without requiring the creation of new financial instruments.

The initiative creates important synergies with existing Union instruments and

policies. It builds on the European Digital Identity framework and the eIDAS

Regulation through the use of interoperable digital credentials and trusted electronic

exchanges. It is fully consistent with the Interoperable Europe framework, the Single

Digital Gateway and the Once-Only Technical System by promoting interoperable

public services, reducing repetitive requests for documents and enabling more

efficient cross-border administrative cooperation. It also complements the

digitalisation of qualifications under the Skills Portability Initiative, where the

digitalisation of qualifications (Action 1) facilitates recognition procedures, while the

European Digital Recognition Solution (Action 2) provides concrete large-scale use

cases that support the uptake of digital qualifications. Together, these initiatives

contribute to the broader objective of delivering interoperable, user-friendly and

efficient digital public services across the Union.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The preferred financing option is direct financing from the Union budget, as the

initiative requires the development, deployment and operation of a common

European Digital Recognition Solution that will be used across all Member States. A

centrally financed solution ensures economies of scale, avoids duplication of

development and maintenance costs, and guarantees interoperability and consistent

implementation across the Union.

Alternative approaches based on separate national developments or decentralised

financing would require multiple parallel investments, increase integration costs and

create risks of fragmentation and inconsistent implementation. Financing through

existing Union programmes and budgetary resources allows the initiative to build on

existing digital infrastructure and expertise while ensuring efficient use of Union

funds. Where appropriate, existing resources will be redeployed to support the

implementation of the initiative.

The current proposal does not entail additional resources as compared to the situation

in the 2021-2027 multiannual financial framework and it builds on the current staff

assigned to the implementation of Directive 2005/36/EC. From 2028 on, the costs

linked to the proposal will be borne by the EU Facility under Heading 1 of the 2028-

EN 7 EN

2034 multiannual financial framework, subject to its adoption and the EU annual

budgetary procedure.

EN 8 EN

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

–  in effect from [DD/MM]YYYY to [DD/MM]YYYY

–  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

✓unlimited duration

– Implementation with a start-up period from YYYY to YYYY,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned

✓Direct management by the Commission

– ✓ by its departments, including by its staff in the Union delegations;

–  by the executive agencies

Shared management with the Member States

Indirect management by entrusting budget implementation tasks to:

–  third countries or the bodies they have designated

–  international organisations and their agencies (to be specified)

–  the European Investment Bank and the European Investment Fund

–  bodies referred to in Articles 70 and 71 of the Financial Regulation

–  public law bodies

–  bodies governed by private law with a public service mission to the extent that they

are provided with adequate financial guarantees

–  bodies governed by the private law of a Member State that are entrusted with the

implementation of a public-private partnership and that are provided with adequate financial

guarantees

–  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on European Union, and

identified in the relevant basic act

– bodies established in a Member State, governed by the private law of a Member

State or Union law and eligible to be entrusted, in accordance with sector-specific rules, with

the implementation of Union funds or budgetary guarantees, to the extent that such bodies are

controlled by public law bodies or by bodies governed by private law with a public service

mission, and are provided with adequate financial guarantees in the form of joint and several

liability by the controlling bodies or equivalent financial guarantees and which may be, for

each action, limited to the maximum amount of the Union support.

Comments

EN 9 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

Monitoring of performance will focus on the extent to which the proposal succeeds

in improving the availability, completeness and reliability of information on

recognition requirements and procedures, simplifying and reducing the cost and

administrative burden of recognition procedures, and strengthening administrative

cooperation between competent authorities.

The Commission will carry out monitoring in cooperation with the national

coordinators and competent authorities in the Member States. Monitoring will rely

on Monitoring will rely on statistics generated by the digital recognition system,

collected annually by the Commission; biennial reporting by competent authorities,

consolidated by National Coordinators; biennial reviews and surveys conducted by

the Commission.

The monitoring framework will include indicators measuring the completeness and

consistency of information on recognition requirements and procedures, the share of

incomplete or incorrectly prepared applications attributable to information gaps, user

satisfaction with the clarity and accessibility of information, the average processing

time for recognition procedures, the average number of documents, translations and

certifications requested, the administrative effort required to process applications,

compliance with procedural deadlines, the average response time to requests for

administrative cooperation, the average number of information requests and

confirmation exchanges per recognition case, and competent authorities' satisfaction

with the quality and usefulness of the responses received.

A pre-implementation benchmark will be established through a first data collection

in 2028. The baseline year for monitoring will be 2029, when the benefits of the

initiative are expected to begin materialising following the deployment of the

European Digital Recognition Solution. The monitoring framework will provide the

evidence necessary to support the evaluation of the initiative approximately five

years after the expiry of the transposition deadline.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

Direct management, as per article 62.1(a) of the Financial Regulation, is the

preferred mode of implementation, as the actions will be carried out by the European

Commission, specifically Directorate-General for Employment, Social Affairs and

Inclusion (DG EMPL), which will ensure the coordination with Member States and

the various stakeholders.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The controls are part of the internal control system of DG EMPL. The new activities

will be subject to the same risk identification and mitigation approach.

EN 10 EN

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The controls are integrated into the internal control system of DG EMPL. The new

activities will generate negligeable additional control costs at DG level.

2.3. Measures to prevent fraud and irregularities

The Commission shall ensure that, when actions financed are implemented, the

financial interests of the Union are protected by the application of preventive

measures against fraud, corruption and any other illegal activities, by effective

checks and by the recovery of the amounts unduly paid and, if irregularities are

detected, by effective, proportional and dissuasive penalties. The Commission is

authorised to carry out checks and verifications in situ under this Decision, in

compliance Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996

concerning on-the-spot checks and inspections carried out by the Commission in

order to protect the European Communities financial interests against fraud and other

irregularities. If need be, investigations shall be carried out by the European Anti-

Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the

European Parliament and of the Council of 25 May 1999 concerning investigations

conducted by the European Anti-Fraud Office.

EN 11 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next Multiannual Financial

Framework. The source of financing and scope of Union financial commitment in the

post-2027 period remain subject to the outcome of interinstitutional negotiations on

the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

Under reserve of adoption of the Draft Budget 2027 for this budget line as proposed

by the Commission, the 2027 work programme a total of EUR 3.5 million has been

programmed under 07.020400: ESF+ - Employment and Social Innovation strand, in

order to support the business analysis, management of data quality, and IT

development of digital systems to support processes for the recognition of

professional qualifications, in particular EDRS.

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure

Contribution – to be determined at later stage for

EFTA, (potential) candidate countries and third

countries

Number

Diff./Non-

diff.27

from

EFTA

countries 28

from

candidate

countries

and

potential

candidates 29

From

other

third

countries

other assigned

revenue

To be determined after the adoption of the

MFF and in the context of the annual

budgetary procedure for the EU Facility –

Successor of 07 02 04 00 – ESF+ EaSI

strand

Diff./Non

-diff. YES/NO YES/NO YES/NO NO

07.020400: ESF+ - Employment and

Social Innovation strand

Diff./Non

-diff. YES/NO YES/NO YES/NO YES/NO

27 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 28 EFTA: European Free Trade Association. 29 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 12 EN

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

–  The proposal/initiative does not require the use of operational appropriations

–  The proposal/initiative requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework Number 1 - Economic, social and territorial cohesion, agriculture, rural and maritime

prosperity and security

DG: EMPL

Year Year Year Year Year Year Year

TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

Operational appropriations

Budget line – successor 07 02 04 Commitments (1a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (2a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Appropriations of an administrative nature financed from the envelope of specific programmes30

Budget line (3) n.a. n.a.n.a.n.a.n.a.n.a.n.a.n.a.

TOTAL appropriations Commitments =1a+1b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

for DG EMPL Payments =2a+2b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Total Heading 1 Year Year Year Year Year Year Year TOTAL

30 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

EN 13 EN

2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

MFF 2028-

2034

TOTAL operational

appropriations

Commitments (4)

p.m. p.m. p.m. p.m. p.m. p.m. p.m.

p.m.

Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from the

envelope for specific programmes

(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

TOTAL

appropriations

under HEADING 1

Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

• TOTAL

operational

appropriations (all

operational

headings)

Commitments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

• TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(all operational headings)

(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

TOTAL

appropriations

Under

Heading 1 to 3

Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

EN 14 EN

of the multiannual

financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

(Reference amount)

For 2027, the resource of the deployment of the system will come from EaSI. This initiative should be financed within the agreed envelope of the

programme.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

Heading of multiannual financial framework 4 ‘Administrative expenditure’31

DG:EMPL

Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

 Human resources 0.388 0.388 0.3880 0.3880 0.3880 0.388 0.388 2.716

 Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG

EMPL Appropriations 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

31 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 15 EN

TOTAL appropriations under HEADING 4 of

the multiannual financial framework

(Total

commitments =

Total payments) 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

EUR million (to three decimal places)

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

TOTAL

appropriations under

HEADINGS 1 to 4

Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indicate

objectives

and outputs

Year

2028

Year

2029

Year

2030

Year

2031

Enter as many years as necessary to show

the duration of the impact (see Section1.6) TOTAL

OUTPUTS

EN 16 EN

ò Type

32

Aver

age

cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost Total

No

Total

cost

SPECIFIC OBJECTIVE No

1 33

…

- Output p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

- Output

- Output

Subtotal for specific objective

No 1

SPECIFIC OBJECTIVE No 2 ...

- Output

Subtotal for specific objective

No 2

TOTALS p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

32 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 33 As described in Section 1.3.2. ‘Specific objective(s)’

EN 17 EN

3.2.3. Summary of estimated impact on administrative appropriations

–  The proposal/initiative does not require the use of appropriations of an

administrative nature

–  The proposal/initiative requires the use of appropriations of an administrative

nature, as explained below

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS

Year Year Year Year Year Year Year TOTAL

2028 -

2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

HEADING 4

Human resources 0.388 0.388 0.388 0.388 0.3880.3880.388 2.716

Other administrative expenditure 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal HEADING 4 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Other expenditure of an administrative nature

0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

3.2.4. Estimated requirements of human resources

–  The proposal/initiative does not require the use of human resources

–  The proposal/initiative requires the use of human resources, as explained

below

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs) 34

VOTED

APPROPRIATIONS

Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and

Commission’s Representation

Offices)

2 2 2 2 2 2 2

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (inFTEs)

20 02 01 (AC, END from the

‘global envelope’) 0 0 0 0 0 0 0

34 Please specify below the table how many FTEs within the number indicated are already assigned to the

management of the action and/or can be redeployed within your DG and what are your net needs.

EN 18 EN

20 02 03 (AC, AL, END and

JPD in the EU Delegations) 0 0 0 0 0 0 0

Admin. Support

line

• at

Headquarte

rs

0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU

Delegation

s

0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) -

Heading 4 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 4

0 0 0 0 0 0 0

TOTAL 2 2 2 2 2 2 2

Considering the overall strained situation in Heading 4, in terms of both staffing and the level of

appropriations, the human resources required will be met by staff from the DG who are already

assigned to the management of the action and/or have been redeployed within the DG or other

Commission services.

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 4

or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts

2 N/A N/A N/A

External staff

(CA, SNEs, INT)

0 N/A N/A N/A

Description of tasks to be carried out by:

Officials and temporary staff Tasks will include overseeing the development and ensuring the legal and

technical compliance of the European Digital Recognition Solution (EDRS);

coordinating the transition from existing EU recognition tools to the EDRS,

including the necessary adaptations required for a smooth replacement of

current systems in cooperation with Member States; establishing and managing

the monitoring and reporting framework, including the collection of statistics

and performance indicators; and ensuring the continuous review and evolution

of the system so that it remains fit for purpose and adapts to future legal,

technical and policy developments.

External staff N/A

EN 19 EN

3.2.5. Overview of estimated impact on digital technology-related investments

Compulsory: the best estimate of the digital technology-related investments entailed

by the proposal/initiative should be included in the table below.

Exceptionally, when required for the implementation of the proposal/initiative, the

appropriations under Heading 4 should be presented in the designated line.

The appropriations under Headings 1-3 should be reflected as “Policy IT expenditure

on operational programmes”. This expenditure refers to the operational budget to be

used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation

of the initiative and their associated investments (e.g. licences, studies, data storage

etc). The information provided in this table should be consistent with details

presented under Section 4 “Digital dimensions”.

TOTAL Digital

and IT

appropriations

Year Year Year Year Year Year Year TOTAL

MFF

2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

IT expenditure (corporate)

0 0 0 0 0 0 0 0

Subtotal

HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Policy IT expenditure on operational programmes

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Subtotal outside

HEADING 4 p.m.p.m.p.m.p.m.p.m.p.m.p.m.p.m.

TOTAL p.m.p.m.p.m.p.m.p.m.p.m.p.m.p.m.

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

–  can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF)

The proposal builds on the Commission’s proposal for the MFF 2028-2034, subject

to its adoption and to the EU annual budgetary procedure, and in particular on the

EU Facility under Heading 1.

–  requires use of the unallocated margin under the relevant heading of the MFF

and/or use of the special instruments as defined in the MFF Regulation

–  requires a revision of the MFF

3.2.7. Third-party contributions

The proposal/initiative:

EN 20 EN

–  does not provide for co-financing by third parties but might be interesting for

EEA EFTA countries or (potential) candidate countries

–  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year

Total 2028 2029 2030 2031 2032 2033 2034

Specify the co-

financing body

(EFTA,

(potential)

candidate

countries, third

countries

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL

appropriations

co-financed

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.3. Estimated impact on revenue

–  The proposal/initiative has no financial impact on revenue.

–  The proposal/initiative has the following financial impact:

–  on own resources

–  on other revenue

–  please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

Budget revenue line:

Appropriations

available for

the current

financial year

Impact of the proposal/initiative 35

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

N/A

Other remarks (e.g. method/formula used for calculating the impact on revenue or

any other information).

N/A

35 In the case of traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts,

i.e. gross amounts after deduction of 10 % for collection costs, as proposed in COM(2025)574.

EN 21 EN

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital solutions and-

or digital public services)

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 56b, 56c

and 56d

Development, operation and use of

the European Digital Recognition

Solution.

The Commission must develop and

operate a European Digital

Recognition Solution for declarations

under Article 7 and recognition

procedures under Title III. Key

functions include:

• procedure configuration by

competent authorities

• applicant creation-editing-

withdrawal-monitoring of

applications

• submission of supporting

evidence from multiple sources

and formats (including digital

European Commission:

develops and operates the

system

Home and Host competent

authorities (users)

Applicants professionals

(users)

Application

processing and

decision on

recognition

Data

Digital public services

Digital solutions

Process digitalisation or

automation

EN 22 EN

qualification attestation format)

• integration with SDG OOTS

for retrieval of evidences

• automated assessment of

completeness

• Notifications to applicant,

including immediate

acknowledgement of receipt

upon submission of the

application

• integration with IMI

• requests for missing evidence

• deadlines for home-host

authorities

• alternative evidence if home

authority delays

• secure communication with

applicants

• decision-making support for

authorities through machine

translation and authenticity

verification

• transparent status information

on application progress

• issuing final decisions as digital

qualification attestations.

EN 23 EN

Member States must:

• ensure all declarations and

recognition requests are

submitted through the system

• use only the system and its IMI

integration for inter-authority

exchanges

• send official communication to

applicants through the system

• offer applicants a language

choice

• allow non-electronic

submission only in justified

exceptional cases, with the

Member State entering the

information into the system.

Article 56f

Processing of personal data.

The article provides rules on the

processing of personal data processing

in the system, including: the purposes

of processing, the Commission as

processor for system management and

infrastructure security, host Member

State as controller for processing of

recognition applications and

declarations for provision of services,

home Member State as controller for

verifying qualifications, confirming

European Commission

Host Member State

Home Member State

Applicants-data subjects

System administrators.

Processing of

personal data

Data

Digital public services

Digital solutions

EN 24 EN

authenticity of documents, responding

to requests (supporting information,

documents) of the applicant or the host

Member State, transparency, training

and audits, obligation for the

Commission concerning the automatic

deletion after 36 months.

Article 60(1),

(1b)

Statistics and reporting from the

system.

The European Commission must

publish:

1. An annual statistical summary

to the Group of Coordinators

using information recorded in

the European Digital

Recognition Solution. This

statistical summary shall

include:

a. The number of decisions

taken, broken down

i. By Member State

ii. By profession

iii. By type of

recognition

procedure

iv. By outcome

(decision)

European Commission

Group of Coordinators

Member States indirectly, as

data providers through

system use.

Reporting of

recognition processes

statistics

Data

Digital solutions

EN 25 EN

b. The statistics on processing

times of applications and

delays

4.2. Data

High-level description of the data in scope

Type of data Reference to the requirement(s) Standard and-or specification (if applicable)

Digital qualification attestations of formal

qualification • Article 56b, 56c, 56d

• Article 56f

Electronic attestations of attributes as defined under

eIDAS Regulation and Commission Implementing

Regulation 2024/2979(EU), OOTS evidence

Non-digital evidences of formal qualification and

other supporting evidences (as listed in Annex VII) • Article 56b, 56c, 56d

• Article 56f

Annex VII

Personal information accompanying declarations

under article 7 and recognition procedures • Article 56b, 56c, 56d

• Article 56f

n/a

Annual statistical summary of recognition

procedures (includes numbers of decisions,

breakdowns, outcomes, processing times and

delays)

• Article 60(1), (1b)

n/a

Alignment with the European Data Strategy

Explanation of how the requirement(s) are aligned with the European Data Strategy

EN 26 EN

In terms of compliance with the General Data Protection Regulation, the main roles and responsibilities related to personal data protection are

already set out in Article 56f.

No data is planned to be published as open data.

Alignment with the once-only principle

Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored

The use of the once-only technical system (OOTS) has already been envisaged for the retrieval of evidences of qualifications from competent

authorities in the Member States. Additionally, the use of the EUDI Wallet as an option for uploading evidence in the central European Digital

Recognition Solution facilitates the interoperable reuse by the citizen/professional of evidences already present in his/her wallet.

Additionally, the application of the once-only principle will continue to be supported – as is the case already today – by the use IMI for

cooperation between public administrations in the Member States. This cooperation helps public administrations avoid asking citizens for

additional documents, in the cases where such information can be retrieved from other public administrations via IMI.

Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

• Personal data (including professional qualifications or information within recognition procedures) is in general not supposed to be

findable or reusable.

• Interoperability of evidence on professional qualifications is guaranteed through the use of EUDI Wallets or OOTS evidences. Such

standard will ensure mutual understanding of qualifications between Member States. While these standards will not be used for all

evidence types, at least in an initial stage, the supporting system will be ready to adapt to new standardised evidences as soon as they

become available.

• Statistical data on recognition procedures and on the use of the EDRS system, as indicated in Article 60, will be published by the EC on

the public part of the RegProf database.

• It is worth mentioning that, as already happening today (i.e. no changes compared to current situation):

o Information on regulated professions, procedures, fees, and appeal routes will be findable and accessible by citizens on national

online sites (as mandated by article 57).

o Information on the list of regulated professions, including a general description of activities covered by each professional will

EN 27 EN

be findable and accessible by citizens on the publicly available database of regulated professions set up by the Commission (as

mandated by Article 59 (1)).

Data flows

High-level description of the data flows

Type of data Reference(s)

to the

requirement(s)

Actors who

provide the

data

Actors who

receive the data

Trigger for the

data exchange

Frequency (if

applicable)

Application information accompanying

declaration under article 7 and

recognition procedures

Development,

operation and

use of the

European

Digital

Recognition

Solution.

Processing of

personal data

Professional

(citizen)

Competent

authority in host

Member State

(via EDRS)

Submission of

declaration under

Article 7 on EDRS

by the professional

Once per

declaration

Digital qualification attestations of

formal qualifications

Development,

operation and

use of the

European

Digital

Recognition

Solution.

Digital

qualification

Professional

(citizen)

Competent

authority in host

Member State

(via EDRS)

Application

preparation for

recognition

procedure by

professional

Once per

application

EN 28 EN

attestations as

supporting

evidence.

Non-digital evidences of formal

qualifications and other supporting

evidences (as listed in Annex 7)

Development,

operation and

use of the

European

Digital

Recognition

Solution

Professional

(citizen)

Competent

authority in host

Member State

(via EDRS as

uploaded

attachments)

Application

preparation for

recognition

procedure by

professional

Annual statistical summary of

recognition procedures (includes

numbers of decisions, breakdowns,

outcomes, processing times and delays)

Statistics and

reporting from

the system.

European

Commission

Group of

Coordinators

Annually

4.3. Digital solutions

High-level description of digital solutions

Digital

solution

Reference(s)

to the

requirement(s)

Main mandated

functionalities

Responsible

body How is accessibility catered for?

How is

reusability

considered?

Use of AI

technologies

(if

applicable)

European

Digital

Recognition

Solution

(EDRS)

Article 56b

and 56c

Article 60(1),

(1b)

Key functions include:

• procedure

configuration by

competent

European

Commission

The EDRS shall be accessible for

persons with disabilities by

complying with the

relevant accessibility requirements

of the Web accessibility directive

The system will

be built on

existing (or in

the process of

being built)

An AI module

is foreseen to

support the

decision-

making in the

EN 29 EN

authorities

• applicant

creation-editing-

withdrawal-

monitoring of

applications

• submission of

supporting

evidence from

multiple sources

and formats

• integration with

SDG OOTS

• integration with

EUDI Wallets

• automated

completeness

assessment

(against

procedure

requirements) of

the application

prior to

submission

• Notifications to

applicant,

including

immediate

acknowledgeme

(Directive (EU) 2016/2102)

components,

including:

• the IMI

workflow

engine and

back-office

module for

competent

authorities

• the

upcoming IMI

front-office

for citizens

• the

existing

RegProf

database for

information

on regulated

professions

and

requirements

• the

EUDI

framework for

issuing and

presenting

digital

recognition

procedure.

Note: The AI

capabilities

will act as a

support, it will

not replace

human

oversight, the

decisions on

recognition,

including the

statement of

reasons,

should remain

the sole

responsibility

of the

competent

authorities

This will

include:

evidence

classification,

evidence

authenticity

and veracity

detection

(detection of

tampering,

forgeries,

EN 30 EN

nt of receipt

upon

submission of

the application

integration with

IMI for secure

message

exchange

between the

competent

authorities of

Member States

• requests for

missing

evidence

• deadlines for

home Member

State and host

Member State

competent

authorities

• Searches for

alternative

evidence by host

Member

competent

authority if

home Member

State’s

competent

qualification