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)

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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’

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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.

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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.

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• 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

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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

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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

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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

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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.

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• 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

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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.

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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

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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

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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

attestations

• the

OOTS system

for retrieving

evidences

from

competent

authorities

etc.),

translation,

matching of

evidence

against

national

procedure

requirements

(including

analysis of

substantial

difference in

training

requirements),

the

identification

of similar

previously

assessed cases

with a view to

promoting

consistency in

decision-

making

EN 31 EN

authority delays

in providing

requested

evidence

• secure

communication

with applicants

• support for

authorities

through

machine

translation,

completeness

assessment in

line with

national

requirements,

and authenticity

verification of

provided

evidence

• transparent

status

information on

the progress of

application

• issuing final

decisions as

digital

qualification

EN 32 EN

attestations.

• Statistical

reporting on the

implementation

of the directive

(including 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)

For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments

EDRS

Digital and-or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act The system will implement dedicated AI functionalities to process documents

submitted by applicants. These functionalities do not involve any of the practices

prohibited under Article 5 of Regulation (EU) 2024/1689. They are limited to

EN 33 EN

narrow procedural tasks, namely document classification and the detection of

tampering, and do not perform profiling of natural persons; all outcomes are subject

to human review and no decision affecting applicants is taken automatically by the

system. On that basis, the functionalities are not expected to be classified as high-

risk, in line with Article 6(3)(a) and (c) of the AI Act, and this assessment will be

documented as required before deployment. Compliance with the transparency

obligations under Article 50 will be verified at the design stage and the necessary

information provided to applicants where those obligations apply. Should the

functionalities rely on general-purpose AI models, these are expected to be made

available through the European Commission's corporate AI services, the related

obligations under Articles 53 to 55 resting with the provider of the model; the

applicable requirements will be verified accordingly.

EU Cybersecurity framework No specific cybersecurity requirements are mandated by the legislative proposal.

eIDAS Integration of the EDRS system with the EUDI Wallets ecosystem is foreseen, in

order to allow applicant to store digital qualification attestations of formal

qualifications in a format of electronic attestations of attributes. This also entails that

eIDAS-compliant authentication to the system will be required. EU Login will be

used for this purpose.

Additionally, the integration with the EUDI ecosystem is foreseen to allow the

EDRS system to issue the attestation of the final decision of the recognition process

as a digital credential in the format of electronic attestations of attributes, directly to

the Wallet of the applicant.

Single Digital Gateway and IMI The EDRS will be built based on IMI (both for the citizen/applicant front-office

module and the back-office module for competent authorities), and it will be

integrated with IMI message exchange module.

Others • SPI Action 1: The action 1 of the Skills Portability Initiative will define the

format of the EUDI digital qualification attestations to be issued by

EN 34 EN

competent institutions in the Member States and uploaded by the citizen

during the recognition process. Synchronisation with action 1 is then crucial.

• ESCO: In order to improve interoperability, a mapping between the current

classification of professions in the RegProf database and the ESCO

classification is foreseen.

• Europass: Europasscould serve as both the starting point and the application

interface. Applicants could retrieve information already stored in Europass to

populate their application and prepare and submit their recognition request

directly through the platform.

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)

Other interoperability solution(s)

European Digital

qualification

recognition service

Service used by applicants and

competent authorities to manage

the overall recognition process.

Article 56b and 56c

Article 60(1), (1b)

n/a IMI, EUDI Wallets

Impact of the requirement(s) as per digital public service on cross-border interoperability

Digital recognition service

Assessment Measure(s) Potential remaining barriers (if applicable)

Alignment with existing digital and • The service will need to be aligned -

EN 35 EN

sectorial policies

Please list the applicable digital and

sectorial policies identified

with the eIDAS Regulation and its

implementing acts in order to support

retrieval and storage of digital

qualification attestations in the format

of electronic attestations of attributes

as set out in the Commission

Implementing Regulation (EU)

2024/2979.

• Provision included in the AI act will

also need to be reviewed and verified

during the design and implementation

phase of the service, and appropriate

measures and safeguards put in place

to ensure transparency, personal data

protection and the prevailing of

human oversight over AI

recommendations and outputs in the

recognition decision process

• The IMI regulation will also apply as

the system will be mainly based on

IMI components.

• SPI Action 1: Action 1 of the Skills

Portability Initiative will define the

format of the EUDI digital

qualification attestations to be issued

by competent institutions in the

Member States and uploaded by the

citizen during the recognition process.

Organisational measures for a • The service is run under the -

EN 36 EN

smooth cross-border digital public

services delivery

Please list the governance measures

foreseen

responsibility of the European

Commission, including its operations,

and leverages on the existing IMI

organisation and governance.

• The service will provide multilingual

support to make sure that it can be

smoothly used by applications and

administrations in all MSs.

• Article 56c mandates Member States

to ensure that all declarations and

requests for recognition are submitted

through the system (apart from

exceptional case).

Measures taken to ensure a shared

understanding of the data

Please list such measures

• Information on regulated professions

(included in the RegProf database,

part of IMI) will be standardised

across Member States and reused by

the EDRS. This measure will include

a mapping between the current

taxonomies used in RegProf to

classify professions and the ESCO

classification.

• Qualifications in digital qualification

attestations format will also be

standardised, in synergy with the

work being carried out by SPI action

1.

• Non-standard qualifications and other evidences

(e.g. manually scanned documents) might continue

to pose an interoperability problem. Complete

standardisation of all possible documentation (e.g.

in digital qualification attestation format),

including documents not strictly related to the

professional qualification process, is not realistic in

the short-term. However, all standardisation efforts

will be supported where necessary, and the service

will be adapted to support new digital evidence in

standard format.

Use of commonly agreed open • OOTS (once-only technical system)

EN 37 EN

technical specifications and

standards

Please list such measures

will be integrated and related

specifications (e.g. on evidence

format) used for interoperability.

• The EUDI framework, including

technical specifications and reference

standards, will be reused to support

digital qualification attestations for

professional qualifications and (where

possible) other documents. The SPI

action 1 will define the exact format

of the digital qualification attestations

for qualifications.

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) Commission

role

(if applicable)

Actors to be

involved

(if applicable)

Expected timeline

(if applicable)

Pilot project for the use of AI in

application assessment for the

applicant

The use of AI capabilities, such as a chatbot, is

being considered to support applicants during the

application preparation stage. This functionality

would assist applicants by answering questions

related to their application for the recognition of

professional qualifications or to a declaration

under Article 7 for the provision of services.

Where necessary, it would also direct applicants to

Commission

(EMPL.B5) and/

or contractor

Before end of

2026/Q1 2027

EN 38 EN

the relevant national assistance centres for further

support in resolving their queries. A pilot project

would be needed to assess this use case and

evaluate how it should function in practice.

Setting up of sub-groups to assist

in the work of the GoC (Group of

Coordinators)

In accordance with Article 5 (3) of Commission

decision of 19 March 2007 setting up the group of

coordinators for the recognition of professional

qualifications (2007/172/EC), subgroups could be

set up when the Commission’s representative

deems that the involvement of experts or

observers with specific competence on a subject

on the agenda of the Group of Coordinators is

necessary.

Support and

facilitation

Commission

Setting up working groups in

Member States for acceptance and

roll-out of EDRS

Working groups would need to be set up in the

Member States to coordinate the testing activities

during the delivery phases of the project

Support and

facilitation

Commission,

Member States

Data Protection Impact

Assessment (DPIA)

Under Regulation (EU) 2018/1725, a data

protection impact assessment (DPIA) is required

before processing where a type of processing is

likely to result in a high risk to the rights and

freedoms of natural persons, in particular when

using new technologies and taking into account

the nature, scope, context and purposes of the

processing.

In the context of EDRS, a DPIA would be

required due to the following reasons:

Controller Commission

(EMPL.B5,

EMPL.A4, DPC

of EMPL,

DPO), EDPS

(optional)

EN 39 EN

1. Systematic and extensive evaluation of

personal aspects based on automated

processing, including profiling, where

decisions are based on that processing and

those decisions produce legal effects

concerning the person or similarly

significantly affect them;

2. Use of new or innovative technologies;

3. Processing on a large scale of special

categories of data referred to in Article 10;

For EDRS, the special category of data under

Article 10 that would apply are for cases when:

a. The processing is necessary for the

purposes of carrying out the

obligations and exercising specific

rights of the controller or of the data

subject in the field of employment and

social security and social protection

law

b. The processing is necessary for

reasons of substantial public interest,

on the basis of Union law which shall

EN 40 EN

be proportionate to the aim pursued,

respect the essence of the right to data

protection

c. the processing is necessary for the

purposes of preventive or

occupational medicine, for the

assessment of the working capacity of

the employee, medical diagnosis, the

provision of health or social care or

treatment or the management of health

or social care systems and services on

the basis of Union law

d. the processing is pursuant to contract

with a health professional

e. the processing is necessary for reasons

of public interest in the area of public

health, such as protecting against

serious cross-border threats to health

or ensuring high standards of quality

and safety of healthcare and of

medicinal products or medical

devices, on the basis of Union law

4. Processing of personal data relating to criminal

convictions and offences referred to in Article 11

EN 41 EN

Contents of a DPIA:

According to Article 39 (7), the DPIA must

contain at least:

1. A systematic description of the envisaged

processing operations and the purposes of

the processing, including where applicable,

the legitimate interest pursued by the

controller

2. An assessment of the necessity and

proportionality of the processing

operations in relation to the purposes

3. An assessment of the risks to the rights and

freedoms of data subjects

4. The measures envisaged to address the

risks, including safeguards (e.g.,

encryption, pseudonymisation, incident

response procedures, logging and audit

trails, etc.) , security measures and

mechanisms to ensure the protection of

personal data and to demonstrate

compliance with this Regulation taking

into account the rights and legitimate

interests of data subjects and other persons

EN 42 EN

concerned.

EDPS prior consultation If the DPIA indicates that the processing would

result in a high risk in the absence of measures

taken to mitigate the risk, the controller

(Commission in the case of EDRS) must consult

the EDPS prior to processing. This is covered by

Article 40 of Regulation (EU) 2018/1725.

When consulting the European Data Protection

Supervisor, 1, the controller shall provide the

European Data Protection Supervisor with:

a. the respective responsibilities of the

controller, joint controllers (where

applicable) and processors involved in the

processing;

b. the purposes and means of the intended

processing;

c. the measures and safeguards provided to

protect the rights and freedoms of data

subjects pursuant to this Regulation;

d. the contact details of the data protection

officer;

Controller Commission

(EMPL.B5,

DPC of EMPL,

DPO), EDPS

EN 43 EN

e. the data protection impact assessment

provided;

f. any other information requested by the

European Data Protection Supervisor.

Accessibility assessment of the

digital platform • Ensure equal access and inclusion for use

of the tool by all individuals, including

persons with disabilities, thereby

supporting non-discrimination

• Improve overall usability and user

experience

• Identify potential accessibility issues at an

early stage

• Reduce operational, compliance and

reputational risks

• Ensure compatibility with relevant

assistive technologies, such as screen

readers, magnification software, voice

recognition tools, and keyboard-only

navigation.

Commission Before roll-out of

EDRS tool

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 992 final

2026/0274 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on portability of qualifications and skills and amending Regulation (EU) 2018/1724

("Skills Portabilty Act")

{SEC(2026) 992 final} - {SWD(2026) 992 final} - {SWD(2026) 993 final} -

{SWD(2026) 994 final}

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The free movement of workers is one of the fundamental freedoms enshrined in the Treaties,

underpinning the ability of Union citizens to pursue professional and economic activities

across the Union. The Charter of Fundamental Rights of the European Union 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. The freedom of movement is 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.

However, as the report by Enrico Letta highlighted, free movement of people has been and

remains the least developed of the four freedoms of the Single Market. One of the reasons is

the limited portability of qualifications and skills. Removing these barriers can facilitate

mobility in all directions, including for people who wish to return to their home regions and

put the qualifications, skills and experience acquired elsewhere to use there. This broader

perspective on mobility also reflects the Commission’s political commitment to the Right to

Stay: ensuring that people have genuine opportunities to build their future in the places they

call home, while preserving their freedom to move and return.

Imperfect information on the level and content of qualifications and skills obtained in other

Member States is a key driver of these limitations: the signalling value of such qualifications

is generally perceived as lower compared to national qualifications owing to the lack of

common data and technical standards and varying level of information available to describe

them. Another barrier to portability is the continued reliance on paper-based attestations of

qualifications. As technology advances, the risk of fraud increasingly undermines trust in

qualification attestations, especially non-national ones. As Member States are progressively

digitalising their qualifications, a coordinated approach with regard to digitalisation and the

use of digital wallets is required to ensure interoperability and reduce barriers for workers to

transmit and/or for employers to receive and read a digital qualification.

The Enrico Letta and Mario Draghi reports on the future of the Single Market and Europe’s

competitiveness stress the urgency of accelerating this digital transformation and removing

barriers that impede the Single Market’s dynamism. Indeed, the limited portability of

qualifications and skills leads to missed opportunities for workers, businesses and the

economy as a whole, as valuable skills remain under-used and undervalued.

Over‑qualification and under‑utilisation of skills are especially pronounced among mobile EU

workers and third‑country nationals. This is particularly damaging in a context of widespread

skilled labour shortages. Strategic sectors – ranging from healthcare and ICT to construction,

energy, transport and tourism – struggle to find the talent they need to master the green and

digital transitions, and these shortages are most acutely felt by SMEs. Moreover, persistent

skills shortages at regional and local levels are being further aggravated by the out-migration

of young people from already sparsely populated or depopulating areas. Conversely, return

mobility can benefit regions of origin when people bring back qualifications, professional

experience and knowledge acquired elsewhere in the Union. Making such mobility easier can

therefore also contribute to territorial cohesion and help regions benefit more fully from the

opportunities offered by the Single Market.

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The European Commission committed to putting forward a Skills Portability Initiative to

“ensure a skill acquired in one country is recognised in another”, in line with its political

guidelines and Communication of March 2025 on a Union of Skills.

The European Council Conclusions of 19 March 2026 have called for faster action, urging for

measures to “enhance free movement of workers by improving mutual recognition of

professional qualifications and strengthening the portability of qualifications and skills across

national borders, including through digitalisation and interoperability, on the basis of a

Commission proposal to be presented by autumn 2026.” On 24 April 2026, the European

institutions agreed on a 'One Europe, One Market' roadmap with a commitment for concrete

actions by the end of 2027, of which the Skills Portability Initiative is a priority deliverable

aiming to support Europe’s competitiveness and foster a more integrated Single Market.

The Skills Portability Initiative is part of the Fair Labour Mobility package1. It aims to

effectively safeguard the right to free movement, allowing workers to move where their

qualifications are most valued and empowering European businesses to recruit the skilled

labour force they need to remain competitive in the global economy. It can also facilitate

mobility back to regions of origin, by ensuring that qualifications and skills acquired

elsewhere are understood and recognised when people return.

This proposal aims to give workers, employers and national authorities across the EU access

to reliable and comparable information on qualifications and skills issued within the Union,

and to enable them to use interoperable and verifiable digital attestations of qualifications and

skills. In doing so, they will have access to simplified, effective and cost-efficient means to

carry, prove, read, understand and compare qualifications and skills obtained in another

Member State. In this way, it supports better matching of jobs and workers and helps reduce

under-utilisation of skills across the EU. In addition, more comparable information is

expected to promote fairness and quality jobs for EU mobile workers by ensuring their

qualifications are better understood and recognised whether they move to another Member

State or return to their country of origin..

The Skills Portability Initiative further includes a proposal for the revision of the Professional

Qualifications Directive and a proposal for a directive on the recognition of qualifications of

third country nationals.

• Consistency with existing policy provisions in the policy area

The proposal supports the freedom of movement of workers provided for in Article 45 TFEU

and Regulation (EU) No 492/2011. It also supports the objectives of simplifying

administrative procedures for individuals, businesses and national authorities: less red tape,

more trust, and better enforcement.

The proposal is fully consistent with the broader policy framework and builds on existing

European legislation, recommendations and tools.

The proposal is fully coherent with the EU's broader digitalisation agenda, including the EU

Digital Decade, the Single Market Strategy and the Interoperable Europe Act. With regard to

digital qualification attestations, it relies on the EU Digital Identity (EUDI) Wallet, as part of

the e-IDAS Regulation (Regulation (EU) No 910/2014), for qualifications up to ten years of

age, while it leverages the Single Digital Gateway and the Once Only Technical System for

older qualifications (in line with Regulation (EU) 2018/1724) to verify information before

issuing a digital qualification into the EUDI Wallet.

1 For more context, see CWP 2026 Commission work programme 2026 - European Commission,

https://commission.europa.eu/strategy-and-policy/strategy-documents/commission-work-

programme/commission-work-programme-2026_en

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The proposal reinforces the objectives of the European Qualifications Framework Council

Recommendation of 22 May 2017 to enhance the transparency, comparability and portability

of qualifications in Europe. It is also fully coherent with the Council Recommendation of 16

June 2022 on a common European approach to micro-credentials, which calls for micro-

credentials to be included in National Qualifications Frameworks, and to consider European

Qualifications Framework (EQF) principles, such as on learning outcomes and quality

assurance. The proposal builds on the Europass framework (Decision (EU) 2018/646), with

the Europass platform serving as the official platform for information on the EQF. This

platform contains information on qualifications and qualifications frameworks and

interconnects information on qualifications from National Qualifications Frameworks

registers and databases.

The proposal is fully consistent with the European classification on Skills, Competences,

Occupations and Qualifications (ESCO), which works as a dictionary of occupations and

skills on the labour market. Adding ESCO skills to learning outcomes has the potential to

further improve the transparency of qualifications when their information is made available

online and used in digital qualification attestations.

The proposal covers all professions – both regulated and non-regulated - and thus

complements the Professional Qualifications Directive (PQD) (2005/36/EC). The proposal is

also a critical enabler for the Skills Portability Initiative’s Action 2 on improving cross-border

recognition procedures under PQD for access to regulated professions, as the availability of

interoperable and verifiable digital qualification attestations will allow for faster and less

burdensome cross-border recognition processes under the PQD. In addition, the proposal also

eases barriers in non-regulated professions, for which recognition procedures are not legally

necessary, by making available comparable, reliable, interoperable and verifiable digitalised

information on qualifications.

The proposal is also consistent with Regulation (EU) No 492/2011 of 5 April 2011 on

freedom of movement for workers within the Union, laying down rules for employment, equal

treatment and workers’ families. More specifically, it supports the rights of any national of a

Member State to seek employment in another Member State in line with the relevant

regulations applicable to national workers and aims to remove barriers related to

qualifications and skills that may pose obstacles to the freedom of movement.

In addition, initiatives, such as European individual cybersecurity skills attestations proposed

under the Cybersecurity Act 2, are consistent and contribute to the objectives of the Skills

Portability Initiative.

• Consistency with other Union policies

The proposal is part of the Fair Labour Mobility Package which contains proposals to

guarantee fair workers’ rights, regardless of where they choose to live and work in Europe.

Next to the Skills Portability Proposals the Fair Labour Mobility Package includes a proposal

for a regulation establishing a European Social Security Pass and a proposal for a regulation

to strengthen the European Labour Authority (ELA).

It is a key deliverable of the “One Europe, One Market” roadmap to “strengthen the

portability of qualifications and skills across national borders, including through digitalisation

and interoperability”. It is in line with the simplification agenda of the European Commission

by aiming at faster, less burdensome, user centric and digital-by-default processes for workers

moving between Member States. It is also consistent with the EU Competitiveness Compass,

which identifies retaining and mobilising talent across the EU as key to boosting the Union’s

competitive standing, by ensuring that qualifications and skills acquired in one Member State

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are readily usable in another. It further contributes to the European Pillar of Social Rights,

notably its principles on fair access to employment and support for labour mobility, and the

Single Market Strategy, which aim to remove remaining barriers to companies and workers

operating across the EU.

The proposal is also consistent with the Union of Equality strategies, which highlighted the

fair portability and transparent recognition of qualifications and skills as a critical driver for

achieving true equal opportunity and non-discrimination across the Single Market.

Finally the proposal is in line with the obligations under the United Nations Convention on

the Rights of Persons with Disabilities and in particular Article 9 of that Convention, as well

as the requirement in Article 9(1) of Directive (EU) 2024/2841, under which digital

qualification attestations should be accessible for persons with disabilities.

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The proposal is based on Article 46 TFEU which provide the legal basis for adopting

measures to facilitate the free movement of workers. Pursuant to Article 46 TFEU, the

European Parliament and the Council are mandated to adopt the necessary measures to bring

about the freedom of movement for workers. This includes, inter alia, the systematic removal

of administrative and legislative obstacles hindering the search, application for, and take-up of

employment across Member States (Article 46(b) TFEU), as well as setting up appropriate

mechanism to bring offers of employment into touch with applications for employment and

facilitating the balance between supply and demand and level of employment in the various

regions and industries (Article 46(d) TFEU).

• Subsidiarity (for non-exclusive competence)

Barriers related to qualifications and skills are one factor hindering individuals to make full

use of their free movement rights and to work in another Member State. They have a negative

impact on the functioning of the Single Market by creating costs for businesses and

individuals and indirectly affecting the potential of labour mobility in addressing labour

shortages in the EU. Without improved information on qualifications and skills obtained in

other Member States and tools facilitating effectively the portability of such qualifications and

skills, businesses and workers face difficulties when considering opportunities across the EU.

Given the cross-border nature of these problems, effective solutions are best pursued at the

EU level to allow for interoperability across Member States instead of 27 different national

frameworks and systems that would create fragmentation, increase administrative burdens and

even worsen the challenges related to cross-border use and recognition of digital qualification

attestations.

The added value of ensuring availability of verifiable and interoperable digitalised

information on qualifications and skills obtained in the EU is that workers will be equipped

with digital qualification attestations that are easily accessible to them as holders of

qualifications and to their potential employers. In the case of regulated professions, in

accordance with Directive 2005/36/EC, they will also be accessible to the recognition

authorities in Member States. Employers will also have access to tools enabling better

understanding and comparison of qualifications issued in different Member States. A common

legal and technical framework underpinning the digitalisation of qualifications will allow

digital qualification attestations issued in another Member State to become more trustworthy

and easier to verify. Digital qualification attestations issued in a standardised manner will be

understood across the EU. This in turn can make job applications less cumbersome and

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facilitate smoother access to jobs in all Member States. Overall, the expected added value of

this action will be greater portability of qualifications and skills.

This Regulation does not harmonise the content of education and training, the organisations of

education and training systems or the conditions of access to professions. It regulates the

format, authenticity and verifiability of digital attestations of qualifications and conditions for

the provision of comparable information on qualifications awarded under national systems,

leaving the design of those systems and the substance of the qualifications to the Member

States.

The proposal will help sustain and further enhance the momentum in advancing European

digital policies and transforming the EU into a modern, resource-efficient and competitive

economy. An EU action will help accelerate the digitalisation of public services on cross-

border interoperability, contribute to a well-functioning, integrated digital single market,

ultimately benefitting European competitiveness. By building on and reinforcing key digital

EU initiatives - such as the Single Digital Gateway Regulation (SDGR), the Once Only

Technical System (OOTS), and the EUDI framework – an EU action will maximise the

impact of prior EU investments, being part of a coherent and cohesive EU digital landscape

that serves the interest of the EU and its Member States. EU-level action at this stage would

help ensure coordinated and interoperable solutions across Member States, while ensuring

alignment with existing EU initiatives. Acting now would also help maximise the benefits of

these initiatives and avoid additional costs and complexity that could arise from having to

align or replace divergent solutions at a later stage.

• Proportionality

The proposal is necessary and proportionate to the objective of facilitating the portability of

qualifications and skills between Member States, ensuring that they have a similar signalling

value across the Union, meaning that they provide a consistent and reliable indication of the

qualifications and skills held by an individual, regardless of the Member State in which they

were issued. It does so by establishing common rules on and standards for the digitalisation of

qualifications and the access to reliable and comparable information on qualifications and

skills issued in the EU. Without such common requirements, Member States would continue

to rely on paper-based or fragmented digital systems when issuing qualifications and

employers (and any other interested party) would continue to have difficulties in assessing the

authenticity of and understanding qualifications from other Member States.

This Regulation confers on a digital qualification attestation the same evidentiary value as

corresponding paper attestation and supports comparability of qualifications awarded under

national systems. It does not confer equivalence between qualifications, nor any right of

recognition of or access to a regulated profession, which continue to be governed by Directive

2005/36.

The proposal does not go beyond what is necessary to achieve the objectives of ensuring an

improved portability of qualifications and skills in the context of the freedom of movement of

workers. The objective of achieving a quick impact was carefully balanced against the

financial and administrative burden created for public administrations, the action focuses on

the most relevant segment of qualifications and takes a pragmatic approach to data fields

required. While newly issued qualifications would be digitalised into the EUDI Wallets by

default, recent qualifications, i.e. those issued in the past ten years, would be digitalised

without delay only on demand for the purpose of employment in another Member State.

Preparing the infrastructure for digitalisation of recent qualification attestations requires a

certain upfront investment but strongly reduces the recurring cost for issuance later on. Data

availability is expected to be high for this ten-year period since it coincides with the time after

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adoption of the EQF Recommendation in which archives tend to be digital already. 25 EU

Member States have their NQFs referenced to the EQF for ten years or more. Today, already

14 EU Member States share information on qualifications with the Europass platform. In

terms of policy impact, it allows a quick rollout for the younger cohorts who tend to change

jobs most frequently and are most likely to move to another EU country. This is also the age

group with still comparatively short work experience, for which qualifications generally

matter more in the recruitment process than for older cohorts. For qualifications obtained

more than 10 years ago, more time is given: for them, digital qualification attestations need to

be issued upon demand in a reasonable timeframe i.e. maximum two weeks. In addition, for

older qualifications, the information needs can be adapted so that Member States can provide

the necessary information, with many fields being optional. Overall, only minimum common

requirements are provided for digital qualification attestations. By relying on existing EU

frameworks, notably the EUDI framework and existing transparency tools such as the EQF,

the proposal employs a cost-effective strategy, minimising costs and optimising resources

efficiently.

• Choice of the instrument

Article 26(2) TFEU provides that the internal market comprises an area without internal

frontiers in which the free movement of goods, persons, services and capital is ensured. For

nationals of a Member State, in accordance with Article 45 TFEU, this includes a right to

accept offers of employment in a Member State other than the one in which they have

obtained their qualifications or skills. Article 46 TFEU lays down that directives or

regulations shall be issued in an ordinary legislative procedure to set out the measures

required to bring about freedom of movement for workers.

Given the cross-border nature of the problem and the need to prevent regulatory

fragmentation, a regulation is the most suitable, effective and proportionate legal instrument

to achieve the defined policy objectives, namely to establish a single framework and set of

standards for digital qualification attestations which are understood and trusted across the

Union. Having a unified and single set of rules and formats will enable digital qualification

attestations to represent qualifications that are comparable and verifiable in all Member

States, irrespective of their awarding origins. As a directly applicable act, it also ensures

uniform application across Member States and provides legal certainty and effectiveness. This

also aligns with the identified legal basis.

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 digitalisation of qualifications,

and therefore no ex-post evaluation or fitness check of such legislation exists. The Skills

Portability Act is a new initiative. It builds on existing tools such as the European

Qualifications Framework and the Europass Framework, which were subject of

evaluations2 in 2024.

2 COM/2024/135 final - Report from the Commission to the European Parliament and the Council on the

implementation and impact of 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 SWD(2024)142 - Commission Staff Working Document Executive

Summary of the Evaluation of the Council Recommendation of 22 May 2017 on the European

Qualifications Framework for lifelong learning

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The European Qualifications Framework was found to be well-suited to promote the

transparency, comparability and portability of qualifications across the EU. All 27 Member

States have referenced their National Qualifications Frameworks (NQFs) or systems to the

EQF. However, ensuring that National Qualifications Frameworks and databases and registers

of qualifications are updated and connected to the Europass platform is mentioned as an area

of improvement.

Europass was found to facilitate mobility for work and study in the EU, by presenting

knowledge, skills, and competences in a standardised format. However, the evaluation points

out that further efforts are needed in developing qualification and learning opportunity

databases and registers that should link to the Europass platform via the Qualification Dataset

Register.

• Stakeholder consultations

A comprehensive consultation took place to gather a broad and representative evidence base

on the portability of qualifications and skills across EU countries. The evidence collected

through these activities supported the problem definition and enabled the assessment of the

feasibility, suitability and potential impacts of selected policy measures.

This comprehensive evidence-gathering exercise included the following activities:

• An open public consultation was run between 5 December 2025 and 27 February

2026 resulting in 785 responses;

• A call for Evidence ran in parallel to the public consultation and 235 responses to the

call for evidence, including 126 position papers;

• Targeted consultations were conducted in the context of this initiative between

October 2025 and April 2026;

• A social partner hearing on 23 January 2026;

• A dedicated survey of SMEs was carried out during February and March of 2026

(159 responses);

• A survey of issuers of qualifications was conducted (574 replies);

• A total of 94 stakeholder interviews were carried out by an external study (covering

140 stakeholders);

• Discussions in focus groups (8 in total), including 88 participants;

• Expert workshops (4 in total), including 41 participants;

• A survey among National Academic Recognition Information Centres was carried

out in April 2026 (16 responses);

• A survey of the EQF Advisory Group (14 responses);

• A survey among EQF National Contact Points took place during March-April 2026

(21 responses);

• Legal reports from the MoveS network on free movement of workers (All 27

Member States covered);

• Eurofound reports on collective agreements in the Member States (20 Member States

covered).

These consultations revealed broad support for digitalisation of qualification attestations,

including a broad consensus on the use of the EUDI Wallets as the primary digital solution.

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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

An external contractor assisted the Commission in conducting a study to support the work on

the Impact Assessment between September 2025 and August 2026. An Inter-Service Steering

Group, comprising more than twenty Commission services including the Legal Service, met

three times to steer the preparation of the Skills Portability Initiative.

• Impact assessment

The proposal for a Regulation is accompanied by an impact assessment report3, a draft of

which was submitted to the Regulatory Scrutiny Board (RSB) on 17 June 2026.

Recommendations received from the RSB in its negative opinion of 15 July 2026 were

addressed, notably by removing the obligation to refer to EQF levels in labour market

contexts and the legal presumption of equivalence of qualifications of the same level, as at

this stage it is not possible to quantify the extent of barriers related to equivalence of

qualification levels in non-regulated professions. Moreover, the problem definition and

intervention logic have been reinforced by expanding the evidence base, integrating the

findings of the EQF and Europass evaluations, strengthening the analysis of labour market

failures and better substantiating the role of qualification portability in supporting worker

mobility. The dynamic baseline has been expanded to better reflect existing EU tools, ongoing

digital initiatives and technological developments, while the description of the policy

measures has been made more operational and implementation-oriented. Finally, the report

provides a stronger assessment of coherence with the other actions of the Skills Portability

Initiative and with relevant EU initiatives in the fields of skills, qualifications, digital identity

and interoperability, demonstrating more clearly how the preferred option builds on existing

EU frameworks and projects.

Following the aforementioned adjustments, the RSB issued a positive opinion with

reservations on 24 August 2026. To address the remaining reservations, the problems

identified in the impact assessment and the analysis of the impacts of the various options were

substantiated further. Both opinions of the RSB are available at [add link at publication].

Overall, the impact assessment considered several legislative Policy Options for the two

Specific Objectives, namely Specific Objective 1: By the end of the transition period, labour

market actors have access to reliable and comparable information on qualifications and skills

issued in the EU. Specific Objective 2: By the end of the transition period, labour market

actors in the EU can benefit from interoperable and verifiable digital attestations of

qualifications and skills.

The following policy options were assessed for the Specific Objectives:

• Policy Option 1: digitalisation with the EUDI Wallets of all new NQF qualifications

(EQF levels 2-8) and all other new skills documents. For past qualifications,

digitalisation with the EUDI Wallets upon request, within a reasonable timeframe

and limited for the purpose of employment in another Member State;

(3) SWD (2026) 993, IMPACT ASSESSMENT REPORT Accompanying the document PROPOSAL FOR

A REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL ON PORTABILITY

OF QUALIFICATIONS AND SKILLS AND AMENDING REGULATION (EU) 2018/1724

(“SKILLS PORTABILITY ACT”).

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• Policy Option 2: digitalisation with the EUDI Wallets of all new NQF qualifications

(EQF levels 2-8). For past qualifications, digitalisation with the EUDI Wallets upon

request and limited for the purpose of employment in another Member State. Those

qualifications awarded in the past 10 years to be issued without delay, and those

older than 10 years, within a reasonable timeframe;

• Policy Option 3: digitalisation with the Europass Wallet of all new NQF

qualifications (EQF levels 2-8) and all other new skills documents. For past

qualifications, digitalisation with the Europass Wallet upon request, within a

reasonable timeframe and limited for the purpose of employment in another Member

State.

All options include a common set of measures to support interoperability and trust. All

options include the same approach to NQFs and the EQF and make it mandatory for Member

States to have a comprehensive NQF in place, and for their NQFs to be clearly and regularly

referenced to the EQF. All options ensure the legal value of digital qualification attestations,

requirements to Member States to have up to date national databases of qualifications,

awarding bodies and accreditation, connected with Europass. All options ensure that the

Europass comparison tool is made more effective and user-friendly to facilitate the

comparison of specific national qualifications. All options share the same trust framework to

ensure verifiability and comparability of digital attestations by employers and other users. All

options are also accompanied by possible non-legislative supporting measures, including

awareness-raising activities, continued support to existing EU tools and encouragement to

make use of available EU funding.

The impact assessment resulted in the choice of the Policy Option 2 as the preferred way

forward to achieve the specific objectives 1 and 2 in an effective and efficient way.

Policy Option 2 is most effective in achieving comparable, reliable, interoperable and

verifiable digitalised information on qualifications and skills obtained in the EU. It ensures a

common information and technical standard for all new NQF qualifications and those issued

in the past 10 years, to facilitate comparison and verification. It is the option with the most

optimal efficiency balance, concentrating digitalisation where labour market impact is greatest

and ensuring that, as part of the NQF, the digitalised qualifications are quality assured by the

Member States.

Policy Option 2 supports also SPI Action 2 and facilitates in general the verification and

understanding of qualifications issued in the EU in the context of both regulated and non-

regulated professions. Together, they form a coherent and functional system for qualifications

and skills portability across the EU's labour market.

• Regulatory fitness and simplification

As shown in the consultation, employers do not understand qualifications from other Member

States well enough to assess what the holder truly knows or is able to do – i.e. the

qualification level and content 4. Confidence of SMEs falls significantly when assessing

qualifications from other EU countries, compared to from their own country. In the SME

Survey, the most frequently cited challenge when assessing qualifications from other EU

countries by SMEs, was insufficient familiarity with foreign education systems, difficulty

verifying the authenticity of qualifications and language barriers. Similarly, the Europass

evaluation5 pointed out that verifying the authenticity of a candidate’s qualifications is very

4 SPI Consultation Social Partners; Expert workshop: Recognition of VET qualifications for the purpose

of worker mobility. 5 EUR-Lex - 52024SC0071 - EN - EUR-Lex

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important for employers when hiring. At the same time, 59% of the employers consider the

process of verifying the authenticity of candidates’ qualifications or experience to be often or

sometimes difficult and slightly more than half of them (54%) consider receiving digitally

certified documents proving qualifications to be important.

This initiative aims to bring simplification for employers and workers by making

qualifications instantly verifiable for labour market actors across the Single Market, and by

facilitating the comparison of the level and content of qualifications issued in the EU without

any cost. It aims to do so by building on existing tools such as the European Qualifications

Framework, Europass and the European Digital Identity Wallet, and through setting common

standards for digital attestations of qualifications to be comparable, reliable, interoperable and

verifiable. This will facilitate recruitment procedures involving cross-border applications, and

make systems for issuing digital qualification attestations interoperable from the start through

a coordinated approach. The availability of the Europass platform centralising reliable and

comparable information will reduce the need for multiple efforts at Member State level to

make available and keep track of information on each others’ NQFs.

Moreover, the proposal contributes to the objectives of regulatory fitness and is consistent

with the ‘Digital check’. It fully aligns with core e-government principles:

i.) digital by default, promoting digital procedures as preferred choice, while still offering

alternative options,

ii.) once-only principle, reducing redundant data submission,

iii.) interoperability by design, facilitating cross-border recognition and verification of

documents as well as cross-border data exchange, and reducing fragmentation,

iv.) user-centricity, putting people at the centre and ensuring predictable processing times,

v.) inclusiveness and accessibility, guaranteeing equal access to all, notably persons with

disabilities, elderly people and individuals with limited digital skills by still offering the

option of paper documents,

vi.) trustworthiness and security, promoting the protection of personal data and high security

standards

vii.) cross-border by default, ensuring interoperability and reducing/preventing unnecessary

barriers to mobility.

• Fundamental rights

This proposal respects fundamental rights and the principles recognised by the Charter of

Fundamental Rights of the European Union including inter alia, the right to private and family

life, the right to protection of personal data, the freedom to conduct a business, the right to a

high level of human health protection, the right to good administration and the right to an

effective remedy.

The proposal is expected to have a positive impact on labour mobility and employment rights

(Articles 15 and 45 of the EU Charter), and reduced administrative barriers to portability of

qualifications, aligning with European Pillar of Social Rights Principle 4 (active employment

support).

The proposed Regulation includes the processing of personal data. It should therefore ensure

that such processing complies with the requirements of the General Data Protection

Regulation (GDPR) and the fundamental rights guaranteed in the Charter, notably the rights

to privacy and data protection under Articles 7 and 8, and in the TFEU, especially Article 16

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on the right to the protection of personal data. The preferred option is expected to ensure a

high-level of security and data protection by giving users control, minimising data exposure,

guaranteeing selective disclosure, and ensuring GDPR-compliant, secure, and transparent

handling of personal data when using EUDI Wallets and benefitting from legal safeguards

when relying on enhanced physical documents.

4. BUDGETARY IMPLICATIONS

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

development and improvement of a comparison tool in Europass (Article 8), the development

of a reference software for the digital verification tool (Recital 18; Article 7); the back office

tool to support the Member States sharing information on qualifications, accreditation and

awarding bodies with Europass (Articles 3 and 8); possible support to Member States in their

implementation of issuance system for the digital qualification attestations (Articles 3, 4, 6, 7,

8, 9); and the Secretariat of the Qualifications Digitalisation Group (Article 11).

The estimated budgetary impact for 2028 and beyond 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.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

A group on digitalisation of qualifications (the ‘Qualifications Digitalisation Group’) is

established to facilitate cross-border cooperation and exchange of information on issues

related to the implementation of this Regulations, notably trust services, European Digital

Identity Wallets, notified electronic identification schemes, semantic model and digital

qualification attestations, and to take all necessary steps to ensure that the information

exchanged is up-to-date. A committee within the meaning of Regulation (EU) No 182/2011

shall assist the Commission in the preparation of the implementing acts under an examination

procedure in accordance with Article 5 of that Regulation.

A draft monitoring framework has been designed to monitor the implementation and evaluate

the initiative’s impact, ensuring that it remains fit for purpose and achieve the intended

objectives. This framework will undergo further refinement based on the ultimate legal

specifications and implementation schedule. Progress will be tracked through a set of output,

result, and impact indicators linked to the operational objectives. The Commission, in close

cooperation with Member States, will regularly collect and analyse data - leveraging existing

reporting mechanisms - to identify implementation gaps, assess the efficiency of the measure,

and provide the necessary evidence base for a future evaluation.

• Detailed explanation of the specific provisions of the proposal

Article 1 defines the subject matter and sets out the rules that will be laid down for skills

portability, as well as which elements of governance will be addressed.

Article 2 sets out the definitions of the main concepts used in the proposed Regulation to

facilitate uniform interpretation and application.

Article 3 sets out the trust framework for digital qualification attestations, which should be

retrievable electronically by holders of qualifications. They are to be issued within European

Digital Identity Wallets as qualified electronic attestations of attributes or as electronic

attestations of attributes issued by or on behalf of a public sector body responsible for an

EN 12 EN

authentic source. The article also sets out that Member States shall communicate lists of the

awarding bodies, accreditations and qualifications included in their National Qualifications

Frameworks to the Commission. The article empowers the Commission to adopt

implementing acts laying down detailed provisions concerning the agreed common language;

formats and protocols for the issuance of digital qualification attestations across the Union;

and the formats of and transfer protocols for lists of awarding bodies, accreditations and

qualifications included in national qualifications frameworks in accordance with the

examination procedure referred to in Article 5 of Regulation (EU) No 182/2011.

Article 4 lays down that Member States shall issue digital qualification attestations, free of

charge for the holders. It also lays down the data requirements for digital qualification

attestations, the fact that they shall be recognised as evidencing qualification awarded to the

holders and be valid across the Union. It further specifies that digital qualification attestations

are issued as the default format for evidencing qualifications which are quality assured as a

part of a Member State’s national qualifications framework; and have been awarded after the

date of entry into force of this Regulation minus 10 years. Member States may limit the

issuance of digital qualification attestations for qualifications awarded during the last 10

years to the cases in which the qualification holder proves the purpose of pursuit of

employment in another Member State. Member States can also issue digital qualification

attestations before that reference date. It finally empowers the Commission to adopt delegated

acts to take account of technical, operational or scientific developments.

Article 5 sets out conditions for the issuance of digital qualification attestations. It states that

holders may request a digital qualification attestation for qualifications awarded to them,

which shall be issued to their European Digital Identity Wallets upon the qualification

holder’s request if the qualification comes from an accredited awarding body listed in the

relevant list and the holder has an active European Digital Identity Wallet.

Article 6 sets out the effects of revocation or suspension of a digital qualification attestation,

including the refusal of issuance where the underlying qualification is withdrawn or

suspended, the sharing of revocation information, and the non-recognition of revoked or

suspended attestations for as long as that status remains in place.

Article 7 sets out the framework for verification by relying parties. It requires Member States

to ensure that relying parties can verify digital qualification attestations, including

accreditations and the status of qualifications, while the Commission is to adopt formats and

procedures for verification by relying parties through implementing acts.

Article 8 sets out the requirement for Member States to provide information on qualifications,

awarding bodies and accreditations through the Europass platform. It sets out the

implementing acts the Commission shall adopt on common formats and protocols for

information transfer and delegated acts to take account of technical, operational or scientific

developments. The article also states that Member States shall ensure that their national

qualifications frameworks are referenced to the European Qualifications Framework and that

the referencing is updated when relevant. It further sets out that National Qualifications

Frameworks include all qualifications under a Member State’s jurisdiction, including micro-

credentials to the extent possible. Finally, it states that the Commission shall provide a digital

tool to compare qualifications in Europass.

Article 9 sets out how Member States are to issue, on request, digital qualification attestations

for older qualifications, on the basis of existing evidence verified by an issuer. It empowers

the Commission to adopt delegated acts to amend data fields in digital qualification

attestations. It includes a possibility for the Member States to limit the issuance of digital

EN 13 EN

qualification attestations for older qualifications to the cases in which the qualification holder

proves the purpose of pursuit of employment in another Member State.

Article 10 sets out that Member States shall provide publicly available information on the

implementation of the Regulation.

Article 11 sets out how the Qualifications Digitalisation Group will support and facilitate

Member States’ cross-border cooperation and exchange of information on trust services,

European Digital Identity Wallets, notified electronic identification schemes, semantic model

and digital qualification attestations.

Article 12 specifies the data protection requirements applicable to the processing of personal

data under this Regulation. It shall ensure that personal data processed in the context of this

Regulation shall be retained no longer than 45 years.

Article 13 contains rules on reporting and review. Depending on the outcomes of an

evaluation and review, the Commission shall, if necessary, submit appropriate proposals to

amend the provisions of this Regulation.

Article 14 determines the conditions under which the Commission is empowered to adopt

delegated acts.

Article 15 establishes a committee to assist the Commission in adopting implementing acts in

accordance with Regulation (EU) No 182/2011.

Article 16 specifies that this Regulation will amend Regulation (EU) 2018/1724 in order to

add information under its Annex I and, under its Annex II, a procedure on requesting proof of

qualification.

Article 17 specifies the entry into force [and entry into application] timeline[s].

EN 0 EN

2026/0274 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on portability of qualifications and skills and amending Regulation (EU) 2018/1724

("Skills Portabilty Act")

(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 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 Committee6,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) [POLITICAL CONTEXT] 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 qualifications and skills 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.

(2) [REG ON FREE MOVEMENT OF WORKERS] Regulation (EU) No 492/2011 of the

European Parliament and of the Council7 provides that any national of a Member

State, irrespective of his or her place of residence, has the right to take up an activity

as an employed person, and to pursue such activity, within the territory of another

Member State in accordance with the provisions laid down by law, regulation or

administrative action governing the employment of nationals of that State and with the

same priority as nationals of that State. Portability of qualifications and skills obtained

in another Member State is necessary for the effective exercise of those rights.

(3) [OBJECTIVE OF THIS REGULATION, Article 1] This Regulation aims

at facilitating portability of qualifications and skills for workers and

employers through improved availability of comparable, reliable, verifiable,

interoperable and digitalised information about qualifications and skills obtained in the

Union.

6 OJ C [...], [...], p. [...] 7 Regulation (EU) No 492/2011 of the European Parliament and of the Council of 5 April 2011 on

freedom of movement for workers within the Union (OJ L 141, 27.5.2011, p. 1, ELI: http://data.europa.eu/eli/reg/2011/492/oj).

EN 1 EN

(4) [REMAINING BARRIERS] Limited skills portability hinders the full exercise of the

freedom of movement of workers enshrined in the Treaty. Employers struggle to

understand the qualifications and skills acquired in another Member State and may

refrain from tapping into the potential pool of workers of the internal market. For

similar reasons, workers in the Union may be discouraged from seeking employment

in another Member State, or returning to their own Member State, when holding

qualifications obtained in another Member State. Improved portability may therefore

also facilitate return and circular mobility, enabling workers to put skills acquired

elsewhere in the Union to use in their Member State or region of origin. Moreover,

digitalisation of qualifications carried out by Member States individually would lead

to further fragmentation of the labour market. These barriers also adversely affect the

functioning of the internal market, restricting opportunities to address labour

shortages, including in strategic sectors, representing a loss of potential for both

workers and businesses and hampering delivery of critical services, as valuable skills

remain partially unused and not valued. Removing those barriers should support both

the effective exercise of free movement and more balanced territorial development,

while allowing mobility to remain a genuine choice rather than a necessity driven by

the lack of local opportunities.

(5) [DIGITALISATION, Articles 3 and 4] The digital transformation of qualification

systems is essential to enhance the reliability, comparability, interoperability and

verifiability, and thus portability of qualifications across the Union, thereby facilitating

cross-border mobility and labour market integration. It contributes to the removal of

administrative barriers to the free movement of workers, such as those related to the

time, translations and procedures needed to review authenticity of non-interoperable

evidence of qualifications, such as paper or PDF formats. Therefore, a common Union

standard should be established for digital qualification attestations issued within the

Union, and reliable and comparable information on qualifications should be shared by

the Member States and made available to labour market actors.

(6) [FORMATS] Digital qualification attestations should be the default format for

qualifications issued to qualification holders. As Member States need time to prepare

for the issuance of digital qualification attestations, that requirement should apply

from three years after the entry into force of this Regulation. Member States should

however have the possibility to issue digital qualification attestations already before

that date. The issuance of qualifications in other formats than the digital qualification

attestations should remain under the responsibility of the Member States.

(7) [EUDI WALLET, Article 3] A more harmonised approach towards digital

qualification attestations reduces the risks and costs of the current fragmentation due

to the use of divergent national solutions or, in some Member States, the absence of

such digital solutions. Such an approach contributes to strengthening the internal

market by providing harmonised digital qualification attestations across the Union.

The European Digital Identity (EUDI) Framework was created by Regulation (EU) No

910/2014 of the European Parliament and of the Council8 with an intention to achieve

a shift from the reliance on national digital solutions only, to the provision of

electronic attestations of qualifications that are valid and legally recognised across the

Union. While every Member State is required to provide an EUDI Wallet, the use of it

8 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 2 EN

remains a matter of choice for its nationals or residents. Digital qualification

attestation should be issued upon request of the qualification holders into their EUDI

Wallets and in accordance with Regulation (EU) 910/2014.

(8) [TRUSTED FRAMEWORK FOR DQAs, Article 3] The digital qualification

attestation should be issued under a trusted framework provided in Regulation (EU)

No 910/2014 to ensure its validity across the Union. To this end, the attestations

should only be issued as qualified electronic attestations of attributes issued by a

qualified trust service provider or electronic attestation of attributes issued by or on

behalf of a public sector body responsible for an authentic source.

(9) [ACCREDITATION, Article 2] Any awarding body that is authorised to award

qualifications that are included in national qualifications frameworks should be

considered as accredited awarding bodies in the context of this Regulation. This

includes situations where an awarding body has been designated by law or, in the case

of non-governmental bodies which are awarding qualifications under the specific rules

of national qualifications frameworks regulations or procedures.

(10) [ISSUANCE and COST of DIGITAL QUALIFICATION ATTESTATIONS, Article 4

and 5] Qualification holders should have a right to be issued digital qualification

attestations as long as they have active EUDI Wallets and request the issuance of it.

Digital qualification attestations should be provided free of charge to the holders of

qualifications. To this end, Member States should refrain from establishing any

administrative fees for the issuance of digital qualification attestations to avoid

hampering their use.

(11) [SCOPE of DIGITAL ATTESTATIONS, Article 4] Digital qualification attestations

under this Regulation should be issued for qualifications at levels 2 to 8 of the

European Qualifications Framework, in order to ensure the broad coverage of

qualifications with labour market relevance. European Qualifications Framework level

1 is not part of the scope, as this level, where it is used in national qualifications

frameworks, largely relates to primary/basic education which is of lesser relevance for

the labour market.

(12) [LEGAL VALUE OF DIGITAL QUALIFICATION ATTESTATIONS, Article 4]

Minimum technical and procedural requirements are necessary for the issuance of

digital qualification attestations to ensure that those attestations are interoperable and

that they constitute legally valid evidence of qualifications awarded in the Union.

(13) [STANDARISATION & eIDAS REG, Articles 4 and 5] The use of Union standard

specifications for digital qualification attestations ensures consistency,

interoperability, and cross-border validity of qualifications, while allowing Member

States the flexibility to adapt to national contexts where necessary. Those

specifications should align with good practices in digital credentialing, including

security, data protection, and long-term verifiability, in accordance with Regulation

(EU) No 910/2014 which lays down rules under Article 5f on cross-border reliance of

EUDI Wallet.

(14) [DQAs WITH DIFFERENT SPEEDS] To facilitate free movement of workers and

portability of their qualifications across the Union, digital qualification attestations for

all qualification awarded between [date of entry into force minus 10 years] and [date

of entry into force] should be issued as soon as possible, and in any case no later than

two weeks after request for their issuance and without the need for manual processing.

However, for qualifications awarded in the period between [date of entry into force

EN 3 EN

minus 45 years] and [date of entry into force minus 10 years], the digital qualification

attestations should be issued digitally within a reasonable time allowing Member

States time to gather the data and check the information and no later than two weeks.

Member States should be allowed to limit issuance of digital qualification attestations

for qualifications awarded in the period between [date of entry into force minus 45

years] and [date of entry into force minus 10 years] to cases where the qualification

holder can prove that the purpose for the use of the attestations is pursuit of

employment in another Member State.

(15) [REVOCATION & SUSPENSION, Article 6] In line with their responsibility in the

education and training policies, Member States should be able to apply their national

provisions on withdrawal or suspension of qualifications awarded by entities in their

territory, irrespective of whether those qualifications are evidenced in the form of

physical or digital qualification attestation. Therefore, digital qualification attestations

should reflect the status of the qualifications, such as whether they have been

suspended or revoked. Arrangements for suspension and revocation are without

prejudice to the alert mechanism under Directive 2005/36/EC.

(16) VERIFICATIONS, Article 7] To ensure trust in and interoperability of digital

qualification attestations across the Union, Member States should establish tools

enabling relying parties such as employers and public authorities to verify the

authenticity and validity of a qualification and the accreditation of an awarding body.

To facilitate verification processes and reduce administrative burdens, the Commission

intends to support Member States, including by providing a reference software

supporting secure, efficient and non-discriminatory verification processes. While

employers cannot refuse a digital qualification attestation issued in accordance with

this Regulation as a proof of a qualification or question its authenticity, the Regulation

imposes no obligation on employers to request or verify the authenticity or validity of

a qualification. The Regulation also does not impact employer’s prerogative to assess

the qualification in the selection process and decide on their relevance.

(17) [EQF & NQF, Article 2 and 8] This Regulation covers qualifications included in a

national qualifications framework of a Member State which are awarded by an

awarding bodies established in the Union. The European Qualifications Framework is

a tool established in 20089, and revised in 201710 (the ‘2017 Recommendation’), to

facilitate the comparison between levels and portability of qualifications awarded by

entities from different Member States. Member States have undertaken significant

efforts to develop national qualifications frameworks and to reference them to the

European Qualifications Framework through a structured referencing

process. National qualifications frameworks are evolving to reflect changes in

qualifications, emerging skills, and new forms of learning, including micro-

credentials. Information on all qualifications that form part of such national

qualifications frameworks should be included in qualifications registries and

databases. Updated national qualifications frameworks should be reflected in the

referencing to the European Qualifications Framework that should remain adequate

9 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 111, 6.5.2008, pp.

1–7). 10 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).

EN 4 EN

and relevant for workers, employers and other stakeholders. To this end, it is essential

that Member States update the referencing of their national qualifications frameworks

to the European Qualifications Framework when needed.

(18) [INTERLINK WITH THE 2017 RECOMMENDATION] This Regulation should

apply to the use of the European Qualifications Framework in the context of the

exercise by workers of their freedom to move. To ensure legal certainty and

coherence, the levels of the European Qualifications Framework and some of the terms

and definitions laid down in the 2017 Recommendation should be incorporated into

this Regulation for the purposes of the free movement of workers. This does not create

any obligation as to how Member States design their national qualifications

frameworks. As far as the 2017 Recommendation covers the use of the European

Qualifications Framework for lifelong learning, that Recommendation should continue

to provide guidance on matters not governed by this Regulation.

(19) [MICRO-CREDENTIALS, Article 8] Micro-credentials play an increasingly

important role in upskilling and reskilling. The European approach to micro-

credentials was established to support the quality, trust and uptake of micro-

credentials, and to make them more comparable and understandable across borders

and sectors. To facilitate their portability, micro-credentials should be included in

national qualifications frameworks and, to the extent possible, align with the Council

Recommendation of 16 June 202211 on a European approach to micro-credentials for

lifelong learning and employability, fostering consistency, transparency and trust in

those credentials across the Union.

(20) [ESCO, Article 8] Member States should ensure that qualifications that are part of

national databases connected to the Europass platform12 include information on

learning outcomes and to the extent possible use standard information on skills. To

this end, Member States should be allowed to make use of the European Guidelines

for the development and writing of short learning-outcomes-based descriptions of

qualifications13. In addition, Member States should have the possibility to make use of

skills terminology from the European Skills, Competences, Qualifications and

Occupations (ESCO) classification introduced by Regulation (EU) 2016/589 of the

European Parliament and of the Council14 which facilitates the understanding of

qualifications in the labour market and contributes to better job matching.

(21) [EUROPASS, Article 8] To improve the availability of comparable digitalised

information about qualifications for workers and employers, Member States should

ensure that national databases are connected to the Europass platform and include

qualifications that are part of national qualifications frameworks referenced to the

European Qualifications Framework. A comparison tool embedded in the

Europass platform will facilitate an automated comparison of qualifications listed in

national qualifications frameworks referenced to the European Qualifications

11 Council Recommendation of 16 June 2022 on a European approach to micro-credentials for lifelong

learning and employability (OJ C 243, 27.6.2022). 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 (OJ L 112,2.5.2018, p. 42). 13 https://www.cedefop.europa.eu/en/publications/6222 14 Regulation (EU) 2016/589 of the European Parliament and of the Council of 13 April 2016 on a

European network of employment services (EURES), workers' access to mobility services and the

further integration of labour markets, and amending Regulations (EU) No 492/2011 and (EU) No

1296/2013 (OJ L 107, 22.04. 2016 , p. 1, ELI: http://data.europa.eu/eli/reg/2016/589/oj).

EN 5 EN

Framework. The comparison generated by the tool is for information purpose,

facilitating the work for social partners, employment services and job applicants.

(22) [TIMELINES, Article 9] For those qualifications and skills which were awarded

before the creation of the national qualifications frameworks and their reference to the

European Qualifications Framework, other means of verifying the authenticity of the

qualifications and accreditations of the awarding bodies are necessary. Therefore, it is

appropriate to provide additional rules and specification with regard to the issuance of

digital qualification attestations for qualifications awarded before [date of entry into

force minus 10 years].

(23) [INFORMATION ON THE REGULATION, Article 10] In order to facilitate the

application of this Regulation and the use of digital qualification attestations, Member

States should make publicly available relevant information. This could

include accessible and reliable sources of guidance on matters governed by this

Regulation, including the issuance of digital qualification attestations and the

availability of comparable information on qualifications.

(24) [MUTUAL ASSISTANCE AND GOVERNANCE, Article 11] Member States should

work together in pursuit of the use and mutual understanding of qualifications awarded

across the Union for the purposes of workers’ mobility. Therefore, a group on

digitalisation of qualifications should be created. This group should consult, on an ad

hoc basis, the European Digital Identity Cooperation Group established under Article

46e of Regulation (EU) No 910/2014 regarding questions related to the format of the

attestations or their efficient use in the European Digital Identity Wallets.

(25) [PERSONAL DATA, Article 12] Any processing of personal data for the

implementation of this Regulation should comply with the data protection framework

of the Union, in particular Regulation (EU) 2016/679 of the European Parliament and

of the Council15. Personal data processed in the context of this Regulation includes

data such as given name, surname, nationality and national ID as specified in Annexes

II and V to this Regulation. This data should be retained for no longer than necessary

throughout an average length of a work career, namely 45 years. No other personal

data than those specified in those annexes should be processed in the context of this

Regulation. The retention period of 45 years is necessary to ensure access to digital

qualification attestations during the whole span of professional career.

(26) [REPORTING & REVIEW, Article 13] In order to enable the preparation of

meaningful reports on the application of this Regulation, the Commission should

receive from the Member States, on a yearly basis, information regarding the number

of digital qualification attestations issued, renewed, revoked and suspended, the share

of qualifications issued in the form of digital qualification attestations in all

qualifications awarded annually and the number of relying parties registered to access

digital qualification attestations. Every two years, Member States should send reports

to the Commission on the application of this Regulation, which should serve as a basis

for the Commission to review and evaluate its application.

(27) [W3C FORMAT FOR Digital Qualification Attestation, Annex I] In accordance with

the objectives of Regulation (EU) No 910/2014, a number of standards should be

selected to meet the specific requirements on issuance of digital qualification

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, and repealing Directive 95/46/EC (OJ L 119, 4.5.2016, p. 1,

ELI: http://data.europa.eu/eli/reg/2016/679/oj)

EN 6 EN

attestation in the EUDI Wallets. Those standards should reflect established practices

and be widely recognised within the relevant sectors. To this end, as the W3C VCDM

format is used as the reference format for attestations, in particular in the

education and training sector, the European Digital Identity Wallets should also

support the format for the digital qualification attestations when the new EUDI

Wallets standards by the European Telecommunications Standards Institute (ETSI) on

the W3C VCDM format are available.

(28) [DELEGATED ACTS, ARTICLE 14] In order to keep this Regulation in line with

global developments and to follow best practices on the internal market, the power to

adopt acts in accordance with Article 290 of the Treaty on the Functioning of the

European Union should be delegated to the Commission in respect of amending the

Annexes to this Regulation to take into account technical, operational or scientific

developments. It is of particular importance that the Commission carries out

appropriate consultations during its preparatory work, including at expert level, and

that those consultations be conducted in accordance with the principles laid down in

the Interinstitutional Agreement of 13 April 2016 on Better Law-Making16. In

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

European Parliament and the Council should 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.

(29) [IMPLEMENTING ACTS, Article 5] In order to ensure uniform conditions for the

implementation of this Regulation laying down detailed provisions concerning the

agreed common language, formats and protocols for the issuance of digital

qualification attestations across the Union; and the formats of and transfer protocols

for transfers of the lists of awarding bodies, accreditations and qualifications included

in national qualifications frameworks, and formats and procedures for verifications by

relying parties, 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 Council17.

(30) [SINGLE DIGITAL GATEWAY, Article 16] Regulation (EU) 2018/1724 of the

European Parliament and of the Council18 provides for access to online procedures

relevant for the functioning of the internal market, including for cross-border users. In

order to allow citizens and residents to enjoy directly the benefits of the internal

market without incurring an unnecessary additional administrative burden, Annexes I

and II to that Regulation should be amended accordingly from the date where the

digital qualifications certifications are to be issued in accordance with this Regulation.

(31) [CROSS BORDER DIGITAL PUBLIC SERVICES] The digital qualification

attestation service constitutes a cross-border digital public services within the meaning

16 OJ L 123, 12.5.2016, p. 1, ELI: http://data.europa.eu/eli/agree_interinstit/2016/512/oj 17 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). 18 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 L295 of 21.11.2018, p.

1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj).

EN 7 EN

of Regulation (EU) 2024/903 of the European Parliament and of the Council19. This

Regulation introduces new binding requirements affecting those cross-border digital

public service and is therefore subject to the obligation laid down in Article 3 of that

Regulation. Accordingly, an interoperability assessment has been carried out and the

resulting report is to be published on the Interoperable Europe Portal.

(32) Since the objectives of this Regulation cannot be sufficiently achieved by the Member

States because no Member State alone is able to ensure interoperability of digitalised

information on qualifications but can rather, by reason of effectiveness of the action,

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

the principle of subsidiarity as set out in Article 5 of the Treaty on European Union. In

accordance with the principle of proportionality, as set out in that Article, this

Regulation does not go beyond what is necessary in order to achieve those objectives.

(33) In order to allow Member States sufficient time to take the necessary measures

required for the issuance of digital qualification attestations and the tools for

verification thereof, the application of the relevant provisions should be deferred to

[entry into force plus 36 months].

(34) 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]20.

HAVE ADOPTED THIS REGULATION:

Chapter 1

General provisions

Article 1

Subject-matter

This Regulation lays down the following rules on portability of qualifications and skills for

nationals of Member States moving within the Union for the purpose of employment:

(a) common procedures, standards and models for digital qualification attestations;

(b) rules on the use of the EUDI Wallet for the purpose of digital qualification

attestations;

(c) provision of comparable information on qualifications;

(d) mutual assistance and cooperation between Member States;

(e) provision of information on this Regulation in the Member States.

Article 2

Definitions

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

19 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). 20 OJ C , , p. .

EN 8 EN

(1) 'qualification' means a formal record of an assessment and validation process

which is obtained when a competent body determines that an individual has

achieved learning outcomes to given standards;

(2) 'digital qualification attestation' means an attestation of a qualification in an

electronic form;

(3) 'national qualifications framework' means a qualifications framework that is

developed by a Member State based on learning outcomes and that is related to

the European Qualifications Framework through a referencing process;

(4) 'skill' means the ability to apply knowledge and use know-how to complete

tasks and solve problems;

(5) ‘micro-credentials’ means the record of the learning outcomes that a learner

has acquired following a small volume of learning;

(6) 'European Digital Identity Wallet' or 'EUDI Wallet' means European Digital

Identity Wallet as defined in Article 3, point (42), of Regulation (EU) No

910/2014;

(7) 'accreditation' means a formal decision by a recognised authority which has

verified that an awarding body meets predefined quality standards;

(8) 'awarding body' means an institution or a competent authority in a Member

State which is accredited to award a qualification;

(9) 'issuer' means an issuer of a digital qualification attestation;

(10) ‘relying party’ means relying party as defined in Article 3, point (6), of

Regulation (EU) No 910/2014;

(11) ‘holder’ is a natural person that has been awarded a qualification by an

awarding body.

Chapter 2

Digital Qualification Attestations

Article 3

Digital qualification attestations in the EUDI Wallets

1. Digital qualification attestations shall be issued to the European Digital Identity

Wallets as one of the following:

(a) qualified electronic attestations of attributes in accordance with Article 45d, of

Regulation (EU) No 910/2014;

(b) electronic attestations of attributes issued by or on behalf of a public sector

body responsible for an authentic source in accordance with Article 45f,

of Regulation (EU) No 910/2014.

2. Member States shall designate the following entities as issuers:

(a) qualified trust service providers as defined in Article 3, point (20), of

Regulation (EU) No 910/2014;

(b) public sector bodies responsible for an authentic source within the meaning of

Article 45f, of Regulation (EU) No 910/2014 or other entities acting on their

behalf in accordance with that Article.

EN 9 EN

3. The issuers shall issue digital qualification attestations in one or more official

languages of the Union of the Member States’ choice and in an agreed common

language to be established in accordance with paragraph 6.

4. By [date of the entry into force plus 30 months] and in any case no later than the date

of the first issuance of a digital qualification attestation, Member States shall

communicate to the Commission the lists of the awarding bodies, accreditations and

qualifications included in their national qualifications frameworks. Those lists

shall include data covering the period from [date of entry into force minus 10 years]

to the date of submission of the lists. Member States shall inform the Commission of

any changes to those lists without delay. The Commission shall make those lists

available to the public.

5. Member States shall ensure that digital qualification attestations are provided, free of

charge, to holders of qualifications upon their application for such attestations.

6. By [date of entry into force plus 18 months], the Commission shall adopt

implementing acts laying down detailed provisions concerning the agreed common

language; formats and protocols for the issuance of digital qualification attestations

across the Union; and the formats of and transfer protocols for the lists of awarding

bodies, accreditations and qualifications included in national qualifications

frameworks. Those implementing acts shall be adopted in accordance with the

examination procedure referred to in Article 15(2).

Article 4

Digital qualification attestations

1. Member States shall, within the deadlines laid down in this Article, ensure that

the qualifications awarded under their jurisdictions are evidenced by digital

qualification attestations based on the Union standard specifications laid down in

Annex I.

2. The digital qualification attestations shall comply with the data fields specifications

laid down in Annex II. This requirement shall not apply to digital qualification

attestations issued in accordance with Article 9.

3. Digital qualification attestations shall constitute evidence of qualifications awarded

to the holder and shall be valid across the Union.

4. From [entry into force plus 36 months], Member States shall ensure that digital

qualification attestations are issued without delay upon request of the qualification

holder as the default format for evidencing qualifications which meet the following

conditions:

(a) they are part of a Member State’s national qualifications framework;

(b) they have been awarded after [date of entry into force minus 10 years].

5. For qualifications awarded between [date of entry into force minus 10 years] and

[date of entry into force], Member States shall issue digital qualification attestations

upon request of the qualification holder as soon as possible, and in any case no later

than within two weeks from receipt of that request;

6. By way of derogation from paragraph 4, for qualifications awarded between [date of

entry into force minus 10 years] and [date of entry into force] Member States may

limit the issuance of digital qualification attestations to cases in which the

EN 10 EN

qualification holder provides evidence that the purpose of the use of digital

qualification attestations is the pursuit of employment in another Member State.

7. Member States may issue digital qualification attestations before [date of the entry

into force plus 36 months] for qualifications meeting the conditions laid down in

paragraphs 4 and 5.

8. From [date of entry into force plus 36 months], Member States shall issue

digital qualification attestations evidencing qualifications awarded in the period

between [date of entry into force minus 45 years] and [date of entry into force minus

10 years] in accordance with Article 9.

9. This Article does not apply to qualifications referenced at Level 1 of the framework

set out in Annex III (the ‘European Qualifications Framework’).

10. The Commission is empowered to adopt delegated acts, in accordance with Article

14, to amend Annexes I, II and III to take account of technical, operational or

scientific developments.

Article 5

Issuance of digital qualification attestations

1. The holders of qualifications may request the issuance of a digital qualification

attestation to evidence qualifications awarded to them.

2. Digital qualification attestations shall be issued to the European Digital Identity

Wallets of the holders of qualifications who meet the following conditions:

(a) they have been awarded a qualification from an awarding body accredited to

award such a qualification and listed in the list of awarding bodies referred to

in Article 3(4);

(b) they hold an active European Digital Identity Wallet;

(c) they request the issuance of a digital qualification attestation.

Article 6

Revocation and suspension of a digital qualification attestation

1. The issuer shall refuse to issue a digital qualification attestation to holders whose

qualification is withdrawn or suspended.

2. Where the issuer is informed that the qualification corresponding to a digital

qualification attestation has been withdrawn or suspended by an awarding body or

another competent authority, the issuer shall revoke or suspend that attestation.

Where an issuer revokes or suspends a digital qualification attestation, it shall make

the information of that revocation or suspension accessible to relying parties across

the Union within 24 hours after the receipt of the request for revocation or

suspension.

3. Issuers shall maintain information on revocation and suspension of a digital

qualification attestation and make it available to relying parties.

4. A digital qualification attestation that has been revoked shall not constitute evidence

of qualifications awarded to the holder.

EN 11 EN

5. A suspended digital qualification attestation shall not constitute evidence of

qualifications awarded to the holder for the duration of the suspension.

6. A digital qualification attestation shall be considered as revoked or suspended until

the person concerned complies with any of the following conditions laid down by the

Member State in the territory of which the qualification was awarded:

(a) conditions for the recovery of the qualification;

(b) conditions to be able to apply for a new digital qualification attestation.

Article 7

Verification by relying parties

1. No later than [entry into force plus 36 months], Member States shall provide a digital

verification tool that enables relying parties to verify that:

(i) the digital qualification attestation was issued by an issuer referred to in Article

3(2);

(ii) the qualification evidenced by the digital qualification attestation was awarded

by an awarding body accredited at the time of the award;

(iii) the digital qualification attestation has not been tampered with since it was

issued;

(iv) the digital qualification attestation has not been suspended or revoked.

2. By [date of entry into force plus 18 months], the Commission shall adopt

implementing acts laying down formats and procedures for verification by relying

parties in accordance with paragraph 1. The implementing acts shall be adopted in

accordance with the examination procedure referred to in Article 15(2).

This Regulation does not oblige relying parties to request or verify digital

qualification attestations.

Article 8

Provision of comparable information on qualifications

1. Member States shall provide information on the qualifications, awarding bodies and

accreditations as referred to in Article 3(4) to the Europass online platform as

follows:

(a) the information shall be presented in the semantic model laid down in point 2

of Annex I;

(b) the minimum data requirements laid down in Annex IV shall be met;

(c) for the description of qualifications, skills terminology from the European

classification of skills and occupations (ESCO) shall be used to the extent

possible.

Member States shall submit updates of the information referred to in the first

subparagraph in real time to the extent possible, and in any case at least each month.

2. The Commission is empowered to adopt delegated acts, in accordance with Article

14, to amend Annex IV to take account of technical, operational or scientific

developments.

EN 12 EN

3. National qualifications frameworks shall include all qualifications awarded under the

jurisdiction of a Member State and be kept up to date. To the extent possible,

Member States shall include micro-credentials in their national qualifications

frameworks.

4. Member States shall use the European Qualifications Framework to reference

national qualifications frameworks or systems and to allow comparison of all types

and levels of qualifications in the Union that are part of national qualifications

frameworks or systems in particular by referencing their qualification levels to levels

of the European Qualifications Framework.

5. Member States shall review and update, when needed, the referencing of the levels of

the national qualifications frameworks or systems to the levels of the European

Qualifications Framework.

6. The Commission shall provide a digital tool to facilitate an

automated comparison of qualifications listed in national qualifications frameworks

referenced to the European Qualifications Framework and make it available through

the Europass platform.

Article 9

Qualifications awarded before digitalisation of qualifications

1. For the qualifications awarded in the period between [date of entry into force minus

45 years] and [date of entry into force minus 10 years], Member States shall ensure

that, upon request of a qualification holder, a digital qualification attestation is issued

within a reasonable time, and in any case no later than within two weeks from the

receipt of the request from the qualification holder, on the basis of existing evidence

verified by the issuer.

2. Member States may limit the issuance of digital qualification attestations in

accordance with paragraph 1 to cases in which a qualification holder provides

evidence that the purpose of the use of the digital qualification attestation is the

pursuit of employment in another Member State.

3. For the purposes of paragraph 1, the issuers may make use of:

(a) verification measures provided by Member States in accordance with Annex

VI to Regulation (EU) No 910/2014;

(b) procedures, assistance and problem-solving services laid down by Regulation

(EU) 2018/1724.

4. For digital qualification attestations to be issued under this Article, Member States

shall use the Union standard specifications for data fields laid down in Annex V.

5. The Commission is empowered to adopt delegated acts, in accordance with Article

14, to amend Annex V to take account of technical, operational or scientific

developments.

Chapter 3

Implementation

Article 10

Information on the digital qualification attestations

EN 13 EN

No later than [date of the entry into force of this Regulation plus 30 months] and in any case

no later than the date of first issuance of digital qualification attestations in accordance with

Article 4(4), each Member State shall make publicly available information concerning digital

qualification attestations .

Article 11

Qualifications Digitalisation Group

1. A group on digitalisation of qualifications (the ‘Qualifications Digitalisation Group’)

is established to facilitate cross-border cooperation and exchange of

information on issues related to the implementation of this Regulation,

including trust services, European Digital Identity Wallet, notified electronic

identification schemes, semantic model and digital qualification attestations, and to

take all necessary steps to ensure that the information exchanged is up-to-date.

2. The Qualifications Digitalisation Group shall be composed of representatives

appointed by each Member State. The Qualifications Digitalisation Group shall be

chaired by the Commission. The Commission shall provide the Qualifications

Digitalisation Group’s Secretariat.

3. The Qualifications Digitalisation Group shall have the following tasks:

(a) support the consistent implementation of this Regulation by facilitating

coordination and project management, the exchange of information and the

promotion of best practices across Member States as well as developing

guidelines to support enforcement;

(b) support the development and operation of electronic data exchanges in

accordance with this Regulation;

(c) provide recommendations to Member States, where appropriate, on further

digitalisation of qualifications.

4. The Qualifications Digitalisation Group shall cooperate, when relevant, with the

European Digital Identity Cooperation Group referred to in Article 46, point (e), of

Regulation (EU) No 910/2014.

5. The Qualifications Digitalisation Group shall adopt its rules of procedure and meet at

least annually until [five years after the entry into force of this Regulation].

Article 12

Data protection

1. Personal data shall be processed in the context of this Regulation only in so far as it

is necessary for issuance and verification of digital qualification attestations in

accordance with Chapter 2.

2. Personal data processed in the context of this Regulation shall be retained no longer

than [45] years.

EN 14 EN

Chapter 4

Final provisions

Article 13

Reporting and review

1. By [[48] months from the date of the entry into force of this Regulation], and every

year thereafter, Member States shall submit to the Commission the following data

concerning the past 12 months:

(a) the number of digital qualification attestations issued, revoked and suspended;

(b) the share of qualifications issued in the form of digital qualification attestations

among all qualifications awarded;

(c) the number of relying parties registered to access digital qualification attestations.

2. By [48] months from the date of the entry into force of this Regulation], and every

two years thereafter, Member States shall submit a report to the Commission on the

application of this Regulation. The report shall include:

(a) the data referred to in paragraph 1;

(b) the information on respective average processing time of a request for issuance

of a digital qualification attestation in accordance with Article 4(5) and Article

9.

Member States shall collect feedback from holders of qualifications, employers,

awarding institutions, issuers, recognition authorities for regulated professions and

other stakeholders necessary for preparing the report as laid down in this paragraph.

3. The information submitted to the Commission in accordance with paragraphs

1 and 2 shall not include personal data.

4. By [the same date as the date of application plus five years], the Commission shall

review and evaluate the application of this Regulation and shall present a report to

that effect to the European Parliament and the Council.

5. Where appropriate, the Commission shall submit relevant legislative proposals.

Article 14

Exercise of the delegation

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 4(10), Article 8(2) and

Article 9(5) shall be conferred on the Commission for an indeterminate period from

[date of entry into force].

3. The delegation of power referred to in Article 4(10), Article 8(2) and Article

9(5) 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.

EN 15 EN

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 4(10), Article 8(2) and Article 9(5) shall

enter into force only if no objection has been expressed either by the European

Parliament or by 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.

Article 15

Committee procedure

1. The Commission shall be assisted by a committee. 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 16

Amendment of Regulation (EU) 2018/1724

Regulation (EU) 2018/1724 is amended as follows:

(1) In the table of Annex I at the level of 'B. Work and retirement within the Union' as

Area, in the second column, point 3 is replaced by the following: “verification,

comparison and recognition, where appropriate, of qualifications with a view to

pursue employment in another Member States”.

(2) In the table of Annex II at the level of 'Working' as Life Event, the following row is

added in the second and third columns:

‘Requesting proof of qualification for

the issuance of a digital qualification

attestation referred to in Article 9 of

Regulation (EU)…of the European

Parliament and of the Council*

Proof of a qualification

*Regulation (EU) .../... of the European Parliament and of the Council of ... on ... (OJ ...).’.

Article 17

Entry into force [and application]

This Regulation shall enter into force on the [twentieth] day following that of its publication

in the Official Journal of the European Union.

[Articles […] and 16 shall apply from [entry into force plus 36 months].

EN 16 EN

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

[...] [...]

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

Contents

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

EN 2 EN

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 10

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 ....................................................... 18

3.2.2. Estimated output funded from operational appropriations......................................... 24

3.2.3. Summary of estimated impact on administrative appropriations ............................... 26

3.2.3.1. Appropriations from voted budget .............................................................................. 26

3.2.3.2. Appropriations from external assigned revenues ....................................................... 26

3.2.3.3. Total appropriations ................................................................................................... 26

3.2.4. Estimated requirements of human resources.............................................................. 27

3.2.4.1. Financed from voted budget....................................................................................... 27

3.2.4.2. Financed from external assigned revenues ................................................................ 28

3.2.4.3. Total requirements of human resources ..................................................................... 28

3.2.5. Overview of estimated impact on digital technology-related investments ................ 30

3.2.6. Compatibility with the current multiannual financial framework.............................. 31

3.2.7. Third-party contributions ........................................................................................... 31

3.3. Estimated impact on revenue ..................................................................................... 31

4. DIGITAL DIMENSIONS .......................................................................................... 32

4.1. Requirements of digital relevance .............................................................................. 32

4.2. Data ............................................................................................................................ 33

4.3. Digital solutions ......................................................................................................... 33

4.4. Interoperability assessment ........................................................................................ 34

4.5. Measures to support digital implementation .............................................................. 34

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Regulation of the European Parliament and of the Council on

portability of qualifications and skills and amending Regulation (EU) 2018/1724

(‘Skills Portability Act’)

1.2. Policy area(s) concerned

Internal Market: Free movement of persons, labour mobility

Digitalisation of public administrations

1.3. Objective(s)

1.3.1. General objective(s)

Facilitating portability of qualifications and skills between Member States in the

context of free movement of workers.

Ensuring access to simplified, effective and cost-efficient ways to carry, prove, read,

understand and compare qualifications and skills obtained in another Member State.

1.3.2. Specific objective(s)

Specific objective 1

Ensuring that labour market actors have access to reliable and comparable

information on skills and qualifications issued in the EU.

Specific objective 2

Ensuring that labour market actors in the EU can benefit from interoperable and

verifiable digital attestations of 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.

The Skills Portability Act is expected to generate benefits by facilitating the

verification and presentation of qualifications across borders, and improving the

transparency and trustworthiness of qualifications through interoperable digital

attestations. Workers will benefit from being able to store and present verifiable

digital attestations through the European Digital Identity (EUDI) Wallet, reducing

the need for comparability statements of qualifications and making it easier and

cheaper to demonstrate their qualifications when seeking employment in another

Member State. In addition to reducing costs, the proposal is expected to simplify

administrative procedures, shorten the time needed to demonstrate qualifications

across borders and facilitate labour mobility.

Employers will benefit from faster and more reliable verification of qualifications

through EUDI Wallet-compatible digital qualification attestations, easier access to

official and comparable information on qualifications across Member States, and

lower administrative costs when recruiting workers from abroad. The proposal is

expected to be particularly valuable for Small and Medium sized Enterprises

(SMEs)s, which often lack dedicated human resources to assess non-national

qualifications and would gain access to reliable information and automated

verification tools.

EN 4 EN

Awarding bodies and issuers of qualifications will benefit from fewer requests to

verify the authenticity of qualifications, as digital attestations enable automatic

verification by employers and other labour market actors. This is expected to

generate administrative savings, reduce routine administrative workload and allow

institutions to focus resources on their core educational activities.

Indirect benefits can also be expected: as the action contributes positively to the

functioning of the internal market and EU competitiveness: it is expected to facilitate

cross-border hiring with some effect on skills mismatches and improved labour

market allocation.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

The Commission will carry out monitoring in cooperation with the Member States

designed to monitor the implementation and evaluate the initiative’s impact, ensuring

that it remains fit for purpose and achieve the intended objectives. The monitoring

framework will include output, result and impact indicators. It will rely on annual

information submitted by Member States on the number of digital qualification

attestations issued, revoked and suspended, the share of qualifications issued in the

form of digital qualification attestations in all qualifications awarded annually, and

the number of relying parties registered to access digital qualification attestations;

biennial reports by Member States on the application of the Regulation, including

information on the average processing time for requests for issuance of digital

qualification attestations and feedback collected from workers, holders of

qualifications, employers, awarding institutions, issuers, recognition authorities for

regulated professions and other relevant stakeholders.

1.4. The proposal/initiative relates to:

 a new action

a new action following a pilot project / preparatory action21

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

Member States will start the application 36 months from the date of entry into force

of the Regulation. The proposal provides for four implementing acts to be adopted by

the Commission no later than within 18 months from the date of adoption of this

Regulation. The implementing acts will lay down detailed provisions concerning the

agreed common language; interoperability of digital qualification attestation across

the Union; the lists of awarding bodies, accreditations and qualifications included in

national qualifications frameworks for issuing and verifying digital qualification

attestations; and finally the detailed rules on verification processes, verification

21 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 5 EN

features and the interface with national systems.

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 free movement of people is a fundamental principle of the European Union.

Barriers related to qualifications and skills are one factor hindering individuals to

make full use of their free movement rights and to work in another Member State.

Without improved information on qualifications and skills obtained in other Member

States and tools facilitating effectively the portability of such qualifications and

skills, businesses and workers face difficulties when considering opportunities across

the EU.

Given the cross-border nature of these problems, effective solutions are best pursued

at the EU level to allow for interoperability across Member States instead of 27

different national frameworks and systems, thereby reducing fragmentation and

administrative burdens by facilitating the cross-border use and recognition of digital

qualification attestations.

Expected generated EU added value (ex-post)

The proposal is expected to generate EU added value by enhancing the availability of

digital qualification attestations that are easily accessible to workers as holders of

qualifications and to their potential employers. In the case of regulated professions,

in accordance with Directive 2005/36/EC, they will also be accessible to the

recognition authorities in Member States. Employers will also have access to tools

enabling better understanding and comparison of qualifications issued in different

Member States. A common legal and technical framework underpinning the

digitalisation of qualifications will allow digital qualification attestations issued in

another Member State to become more trustworthy, easier to verify and better

understood across the EU. This in turn can make job applications less cumbersome

and facilitate smoother access to jobs in all Member States. Overall, the expected

added value of this action will be greater portability of qualifications and skills.

1.5.3. Lessons learned from similar experiences in the past

The Skills Portability Act builds on existing tools such as the European

Qualifications Framework and the Europass Framework, which were the subject of

evaluations22 in 2024.

The European Qualifications Framework was found to be well-suited to promote the

transparency, comparability and portability of qualifications across the EU. All 27

Member States have referenced their national qualifications frameworks (NQFs) or

systems to the EQF. However, ensuring that National Qualifications Frameworks and

22 COM/2024/135 final - Report from the Commission to the European Parliament and the Council on the

implementation and impact of 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 SWD(2024)142 - Commission Staff Working Document Executive

Summary of the Evaluation of the Council Recommendation of 22 May 2017 on the European

Qualifications Framework for lifelong learning

EN 6 EN

databases and registers of qualifications are updated and connected to the Europass

platform is mentioned as an area for improvement.

Europass was found to facilitate mobility for work and study in the EU, by

presenting knowledge, skills, and competences in a standardised format. However,

further efforts are needed in developing qualification and learning opportunity

databases and registers that should link to the Europass platform via the

Qualifications Dataset Register.

Moreover, to test the use of the EUDI wallet in relation to the issuance, storage and

presentation of verifiable digital credentials through wallet-based solutions for

educational qualifications and learning achievements, the Digital Credentials for the

European Union (DC4EU) was conducted as a large-scale pilot project. The pilot

confirmed the potential efficiency gains from digital credentials, while also

illustrating the risk of fragmentation if Member States proceed with different

technical solutions in the absence of common standards.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

This proposal is compatible with the Multiannual Financial Framework 2028-2034 as

proposed by the Commission.

The proposal creates synergies with existing Union instruments and policies. It

builds on the European Digital Identity framework and the eIDAS Regulation

through the use of interoparble digital attestations for qualifications and skills and the

trusted framework for exchanges. The proposal includes also an amendment of

Regulation (EU) 2018/1724 to allow for the use of solutions based on the Single

Digital Gateway and the Once-Only Technical System.

Finally, this proposal supports a proposal to review the Professional Qualifications

Directive under Skills Portability Initiative, which aims to facilitate recognition

procedures under the Professional Qualifications Directive through the provision of

interoperable digitial qualification attestations.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

This proposal builds on the financial envelope proposed under the Erasmus+

programme and European Competitiveness Fund under Heading 2 of the Multiannual

Financial Framework 2028-2034, subject to its adoption and the EU annual

budgetary procedure.

EN 7 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 2028 to 2034,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned23

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

23 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 8 EN

This proposal is foreseen to be implemented by the Commission’s department from

2028 onwards. The additional staff needed to implement this proposal is assessed at

6 Full Time Equivalents. Part of the proposal might be implemented by an executive

agency, in particular under the proposed European Competitiveness Fund.

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 increasing the availability, uptake and use of digital qualification attestations,

improving the efficiency of issuing and accessing such attestations, and supporting

the cross-border verification and recognition of qualifications. The monitoring

framework will include output, result and impact indicators measuring. The

Commission will carry out monitoring in cooperation with the Member States.

Monitoring will rely on annual information submitted by Member States on the

number of digital qualification attestations issued, revoked and suspended, the share

of qualifications issued in the form of digital qualification attestations in all

qualifications awarded annually, and the number of relying parties registered to

access digital qualification attestations; biennial reports by Member States on the

application of the Regulation, including information on the average processing time

for requests for issuance of digital qualification attestations.

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, more specifically the Directorate-General for Employment, Social

Affairs and Inclusion (DG EMPL), which will ensure the coordination with Member

States and 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 with 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 Union’s 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

EN 10 EN

Eureopan 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 2028-2034 Multiannual

Financial Framework (MFF). 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 2028-2034 MFF and thereafter shall be

determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

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.

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.24

from

EFTA

countries 25

from

candidate

countries

and

potential

candidates 26

From

other

third

countries

other assigned

revenue

2

To be determined after the adoption of the

MFF and in the context of the annual

budgetary procedure – successor of 07 03

02 – Erasmus+

Diff. YES/NO YES/NO YES/NO NO

2

To be determined after the adoption of the

MFF and in the context of the annual

budgetary procedure – European

Competitiveness Fund

Diff. YES YES YES YES

24 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 25 EFTA: European Free Trade Association. 26 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 2 - Competitiveness, 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

Erasmus+ Commitments (1a) 0.500 1.200 1.100 0.815 0.815 0.815 0.815 6.060

Payments (2a) 0.500 1.200 1.100 0.815 0.815 0.815 0.815 6.060

European Competitiveness Fund Commitments (1b) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (2b) 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 programmes27

Budget line (3) 0 0 0 0 0 0 0 0

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.

27 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

This proposal builds on two financial envelopes that work in synergy: Erasmus+ and the European Competitiveness Fund (ECF) for skills

development and for the objective of implementing the Union of Skills, including making use of EU digital identity wallets.

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

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) 0 0 0 0 0 0 0 0

TOTAL

appropriations

under HEADING 2 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 and

subsequent

years

• 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 (6) 0 0 0 0 0 0 0 0

EN 14 EN

the envelope for specific programmes

(all operational headings)

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.

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)

EN 15 EN

Heading of multiannual financial framework 4 ‘Administrative expenditure’28

DG: EMPL Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

 Human resources 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

 Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG EMPL Appropriations 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

TOTAL appropriations under HEADING 4 of

the multiannual financial framework

(Total

commitments

= Total

payments)

1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

28 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 16 EN

The staff needed to implement this proposal has been assessed at 9 full time equivalent (FTE), of which 3 AD and 2 contract agents are redeployed from existing staff in the

DG, 3 AD and1 AST are to be covered by the redeployment pool of the Commission.

EN 17 EN

EUR million (to three decimal places)

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

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.

EN 18 EN

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

Year 2032

Year 2033

Year 2034

TOTAL

OUTPUTS

Type 29

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 objectives 1

and 2

- Output Activ

ities

funde

d

under

Eras

mus+

30

1 0.500 1 1.200 1 1.100 1 0.815 1 0.81

5

1 0.815 1 0.815 7 6.060

29 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 30 This includes mainly work on Europass (comparison tool, back office to connect databases on qualifications, accreditation and awarding bodies).

EN 19 EN

- Output Activ

ities

funde

d

under

the

Euro

pean

Com

petiti

venes

s

Fund 31

1 0 1 p.m. 1 p.m. 1 p.m. 1 1 p.m. 1 p.m. 7 p.m.

Subtotal for specific

objectives

1 p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 7 p.m.

TOTALS 1 p.m. 1 p.m. 1 0p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 7 p.m.

31 These include activities such as supporting Member States in setting up the trust framework needed for the digitalisation of qualifications in line

with the eIDAS Regulation under the EUDI Wallet (i.e. national registries of qualifications, awarding bodies and accreditations), putting in place the

verification software and preparing the digital issuing infrastructure for qualifications.

EN 20 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

HEADING 4

Human resources 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

Other administrative expenditure 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal HEADING 4 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

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 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

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.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the 2028-2034 Multiannual

Financial Framework (MFF). 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 2028-2034 MFF and thereafter shall be determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

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

EN 21 EN

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs)32

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) 7 7 7 7 7 7 7

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’) 2 2 2 2 2 2 2

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0 0 0 0

Admin. Support line • at Headquarters 0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU Delegations 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

32 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 22 EN

Other budget lines (specify) - Outside Heading 4 0 0 0 0 0 0 0

TOTAL 9 9 9 9 9 9 9

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

6 AD and 1 AST

N/A N/A

External staff

(CA, SNEs, INT)

2 CA N/A N/A

*

5 staff (3 AD, 2 CA) will be redeployed from existing staff in the DG to work on the implementation of the Skills Portability Act, but the

implementation of this entirely new initiative will require 4 additional staff (3 AD, 1 AST) from the redeployment pool of the Commission

The tasks related to the implementation include the oversight and coordination of the project, the management of the Qualifications Digitalisation

Group, the digital implementation of the Regulation, the monitoring and future reporting of the Regulation, as well as the policy steer. . The

implementation of the regulation will require the drafting of several implementing acts (with the bulk of the work expected to take place within 18

months of the adoption) and the adoption of the implementing acts as soon as possible to allow Member States to prepare the entry into force of the

regulation on time. This will require also technical work (including IT development) and technical support to ensure that Member States are ready for

implementation within the legal deadline. After these initial years, staff will be needed to continue providing support in the implementation of the

Member States, updating the implementing acts and preparing delegated acts when necessary, as well as monitoring and enforcement of the

EN 23 EN

regulation’s implementation. Throughout the entire period, staff will be needed for the running of governance, communication and awareness-raising

activities, and technical support for the Member States.

The Skills Portability Act, will require investing in IT solutions that will support its implementation (e.g. supplying a reference application to verify

whether a digitalised qualification has not been forged since its issuance, improving the IMI solution to better support recognition of qualifications in

the domain of regulated professions). To support the policy units in the implementation of these IT activities, besides the requested IT budget that will

be used to procure the IT activities (e.g. acquisition of IT service providers, or full outsourcing). Additional staff is required, to cover all project

management related tasks (i.e. planning the work, drafting the project charter, managing a team of IT service providers, monitoring and controlling the

work plan and deliverables, etc.).

Description of tasks to be carried out by:

Officials and temporary staff 1 AST for IT unit to cover all project management related tasks (i.e. planning the

work, drafting the project charter, managing a team of IT service provicers, monitoring

and controlling the work plans vs deliverables, etc.).

6 AD to draft the implemention acts, to provide for technical support to Member

States, to run the Qualifications Digitalisation Grouop, to implement communication

and awareness raising activities. Oversight and coordination of the project for the

digital implementation of the Regulation, the monitoring and future reporting of the

Regulation, as well as policy steer.

External staff To second the 6 AD in all their tasks.

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”.

EN 24 EN

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

0.5 p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Subtotal outside HEADING 4 0.5 p.m. p.m. p.m.p.m. p.m.p.m. p.m.

TOTAL 0.5 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)

–  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 25 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 Year Year Year Year Year Year Total

2028 2029 2030 2031 2032 2033 2034

Specify the co-financing

body EEA EFTA 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 26 EN

Budget revenue line:

Appropriations available

for the current financial

year

Impact of the proposal/initiative33

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.

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

N/A

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

Article 3 (1-3) Member States shall designate issuers

who shall issue digital qualification

attestations within the European

Issuing authorities in the

Member States:

o Qualified trust

Issuance of digital

credentials

Data

Digital public

service

33 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 27 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Digital Identity Wallet as:

• Qualified Electronic

Attestation of Attributes in

accordance with Article 45(d)

of Regulation (EU) No

910/2014;

• An electronic attestation of

attributes issued by or on

behalf of a public sector body

responsible for an authentic

source in accordance with

Article 45(f) in that

Regulation.

Digital qualification attestations shall

be issued in one or more official

languages of the Union of their choice

plus a mutually‑agreed common

language.

service providers

as defined in

Article 3, point 20

of Regulation (EU)

No 910/2014;

o Public sector

bodies responsible

for an authentic

source or other

entities acting on

their behalf.

Process

digitalisation &

automation

Digital solution

Article 3 (4)

Member States should transmit to the

Commission up‑to‑date lists of

awarding bodies, accreditations and

qualifications (covering the previous

ten years).

Member States

European Commission

Preparation, updating and

transmission of trusted lists

Data

Process

digitalisation &

automation

Digital solution

EN 28 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 3 (5)

Holders of qualifications must be able

to retrieve digital qualification

attestations electronically free of

charge upon their application for such

attestations.

EU citizens and EU

residents (Qualification

holders)

Identity check/matching of

wallet holder

Provision of the credential

(free, electronic)

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

Article 3 (6)

The Commission shall adopt

implementing acts laying down

detailed provisions concerning the

agreed common language; formats and

protocols for the issuance of digital

qualification attestations across the

Union; and the formats of and transfer

protocols for the lists of awarding

bodies, accreditations and

qualifications included in national

qualifications frameworks. Those

implementing acts shall be adopted in

accordance with the examination

procedure referred to in Article 15(2)

Member States

European Commission

Issuance of digital

credentials

Exchange of information:

lists of awarding bodies,

accreditations and

qualifications included in

the NQF

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

Article 4 (1‑3) Member States must evidence

qualifications by means of digital

qualification attestations that meet

Issuing authorities in the

Member States

Identity check/matching of

wallet holder

Issuance of digital

Data

Digital public

EN 29 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

the Union‑wide standard

specifications (Annex I).

Digital attestations shall comply with

the data fields specifications laid down

in Annex I, except for digital

qualification attestations issued in

accordance with Article 9.

Digital qualification attestations shall

constitute evidence of qualifications

awarded to the holder and shall be

valid across the Union.

Awarding bodies

EU citizens and EU

residents (Qualification

holders)

credentials

Qualifications are quality

assured as part of a Member

State’s National

Qualifications Framework

service

Process

digitalisation &

automation

Digital solution

Article 4(4‑5)

From [entry into force plus 36

months], Member States shall ensure

that digital

qualification attestations are issued

without delay upon request of the

qualification holder as the default

format for evidencing

qualifications which meet the

following conditions:

(a) they are part of a

Member State’s

national qualifications

framework;

Issuing authorities in the

Member States

Awarding bodies

EU citizens and EU

residents (Qualification

holders)

Identity check/matching of

wallet holder

Issuance of digital

credentials

Data

Digital public

service

Process

digitalisation &

automation

EN 30 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

(b) they have

been awarded after

[date of entry into force

minus 10 years].

For qualifications awarded between

[date of entry into force minus 10

years] and [date of entry into force],

Member States shall issue digital

qualification attestations upon request

of the qualification holder, to the

extent possible, without delay, and in

any case no later than within two

weeks from receipt of that request.

Article 5 (1)

Digital qualification attestations shall

be issued to the European Digital

Identity Wallets to the holders of

qualifications who meet the following

conditions:

• They have been awarded a

qualification from an awarding

body; and

• They hold an active European

Digital Identity Wallet

• They request the issuance of a

Issuing authorities in the

Member States Awarding

Bodies

EU citizens and EU

residents (Qualification

holders)

Issuance of digital

credentials

Identity check/matching of

wallet holder

Provision of the credential

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

EN 31 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

digital qualification attestation.

This includes re-issuance where the

holder no longer has access to a

previously held attestation.

Article 6 (1‑3)

Digital credentials must be refused,

revoked or suspended when the

underlying qualification has been

withdrawn or suspended in either the

issuing or a receiving Member State

by an awarding body or another

competent authority. The status is

reflected in the verification system

within 24 hours.

The information on revocation and

suspension of digital qualification

attestations should be made available

to relying parties by issuers.

Issuing authorities in the

Member States

Relying parties

EU citizens and EU

residents (Qualification

holders)

Receiving Member States

Decision to refuse issuance

Revocation or suspension

Updating of revocation lists

and making the status

available through the

verification process

Data

Digital public

service

Process

digitalisation &

automation

Article 7 (1‑2)

No later than [entry into force plus 36

months], Member States shall provide

a digital verification tool that enables

relying parties to verify that:

3. the digital qualification

attestation was issued by an

issuer referred to in Article

Relying parties (employers,

regulators, Competent

Authorities etc.)

European Commission

Verification‑software

developers

Credentials verification

process

Development/sharing of

verification tools

Compliance with procedural

rules

Data

Digital public

service

Digital solution

Process

digitalisation &

EN 32 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

3(2);

4. the qualification evidenced by

the digital qualification

attestation was awarded by an

awarding body accredited at

the time of the award;

5. the digital qualification

attestation has not been

tampered with since it was

issued;

6. the digital qualification

attestation has not been

suspended or revoked.

The Commission shall adopt

implementing acts laying down

formats and procedures for

verification by relying parties in

accordance with paragraph 1,.

The implementing acts shall be

adopted in accordance with the

examination procedure referred to in

Article 15(2).

Qualification holders automation

EN 33 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 8 (1)

Member States shall provide

information on the qualifications,

awarding bodies and accreditations to

the Europass online platform in

accordance with:

• a common semantic model laid

down in point 1, of Annex I,

• the minimum requirements

provided in Annex IV,

• for the description of

qualifications, to the extent

possible, making use of skills

terminology from the

European classification of

skills and occupations (ESCO)

based on a mapping between

Member States’ classification

systems and the European

classification.

Member States shall, to the extent

possible, submit updates of this

information in real time and in any

case at least each month.

Member States

European Commission

Comparable information on

qualifications

Data

Digital public

service

Digital solution

Process

digitalisation &

automation

EN 34 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 8 (3-5)

National Qualifications Frameworks

(NFQ) shall include all qualifications

awarded under the jurisdiction of a

Member State and be kept up to date.

To the extent possible, Member States

shall include micro-credentials in their

national qualifications frameworks.

Member States shall use the European

Qualifications Framework (EQF) to

reference national qualifications

frameworks or systems and to

compare all types and levels of

qualifications in the Union that are

part of national qualifications

frameworks or systems, in particular

by referencing their qualification

levels to levels of the European

Qualifications Framework set out in

Annex III.

Member States national

authorities

Qualification providers

Mapping to EQF and

updating NQF registers

Data

Digital public

service

Digital solution

Process

digitalisation &

automation

Article 8 (6)

The Commission shall provide a

digital tool to facilitate an

automated comparison of qualification

s listed in national qualifications

frameworks referenced to

European Commission

National authorities (for the

provision of the data)

Publication of NQFs data

on Europass

Compare two single

qualifications side-by-side

Export the comparison view

Data

Digital solution

Process

digitalisation &

EN 35 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

the European Qualifications

Framework and make it available

through Europass platform.

(for information purposes)

Find an EQF level based on

a qualification title

Compare two national

qualifications frameworks

automation

Article 9 (1‑4)

For qualifications awarded more than

ten years ago, Member States must, on

request, issue a digital credential based

on existing evidence (using eIDAS

(Regulation (EU) 910/2014) Annex VI

or OOTS common services (Single

Digital Gateway Regulation (EU)

2018/1724)) and in accordance with

the Union standard specification.

Member States shall use Union

standard specifications for data fields

laid down in Annex V, for these

digital qualification attestations.

EU citizens and EU

residents (Qualification

holders)

Issuing authorities

Retrieval of historic

evidence

Creation of a digital

credential for legacy

qualifications

Alignment with standard

specification

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

Article 12 (1‑2)

Personal data shall be processed in the

context of this Regulation only in so

far as it is necessary for issuance and

verification of digital qualification

attestations in accordance

with Chapter 2.

Data controllers (issuing

authorities and verifiers)

Data Protection Officers

EU citizens and EU

residents (Qualification

Collection, storage,

retention, and deletion of

personal data related to

credential issuance and

verification

Data

EN 36 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Personal data processed in the

context of this Regulation shall be

retained no longer than [45] years.

holders)

Article 13 (1‑4)

By [[48] months from the date of the

entry into force of this

Regulation], and every

year thereafter, Member States shall

submit to the Commission the

following data concerning the past 12

months:

(a) the number of digital

qualification attestations

issued, revoked and suspended;

(b) the share of qualifications

issued in the form of digital

qualification attestations

among all qualifications

awarded;

(c) the number of relying parties

registered to and requesting access to

digital qualification attestations. By

[48] months from the date of the entry

into force of this Regulation], and

every two years thereafter, Member

National reporting units

European Commission

Evaluation bodies

Data collection for

statistical reporting,

preparation of annual and

biennial reports, and

transmission to the

Commission

Data

Process

digitalisation &

automation

EN 37 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

States shall submit a report to the

Commission on the application of this

Regulation. The report shall include:

(c) the data referred to in paragraph

1;

(d) the information on respective

average processing time of a

request for issuance of a digital

qualification attestation in

accordance with Article 4(5)

and Article 9.

Member States shall collect feedback

from holders of qualifications,

employers, awarding institutions,

issuers, recognition authorities for

regulated professions and other

stakeholders necessary for preparing

the report as laid down in this

paragraph.

The information submitted to the

Commission in accordance

with paragraphs 1 and 2 shall not

include personal data.

By [the same date as the date of

application plus five years], the

EN 38 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Commission shall review and evaluate

the application of this Regulation and

shall present a report to that effect to

the European Parliament and the

Council.

EN 39 EN

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 3 (1-3)

Article 3 (4-6)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 7 (1‑2)

Article 8 (1)

Article 8 (3-5)

Article 9 (1‑4)

Article 12 (1‑2)

EUDI electronic attestations of attributes, standards

and processes described in Annex I, Annex II,

Annex IV and Annex V.

Revocation/suspension data Article 6 (1‑3) Revocation lists managed by Member States and

made accessible to others

Lists of awarding bodies Article 3 (4)

Article 3 (6)

Article 5 (1)

Article 8 (1-2)

Standards and processes described in Annex IV.

EN 40 EN

List of accreditations Article 3 (4)

Article 3 (6)

Article 5 (1)

Article 8 (1-2)

Standards and processes described in Annex IV.

Lists of current and past 10 years of qualifications

and data on qualifications listed in Member State’s

National Qualifications Frameworks (NQFs)

Article 3 (4)

Article 3 (6)

Article 8 (3-6)

ESCO, EQF, and ISCED classifications should be

used where possible.

Standards and processes described in Annex IV.

Annual statistical summary on numbers of digital

credentials issued/renewed/withdrawn/suspended,

processing times, user experience and stakeholder

feedback.

Article 13 (1‑4)

Personal data of qualification holdersArticle 12 (1‑2) Processed under Regulation (EU) 2016/679

(GDPR); data minimisation and storage limitation

Alignment with the European Data Strategy

Explanation of how the requirement(s) are aligned with the European Data Strategy

In terms of compliance with GDPR, the main roles and responsibilities related to personal data protection are already set out in Article 12.

Qualifications and accreditation data are already made available as Open data on the data.europa.eu portal34. Qualifications, awarding bodies,

and accreditation information does not contain any personal data.

34 https://data.europa.eu/data/datasets/european-learning-data?locale=en

EN 41 EN

The initiative supports the European Data Strategy by making qualification data interoperable, portable and reusable across borders under the

holder’s control.

Digital credentials are stored in the citizen’s EUDI Wallet, which enables selective disclosure and user-controlled sharing, in line with the

Strategy’s objective of empowering individuals over their data.

EN 42 EN

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

Reusing the EUDI Wallet framework will guarantee the once only principle, as it will reuse the existing wallet and the accompanying trust

framework.

Reuse of the Europass framework, in particular the Qualification Dataset Register, is foreseen, as this mechanism is already in place for the

publication of accreditation and qualifications in Europass. Furthermore, the Europass qualifications comparison tool will draw upon the

qualifications database, and upon existing functionality within Europass.

Reuse of the European Learning Model (ELM) is planned for semantic interoperability for digital qualification attestations and for information

on qualifications, awarding bodies and accreditation information.

Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

Personal data (including qualifications or information within recognition procedures) is in general not supposed to be findable or reusable.

Interoperability of attestations about qualifications is guaranteed through the use of the EUDI framework and infrastructure and by the

common standards described in the Annexes and the use of a common semantic data model. Such standards will ensure mutual understanding

of the qualifications in cross-border contexts.

Information on national qualifications frameworks will be kept up-to-date by Member States and published on Europass (according to Article

8)

EN 43 EN

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)

Digital Qualification Attestations Article 3 (1-3)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 7 (1-2)

Member States

Issuing

Authorities

Awarding

Bodies

EU Citizen/EU

resident

EU Citizen/EU

resident

Relying Parties

Request from the

EU citizen/EU

resident

Automatic

renewal of

credentials (e.g.

after expiry)

Request from the

relying party (e.g.

during an

application

process)

Lists of awarding bodies Article 3 (4) Member States

National

Authority

European

Commission

Update to the

awarding body

data

Lists of accreditations Article 3 (4) Member States

National

Authority

European

Commission

Update to the

accreditation data

Lists of qualifications and data on

qualifications listed in National

Article 8 (1-2)

Article 8 (3-5)

Member States

National

European

Commission

Update to the

qualifications data

EN 44 EN

Qualifications Frameworks (NQFs) Authority (Europass)

Annual statistical summary on numbers

of digital credentials

issued/renewed/withdrawn/suspended,

processing times, user experience and

stakeholder feedback.

Article 13 (1‑2) Member States

National

Authority

European

Commission

Annually

Revocation/ Suspension data Article 6 (1‑3)

Member State

issuing

authority

Other Member

States / relying

parties

Withdrawal or

suspension event

As it occurs

Comparable information on

qualifications

Article 8 (1-2)

Member States Europass

platform

European

Commission

Updates on the

information on the

qualifications,

awarding bodies

and accreditations

As the update

happens

EN 45 EN

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

Qualification

attestations

issuing and

revocation

System

Article 3 (1-3)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 9 (1‑4)

Article 12 (1‑2)

Issuance of digital

credentials to EUDI

Wallets in the form of

EUDI electronic

attestations of attributes.

Retrieval of historic

evidence by embedding

attributes in the body of

the digital credential.

Revocation list

management, and making

such lists available to

Relying Parties

Member States

issuing

authorities

Following

EUDI

specifications

By definition, the

issuing systems will

reuse EUDI

infrastructure

(including EUDI

trust framework and

relevant ETSI

standards) and

specifications

N/A

Digital

Qualification

attestations

Verification

Tool

Article 7 (1-2) Digital verification tool

to ensure that the

relying parties are able to

verify digital

qualification

attestations in accordance

with common minimum

verification requirements

Member States Article 7 (1-

2) requires

Member

States to

implement a

verification

application

suitable for

If deemed useful, the

Commission might

provide a reference

implementation of

the app to be

reused/configured by

Member States, on a

voluntary basis as

N/A

EN 46 EN

and processes use by all

their

qualification

holders.

described in the

supporting measures

(and Recital 16)

Europass System Article 8 (1)

Article 8 (6)

Storing data on

qualifications, awarding

bodies and

accreditations.

Presenting the

information on

qualifications and

accreditations.

Qualifications

information is also used

in the Europass

comparison of single

qualification tool.

In order to fully support

the SPI, the following

developments must be

carried out:

1. Support for an

awarding body

registry

2. Versioning, and

timestamping of

qualifications and

accreditations

3. Improving

European

Commission and

Member States

(data providers)

Built on

existing

Europass

tools which

already

follow Web

Content

Accessibility

Guidelines

(WCAG) 2.1

Enhancement of

existing Europass

tools

N/A

EN 47 EN

performance and

scalability

4. Adaptations

following ELM

modifications

Enhancement of the

existing qualifications

comparison tool

functionality to include:

1. Mechanism to

determine the

EQF level of a

given

qualification and

export it

Search for similar

national qualifications in

other MSs

For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments

EN 48 EN

Digital Qualification attestations issuing and revocation System

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act It is not foreseen to create or use any AI systems for this solution.

EU Cybersecurity framework All issuance protocols will be compliant with EUDI protocols and standards for the

digital attestation format.

No additional cybersecurity requirements will be added by the regulation.

eIDAS Since the issuing systems need to issue EUDI attestation, they need to rely on

specifications set out in EUDI regulation (by definition compliant with eIDAS).

Single Digital Gateway and IMI The Once Only Technical System can be leveraged for confirming information to

be included in a digital qualification attestation and for issuers to identify the

authentic source.

GDPR (Reg. 2016/679) Processing of personal data is limited to what is necessary for issuance (article 13);

data minimisation and storage limitation apply.

Others N/A

EN 49 EN

Digital Qualification attestations Verification Tool

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act It is not foreseen to create or use any AI systems for this solution.

EU Cybersecurity framework All verification protocols will be compliant with EUDI protocols and standards for

the digital attestation format.

No additional cybersecurity requirements will be added by the regulation.

eIDAS The verification of EUDI digital attestation will be compliant with EUDI protocols

and standards, based on eIDAS.

Single Digital Gateway and IMI No interface with the Single Digital Gateway or IMI foreseen.

Others N/A

Europass

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act It is not foreseen to create or use any AI systems for this solution.

EU Cybersecurity framework No new specific cybersecurity requirements mandated by the regulation.

eIDAS N/A

Single Digital Gateway and IMI N/A

EN 50 EN

GDPR (Reg. 2016/679) Europass publishes NQF/Qualification metadata, not personal data of individual

holders.

Others N/A

EN 51 EN

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)

Other interoperability

solution(s)

Digital Qualification

attestations issuing and

revocation service

Service provided by Member

States issuing authorities to

issue digital credentials for

qualifications to citizens.

Service provided under the

EUDI Wallet framework and

implemented by the Member

States issuing authorities to

revoke or suspend a credential

when the underlying

qualification has been

withdrawn or suspended in

either the issuing or a

receiving Member State.

Qualification life-event

procedure and Digital

Credentials output added to

the Single Digital Gateway

Article 3 (1-3)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 9 (1‑4)

Article 16

N/A EUDI Wallet, EUDI trust

framework, EQF alignment,

European Learning Model35

Your Europe and the Single

Digital Gateway

Digital Qualification

attestations verification

Service provided by relying

parties in the Member States

(employers, regulators, etc.)

Article 7 (1‑2)

N/A EUDI trust framework, ELM,

Reference Implementation of the

verification service (Recital 16

35 ELM was CAMSS assessed: https://interoperable-europe.ec.europa.eu/collection/common-assessment-method-standards-and-specifications-camss/solution/camss-

assessment-elm-eif-scenario

EN 52 EN

service to accept and verify digital

credentials

(Reference to section 4.5:

Measures to support digital

implementation))

Publication of National

Qualifications data service

(Europass and EU open

data portal)

Service provided by the

European Commission (on

Europass and EU Open Data

portal)

Article 3 (4)

Article 8 (3-6)

N/A European Learning Model

EN 53 EN

Impact of the requirement(s) as per digital public service on cross-border interoperability

Digital Qualification attestations issuing and revocation system

Assessment Measure(s) Potential remaining barriers (if applicable)

Alignment with existing digital and

sectorial policies

Please list the applicable digital and

sectorial policies identified

Issuance:

• EUDI Regulation for the issuing of digital

credentials which will require an

amendment to the ETSI profiles to

support W3C VCDM.

• Skills Portability Initiative Regulation

• SDG Regulation

Revocation:

• EUDI Regulation

• Skills Portability Initiative

N/A

Organisational measures for a

smooth cross-border digital public

services delivery

Please list the governance measures

foreseen

Issuance:

• Registration of issuers in the EUDI trust

framework to be recognised as an

authorised issuer

• Communication to the Commission of list

of lists of awarding bodies, accreditations

and qualifications, and publication on

Qualifications Digitalisation Group

Revocation:

Governance: separate and binding roles (the

issuer refuses issuance, revokes or suspends,

and maintains the information; relying parties

N/A

EN 54 EN

across the Union must refuse validity), with

the conditions for recovery of the

qualification left to the awarding Member

State – a national decision with Union-wide

effect.

Management: a cross-border

status/revocation service making the

information accessible within 24 hours of the

request, with a record of revocation and

suspension statuses, a distinction between

permanent and temporary states, and a re-

issuance workflow conditional on

verification of national requirements.

Measures taken to ensure a shared

understanding of the data

Please list such measures

• Data specifications described in Annex I

II, IV and V

• CAMMS assessment performed on the

ELM model

• A publicly available ELM Browser which

precisely describes the ontology, all the

application profiles, and properties.

• Futurium peer exchange group for ELM

N/A

Use of commonly agreed open

technical specifications and

standards

• Technical specifications described in

Annex I, II, IV and V.

N/A