| Dokumendiregister | Riigikantselei |
| Viit | 26-01918-1 |
| Registreeritud | 29.09.2026 |
| Sünkroonitud | 30.09.2026 |
| Liik | |
| Funktsioon | |
| Sari | 02 Vabariigi Valitsuse istungite ja nõupidamiste ettevalmistamine ja korraldamine/2-5 Vabariigi Valitsuse otsuste alusdokumendid |
| Toimik | |
| Juurdepääsupiirang | Avalik |
| Adressaat | Haridus- ja Teadusministeerium, Justiits- ja Digiministeerium, Majandus- ja Kommunikatsiooniministeerium, Regionaal- ja Põllumajandusministeerium, Siseministeerium, Sotsiaalministeerium |
| Saabumis/saatmisviis | Haridus- ja Teadusministeerium, Justiits- ja Digiministeerium, Majandus- ja Kommunikatsiooniministeerium, Regionaal- ja Põllumajandusministeerium, Siseministeerium, Sotsiaalministeerium |
| Vastutaja | |
| Originaal | Ava uues aknas |
| Taotle dokumendi eemaldamist või parandamist |
EN EN
EUROPEAN COMMISSION
Strasbourg, 15.9.2026 COM(2026) 995 final
2026/0273 (COD)
Proposal for a
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
amending Directive 2005/36/EC as regards the digitalisation of procedures and
recognition of professional qualifications issued outside the Union and Regulation (EU)
No 1024/2012
{SEC(2026) 995 final} - {SWD(2026) 995 final} - {SWD(2026) 996 final} -
{SWD(2026) 997 final}
(Text with EEA relevance)
EN 1 EN
EXPLANATORY MEMORANDUM
1. CONTEXT OF THE PROPOSAL
• Reasons for and objectives of the proposal
The free movement of workers, freedom of establishment and freedom to provide services are
fundamental freedoms enshrined in the Treaties, underpinning the ability of Union citizens to
pursue professional and economic activities across the Union. These Treaty freedoms are
complemented by the Charter of Fundamental Rights of the European Union, which
recognises the right to engage in work and to pursue a freely chosen or accepted occupation,
as well as the freedom of Union citizens to seek employment, work, exercise the right of
establishment and provide services in any Member State. They are further supported by the
European Pillar of Social Rights, proclaimed in 2017, whose first chapter on equal
opportunities and access to the labour market emphasises the importance of skills and
employability. In particular, Principle 1 on education, training and lifelong learning
recognises everyone’s right to maintain and acquire skills enabling full participation in society
and successful transitions in the labour market, while Principle 4 provides for the right to
active support to find or change jobs, including re-skilling and job-search assistance.
This long-standing framework is reflected in the Commission’s Political Guidelines for 2024–
2029, which place skills portability and the effective use of skills acquired across borders
among the priorities for strengthening labour mobility and enabling people to make full use of
their skills throughout the Union. In her Political Guidelines for 2024–2029, the President of
the Commission underlined the need to ensure that the Union benefits from high-quality
skills, irrespective of where and how they were acquired, and to facilitate the recognition of
skills acquired in one country in another. These objectives are also reflected in the ‘One
Europe, One Market’ roadmap, launched in April 2026 with the objective of further
deepening and completing the Single Market by the end of 2027, including by removing
remaining barriers, reducing administrative burden and strengthening the Union’s
competitiveness.
This proposal forms part of the Skills Portability Initiative (SPI), which is a key component of
the Fair Labour Mobility Package (FLMP). The SPI was announced under the Union of
Skills, adopted in March 2025 as the Commission’s strategy to strengthen Europe’s human
capital and competitiveness, including by improving the portability of skills and qualifications
across the Union. The present proposal implements Action 2 of the SPI. It aims at further
facilitating and modernising the recognition of professional qualifications in regulated
professions by leveraging digital tools to streamline, accelerate and make recognition
procedures more efficient, while strengthening administrative cooperation between competent
authorities and improving the monitoring of the implementation and functioning of the
recognition system.
By amending the Directive, this proposal aims to reduce the time and cost required to have a
professional qualification recognised in another Member State, making recognition more
transparent and digital.
For regulated professions, Directive 2005/36/EC on the recognition of professional
qualifications (‘the Directive’) is a cornerstone of the Union framework for professional
mobility. It facilitates the free movement of professionals by establishing rules for the
recognition of professional qualifications, while taking account of Member States’
EN 2 EN
competence to regulate professions and to lay down requirements for their pursuit in order to
safeguard relevant public interests.
The need for action is supported by the Commission's report on the implementation of the
Directive covering the period 2020–2024, as well as by the studies and stakeholder
consultations underpinning the impact assessment accompanying this proposal. This evidence
points to persistent shortcomings in the availability and quality of information provided to
applicants, inefficiencies and unnecessary burdens in recognition procedures, and challenges
affecting administrative cooperation between competent authorities.
The proposal therefore introduces targeted amendments to simplify and accelerate recognition
procedures, to improve the availability, completeness and reliability of information on
recognition requirements and procedures, and to strengthen administrative cooperation
between competent authorities. Across these areas, it promotes the use of interoperable digital
tools to support more efficient, transparent and user-friendly recognition processes throughout
the Union. The proposal does not alter the conditions under which Member States regulate
professions or the national arrangements for taking recognition decisions.
The other two legislative initiatives under the Skills Portability Initiative concern digital
qualification attestations and recognition of professional qualifications obtained outside the
EU (in a third country). The former relies on the measures developed under the proposal for
the Regulation establishing a framework for portability of skills and qualifications (SPI
Action 1, “Skills Portability Act”). The latter refers to a proposal of the Directive establishing
a framework for the recognition of third-country qualifications held by third-country
nationals, to ensure that holders of such qualifications who are EU nationals are not treated
less favourably than third country nationals (SPI Action 3). When applicable, all three
proposals under the SPI refer to each other to avoid repetitions and ensure coherence.
• Consistency with existing policy provisions in the policy area
This proposal is fully consistent with the existing EU framework governing the recognition of
professional qualifications. Directive 2005/36/EC remains the central Union instrument in this
area, without prejudice to the limited number of sector-specific rules laid down in other Union
legal acts. It also continues to govern both establishment and the temporary and occasional
provision of services in regulated professions. As recognised by Article 3 of Directive
2006/123/EC on services in the internal market, where the provisions of the two Directives
overlap, Directive 2005/36/EC prevails. This proposal does not affect that relationship.
• Consistency with other Union policies
This proposal is consistent with the Union's broader policy and legislative framework on the
digital transformation of public administration. In particular, it complements the Single
Digital Gateway Regulation (EU) 2018/1724 and the Once-Only Technical System
established thereunder, Regulation (EU) No 910/2014 (eIDAS) as amended by Regulation
(EU) 2024/1183 establishing the European Digital Identity framework, and the Interoperable
Europe Regulation (EU) 2024/903 in particular as regards the principle of interoperability by
design and the requirements applicable to binding requirements affecting cross-border
interoperable digital public services. By promoting interoperable digital credentials, trusted
electronic exchanges of information and interoperable public services, the proposal
contributes to the common objective of delivering more efficient, user-friendly and seamless
cross-border administrative procedures across the Union.
EN 3 EN
2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY
• Legal basis
The proposal is based on the same legal basis as Directive 2005/36/EC, namely, Articles 46,
53(1) and 62 of the Treaty on the Functioning of the European Union (TFEU). These
provisions empower the Union to adopt measures facilitating the free movement of workers,
the freedom of establishment and the freedom to provide services, including through the
mutual recognition of diplomas, certificates and other evidence of formal qualifications and
the coordination of national provisions governing access to and the pursuit of regulated
professions.
• Subsidiarity (for non-exclusive competence)
The initiative concerns the functioning of the internal market, an area of shared competence
between the Union and the Member States pursuant to Article 4(2)(a) TFEU. Accordingly, the
principle of subsidiarity applies.
EU-level action is this area has been established as necessary and appropriate since the
adoption of the original framework in 2005, and subsequent updates to this common
framework can only be achieved through action at Union level.
Coordinated action is necessary because professional recognition inherently requires cross-
border interaction between competent authorities, including information exchange,
qualification validation, and document verification. Because these challenges are structural
and transnational, isolated national measures cannot ensure reciprocity, establish common
operational rules, or eliminate heterogeneous practices. Furthermore, integrating digital tools
to streamline these procedures requires a unified approach; developing such solutions
independently at the national level risks fragmentation, duplication, and lack of
interoperability.
Union action is also essential to strengthen transparency and enforcement. Current monitoring
relies heavily on complaints by individual applicants and Member States’ self-reported data,
which fail to provide a comprehensive basis for identifying systematic non-compliance.
Action at EU level is required to establish consistent, comparable data to enable more timely
and more accurate monitoring, supporting targeted corrective measures. By streamlining
information requirements, deadlines, and cooperation practices, a coordinated framework
reduces administrative effort, lowers reporting costs, and minimizes divergent assessments.
Ultimately, only coordinated national systems can achieve this level of transparency; Union
intervention is necessary to resolve persistent administrative burdens and legal uncertainty,
ensuring the existing framework operates as intended and Treaty-conferred rights can be
effectively exercised in practice.
EU-level action also offers clear economies of scale. A single, streamlined framework is
significantly more cost-effective than multiple, parallel national systems requiring complex
technical interfaces. While national administrations will incur initial adaptation costs, these
will be well offset by long-term efficiency gains, reduced reporting burdens, and lower error
rates. Ultimately, uncoordinated national approaches cannot achieve the required consistency
or scale, making Union intervention the most effective way to ensure Treaty rights are able to
be meaningfully exercised.
EN 4 EN
• Proportionality
The proposal concerns the revision of Directive 2005/36/EC, an area where the need for
Union action is already established. The proposed amendments are limited to addressing
specific implementation shortcomings, namely fragmented information, unnecessarily
burdensome recognition procedures, uneven levels of digitalisation and inefficiencies in
administrative cooperation between competent authorities.
The proposal does not harmonise the substantive rules governing regulated professions or the
conditions for the recognition of professional qualifications. Member States remain fully
responsible for regulating professions, determining professional qualifications, assessing
applications and taking recognition decisions. Rather, the focus of the proposed measures is
on procedural improvements, such as clarifying certain procedural obligations, strengthening
administrative cooperation and facilitating the use of interoperable digital tools.
The proportionality of these measures was thoroughly evaluated across all policy options in
the impact assessment, balancing expected benefits against implementation effort.
Proportionality was assessed in the comparison of the policy options considered in the impact
assessment. The assessment also examined whether the scope, intensity and implementation
requirements of the proposed measures were commensurate with the objectives pursued. The
preferred option was selected as the most effective response while remaining strictly
necessary and proportionate. Although it entails a greater degree of intervention than
alternative options, this reflects the magnitude and persistence of the problems addressed and
remains confined to procedural aspects of the recognition framework, fully respecting
Member States' competence over the regulation of professions or substantive recognition
decisions as well as their competence in safeguarding public health, safety and the quality of
services.
• Choice of the instrument
As this proposal amends Directive 2005/36/EC, the appropriate legal instrument is a directive.
A coordinating amendment concerning Regulation 1024/2012 is ancillary to the amendment
of Directive 2005/36/EC.
3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER
CONSULTATIONS AND IMPACT ASSESSMENTS
• Ex-post evaluations/fitness checks of existing legislation
No ex-post evaluation was carried out specifically for the preparation of this proposal. The
most recent evaluation of the Directive was conducted in the context of its 2013 revision.
Subsequently, the main innovations introduced by Directive 2013/55/EU, namely the
European Professional Card and the Alert Mechanism, were subject to a dedicated assessment
in 2018. The decision not to undertake a further evaluation was based on the availability of a
recent and comprehensive implementation report for the years 2020-20241, published only a
few months before the preparation of this proposal. That report and the accompanying Staff
Working Document (SWD)2 provide an extensive assessment of the functioning of the
Directive, drawing on a broad range of evidence, including data from the Regulated
Professions Database, targeted surveys of competent authorities, national coordinators and
professional organisations, as well as other stakeholder input. It offers a detailed analysis of
1 COM(2026) 86 final 2 SWD(2026)64 final
EN 5 EN
the implementation of the existing framework, identifies the main challenges encountered in
practice and provides a robust evidence base for the preparation of this proposal.
• Stakeholder consultations
As detailed in the impact assessment accompanying this proposal, the preparation of the
initiative was supported by extensive stakeholder consultation activities.
In addition to the consultations carried out in the context of the recent implementation report,
the Commission conducted an open public consultation as part of the Skills Portability
Initiative as well as a series of targeted stakeholder consultations. Furthermore, a range of
targeted consultation activities were organised with competent authorities, national
coordinators, professional organisations and representatives of regulated professions, as well
as targeted surveys of competent authorities and citizens who had undergone recognition
procedures.
These consultation activities provided valuable evidence on the practical functioning of the
current framework, the challenges encountered by applicants and competent authorities, and
stakeholders' views on possible policy responses. Together with the other sources of evidence
supporting the impact assessment, they informed both the identification of the problems the
development of the measures included in this proposal.
The consultation activities revealed broad agreement among stakeholders on the main
challenges affecting the functioning of the current recognition system. In particular,
stakeholders consistently identified shortcomings in the information available to applicants,
inefficiencies in recognition procedures and scope for improving administrative cooperation
between competent authorities. There was also broad support for further digitalisation and
simplification of recognition procedures as a means of reducing administrative burden and
improving efficiency. Stakeholders further emphasised the need to support competent
authorities in implementing the Directive through common tools, clearer rules and
strengthened cooperation.
These views are reflected in the proposal, which addresses both shortcomings in the design of
the current framework and challenges relating to its implementation. On the one hand, it
introduces new common structural elements, most notably a mandatory European digital
workflow supporting recognition procedures across the Union. On the other hand, it
strengthens the implementation of the existing framework by clarifying procedural rules to
apply the Directive more consistently. Together, these measures are intended to remove the
main obstacles identified by stakeholders and improve the efficiency, predictability and
consistency of recognition procedures across the Union.
• Collection and use of expertise
The Impact assessment accompanying this legislative proposal was support by an external
study commissioned from EY Advisory Services S.p.A and Istituto per la Ricerca Sociale.
• Impact assessment
An impact assessment was carried out in support of this proposal and was informed by an
external study prepared for the Commission.
The impact assessment examined three policy options aimed at improving the consistent
implementation and effectiveness of the Directive. The first option focused on promoting
EN 6 EN
greater administrative convergence through non-legislative measures, such as guidance,
recommendations, peer learning and the exchange of good practices. The second option
combined targeted legislative amendments with increased digitalisation by proposing a
common European digital solution while allowing Member States to continue using
interoperable national systems. The third and preferred option complemented the digital
transformation of recognition procedures with a broader package of legislative measures
addressing additional sources of administrative burden and inefficiency, including the quality
of information provided to applicants, administrative cooperation between competent
authorities, document requirements, fees, paper-based procedures and procedural deadlines.
The third option was selected as the preferred one because it is expected to achieve the
objectives of the initiative most effectively while ensuring cost-effectiveness. It combines a
common European digital recognition solution, developed and financed by the Commission,
with legislative amendments designed to improve the operation of the recognition system. By
providing a common digital infrastructure at Union level, the preferred option reduces
implementation costs for Member States, creates economies of scale, and supports a more
consistent implementation of the Directive.
The impact assessment concludes that the preferred option will generate significant economic
and social benefits. It is expected that the preferred option will reduce the administrative costs
incurred by applicants and competent authorities in recognition procedures, while shortening
processing times and enabling professionals to enter the labour market more quickly.
Employers are also expected to benefit from faster and less cumbersome recruitment, reduced
vacancy durations and improved access to skilled workers.
Beyond these direct benefits, the proposal is expected to improve the functioning of the
internal market for professional services by facilitating the more efficient allocation of skills
across Member States. This is expected to contribute to addressing labour and skills shortages,
improving labour market matching, increasing labour productivity and strengthening the
resilience and competitiveness of the European economy. The proposal is also expected to
generate positive social impacts by improving employment opportunities, supporting upward
career mobility and enhancing income security for professionals seeking to exercise their
profession in another Member State.
• Regulatory fitness and simplification
The proposal contributes to the objectives of regulatory fitness by simplifying the recognition
of professional qualifications and reducing administrative burdens for applicants, competent
authorities and employers. It directly addresses the procedural complexities and inefficiencies
identified in the current framework, while preserving the core principles of the Directive and
Member States' responsibility for recognition decisions.
For applicants, the proposal makes it simpler to request and quicker to obtain a recognition
decision. Reducing reliance on paper-based processes, promoting the use of digital
attestations, limiting documentary requirements and providing more complete and
standardised information on recognition procedures should make recognition procedures more
predictable, reduce the number of incomplete applications and requests for additional
information, and lower the time and costs associated with preparing and submitting
applications.
For competent authorities, the proposal introduces a common digital workflow, integrating
artificial intelligence support, strengthens administrative cooperation and provides clearer
EN 7 EN
procedural rules. These measures are expected to reduce administrative effort, avoid
duplication of work, streamline the handling of recognition procedures and improve the
consistency and efficiency of decision-making across Member States.
For employers, faster and more predictable recognition procedures are expected to facilitate
recruitment, improve workforce planning and accelerate access to qualified professionals,
including in sectors experiencing labour and skills shortages.
The proposal contributes to the Union’s competitiveness by shortening the time needed to fill
vacancies in regulated professions. Small and medium enterprises are expected to benefit
proportionately more, while no new obligations are imposed on businesses.
Although the implementation of the new digital infrastructure will require initial investment
in IT systems, training and organisational adjustments, these transitional costs are expected to
be outweighed by lasting reductions in administrative burden, shorter processing times and a
more efficient and coherent recognition system across the Union.
• Fundamental rights
By facilitating the recognition of professional qualifications across Member States, the
proposal supports the effective exercise of the freedoms of movement, namely establishment
and the provision of services within the internal market and freedom of movement for
workers. By reducing administrative and regulatory barriers, the proposal enables mobile
professionals to pursue their profession on the basis of their qualifications and merits,
irrespective of their nationality and the Member State in which they obtained their
qualifications. In doing so, it contributes to the principles of equal treatment and non-
discrimination, as enshrined in Article 21 of the Charter of Fundamental Rights, and
facilitates the effective exercise of the rights conferred by the Treaties. It also promotes the
right to engage in work and to pursue a freely chosen occupation, as enshrined in Article 15 of
the Charter of Fundamental Rights, in particular paragraph 2, which guarantees Union citizens
the freedom to seek employment, to work, to exercise the right of establishment and to
provide services in any Member State.
4. BUDGETARY IMPLICATIONS
The proposal has budgetary implications for the Union budget related to the development,
deployment and operation of the European Digital Recognition Solution (EDRS), which will
be developed, financed and operated by the Commission, within three years after entry into
force of this Directive.
The EDRS will provide a common digital workflow for the recognition of professional
qualifications across the Union and will include interfaces for applicants and competent
authorities, AI-assisted functionalities to support the processing of recognition applications,
interoperability with relevant Union systems, including the Single Digital Gateway Once-
Only Technical System and the European Digital Identity Wallet, analytical and statistical
functionalities, and integration with the enhanced Regulated Professions Database.
For 2027, the resource of the deployment of the system will come from EaSI. This initiative
should be financed within the agreed envelope of the programme For the following years, the
resources needed may be provided in the Commission’s proposal for the next MFF 2028-
2034, in particular the EU Facility under the National and Regional Partnership Plans. The
Commission assesses that the HR needs will be covered by redeployment to meet the needs
EN 8 EN
generated by this proposal. The estimated impact on expenditure and staffing for 2028 and
beyond is added for illustrative purposes only and does not pre-judge the next Multiannual
Financial Framework. The source of financing and scope of Union financial commitment in
the post-2027 period remain subject to the outcome of interinstitutional negotiations on the
MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.
All appropriations and staffing allocations as of 2028 are indicative.
The Commission will keep Member States informed about the development of EDRS,
allowing them to prepare for its deployment. In any case, the EDRS must be made operational
ahead of the date for the transposition of the corresponding procedural obligations of the
Member States under this proposal. Member States are not required to bear costs for
developing or adapting national solutions supporting recognition processes, as the EDRS
together with other EU solutions such as IMI will fully cover the functionality that competent
authorities need to process applications for recognition of professional qualifications.
By providing and financing a common Union-wide digital infrastructure, the proposal avoids
the need for Member States to develop and maintain separate national solutions, thereby
reducing implementation costs, creating economies of scale and supporting the consistent
implementation of the Directive across the Union. The detailed budgetary implications of the
proposal are set out in the accompanying financial statement.
5. OTHER ELEMENTS
• Implementation plans and monitoring, evaluation and reporting arrangements
The Commission will monitor implementation in close cooperation with the national
coordinators and competent authorities. Monitoring will focus on the extent to which the
proposal succeeds in simplifying recognition procedures, reducing administrative burden and
costs, and improving administrative cooperation.
Monitoring will be based on two complementary sources: biennial reporting by Member
States, coordinated by the national coordinators, and annual data generated through the
EDRS. The first data collection will take place before the deployment of the new system to
establish a baseline, followed by regular monitoring after implementation.
The monitoring framework includes indicators measuring the quality and completeness of
information provided to applicants, the efficiency and timeliness of recognition procedures,
the administrative burden associated with recognition applications, and the effectiveness of
administrative cooperation between competent authorities. A detailed set of indicators,
together with the data sources and collection methods, is set out in the Impact Assessment
accompanying this proposal. The Commission will carry out an evaluation of the Directive
approximately five years after the expiry of the transposition deadline.
• Explanatory documents (for directives)
Pursuant to Article 3 of this Directive, Member States are required to transpose its provisions
into national law and to notify the Commission of the corresponding national measures. When
notifying those measures, Member States should provide sufficient information to enable the
Commission to assess the completeness and correctness of transposition. This information
should clearly indicate how the provisions of the Directive have been implemented in national
law.
EN 9 EN
• Detailed explanation of the specific provisions of the proposal
Article 1 sets out the amendments to Directive 2005/36/EC. Article 2 contains an amendment
of the provisions referred to in the annex of Regulation (EU) No 1024/2012 on administrative
cooperation through the Internal Market Information System (‘the IMI Regulation’). Article 3
contains the provisions on transposition, Article 4 concerns the entry into force of the
amending Directive, and Article 5 specifies its addressees.
The substantive amendments introduced by Article 1 are organised around the following main
themes:
Digitalisation of recognition procedures: The proposal replaces the existing European
Professional Card framework with a European Digital Recognition Solution established by
new Article 56b. While recognition decisions remain the responsibility of Member States, the
entire administrative workflow will be carried out through a common digital infrastructure
used by all competent authorities. The proposal also introduces a digital-only principle
through Article 56c.
Faster and more predictable recognition procedures: The proposal introduces, through
Article 56d, deadlines for each key procedural step, creating a structured workflow from the
submission of an application to the final recognition decision. This replaces the current
approach, under which only the overall duration of the procedure is defined, and substantially
reduces the maximum duration of recognition procedures under both the automatic
recognition system and the general system. For temporary and occasional provision of
services, Article 7(4) similarly shortens the duration of prior checks. To reinforce compliance,
the new Article 56e introduces a financial compensation mechanism for applicants affected by
excessive delays in the administrative handling of their recognition applications.
Simplification of procedural requirements: The proposal further harmonises the procedural
framework by clarifying, through amendments to Article 50, that competent authorities may
request only the documents expressly provided for by the Directive. Article 50(8) requires
Member States to accept those documents in any official language of the Union, while Article
56c(3) establishes rules on communication with applicants. A new Article 51a introduces
common principles governing recognition fees. Together, these measures reduce unnecessary
administrative burdens, improve legal certainty and promote more consistent application of
the Directive.
Modernisation of notifications and reporting: The proposal modernises the notification
framework by amending Article 59(1), requiring Member States to submit notifications
concerning regulated professions through the Internal Market Information System. It also
strengthens the Commission's role in monitoring the implementation of the Directive through
amendments to Article 60, enabling reporting to rely on statistical information generated by
the European Digital Recognition Solution and thereby improving the quality, comparability
and availability of implementation data.
Strengthened cooperation and governance: The proposal introduces a more structured
governance framework through new Article 60a, strengthening cooperation between the
Commission and the Member States within the Group of Coordinators on the Recognition of
Professional Qualifications. Annual work programmes will provide a clearer framework for
monitoring implementation, identifying common challenges, exchanging good practices and
preparing future developments of the recognition system. The strengthened governance
EN 10 EN
framework is also intended to facilitate and streamline the use of the Directive's delegated
powers, in particular with regard to the establishment of Common Training Frameworks.
Equal treatment of EU nationals and third-country nationals: Amendments to Articles
2(2), 3(3) and 10(g) of Directive 2005/36/EC align the Directive with [Directive xxxx/xxx/EU
on the recognition of qualifications of third-country nationals], which establishes a framework
for the recognition of third-country qualifications held by third-country nationals. The
existing provisions are replaced by new rules on recognition of qualifications obtained outside
the Union in Title Va, ensuring coherence between the two legal frameworks while preserving
the distinction between the general system and automatic recognition under Directive
2005/36/EC as well as the main features underlying each of those systems.
EN 11 EN
2026/0273 (COD)
Proposal for a
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
amending Directive 2005/36/EC as regards the digitalisation of procedures and
recognition of professional qualifications issued outside the Union and Regulation (EU)
No 1024/2012
(Text with EEA relevance)
THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular
Article 46, Article 53(1) and Article 62 thereof,
Having regard to the proposal from the European Commission,
After transmission of the draft legislative act to the national parliaments,
Having regard to the opinion of the European Economic and Social Committee3,
Acting in accordance with the ordinary legislative procedure,
Whereas:
(1) The Single Market is a cornerstone of European integration and a key driver of the
Union’s competitiveness, prosperity and resilience. Its full potential depends, inter
alia, on enabling people to move freely across the Union and to put their skills and
qualifications to use wherever they are needed. Facilitating mobility contributes to a
better allocation of skills across the Union, helps address labour and skills shortages
and strengthens the capacity of the Union economy to respond to changing economic
and demographic needs. Therefore, remaining barriers to the mobility of professionals
should be reduced. This is particularly important in the field of regulated professions,
where access to or pursuit of a professional activity is subject to the possession of
specific professional qualifications. Differences in national qualification requirements
may raise obstacles to the mobility of qualified professionals between Member States.
(2) Directive 2005/36/EC of the European Parliament and of the Council4 sets out the
rules governing the recognition of professional qualifications for access to and pursuit
of regulated professions and is a crucial instrument supporting the mobility of workers
and services within the Single Market. It establishes a Union framework for the
recognition of professional qualifications and thereby plays a central role in enabling
professionals to exercise their right to free movement while ensuring that the
requirements governing access to regulated professions in the host Member State are
appropriately taken into account. In order to further facilitate professional mobility
within the Single Market, that framework should be modernised and made simpler,
3 OJ C […], […], p. […]. 4 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the
recognition of professional qualifications, OJ L 255, 30.9.2005, p. 22, ELI:
http://data.europa.eu/eli/dir/2005/36/oj
EN 12 EN
faster and more efficient, in particular by making better use of digital tools,
streamlining recognition procedures and strengthening administrative cooperation
between competent authorities.
(3) Directive 2005/36/EC, which lays down rules governing the recognition of
professional qualifications of Union citizens, already contains specific rules
concerning qualifications obtained in third countries. In particular, its Article 2(2)
provides that each Member State may, in accordance with its national rules, permit
Member State nationals holding evidence of professional qualifications obtained in a
third country to pursue a regulated profession on its territory and that, in the case of
professions covered by Title III, Chapter III, that recognition is to respect the
minimum training conditions laid down in that Chapter. In addition, Article 3(3) of
Directive 2005/36/EC, first sentence, read in conjunction with Article 10, point (g),
ensures that, where a Member State national has obtained recognition of their third-
country qualification in one Member State and has three years of certified professional
experience in that profession within the same Member State, their third-country
qualification is to be regarded as evidence of formal qualifications under that
Directive, which should entitle them to recognition of their evidence of professional
qualifications under the general system when seeking access to the profession in
another Member State. With the adoption of [Directive xxxx/xxx/EU on the
recognition of qualifications of third-country nationals5], establishing a framework for
the recognition, for the purpose of establishment, of third-country qualifications held
by third-country nationals, it is appropriate to ensure that Directive 2005/36/EC also
establishes a coordinated approach to the recognition of qualifications obtained by
Member State nationals outside the Union.
(4) To that end, the necessary adjustments should be made to Directive 2005/36/EC to
ensure coherence between the two legal acts. It is therefore necessary to include a new
Title Va of Directive 2005/36/EC so as to ensure that each Member State develops
appropriate procedures for the recognition of professional qualifications obtained
outside the Union held by nationals of a Member State. Such procedures should ensure
that nationals of a Member State seeking recognition of their professional
qualifications in a host Member State for the purposes of establishment are not subject
to rules that are less favourable than those applicable to the third-country nationals
seeking recognition of their professional qualifications in that Member State.
(5) The distinction between, and underlying logic of, the general system of recognition
and the system of automatic recognition established by Directive 2005/36/EC should
be preserved, while taking due account of the specificities of qualifications awarded
outside the Union to ensure that the conditions required for access to and pursuit of the
profession in the host Member State are met.
(6) In its Special Report 10/24 on the recognition of professional qualifications in the
Union,6 the European Court of Auditors considered that, while Directive 2005/36/EC
is an essential mechanism, it is used sparsely and inconsistently. To improve the
system of recognition of professional qualifications, it notably recommended annual
updating of Annex V to that Directive, reducing the deadline for recognition through
the automatic system that benefits professions for which mandatory minimum training
5 […] 6 Special report 10/2024: The recognition of professional qualifications in the EU – An essential
mechanism, but used sparsely and inconsistently
EN 13 EN
requirements are set under the Directive, as well as ensuring reliable and consistent
information for citizens.
(7) Procedures for the recognition of professional qualifications can come with a high
burden for applicants. Professionals seeking recognition of qualifications acquired in
another Member State are required to submit multiple supporting documents,
including certified copies and translations, sometimes in paper form, and to bear fees
which vary considerably between Member States. Such requirements may discourage
professionals from pursuing opportunities in other Member States. Reducing the
reliance on physical documents while ensuring access to underlying information is
therefore key to facilitate the free movement of professionals within the Union.
(8) While most procedures for the recognition of professional qualifications under
Directive 2005/36/EC are completed within the applicable timeframes, persistent
delays in some cases continue to affect applicants and may hinder the timely access to
regulated professions. Such delays can entail significant costs or lost opportunities for
applicants while also affecting employers awaiting the recruitment of qualified
professionals, particularly in sectors facing labour and skills shortages. It is therefore
necessary to modernise, simplify and improve the efficiency of procedures for the
recognition of professional qualifications by laying down precise deadlines for the
exchange of information and for mutual assistance between the competent authorities
of the host Member State and those of the home Member State.
(9) To be able to submit complete recognition applications, applicants should be provided
with reliable information to support them in the process of recognition of their
qualifications. They should be able to understand, at an early stage, whether and under
which conditions they may access a regulated profession in another Member State. It
is therefore necessary to ensure that clear, trustworthy and up-to-date information is
available for applicants before starting a procedure and that they are appropriately
guided towards the relevant profession, applicable national rules and required
supporting documents.
(10) The European Professional Card introduced by Directive 2013/55/EU of the European
Parliament and of the Council7 has remained confined to a limited number of
professions and, given its case-specific design, has not proven capable of being scaled
up into a broader or more comprehensive solution for the recognition of professional
qualifications. To ensure a smooth and orderly transition to that solution, the European
Professional Card (EPC) should therefore be phased out gradually. To that end,
Member States should, during a limited transitional period, continue issuing the EPC.
(11) To facilitate the recognition of professional qualifications, a common Union IT
solution, the European Digital Recognition Solution, should be established at Union
level to support the digitalisation of procedures for the recognition of professional
qualifications. That system should provide a common digital infrastructure enabling
applicants to submit applications and supporting documents, including by reusing
relevant data from national identity or credential systems, and to receive information
on the status and outcome of their applications. It should facilitate secure and efficient
cooperation between competent authorities, reduce administrative burden and undue
7 Directive 2013/55/EU of the European Parliament and of the Council of 20 November 2013 amending
Directive 2005/36/EC on the recognition of professional qualifications and Regulation (EU)
No 1024/2012 on administrative cooperation through the Internal Market Information System ( ‘the IMI
Regulation’ ) OJ L 354, 28.12.2013, pp. 132–170,ELI: http://data.europa.eu/eli/dir/2013/55/oj
EN 14 EN
delays, and simplify procedures for applicants and competent authorities. It should
also contribute to the consistent application and uniform implementation of Directive
2005/36/EC across Member States, while fully respecting data protection requirements
and the organisation and functioning of national administrative systems.
(12) The introduction of stricter procedural timeframes for the exchange of information and
mutual assistance between the competent authorities should be accompanied with
measures that support Member States in making that cooperation more efficient
through a common digital workflow. The European Digital Recognition Solution
should therefore support secure communication, full traceability of procedural steps,
legal certainty and the timely handling of applications.
(13) The use of digital solutions should contribute to the more efficient organisation of
procedures for the recognition of professional qualifications. To that end, based on the
digital qualification attestations made available under [Regulation(EU)XXX
establishing a framework for portability of skills and qualifications and amending
Regulation (EU) 2018/1724]8, applicants should be able to obtain, by digital means,
formal evidence of qualifications issued by the competent authorities of the home
Member State and to verify, prior to submission, whether their application is complete,
including as regards the adequacy of supporting documents and translations. Digital
tools should also support competent authorities in the assessment of applications,
including the examination of supporting evidence, facilitate the secure exchange of
information with authorities in other Member States, and improve communication
with the applicants. These improvements should contribute to shorter processing times
for applications and to a reduction in the applicable deadlines.
(14) The Internal Market Information System (‘IMI’), established by Regulation (EU) No
1024/2012 of the European Parliament and of the Council9, is a tool supporting
administrative cooperation between competent authorities in the recognition of
professional qualifications under Directive 2005/36/EC. The European Digital
Recognition Solution established under Directive 2005/36/EC should build on and
interoperate with IMI, avoiding duplication of communication channels and preserving
the accumulated functionality of the existing tool. The Annex to that Regulation
should be amended in accordance with the amendments to the provisions of this
Directive.
(15) Regulation (EU) 2018/1724 of the European Parliament and of the Council10
established the Single Digital Gateway and the Once-Only Technical System, enabling
the cross-border exchange of evidence between competent authorities without
requiring users to resubmit documents already held by another public authority. Its
continued implementation can support more efficient recognition procedures by
allowing supporting documents exchanged through the Once-Only Technical System
to be used within the European Digital Recognition Solution, reducing the burden on
applicants to obtain and submit certified copies of evidence already available through
public registers or authorities in another Member State.
8 […] 9 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on
administrative cooperation through the Internal Market Information System and repealing Commission
Decision 2008/49/EC, OJ L 316, 14.11.2012, p.1, ELI: http://data.europa.eu/eli/reg/2012/1024/oj 10 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018
establishing a single digital gateway to provide access to information, to procedures and to assistance
and problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p.
1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj
EN 15 EN
(16) The publicly available database of regulated professions referred to in Article 59(1) of
Directive 2005/36/EC set up and maintained by the Commission provides a centralised
overview of professions that are regulated in each Member State, the applicable legal
provisions, and the competent authorities responsible. To ensure legal certainty and
consistency, that database should constitute the single authoritative source of
information on the regulatory status of professions across the Union, and Member
States should keep the information they notify complete, accurate and up to date.
(17) Language barriers can complicate and delay recognition procedures. Recent advances
in machine translation, including the Commission's eTranslation service, make it
possible to process documents submitted in another official language of the Union by
facilitating understanding of their content. The continuous improvement in the quality
of machine translation is steadily increasing confidence in translated documents and is
reshaping the contribution of human translators towards quality assurance and
verification. Competent authorities should therefore be able to rely on machine
translation integrated into the European Digital Recognition Solution to facilitate the
handling of applications, while preserving the possibility of requesting a certified
human translation where appropriate.
(18) To support the digitalisation of procedures under Directive 2005/36/EC, the European
Digital Recognition Solution, which would be built on a Union-wide infrastructure for
digital qualification attestations should allow applicants to use and share trusted digital
evidence across borders more efficiently. The European Digital Recognition Solution
established by this Directive constitutes a cross-border digital public service within the
meaning of Regulation (EU) 2024/903 of the European Parliament and of the Council
(Interoperable Europe Act)11 and is subject to the requirements laid down in that
Regulation, including the obligation to carry out an interoperability assessment. In
accordance with the requirements applicable to European Digital Identity Wallets
under Regulation (EU) 910/2014 of the European Parliament and of the Council12, the
European Digital Recognition Solution should be interoperable with the EU Digital
Identity Wallet so that applicants can submit, reuse and securely share, under their
control, pre-authenticated digital documents stored therein, including evidence of
formal qualifications. By relying on standardised digital qualification attestations and
interoperable systems, such a framework should help competent authorities access
reliable and up-to-date information more quickly, accelerate verification, reduce
repeated requests for the same evidence, and support faster, more consistent
recognition decisions across Member States.
(19) To support the digitalisation of recognition procedures under Directive 2005/36/EC,
Member States should ensure the secure receipt and verification of credentials, as well
as their use in the digital processing of recognition requests and the issuance of
recognition decisions. The European Digital Recognition Solution should further
reinforce confidence of applicants and employers in the use of digital evidence in
cross-border recognition procedures for regulated professions. Digital qualification
attestations issued in accordance with [Regulation(EU)XXX establishing a framework
11 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying
down measures for a high level of public sector interoperability across the Union (Interoperable Europe
Act), OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj 12 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on
electronic identification and trust services for electronic transactions in the internal market and
repealing Directive 1999/93/EC, OJ L 257, 28.8.2014, p. 73, ELI:
http://data.europa.eu/eli/reg/2014/910/oj
EN 16 EN
for portability of skills and qualifications and amending Regulation (EU) 2018/1724]
should enable competent authorities to rely on their authenticity without carrying out
further checks. For other documents submitted in support of recognition requests,
where checks of authenticity are necessary, greater digitalisation should enable
competent authorities to carry out such checks more efficiently and consistently,
helping to detect irregularities and prevent fraudulent submissions.
(20) To guarantee equal treatment and effective access, applicants who are unable to
undergo the procedure by electronic means only, including due to limited digital skills,
should not be disadvantaged in the exercise of their rights under Directive
2005/36/EC. Member States should make appropriate arrangements to enable such
applicants to pursue the relevant procedures by non-electronic means, while ensuring
that their applications are handled with the same diligence, without undue delay and
subject to the same procedural safeguards as applications submitted through the digital
solution. In this context, documents submitted in the course of such procedures may be
provided in different formats, including paper documents that have been scanned and
converted into electronic form, as well as electronic documents including electronic
attestations of attributes set out in Commission Implementing Regulation (EU)
2024/297913. The use of different formats should not lead to discrimination against the
applicant provided that the authenticity, integrity and, where relevant, origin of the
documents can be appropriately assessed. Where an applicant makes use of non-
electronic means for justified reasons, Member States should ensure that the
competent authority, or another designated body, enters the necessary data and
documents into the digital system without undue delay and keeps the applicant
appropriately informed of the progress of the procedure. Member States should also
provide adequate technical and digital support to applicants using the digital solution,
in particular to those with limited digital skills, to ensure effective access on an equal
basis.
(21) Competent authorities may, in the examination of applications for the recognition of
professional qualifications, be assisted by the European Digital Recognition Solution.
Such assistance could entail the assessment of the completeness of applications with
respect to the appropriate information and relevant evidence provided, the authenticity
of documents submitted, the identification of substantial differences between the
training evidenced by the applicant and the national training requirements, the
indication of possible compensation measures (aptitude tests or adaptation periods) in
accordance with Directive 2005/36/EC, and the identification of similar previously
assessed cases with a view to promoting consistency in decision-making.
(22) The Commission and Member States, in their respective capacities as processor and
controllers, within the meaning of Article 29(3) of Regulation (EU) 2018/1725 of the
European Parliament and of the Council14 and Article 28(3) of Regulation (EU)
13 Commission Implementing Regulation (EU) 2024/2979 of 28 November 2024 laying down rules for the
application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards
the integrity and core functionalities of European Digital Identity Wallets, OJ L, 2024/2979, 4.12.2024,
ELI:http://data.europa.eu/eli/reg_impl/2024/2979/oj 14 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the
protection of natural persons with regard to the processing of personal data by the Union institutions,
bodies, offices and agencies and on the free movement of such data, OJ L 295, 21.11.2018, p. 39, ELI:
http://data.europa.eu/eli/reg/2018/1725/oj
EN 17 EN
2016/679 of the European Parliament and of the Council15, should implement
appropriate technical and organisational measures to safeguard personal data against
unauthorised access, accidental loss, or unlawful processing.
(23) Where an excessive delay is attributable to the competent authority and not to the
applicant, it should entitle the latter to an appropriate and proportionate compensation
for the economic disadvantage caused by the delay.
(24) The benefits of automatic recognition could be further extended to additional
professions through fuller use of the mechanism established by Directive 2005/36/EC
for the development of common training frameworks. Where a common set of
minimum knowledge, skills and competences necessary for the pursuit of a specific
profession can be identified and is shared by at least one third of the Member States,
common training frameworks can provide an effective means of promoting
professional mobility while respecting national regulatory approaches and training
systems. To attain this objective, a strengthened cooperation among competent
authorities is needed through the Group of Coordinators established by Commission
Decision 2007/172/EC16. While contributing to the overall consistent and effective
implementation of Directive 2005/36/EC, including through the preparation of annual
work programmes and the exchange of experience and best practices, the Group
should also serve as a forum for outreach to and exchange with professionals, their
representative organisations and social partners, including on labour market needs,
quality standards and professional autonomy. In particular, it should contribute to
identifying emerging common sets of knowledge, skills and competences, assessing
needs and expectations in the professions, and exploring opportunities for the
development of common training frameworks in accordance with this Directive.
(25) To ensure coherence, transparency and proportionality, and to avoid duplicative
reporting obligations, the additional monitoring and evaluation requirements linked to
the digitalisation and simplification measures introduced by this Directive should be
integrated into the reporting framework established by Article 60 of Directive
2005/36/EC. Evaluation should in particular assess the functioning of the European
Digital Recognition Solution, its effect on administrative burdens and procedure
duration, and its impact on the mobility of professionals and addressing labour and
skills shortages in the internal market.
(26) Directive 2005/36/EC and Regulation (EU) 1024/2012 should therefore be amended
accordingly.
(27) The European Data Protection Supervisor was consulted in accordance with Article
42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council
and delivered its opinion on [date]17.
15 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement of
such data, OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj
16 Commission Decision 2007/172/EC of 19 March 2007 setting up the group of coordinators for the
recognition of professional qualifications, OJ L 79, 20.3.2007, pp. 38–39 (BG, ES, CS, DA, DE, ET,
EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, RO, SK, SL, FI, SV), OJ L 219M, 24.8.2007, pp. 367–368
(MT), ELI: http://data.europa.eu/eli/dec/2007/172/oj 17 OJ C , , p. .
EN 18 EN
HAVE ADOPTED THIS DIRECTIVE:
Article 1
Amendments to Directive 2005/36/EC
Directive 2005/36/EC is amended as follows:
(1) Article 1 is replaced by the following:
'Article 1
Subject matter
1. This Directive establishes rules according to which a Member State which makes access to
or pursuit of a regulated profession in its territory contingent upon possession of specific
professional qualifications (‘the host Member State’) shall recognise professional
qualifications obtained in one or more other Member States (‘the home Member State’) and
which allow the holder of the said qualifications to access and pursue the said profession in
the host Member State.
2. This Directive also establishes rules concerning partial access to a regulated profession and
recognition of professional traineeships pursued in another Member State.
3. This Directive also lays down rules under which a host Member State shall recognise
professional qualifications obtained in a third-country for the purpose of establishment in that
Member State and which allow the holder of the said qualifications to access and pursue the
profession in that Member State under conditions that are not less favourable than those for
third-country nationals.';
(2) Article 2 is amended as follows:
(a) the first subparagraph of paragraph 1 is replaced by the following:
'1. This Directive shall apply to all nationals of a Member State wishing to pursue a
regulated profession in a Member State, including those belonging to the liberal
professions, on either a self-employed or employed basis, and who obtained their
professional qualifications in another Member State or in a third country';
(b) paragraph 2 is deleted;
(3) Article 3 is amended as follows:
(a) paragraph 1 is amended as follows:
(i) point k is deleted;
(ii) the following point o is added:
'(o) ‘digital qualification attestation’ an attestation of a qualification that is
awarded in a digital format in accordance with Regulation (EU) xxxx/xxx on
portability of skills and qualifications and amending Regulation (EU)
2018/172418';
(b) paragraph 3 is deleted;
18 […]
EN 19 EN
(4) Article 4 is amended as follows:
'Article 4
Effects of recognition
1. The recognition of professional qualifications by the host Member State shall allow
beneficiaries to gain access in that Member State to the same profession as the one for which
they are qualified in the home Member State or in the third country where they obtained their
qualifications under the same conditions as its nationals.
2. For the purposes of this Directive, the profession which the applicant wishes to pursue in
the host Member State shall be considered the same as the one for which they are qualified in
their home Member State or in the third country if the activities covered are comparable.
3. By way of derogation from paragraph 1 of this Article, partial access to a profession in the
host Member State shall be granted under the conditions laid down in Article 4f.';
(5) Articles 4a, 4b, 4c, 4d and 4e are deleted;
(6) Article 4f is amended as follows:
'Article 4f
Partial access
1. The competent authority of the host Member State shall grant partial access, for the purpose
of establishment, on a case-by-case basis, to a professional activity in its territory only when
all the following conditions are fulfilled:
(a) the professional is fully qualified to exercise in the home Member State or in
the third country the professional activity for which partial access is sought in
the host Member State;
(b) differences between the professional activity legally exercised in the home
Member State or in the third country and the regulated profession in the host
Member State as such are so large that the application of compensation
measures would amount to requiring the applicant to complete the full
programme of education and training required in the host Member State to
have access to the full regulated profession in the host Member State;
(c) the professional activity can objectively be separated from other activities
falling under the regulated profession in the host Member State.
For the purpose of the first subparagraph, point (c), the competent authority of the
host Member State shall take into account whether the professional activity can be
pursued autonomously in the home Member State or in the third country.
2. The competent authority of the host Member State shall grant partial access, for the purpose
of temporary and occasional services in the host Member State, on a case-by-case basis, to a
professional activity in its territory only when all the following conditions are fulfilled:
(a) the professional is fully qualified to exercise in the home Member for the
professional activity for which partial access is sought in the host Member
State;
(b) differences between the professional activity legally exercised in the home
Member State and the regulated profession in the host Member State as such
are so large that the application of compensation measures would amount to
requiring the applicant to complete the full programme of education and
EN 20 EN
training required in the host Member State to have access to the full regulated
profession in the host Member State;
(c) the professional activity can objectively be separated from other activities
falling under the regulated profession in the host Member State.
For the purpose of the first subparagraph, point (c), the competent authority of the
host Member State shall take into account whether the professional activity can be
pursued autonomously in the home Member State or in the third country.
3. Partial access may be rejected if such rejection is justified by overriding reasons of general
interest, suitable for securing the attainment of the objective pursued, and does not go beyond
what is necessary to attain that objective.
4. Applications for the purposes of establishment in a Member State shall be examined in
accordance with Chapters I and IV of Title III for professionals seeking partial access based
on professional qualifications obtained in their home Member State and in accordance with
Title Va for professionals seeking partial access based on the professional qualifications
obtained in a third country.
5. Applications for the purposes of providing temporary and occasional services in the host
Member State concerning professional activities that have public health or safety implications
shall be examined in accordance with Title II.
6. By way of derogation from Article 52 of this Directive, the professional activity shall be
exercised under the professional title of the third country or of the other Member State once
partial access has been granted. The host Member State may require use of that professional
title in the languages of the host Member State. Professionals benefiting from partial access
shall clearly indicate to the service recipients the scope of their professional activities.
7. This Article shall not apply to professionals benefiting from automatic recognition of their
professional qualifications under the provisions referred to under Title Va of this Directive.';
(7) Article 7 is amended as follows:
(a) paragraph 1 is replaced by the following:
'1. Member States may require that, where the service provider first moves from one
Member State to another in order to provide services, the service provider shall inform
the competent authority in the host Member State in a written declaration to be made
in advance including the details of any insurance cover or other means of personal or
collective protection with regard to professional liability. Such declaration shall be
renewed once a year if the service provider intends to provide temporary or occasional
services in that Member State during that year.';
(b) in paragraph 4, the second subparagraph is replaced by the following:
'Within two weeks of informing the applicant that the declaration referred to in
paragraphs 1 and 2 of this Article is complete, as stipulated in Article 56d(4), the
competent authority shall notify the service provider of its decision which may be one
of the following:
(a) not to check the professional qualifications;
(b) where the professional qualifications have been checked:
(i) to require the service provider to take an aptitude test; or
(ii) to allow the provision of services';
EN 21 EN
(8) in Article 8, paragraph 1 is replaced by the following:
'1. The competent authorities of the host Member State may ask the competent authorities of
the Member State of establishment, in the event of justified doubts, to provide any
information relevant to the legality of the service provider’s establishment and good conduct,
as well as the absence of any disciplinary or criminal sanctions of a professional nature. In the
event that the competent authorities of the host Member State decide to check the service
provider’s professional qualifications, they may ask the competent authorities of the Member
State of establishment for information about the service provider’s training courses to the
extent necessary to assess substantial differences likely to be harmful to public health or
safety. The competent authorities of the Member State of establishment shall provide that
information in accordance with Articles 56 and 56d. In the case of non-regulated professions
in the home Member State, the assistance centres referred to in Article 57b may also provide
such information.';
(9) in Article 10, point (g) is deleted;
(10) Article 14 is amended as follows:
(a) in paragraph 3, the second subparagraph is replaced by the following:
'This applies also to the cases provided for in Article 10 points (b) and (c), in Article
10 point (d) concerning medical doctors and dental practitioners, in Article 10 point (f)
when the migrant seeks recognition in another Member State where the relevant
professional activities are pursued by nurses responsible for general care or specialised
nurses holding evidence of formal qualifications as a specialist who have taken part in
the training leading to the possession of the titles listed in Annex V, point 5.2.2.';
(b) the following paragraph 8 is added:
'8. Member States shall ensure that applicants who fail an aptitude test, or one or more
tests forming part of an adaptation period, are given the opportunity to retake the
respective tests. Member States shall ensure that feedback detailing assessment results
and areas for improvement is provided to applicants, and that applicants are entitled to
at least two further attempts to pass each test that they have failed.';
(11) in Article 21, paragraph 1 is replaced by the following:
'1. Each Member State shall recognise evidence of formal qualifications as doctor giving
access to the professional activities of doctor with basic training and specialised doctor, as
nurse responsible for general care, as dental practitioner, as specialised dental practitioner, as
veterinary surgeon, as pharmacist and as architect, listed in Annex V, points 5.1.1, 5.1.2,
5.2.2, 5.3.2, 5.3.3, 5.4.2, 5.6.2 and 5.7.1 respectively, which satisfy the minimum training
conditions referred to in Articles 24, 25, 31, 34, 35, 38, 44 and 46 respectively, and shall, for
the purposes of access to and pursuit of the professional activities, give such evidence the
same effect on its territory as the evidence of formal qualifications which it itself issues.
Such evidence of formal qualifications shall be issued by the competent bodies in the Member
States and accompanied, where appropriate, by the certificates listed in Annex V, points 5.1.1,
5.1.2, 5.2.2, 5.3.2, 5.3.3, 5.4.2, 5.6.2 and 5.7.1 respectively.
Member States shall ensure that any person to whom they award the evidence of formal
qualifications in that Member State referred to in Annex V, points 5.1.1, 5.1.2, 5.2.2, 5.3.2,
5.3.3, 5.4.2, 5.6.2, and 5.7.1, may request that the relevant certificate accompanying that
evidence of formal qualification, listed in Annex V, be issued as a digital qualification
attestation in accordance with [Regulation(EU)XXX establishing a framework for portability
of skills and qualifications and amending Regulation (EU) 2018/1724]. Any person holding
EN 22 EN
such evidence of formal qualifications and, where appropriate, the relevant certificate listed in
Annex V, which was issued in a non-digital form, may request from the issuing Member State
a digital qualification attestation of that certificate in accordance with [Regulation(EU)XXX
establishing a framework for portability of skills and qualifications and amending Regulation
(EU) 2018/1724].
The provisions of the first and second subparagraphs shall not affect the acquired rights
referred to in Articles 23, 27, 33, 37, 39 and 49.
The provisions of the third and fourth subparagraphs are without prejudice to the provisions
of [Regulation(EU)XXX establishing a framework for portability of skills and qualifications
and amending Regulation (EU) 2018/1724] concerning digital qualification attestation.';
(12) in Article 25, the following paragraph 6 is inserted:
'6. In order to reflect generally acknowledged changes in the medical terminology across the
Union, the Commission is empowered to adopt delegated acts in accordance with Article 57c
in order to update the generic name of specialties in points 5.1.3 and 5.3.3 of Annex V. ';
(13) Articles 50 and 51 are replaced by the following:
'Article 50
Documentation and formalities
1. Where the competent authorities of the host Member State decide on an application for
authorisation to pursue the regulated profession by virtue of this Title, those authorities may
require solely the documents and certificates listed in Annex VII.
Where the host Member State decides to impose a requirement as to the date of issue of the
documents referred to in Annex VII, points 1(d), (e) and (f), it shall accept documents issued
within a specific period that may not be shorter than the three months preceding the date on
which they are submitted.
The Member States, bodies and other legal persons shall guarantee the confidentiality of the
information which they receive.
2. In cases of justified doubts, the host Member State may require from the competent
authorities of a Member State confirmation of the authenticity of the attestations and evidence
of formal qualifications awarded in that other Member State, as well as, where applicable,
confirmation of the fact that the beneficiary fulfils, for the professions referred to in Chapter
III of this Title, the minimum training conditions set out respectively in Articles 24, 25, 28,
31, 34, 35, 38, 40, 44 and 46.
3. By way of derogation from paragraph 2, Member States shall not require confirmation of
authenticity where evidence of formal qualifications is submitted as a digital qualification
attestation or where attestations or evidence are obtained through the technical system for the
cross-border automated exchange of evidence, as established under Regulation (EU)
2018/1724 of the European Parliament and of the Council19. This shall be without prejudice to
the possibility for Member States to verify compliance with the minimum training
requirements applicable under Chapter III of this Title.
19 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018
establishing a single digital gateway to provide access to information, to procedures and to assistance
and problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p.
1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj
EN 23 EN
4. In cases of justified doubt, where evidence of formal qualifications has been issued by a
competent authority in a Member State and includes training received in whole or in part in an
establishment legally established in the territory of another Member State, the host Member
State shall be entitled to verify with the competent body in the Member State of origin of the
award:
(a) whether the training course at the establishment which gave the training has
been formally certified by the educational establishment based in the Member
State of origin of the award;
(b) whether the evidence of formal qualifications issued is the same as that which
would have been awarded if the course had been followed entirely in the
Member State of origin of the award;
(c) whether the evidence of formal qualifications confers the same professional
rights in the territory of the Member State of origin of the award.
5. In cases of justified doubts, the host Member State may require from the competent
authorities of a Member State confirmation of the fact that the applicant is not suspended or
prohibited from the pursuit of the profession as a result of serious professional misconduct or
conviction of criminal offences relating to the pursuit of any of their professional activities.
6. Exchange of information between competent authorities of different Member States under
this Article shall take place through the Internal Market Information system (IMI) established
by Regulation (EU) 1024/2012 of the European Parliament and of the Council20.
7. Where a host Member State requires its nationals to swear a solemn oath or make a sworn
statement in order to gain access to a regulated profession, and where the wording of that oath
or statement cannot be used by nationals of the other Member States, the host Member State
shall ensure that the persons concerned can use an appropriate equivalent wording.
8. Member States shall accept the documents referred to in paragraph 1 in any of the official
languages of the Union.
Article 51
Procedure for the mutual recognition of professional qualifications
1. The competent authority in the host Member State shall examine an application for
authorisation to practise a regulated profession without undue delay and shall adopt a duly
substantiated decision within two weeks after the date on which the applicant is informed in
accordance with Article 56d(4) that the application is complete and no additional information
is required. That deadline may be extended by four weeks in cases falling under Chapters I
and II of this Title.
2. The decision of the competent authority, or failure to reach a decision within the period
laid down in paragraph 1, shall be subject to appeal under national law.';
(14) the following Article 51a is inserted:
'Article 51a
Fees and charges
20 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on
administrative cooperation through the Internal Market Information System and repealing Commission
Decision 2008/49/EC, OJ L 316, 14.11.2012, p.1, ELI: http://data.europa.eu/eli/reg/2012/1024/oj
EN 24 EN
1. A host Member State shall either waive fees for recognition procedures and compensation
measures or ensure that any fees charged do not exceed the actual costs incurred in providing
the service to applicants.
2. By way of derogation from paragraph 1, Member States may impose flat-rate charges if
they can be justified by the average cost of providing the service to applicants.
3. Any potential or actual damage claims or compensations that could be derived from the
non-respect of the deadlines laid down in Article 56d shall not be considered in the
calculation of costs of service or costs of processing applications.
4. Member States shall ensure that detailed information on the structure of the fee and
justification for any charges imposed as part of the recognition process is publicly available
and easily accessible.
5. Through IMI or another electronic interface that the Commission shall make available for
that purpose, each Member State shall notify the Commission of the fees charged for
recognition procedures and for compensation measures for each profession. Through the same
interface, each Member State shall notify any changes to these fees before these changes take
effect.';
(15) in Article 53(3), the second subparagraph is replaced by the following:
'Controls may be carried out only after the recognition of a professional qualification.';
(16) in Article 56, paragraph 2 is replaced by the following:
'2. The competent authorities of the home and the host Member States shall exchange
information regarding disciplinary action or criminal sanctions taken or any other serious,
specific circumstances which are likely to have consequences for the pursuit of activities
under this Directive.
The competent authorities of the home Member State shall examine the veracity of the
circumstances and shall decide on the nature and scope of the investigations which need to be
carried out and shall inform the competent authorities of the host Member State of the
conclusions which the competent authorities of the home Member State draw from the
information available to them.';
(17) the following Articles 56b, 56c, 56d, 56e and 56f are inserted:
'Article 56b
European Digital Recognition Solution
1. The Commission shall establish and maintain a comprehensive European Digital
Recognition Solution ('the EDRS'), available in all official languages of the Union, which
shall provide a platform for the submission of declarations made in accordance with Article 7
and for applications for recognition of professional qualifications under Title III.
2. The EDRS shall provide the following functions:
(a) allow competent authorities to configure the evidence that a professional is
required to provide when applying for the recognition of professions notified
pursuant to Article 59(1), and the evidence that a professional must provide for
prior checks pursuant to Article 7(4);
(b) allow applicants to create, edit, withdraw, and monitor any declarations made
in accordance with Article 7 or any applications for recognition under Title III;
EN 25 EN
(c) allow applicants to provide all required supporting evidence from a range of
sources and in various formats, including scanned paper documents, electronic
attestations of attributes stored in a European Digital Identity Wallet in
accordance with Regulation (EU) No 910/2014 of the European Parliament and
of the Council21, and documents requested through the technical system for the
cross-border automated exchange of evidence established under Regulation
(EU) 2018/1724 of the European Parliament and of the Council;
(d) perform an initial automated assessment of the completeness of the application
and accompanying supporting evidence before the applicant submits the
declaration or application;
(e) make applications and declarations with supporting evidence accessible to the
host Member State;
(f) acknowledge receipt of the application to the applicant.
For the purposes of the first subparagraph, point (a), the solution shall allow
competent authorities to configure the required supporting evidence for each
procedure type and profession. It shall also ensure that, for applications under Title
III, the required evidence does not exceed that set out in Article 50 read in
conjunction with Annex VII, and that, for the declarations made in accordance with
Article 7, the required evidence does not exceed that specified in that Article.
3. The EDRS shall build on and interoperate with IMI. It shall allow direct use of the
functionality of IMI for secure communication between competent authorities, and it shall
facilitate secure communication of competent authorities with the applicant.
4. In the development and operation of EDRS the Commission shall ensure that it is designed
to support competent authorities in their work to assess applications and to take decisions on
recognition, including through machine translation of documents, and to support the
verification of authenticity of evidence.
5. The EDRS shall ensure that the applicant is informed without undue delay of the
completion of each stage of the procedure, and of any compensation that is due in accordance
with Article 56d.
6. The Commission shall publish on its website the formats and standards the EDRS uses for
the issuance, in the form of digital qualification attestations, of recognition decisions taken by
Member States.
Article 56c
Digital processing of applications
1. Member States shall ensure that declarations made under Article 7 and requests for
recognition under Title III are submitted through EDRS.
In cases where the applicant is not able to use EDRS, Member States shall provide the
applicant with the option to submit declarations and applications in non-electronic format. In
such exceptional circumstances, the Member State shall upload without undue delay the
submitted information into EDRS, ensuring all submissions are processed within this EDRS,
21 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on
electronic identification and trust services for electronic transactions in the internal market and
repealing Directive 1999/93/EC, OJ L 257, 28.8.2014, p. 73, ELI:
http://data.europa.eu/eli/reg/2014/910/oj
EN 26 EN
and regularly informing the applicant on the progress of the processing of the application or
declaration.
2. Competent authorities shall use IMI and EDRS to exchange information that is needed for
the processing of applications and declarations with the competent authorities of other
Member States or with applicants.
3. Member States shall ensure that any official communication to applicants is made in all
official languages of that Member State that are also official languages of the Union, and at
least one other official language of the Union. Member States shall ensure that any official
communication to applicants, such as acknowledgement of receipts, decisions and any other
information related to the procedure, shall be transmitted through EDRS.
Article 56d
Procedure for the digital processing of applications
1. Competent authorities of the host Member State shall assess the completeness of the
application and of the evidence provided and inform the applicant through EDRS of any
missing documents no later than one week after submission of the application or declaration.
2. Competent authorities of the host Member State shall communicate to the home Member
State any justified doubts they have on the supporting evidence issued by that Member State
and identify any need for information or attestations to be provided by that Member State.
To this end, no later than one week after the submission of the complete file of the application
or declaration, the host Member State shall request the home Member State to provide
through EDRS the required information, confirmation or attestations needed to proceed with
the application or to dispel any justified doubts.
3. Competent authorities of the home Member State shall provide any evidence or attestations
that are requested through EDRS within two weeks. For procedures under Article 7(4), and
Chapters I and II of Title III, this period may be extended by two additional weeks upon
request of the home Member State.
4. After having access to the complete file, and having received, if required, any other
supporting evidence in accordance with paragraphs (1) to (3), the host Member State shall
without undue delay inform the applicant through EDRS that the application file for
recognition made in accordance with Title III or the declaration made in accordance with
Article 7(4) is complete and no additional information is required from the applicant or the
home Member State to process the application or to perform the required prior checks.
5. For declarations made under Article 7, with the exception of those requiring a prior check
pursuant to paragraph 4 of that Article, the host Member State shall inform the applicant via
EDRS without undue delay after receipt of the declaration that the execution of services in its
territory may start immediately.
6. In relation to procedures under Title III and to the outcome of prior checks carried out in
accordance with Article 7(4), point (b), the final decision taken by the host Member State
shall be issued in the form of a digital qualification attestation through EDRS.
EN 27 EN
Article 56e
Non-respect of deadlines
1. If the home Member State exceeds the deadlines set out in Article 21(1) or Article 56d(3)
by more than five calendar days, it shall ensure that applicants are entitled to claim and
receive compensation for the delay. The compensation shall take the form of a lump sum for
each day of non-respect of the deadline, starting on the first day after the expiry of the
relevant deadline and ending on the date the home Member State treated all open requests for
evidence or attestations related to the application.
2. If the host Member State exceeds the deadlines set out in Article 51 or Article 56d by more
than ten calendar days, it shall ensure that applicants are entitled to claim and receive
compensation for the delay. The compensation shall take the form of a lump sum for each day
of non-respect of the deadline, starting on the first day after the expiry of the relevant deadline
and ending on the date of receipt of the final decision by the applicant. No compensation shall
accrue in respect to any period between a request made by the host Member State and the date
on which the home Member State or, under Title Va, the third country issuing the
qualification provides the evidence or the attestations requested. Such periods shall be taken
into account for the purposes of paragraph 1.
3. Member States may set a maximum amount for the total compensation payable under
paragraphs 1 and 2 expressed as a specific number of daily lump sum compensations.
4. At the request of the applicant and without prejudice to paragraph 5, Member States shall
pay the compensation referred to in paragraphs 1 and 2 as soon as the recognition procedure
or the processing of the declaration is completed.
5. Member States shall ensure that applicants have the right to seek, in accordance with
national law, compensation in respect of any damage or loss suffered exceeding the lump sum
compensation due to the non-respect of deadlines by that Member State.
Article 56f
Processing of personal data
1. Processing of personal data through the EDRS shall be carried out only to the extent that is
necessary for for carrying out tasks laid down in paragraphs 3, 4, 5 and 6.
2. Each Member State shall designate one or more competent authorities responsible for
operating its connection to the EDRS.
3. Where the competent authorities of the home and host Member States exchange personal
data through the EDRS for the purposes of this Directive, they shall act as joint controllers,
within the meaning of Article 26 of Regulation (EU) 2016/679 of the European Parliament
and of the Council22, solely in respect of the cross-border processing operations that are
strictly necessary for that exchange, including the transmission, routing, receipt, consultation
and technical provision of the personal data concerned through the EDRS, as well as the
management of related access rights, logging, security measures and incident handling.
22 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement of
such data, OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj
EN 28 EN
4. The Commission shall act as a processor, within the meaning of Article 3, point (12), of
Regulation (EU) 2018/1725 of the European Parliament and of the Council23, on behalf of the
joint controllers referred to in paragraph 3 of this Article, for the processing of personal data
carried out through the EDRS. In that capacity, it shall provide, technically maintain and
operate the solution, and ensure its interoperability, security, and supervision in accordance
with this Directive. The processing operations carried out by the Commission on behalf of the
joint controllers and the respective responsibilities of the Commission and those joint
controllers shall be governed by arrangements concluded in accordance with Article 29(3) of
Regulation (EU) 2018/1725 and, where applicable, Article 28(3) of Regulation (EU)
2016/679. This paragraph is without prejudice to the responsibilities of the competent
authorities of the Member States, acting as controllers or joint controllers, for processing
operations falling within their respective competence under this Directive.
5. The competent authority of the host Member State shall be the controller, within the
meaning of Article 4, point (7), of Regulation (EU) 2016/679 for the processing of personal
data necessary for the following:
(a) the handling of applications for recognition of professional qualifications;
(b) the assessment of applications, including the verification of supporting
information;
(c) the adoption of decisions and the management of redress procedures;
(d) the handling of personal data related to declarations for provision of services.
6. The competent authority of the home Member State shall be the controller, within the
meaning of Article 4 point (7), of Regulation (EU) 2016/679 for the processing of personal
data necessary for the following:
(a) verifying qualifications or confirming the authenticity of documents;
(b) providing supporting information or documents to the applicant or to the host
Member State;
(c) responding to requests for information made by the applicant and/or the host
Member State, pursuant to this Directive.
7. Where the processing of personal data by the competent authorities of the host or the home
Member State involves automated individual decision-making concerning the applicant,
including profiling, within the meaning of Article 22 of Regulation (EU) 2016/679 of the
European Parliament and of the Council, Member States shall ensure appropriate safeguards
ensuring that decisions affecting the recognition of professional qualifications are taken in a
lawful, fair and transparent manner. These safeguards shall at least include:
(a) the right of the data subject (applicant) to obtain meaningful information on the
use of automated processing in the examination of the application;
(b) the right of the data subject (applicant) to request that the decision be reviewed
by a natural person competent to assess the application;
(c) the right of the data subject (applicant) to express his or her point of view and
to submit observations or additional evidence;
23 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the
protection of natural persons with regard to the processing of personal data by the Union institutions,
bodies, offices and agencies and on the free movement of such data, OJ L 295, 21.11.2018, p. 39, ELI:
http://data.europa.eu/eli/reg/2018/1725/oj
EN 29 EN
(d) the right of the data subject (applicant) to contest the decision by means of the
remedies available under national law.
8. Access to personal data processed pursuant to this Directive shall be limited to:
(a) the Commission, to the extent necessary for the operation, maintenance,
security and supervision of the solution;
(b) the competent authorities of the host and home Member States, to the extent
necessary for the performance of their tasks under paragraphs 3, 5 and 6 of this
Article.
9. Personal data shall be shared between the Commission and the competent authorities of the
Member States, or between the competent authorities of the host and home Member States,
only to the extent necessary for the purposes of paragraphs 3, 5 and 6 of this Article. Such
sharing shall not affect the responsibility of each controller for the processing operations
falling within its competence.
10. Each controller referred to in paragraphs 5 and 6 shall determine, within the limits of
applicable Union and national law, the retention periods for personal data applicable to the
processing operations for which it is responsible. Those periods shall be proportionate and
limited to what is necessary for the purposes of processing. The Commission shall ensure the
automatic deletion, 36 months after the completion of the recognition procedure, of the record
of that procedure and of the documents used therein from the solution, without affecting the
availability of those documents through the technical system for the cross-border automated
exchange of evidence established under Regulation (EU) 2018/1724 of the European
Parliament and of the Council, for their subsequent reuse.
11. The Commission and the competent authorities of the Member States shall cooperate,
within the scope of their respective responsibilities, to ensure the secure and lawful processing
of personal data under this Directive, including as regards:
(a) access management and logging;
(b) incident handling and personal data breach notification;
(c) data quality and accuracy;
(d) the handling of requests from data subjects and supervisory authorities.';
(18) in Article 57(1), point (b) is deleted;
(19) Article 57a is deleted;
(20) Article 57c is amended as follows:
(a) paragraph 2 is replaced by the following:
'2. The power to adopt delegated acts referred to in the third subparagraph of Article
3(2), Article 20, the second subparagraph of Article 21(6), Article 21a(4), Article
25(5), Article 25(6), the second paragraph of Article 26, the second subparagraph of
Article 31(2), the second subparagraph of Article 34(2), Article 35(4) and (5), the
second subparagraph of Article 38(1), the third subparagraph of Article 40(1), the
second subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) shall be
conferred on the Commission for a period of five years from 17 January 2014. The
Commission shall draw up a report in respect of the delegation of power not later than
nine months before the end of the five-year period. The delegation of power shall be
tacitly extended for periods of an identical duration, unless the European Parliament or
EN 30 EN
the Council opposes such extension not later than three months before the end of each
period.';
(b) paragraph 3 is replaced by the following:
'3. The power to adopt delegated acts referred to in the third subparagraph of Article
3(2), Article 20, the second subparagraph of Article 21(6), Article 21a(4), Article
25(5), Article 25(6), the second paragraph of Article 26, the second subparagraph of
Article 31(2), the second subparagraph of Article 34(2), Article 35(4) and (5), the
second subparagraph of Article 38(1), the third subparagraph of Article 40(1), the
second subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) may be
revoked at any time by the European Parliament or by the Council. A decision to
revoke shall put an end to the delegation of the power specified in that decision. It
shall take effect the day following the publication of the decision in the Official
Journal of the European Union or at a later date specified therein. It shall not affect
the validity of any delegated acts already in force.';
(c) paragraph 5 is replaced by the following:
'5. A delegated act adopted pursuant to the third subparagraph of Article 3(2), Article
20, the second subparagraph of Article 21(6), Article 21a(4), Article 25(5), Article
25(6), the second paragraph of Article 26, the second subparagraph of Article 31(2),
the second subparagraph of Article 34(2), Article 35(4) and (5), the second
subparagraph of Article 38(1), the third subparagraph of Article 40(1), the second
subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) shall enter into force
only if no objection has been expressed either by the European Parliament or the
Council within a period of two months of notification of that act to the European
Parliament and the Council or if, before the expiry of that period, the European
Parliament and the Council have both informed the Commission that they will not
object. That period shall be extended by two months at the initiative of the European
Parliament or of the Council.';
(21) Article 59 is replaced by the following:
'Article 59
Transparency
1. Member States shall notify to the Commission a list of existing regulated professions,
specifying the activities covered by each profession, and a list of regulated education and
training, and training with a special structure, referred to in Article 11, point (c)(ii), in their
territory. Any change to those lists shall also be notified to the Commission via IMI before its
entry into force. The Commission shall set up and maintain a publicly available database of
regulated professions, including a general description of activities covered by each profession.
2. By 18 January 2016, Member States shall notify to the Commission the list of professions
for which a prior check of qualifications is necessary under Article 7(4). Member States shall
provide the Commission with a specific justification for the inclusion of each of those
professions on that list. Member States shall notify any changes to that list to the Commission
via IMI.
3. Member States shall examine whether requirements under their legal system restricting the
access to a profession or its pursuit to the holders of a specific professional qualification,
including the use of professional titles and the professional activities allowed under such title,
are compatible with the following principles:
EN 31 EN
(a) they shall not directly nor indirectly discriminate on the basis of nationality or
residence;
(b) they shall be justified by overriding reasons of general interest;
(c) they shall be suitable for securing the attainment of the objective pursued and
shall not go beyond what is necessary to attain that objective.
4. Paragraph 1 of this Article shall also apply to professions regulated in a Member State by
an association or organisation within the meaning of Article 3(2) and any requirements for
membership of those associations or organisations.
5. Before introducing any new requirements referred to in paragraph 3, Member States shall
inform the Commission and shall indicate the reasons for considering that those requirements
comply with points (a), (b) and (c) of that paragraph.';
(22) the following Title Va is inserted:
'TITLE Va
RECOGNITION OF QUALIFICATIONS OBTAINED IN A THIRD COUNTRY
Article 59a
Applicable provisions
1. Member States shall establish procedures for the recognition of professional qualifications
obtained in a third country. For that purpose, Chapter 2 of Title II, Article 11, Article 27,
Article 29(1) and (3) to (5), Article 30(1), Article 31, Article 32(1), (2), (4) and (7) to (10) and
Article 37 of [Directive xxxx/xxx/EU on the recognition of qualifications of third-country
nationals 24] shall apply mutatis mutandis.
2. For the purposes of this Title, Article 3(1) point (c) of this Directive shall be understood as
referring to diplomas, certificates and other evidence, issued by an authority in a third country
designated pursuant to legislative, regulatory or administrative provisions of that third
country, certifying successful completion of professional training.
3. For the purposes of paragraph 1 of this Article, Title III of this Directive shall not apply,
except Article 52(1) and (2), as provided in paragraph 4 of this Article.
4. For the purposes of paragraph 1 of this Article, Article 52(1) and (2), Title IV and Title V
of this Directive shall apply mutatis mutandis to the recognition of professional qualifications
obtained in a third country , with the exception of Article 55a.
Article 59b
Minimum training requirements for certain professions
Where Articles 24, 25, 28, 31, 34, 35, 38, 40 and 44 of this Directive set out minimum
conditions on the training for certain professions, the recognition of professional
qualifications under this Title shall be contingent upon fulfilment of those minimum
conditions.
Article 59c
Use of services for the assessment of authenticity
24 […]
EN 32 EN
For the purposes of assessing an application within the scope of this Directive, the competent
authority of a Member State may request from the Commission to assess the authenticity of
qualifications, diplomas, certificates or other evidence of formal qualifications issued in a
third country, pursuant to Article 28 of [Directive xxxx/xxx/EU on the recognition of
qualifications of third-country nationals].';
(23) Article 60 is replaced by the following:
'Article 60
Evaluation, statistics and reporting
1. From [the date falling 4 years after the adoption of this Directive] Member States shall,
every two years, send a report to the Commission on the application of the system. The report
shall contain general observations and a description of the main problems arising from the
application of this Directive.
2. The Commission shall, every year, provide the Group of Coordinators established under
Commission Decision 2007/172/EC with a statistical summary of the processing of
applications through the solution referred to in Article 56b. This summary shall include the
number of decisions taken, broken down by Member State, by profession, by type of
procedure and by outcome, as well as statistics on processing times and delays. This statistical
summary shall not include any personal data.
3. Every five years from [the date falling 8 years after the adoption of this Directive] the
Commission shall publish a report on the implementation of this Directive.
4. With a view to evaluating the functioning of EDRS referred to in Article 56b of this
Directive, the first report published in accordance with paragraph 3 of this Article shall carry
out an evaluation of this Directive. The Commission shall present a report on the main
findings of that evaluation to the European Parliament, the Council, the European Economic
and Social Committee and the Committee of the Regions regarding the use of digital tools, the
reduction of administrative burden and costs, the availability of relevant information to
applicants, and the duration of recognition procedures.
5. Member States shall provide all the necessary information for the preparation of the reports
referred to in paragraph 3 and 4.';
(24) the following Article 60a is inserted:
'Article 60a
Cooperation between the Commission and the Member States
1. The Commission shall cooperate with the Group of Coordinators established under
Decision 2007/172/EC25, on matters related to the implementation of this Directive with a
view to sharing best practices, identifying the need for guidance and promoting convergence
among Member States.
2. The Commission shall adopt an annual work programme for the Group of Coordinators. It
shall make that work programme, together with the relevant preparatory documents, publicly
available.
25 Commission Decision 2007/172/EC of 19 March 2007 setting up the group of coordinators for the
recognition of professional qualifications, OJ L 79, 20.3.2007, pp. 38–39 (BG, ES, CS, DA, DE, ET,
EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, RO, SK, SL, FI, SV), OJ L 219M, 24.8.2007, pp. 367–368
(MT), ELI: http://data.europa.eu/eli/dec/2007/172/oj
EN 33 EN
3. The annual work programme shall include:
(a) priority topics and issues to be addressed;
(b) appropriate tools and methods to be applied;
(c) expected outputs and deliverables, including those deriving from potential
work on common training frameworks in accordance with Article 49a, together
with indicative timelines, where appropriate;
(d) the subgroups to be established, maintained or discontinued, together with their
mandates.
4. The Commission shall submit the draft annual work programme to the Group of
Coordinators for endorsement no later than at the final meeting of the preceding year.
5. The Group of Coordinators shall establish a subgroup for the digitalisation of recognition
procedures. The subgroup’s tasks shall be the following:
(a) to establish cooperation between Member States’ authorities and the
Commission on questions relating to the digitalisation of procedures for the
recognition of professional qualifications;
(b) to facilitate the implementation of Articles 56b(4), 56c to 56e of this Directive;
(c) to liaise with other relevant recognition networks and expert groups on
digitalisation, in particular the Digitalisation Group established on the basis of
[Regulation(EU)XXX establishing a framework for portability of skills and
qualifications and amending Regulation (EU) 2018/1724], to ensure synergies
are fully exploited.
6. The Commission may adopt work programmes for the subgroups of the Group of
Coordinators upon submitting the draft work programme for endorsement by the subgroup
concerned. It shall make those work programmes, together with the relevant preparatory
documents, publicly available.';
(25) Annex VII is amended in accordance with the Annex to this Directive.
Article 2
Amendment to Regulation (EU) No 1024/2012
Point 2 of the Annex to Regulation (EU) No 1024/2012 is replaced by the following:
‘2. Directive 2005/36/EC of the European Parliament and of the Council on the
recognition of professional qualifications: Article 8, Article 21a, Article 50, Article
51a(5), Article 56, Article 56a to 56f and Article 59(1), (2) and (5) and Article 60(1)
of Directive 2005/36/EC, and in Article 11(1) of Directive (EU) 2018/958.’
Article 3
Transposition
1. Member States shall bring into force the laws, regulations and administrative provisions
necessary to comply with this Directive by 2 years after entry into force at the latest. They
shall forthwith communicate to the Commission the text of those provisions.
EN 34 EN
When Member States adopt those provisions, they shall contain a reference to this Directive
or be accompanied by such a reference on the occasion of their official publication. Member
States shall determine how such reference is to be made.
2. Member States shall apply the measures referred to in paragraph 1:
(a) from 2 years after entry into force of this Directive as regards Article 1,
paragraphs 3(a)(i), 5, 12, 15, 18, 20 and 24;
(b) from [the date of application of Directive xxxx/xxx/EU on the recognition of
qualifications of third-country nationals] as regards Article 1, paragraphs 1, 2,
3(b), 4, 6, 9, 10, 22 and 25;
(c) from [3 years after entry into force] of this Directive as regards Article 1,
paragraphs 3(a)(ii), 7, 8, 11, 13, 14, 15, 16, 17, 19, 21, 23 and Art. 2.
3. Member States shall communicate to the Commission the text of the main provisions of
national law which they adopt in the field covered by this Directive.
Article 4
Entry into force
This Directive shall enter into force on the […] day following that of its publication in the
Official Journal of the European Union.
Article 5
Addressees
This Directive is addressed to the Member States.
Done at Strasbourg,
For the European Parliament For the Council
The President The President
EN 1 EN
LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3
1.1. Title of the proposal/initiative ...................................................................................... 3
1.2. Policy area(s) concerned .............................................................................................. 3
1.3. Objective(s) .................................................................................................................. 3
1.3.1. General objective(s) ..................................................................................................... 3
1.3.2. Specific objective(s) ..................................................................................................... 3
1.3.3. Expected result(s) and impact ...................................................................................... 3
1.3.4. Indicators of performance ............................................................................................ 3
1.4. The proposal/initiative relates to: ................................................................................. 4
1.5. Grounds for the proposal/initiative .............................................................................. 4
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative ............................................................ 4
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone. ................................................................................. 4
1.5.3. Lessons learned from similar experiences in the past .................................................. 4
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments ....................................................................................... 5
1.5.5. Assessment of the different available financing options, including scope for
redeployment ................................................................................................................ 5
1.6. Duration of the proposal/initiative and of its financial impact .................................... 6
1.7. Method(s) of budget implementation planned ............................................................. 6
2. MANAGEMENT MEASURES................................................................................... 8
2.1. Monitoring and reporting rules .................................................................................... 8
2.2. Management and control system(s) ............................................................................. 8
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed .................. 8
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them............................................................................................................ 8
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between
the control costs and the value of the related funds managed), and assessment of the
expected levels of risk of error (at payment & at closure) ........................................... 8
2.3. Measures to prevent fraud and irregularities ................................................................ 9
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10
3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)
affected ....................................................................................................................... 10
EN 2 EN
3.2. Estimated financial impact of the proposal on appropriations ................................... 12
3.2.1. Summary of estimated impact on operational appropriations.................................... 12
3.2.1.1. Appropriations from voted budget ............................................................................. 12
3.2.1.2. Appropriations from external assigned revenues ....................................................... 17
3.2.2. Estimated output funded from operational appropriations......................................... 22
3.2.3. Summary of estimated impact on administrative appropriations ............................... 24
3.2.3.1. Appropriations from voted budget .............................................................................. 24
3.2.3.2. Appropriations from external assigned revenues ....................................................... 24
3.2.3.3. Total appropriations ................................................................................................... 24
3.2.4. Estimated requirements of human resources.............................................................. 25
3.2.4.1. Financed from voted budget....................................................................................... 25
3.2.4.2. Financed from external assigned revenues ................................................................ 26
3.2.4.3. Total requirements of human resources ..................................................................... 26
3.2.5. Overview of estimated impact on digital technology-related investments ................ 28
3.2.6. Compatibility with the current multiannual financial framework.............................. 28
3.2.7. Third-party contributions ........................................................................................... 28
3.3. Estimated impact on revenue ..................................................................................... 29
4. DIGITAL DIMENSIONS .......................................................................................... 29
4.1. Requirements of digital relevance .............................................................................. 30
4.2. Data ............................................................................................................................ 30
4.3. Digital solutions ......................................................................................................... 31
4.4. Interoperability assessment ........................................................................................ 31
4.5. Measures to support digital implementation .............................................................. 32
EN 3 EN
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE
1.1. Title of the proposal/initiative
Proposal for a Directive of the European Parliament and of the Council amending
Directive 2005/36/EC on the recognition of professional qualifications as regards the
digitalisation of recognition procedures and recognition of professional qualifications
issued outside the Union and Regulation (EU) No 1024/2012.
1.2. Policy area(s) concerned
People, society and social model, Free movement of persons, labour mobility
Freedom of establishment, freedom to provide services
Digitalisation of public administrations
1.3. Objective(s)
1.3.1. General objective(s)
Improve the functioning of the EU system for the recognition of professional
qualifications by amending Directive 2005/36/EC
1.3.2. Specific objective(s)
Improve the availability, completeness and reliability of information on recognition
requirements and procedures.
Simplify and accelerate recognition procedures.
Strengthen administrative cooperation between competent authorities.
These objectives will be pursued through the increased use of interoperable digital
tools and workflows, supporting more efficient, transparent and user-friendly
recognition processes across the Union.
1.3.3. Expected result(s) and impact
Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.
Professionals seeking recognition of their qualifications will benefit from faster,
simpler and more predictable recognition procedures, improved access to
information on recognition requirements and procedures, and quicker access to
employment in another Member State.
Competent authorities will benefit from more efficient and interoperable digital
workflows, reduced administrative burden and costs, improved administrative
cooperation, and more consistent implementation of the Directive across the Union.
Employers will benefit from faster recruitment processes, shorter vacancy durations
and improved access to skilled workers, helping to address labour and skills
shortages.
The economy is expected to benefit from a better-functioning internal market for
professional services, supported by a common European digital recognition solution
that creates economies of scale, reduces implementation costs, facilitates a more
efficient allocation of skills across Member States, improves labour market matching
and productivity, and strengthens resilience and competitiveness.
EN 4 EN
Society is expected to benefit from enhanced labour mobility, improved employment
opportunities, greater upward career mobility and increased income security for
professionals exercising their profession in another Member State. By improving the
allocation of skills across the Union, the proposal will also help address labour and
skills shortages and reinforce the delivery of services in sectors of particular
importance to society, including healthcare and education.
1.3.4. Indicators of performance
Specify the indicators for monitoring progress and achievements.
Progress towards the specific objectives will be monitored through the following
indicators:
Availability and quality of information for applicants:
Presence and completeness of the information required under the Directive on
national portals.
Consistency between information provided through national portals and the RegProf
database.
Share of incomplete or incorrectly prepared applications attributable to information
gaps.
User satisfaction with the clarity and accessibility of information provided on
recognition procedures.
Efficiency of recognition procedures:
Average processing time for recognition procedures.
Average number of documents, translations and certified copies requested per
application.
Administrative effort required by competent authorities to process applications.
Share of recognition decisions adopted within the deadlines laid down in the
Directive.
Administrative cooperation between competent authorities:
Average response time to requests for administrative cooperation.
Average number of information requests and confirmation exchanges required per
recognition case.
Satisfaction of competent authorities with the quality and usefulness of the
information received from their counterparts.
1.4. The proposal/initiative relates to:
✓a new action
a new action following a pilot project / preparatory action26
the extension of an existing action
a merger or redirection of one or more actions towards another/a new action
26 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.
EN 5 EN
1.5. Grounds for the proposal/initiative
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative
The Commission will start developing and testing the European Digital Recognition
Solution during the transposition period. Member States will have to transpose the
Directive and initiate the necessary legal, administrative and technical preparations.
After the expiry of the transposition deadline, the European Digital Recognition
Solution should be operational and Member States should have completed the
implementation and technical preparations necessary to apply the revised recognition
framework.
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone.
Reasons for action at EU level (ex-ante)
The initiative concerns the functioning of the internal market, an area of shared
competence. Since the recognition of professional qualifications inherently involves
cross-border interactions between competent authorities, including the exchange of
information, validation of qualifications and verification of documents, effective
action requires a common Union framework. Member States acting individually
cannot establish common operational rules, ensure reciprocity or prevent divergent
administrative practices. Likewise, the deployment of interoperable digital solutions
cannot be achieved through isolated national initiatives without creating
fragmentation, duplication and a lack of interoperability. Union action is therefore
necessary to improve the functioning of the existing framework, enhance
transparency and monitoring, strengthen administrative cooperation, and ensure that
professionals can effectively exercise their Treaty rights to free movement.
Expected generated EU added value (ex-post)
The proposal is expected to generate EU added value by improving the legal
framework for the recognition of professional qualifications across the Union and
supporting it with unified digital tools. It will increase legal certainty and the
consistency of implementation, reduce administrative burdens and compliance costs
for both competent authorities and applicants, and improve the efficiency and
transparency of cross-border recognition procedures. The common European digital
recognition solution will create significant economies of scale by replacing the need
for multiple parallel national solutions and facilitating interoperability across
Member States. The proposal will also strengthen monitoring and enforcement
through the availability of comparable Union-wide data, enabling the Commission
and Member States to identify implementation problems more effectively and
support the consistent application of Union law. Together, these benefits will
contribute to a better-functioning internal market, more efficient labour mobility and
a more effective exercise of the Treaty rights of citizens and professionals
1.5.3. Lessons learned from similar experiences in the past
The experience gained from the implementation of the 2013 revision of Directive
2005/36/EC demonstrates the benefits of introducing digital elements into
EN 6 EN
recognition procedures, while also highlighting the limitations of an approach based
primarily on voluntary and decentralised implementation. Although digital tools have
improved certain aspects of administrative cooperation and information exchange,
their uptake has been uneven across Member States and they have not resulted in a
scalable, end-to-end digital recognition process. These lessons point to the need for a
more integrated and interoperable approach based on a common digital workflow at
Union level, while preserving Member States' competence for decisions on the
recognition of professional qualifications.
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments
The proposal is compatible with the current Multiannual Financial Framework. The
development, deployment and operation of the European Digital Recognition
Solution will be financed from existing Union programmes and budgetary resources
dedicated to digital public administration and the functioning of the internal market,
without requiring the creation of new financial instruments.
The initiative creates important synergies with existing Union instruments and
policies. It builds on the European Digital Identity framework and the eIDAS
Regulation through the use of interoperable digital credentials and trusted electronic
exchanges. It is fully consistent with the Interoperable Europe framework, the Single
Digital Gateway and the Once-Only Technical System by promoting interoperable
public services, reducing repetitive requests for documents and enabling more
efficient cross-border administrative cooperation. It also complements the
digitalisation of qualifications under the Skills Portability Initiative, where the
digitalisation of qualifications (Action 1) facilitates recognition procedures, while the
European Digital Recognition Solution (Action 2) provides concrete large-scale use
cases that support the uptake of digital qualifications. Together, these initiatives
contribute to the broader objective of delivering interoperable, user-friendly and
efficient digital public services across the Union.
1.5.5. Assessment of the different available financing options, including scope for
redeployment
The preferred financing option is direct financing from the Union budget, as the
initiative requires the development, deployment and operation of a common
European Digital Recognition Solution that will be used across all Member States. A
centrally financed solution ensures economies of scale, avoids duplication of
development and maintenance costs, and guarantees interoperability and consistent
implementation across the Union.
Alternative approaches based on separate national developments or decentralised
financing would require multiple parallel investments, increase integration costs and
create risks of fragmentation and inconsistent implementation. Financing through
existing Union programmes and budgetary resources allows the initiative to build on
existing digital infrastructure and expertise while ensuring efficient use of Union
funds. Where appropriate, existing resources will be redeployed to support the
implementation of the initiative.
The current proposal does not entail additional resources as compared to the situation
in the 2021-2027 multiannual financial framework and it builds on the current staff
assigned to the implementation of Directive 2005/36/EC. From 2028 on, the costs
linked to the proposal will be borne by the EU Facility under Heading 1 of the 2028-
EN 7 EN
2034 multiannual financial framework, subject to its adoption and the EU annual
budgetary procedure.
EN 8 EN
1.6. Duration of the proposal/initiative and of its financial impact
limited duration
– in effect from [DD/MM]YYYY to [DD/MM]YYYY
– financial impact from YYYY to YYYY for commitment appropriations and
from YYYY to YYYY for payment appropriations.
✓unlimited duration
– Implementation with a start-up period from YYYY to YYYY,
– followed by full-scale operation.
1.7. Method(s) of budget implementation planned
✓Direct management by the Commission
– ✓ by its departments, including by its staff in the Union delegations;
– by the executive agencies
Shared management with the Member States
Indirect management by entrusting budget implementation tasks to:
– third countries or the bodies they have designated
– international organisations and their agencies (to be specified)
– the European Investment Bank and the European Investment Fund
– bodies referred to in Articles 70 and 71 of the Financial Regulation
– public law bodies
– bodies governed by private law with a public service mission to the extent that they
are provided with adequate financial guarantees
– bodies governed by the private law of a Member State that are entrusted with the
implementation of a public-private partnership and that are provided with adequate financial
guarantees
– bodies or persons entrusted with the implementation of specific actions in the
common foreign and security policy pursuant to Title V of the Treaty on European Union, and
identified in the relevant basic act
– bodies established in a Member State, governed by the private law of a Member
State or Union law and eligible to be entrusted, in accordance with sector-specific rules, with
the implementation of Union funds or budgetary guarantees, to the extent that such bodies are
controlled by public law bodies or by bodies governed by private law with a public service
mission, and are provided with adequate financial guarantees in the form of joint and several
liability by the controlling bodies or equivalent financial guarantees and which may be, for
each action, limited to the maximum amount of the Union support.
Comments
EN 9 EN
2. MANAGEMENT MEASURES
2.1. Monitoring and reporting rules
Monitoring of performance will focus on the extent to which the proposal succeeds
in improving the availability, completeness and reliability of information on
recognition requirements and procedures, simplifying and reducing the cost and
administrative burden of recognition procedures, and strengthening administrative
cooperation between competent authorities.
The Commission will carry out monitoring in cooperation with the national
coordinators and competent authorities in the Member States. Monitoring will rely
on Monitoring will rely on statistics generated by the digital recognition system,
collected annually by the Commission; biennial reporting by competent authorities,
consolidated by National Coordinators; biennial reviews and surveys conducted by
the Commission.
The monitoring framework will include indicators measuring the completeness and
consistency of information on recognition requirements and procedures, the share of
incomplete or incorrectly prepared applications attributable to information gaps, user
satisfaction with the clarity and accessibility of information, the average processing
time for recognition procedures, the average number of documents, translations and
certifications requested, the administrative effort required to process applications,
compliance with procedural deadlines, the average response time to requests for
administrative cooperation, the average number of information requests and
confirmation exchanges per recognition case, and competent authorities' satisfaction
with the quality and usefulness of the responses received.
A pre-implementation benchmark will be established through a first data collection
in 2028. The baseline year for monitoring will be 2029, when the benefits of the
initiative are expected to begin materialising following the deployment of the
European Digital Recognition Solution. The monitoring framework will provide the
evidence necessary to support the evaluation of the initiative approximately five
years after the expiry of the transposition deadline.
2.2. Management and control system(s)
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed
Direct management, as per article 62.1(a) of the Financial Regulation, is the
preferred mode of implementation, as the actions will be carried out by the European
Commission, specifically Directorate-General for Employment, Social Affairs and
Inclusion (DG EMPL), which will ensure the coordination with Member States and
the various stakeholders.
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them
The controls are part of the internal control system of DG EMPL. The new activities
will be subject to the same risk identification and mitigation approach.
EN 10 EN
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between
the control costs and the value of the related funds managed), and assessment of the
expected levels of risk of error (at payment & at closure)
The controls are integrated into the internal control system of DG EMPL. The new
activities will generate negligeable additional control costs at DG level.
2.3. Measures to prevent fraud and irregularities
The Commission shall ensure that, when actions financed are implemented, the
financial interests of the Union are protected by the application of preventive
measures against fraud, corruption and any other illegal activities, by effective
checks and by the recovery of the amounts unduly paid and, if irregularities are
detected, by effective, proportional and dissuasive penalties. The Commission is
authorised to carry out checks and verifications in situ under this Decision, in
compliance Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996
concerning on-the-spot checks and inspections carried out by the Commission in
order to protect the European Communities financial interests against fraud and other
irregularities. If need be, investigations shall be carried out by the European Anti-
Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the
European Parliament and of the Council of 25 May 1999 concerning investigations
conducted by the European Anti-Fraud Office.
EN 11 EN
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE
The estimated impact on expenditure and staffing for 2028 and beyond is added for
illustrative purposes only and does not pre-judge the next Multiannual Financial
Framework. The source of financing and scope of Union financial commitment in the
post-2027 period remain subject to the outcome of interinstitutional negotiations on
the MFF 2028-2034 and thereafter shall be determined through the annual budgetary
procedure. All appropriations and staffing allocations as of 2028 are indicative.
Under reserve of adoption of the Draft Budget 2027 for this budget line as proposed
by the Commission, the 2027 work programme a total of EUR 3.5 million has been
programmed under 07.020400: ESF+ - Employment and Social Innovation strand, in
order to support the business analysis, management of data quality, and IT
development of digital systems to support processes for the recognition of
professional qualifications, in particular EDRS.
3.1. Heading(s) of the multiannual financial framework and expenditure budget
line(s) affected
In order of multiannual financial framework headings and budget lines.
Heading of
multiannual
financial
framework
Budget line Type of
expenditure
Contribution – to be determined at later stage for
EFTA, (potential) candidate countries and third
countries
Number
Diff./Non-
diff.27
from
EFTA
countries 28
from
candidate
countries
and
potential
candidates 29
From
other
third
countries
other assigned
revenue
To be determined after the adoption of the
MFF and in the context of the annual
budgetary procedure for the EU Facility –
Successor of 07 02 04 00 – ESF+ EaSI
strand
Diff./Non
-diff. YES/NO YES/NO YES/NO NO
07.020400: ESF+ - Employment and
Social Innovation strand
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
27 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 28 EFTA: European Free Trade Association. 29 Candidate countries and, where applicable, potential candidates from the Western Balkans.
EN 12 EN
3.2. Estimated financial impact of the proposal on appropriations
3.2.1. Summary of estimated impact on operational appropriations
– The proposal/initiative does not require the use of operational appropriations
– The proposal/initiative requires the use of operational appropriations, as explained below
3.2.1.1. Appropriations from voted budget
EUR million (to three decimal places)
Heading of multiannual financial framework Number 1 - Economic, social and territorial cohesion, agriculture, rural and maritime
prosperity and security
DG: EMPL
Year Year Year Year Year Year Year
TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033
2034 and
subsequent
years
Operational appropriations
Budget line – successor 07 02 04 Commitments (1a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payments (2a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Appropriations of an administrative nature financed from the envelope of specific programmes30
Budget line (3) n.a. n.a.n.a.n.a.n.a.n.a.n.a.n.a.
TOTAL appropriations Commitments =1a+1b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
for DG EMPL Payments =2a+2b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Total Heading 1 Year Year Year Year Year Year Year TOTAL
30 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.
EN 13 EN
2028 2029 2030 2031 2032 2033
2034 and
subsequent
years
MFF 2028-
2034
TOTAL operational
appropriations
Commitments (4)
p.m. p.m. p.m. p.m. p.m. p.m. p.m.
p.m.
Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
TOTAL appropriations of an
administrative nature financed from the
envelope for specific programmes
(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
TOTAL
appropriations
under HEADING 1
Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
of the multiannual
financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Year Year Year Year Year Year Year TOTAL
MFF
2028-2034 2028 2029 2030 2031 2032 2033 2034
• TOTAL
operational
appropriations (all
operational
headings)
Commitments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
• TOTAL appropriations of an
administrative nature financed from
the envelope for specific programmes
(all operational headings)
(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
TOTAL
appropriations
Under
Heading 1 to 3
Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
EN 14 EN
of the multiannual
financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
(Reference amount)
For 2027, the resource of the deployment of the system will come from EaSI. This initiative should be financed within the agreed envelope of the
programme.
The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next
Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to
the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.
All appropriations and staffing allocations as of 2028 are indicative.
Heading of multiannual financial framework 4 ‘Administrative expenditure’31
DG:EMPL
Year Year Year Year Year Year Year TOTAL
MFF
2028-2034 2028 2029 2030 2031 2032 2033
2034 and
subsequent
years
Human resources 0.388 0.388 0.3880 0.3880 0.3880 0.388 0.388 2.716
Other administrative expenditure 0 0 0 0 0 0 0 0
TOTAL DG
EMPL Appropriations 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716
31 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.
EN 15 EN
TOTAL appropriations under HEADING 4 of
the multiannual financial framework
(Total
commitments =
Total payments) 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716
EUR million (to three decimal places)
Year Year Year Year Year Year Year TOTAL
MFF 2028-
2034 2028 2029 2030 2031 2032 2033
2034 and
subsequent
years
TOTAL
appropriations under
HEADINGS 1 to 4
Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
of the multiannual
financial framework Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next
Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to
the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.
All appropriations and staffing allocations as of 2028 are indicative.
3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)
Commitment appropriations in EUR million (to three decimal places)
Indicate
objectives
and outputs
Year
2028
Year
2029
Year
2030
Year
2031
Enter as many years as necessary to show
the duration of the impact (see Section1.6) TOTAL
OUTPUTS
EN 16 EN
ò Type
32
Aver
age
cost
N o
Cost
N o
Cost
N o
Cost
N o
Cost
N o
Cost
N o
Cost
N o
Cost Total
No
Total
cost
SPECIFIC OBJECTIVE No
1 33
…
- Output p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
- Output
- Output
Subtotal for specific objective
No 1
SPECIFIC OBJECTIVE No 2 ...
- Output
Subtotal for specific objective
No 2
TOTALS p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
32 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 33 As described in Section 1.3.2. ‘Specific objective(s)’
EN 17 EN
3.2.3. Summary of estimated impact on administrative appropriations
– The proposal/initiative does not require the use of appropriations of an
administrative nature
– The proposal/initiative requires the use of appropriations of an administrative
nature, as explained below
3.2.3.1. Appropriations from voted budget
VOTED APPROPRIATIONS
Year Year Year Year Year Year Year TOTAL
2028 -
2034 2028 2029 2030 2031 2032 2033
2034 and
subsequent
years
HEADING 4
Human resources 0.388 0.388 0.388 0.388 0.3880.3880.388 2.716
Other administrative expenditure 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000
Subtotal HEADING 4 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716
Outside HEADING 4
Human resources 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000
Other expenditure of an administrative nature
0.000 0.000 0.000 0.000 0.0000.0000.000 0.000
Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
TOTAL 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716
3.2.4. Estimated requirements of human resources
– The proposal/initiative does not require the use of human resources
– The proposal/initiative requires the use of human resources, as explained
below
3.2.4.1. Financed from voted budget
Estimate to be expressed in full-time equivalent units (FTEs) 34
VOTED
APPROPRIATIONS
Year Year Year Year Year Year Year
2028 2029 2030 2031 2032 2033
2034 and
subsequent
years
Establishment plan posts (officials and temporary staff)
20 01 02 01 (Headquarters and
Commission’s Representation
Offices)
2 2 2 2 2 2 2
20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0
(Indirect research) 0 0 0 0 0 0 0
(Direct research) 0 0 0 0 0 0 0
Other budget lines (specify) 0 0 0 0 0 0 0
• External staff (inFTEs)
20 02 01 (AC, END from the
‘global envelope’) 0 0 0 0 0 0 0
34 Please specify below the table how many FTEs within the number indicated are already assigned to the
management of the action and/or can be redeployed within your DG and what are your net needs.
EN 18 EN
20 02 03 (AC, AL, END and
JPD in the EU Delegations) 0 0 0 0 0 0 0
Admin. Support
line
• at
Headquarte
rs
0 0 0 0 0 0 0
[XX.01.YY.YY] • in EU
Delegation
s
0 0 0 0 0 0 0
(AC, END - Indirect research) 0 0 0 0 0 0 0
(AC, END - Direct research) 0 0 0 0 0 0 0
Other budget lines (specify) -
Heading 4 0 0 0 0 0 0 0
Other budget lines (specify) - Outside Heading 4
0 0 0 0 0 0 0
TOTAL 2 2 2 2 2 2 2
Considering the overall strained situation in Heading 4, in terms of both staffing and the level of
appropriations, the human resources required will be met by staff from the DG who are already
assigned to the management of the action and/or have been redeployed within the DG or other
Commission services.
The staff required to implement the proposal (in FTEs):
To be covered by
current staff
available in the
Commission
services
Exceptional additional staff*
To be financed
under Heading 4
or Research
To be financed
from BA line
To be financed
from fees
Establishment
plan posts
2 N/A N/A N/A
External staff
(CA, SNEs, INT)
0 N/A N/A N/A
Description of tasks to be carried out by:
Officials and temporary staff Tasks will include overseeing the development and ensuring the legal and
technical compliance of the European Digital Recognition Solution (EDRS);
coordinating the transition from existing EU recognition tools to the EDRS,
including the necessary adaptations required for a smooth replacement of
current systems in cooperation with Member States; establishing and managing
the monitoring and reporting framework, including the collection of statistics
and performance indicators; and ensuring the continuous review and evolution
of the system so that it remains fit for purpose and adapts to future legal,
technical and policy developments.
External staff N/A
EN 19 EN
3.2.5. Overview of estimated impact on digital technology-related investments
Compulsory: the best estimate of the digital technology-related investments entailed
by the proposal/initiative should be included in the table below.
Exceptionally, when required for the implementation of the proposal/initiative, the
appropriations under Heading 4 should be presented in the designated line.
The appropriations under Headings 1-3 should be reflected as “Policy IT expenditure
on operational programmes”. This expenditure refers to the operational budget to be
used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation
of the initiative and their associated investments (e.g. licences, studies, data storage
etc). The information provided in this table should be consistent with details
presented under Section 4 “Digital dimensions”.
TOTAL Digital
and IT
appropriations
Year Year Year Year Year Year Year TOTAL
MFF
2028 -
2034 2028 2029 2030 2031 2032 2033 2034
HEADING 4
IT expenditure (corporate)
0 0 0 0 0 0 0 0
Subtotal
HEADING 4 0 0 0 0 0 0 0 0
Outside HEADING 4
Policy IT expenditure on operational programmes
p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Subtotal outside
HEADING 4 p.m.p.m.p.m.p.m.p.m.p.m.p.m.p.m.
TOTAL p.m.p.m.p.m.p.m.p.m.p.m.p.m.p.m.
3.2.6. Compatibility with the current multiannual financial framework
The proposal/initiative:
– can be fully financed through redeployment within the relevant heading of the
multiannual financial framework (MFF)
The proposal builds on the Commission’s proposal for the MFF 2028-2034, subject
to its adoption and to the EU annual budgetary procedure, and in particular on the
EU Facility under Heading 1.
– requires use of the unallocated margin under the relevant heading of the MFF
and/or use of the special instruments as defined in the MFF Regulation
– requires a revision of the MFF
3.2.7. Third-party contributions
The proposal/initiative:
EN 20 EN
– does not provide for co-financing by third parties but might be interesting for
EEA EFTA countries or (potential) candidate countries
– provides for the co-financing by third parties estimated below:
Appropriations in EUR million (to three decimal places)
Year Year Year Year Year Year Year
Total 2028 2029 2030 2031 2032 2033 2034
Specify the co-
financing body
(EFTA,
(potential)
candidate
countries, third
countries
p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
TOTAL
appropriations
co-financed
p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
3.3. Estimated impact on revenue
– The proposal/initiative has no financial impact on revenue.
– The proposal/initiative has the following financial impact:
– on own resources
– on other revenue
– please indicate, if the revenue is assigned to expenditure lines
EUR million (to three decimal places)
Budget revenue line:
Appropriations
available for
the current
financial year
Impact of the proposal/initiative 35
Year
2028
Year
2029
Year
2030
Year
2031
Year
2032
Year
2033
Year
2034
Article ………….
For assigned revenue, specify the budget expenditure line(s) affected.
N/A
Other remarks (e.g. method/formula used for calculating the impact on revenue or
any other information).
N/A
35 In the case of traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts,
i.e. gross amounts after deduction of 10 % for collection costs, as proposed in COM(2025)574.
EN 21 EN
4. DIGITAL DIMENSIONS
4.1. Requirements of digital relevance
High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital solutions and-
or digital public services)
Reference to the
requirement Requirement description
Actors affected or
concerned by the
requirement
High-level Processes Categories
Article 56b, 56c
and 56d
Development, operation and use of
the European Digital Recognition
Solution.
The Commission must develop and
operate a European Digital
Recognition Solution for declarations
under Article 7 and recognition
procedures under Title III. Key
functions include:
• procedure configuration by
competent authorities
• applicant creation-editing-
withdrawal-monitoring of
applications
• submission of supporting
evidence from multiple sources
and formats (including digital
European Commission:
develops and operates the
system
Home and Host competent
authorities (users)
Applicants professionals
(users)
Application
processing and
decision on
recognition
Data
Digital public services
Digital solutions
Process digitalisation or
automation
EN 22 EN
qualification attestation format)
• integration with SDG OOTS
for retrieval of evidences
• automated assessment of
completeness
• Notifications to applicant,
including immediate
acknowledgement of receipt
upon submission of the
application
• integration with IMI
• requests for missing evidence
• deadlines for home-host
authorities
• alternative evidence if home
authority delays
• secure communication with
applicants
• decision-making support for
authorities through machine
translation and authenticity
verification
• transparent status information
on application progress
• issuing final decisions as digital
qualification attestations.
EN 23 EN
Member States must:
• ensure all declarations and
recognition requests are
submitted through the system
• use only the system and its IMI
integration for inter-authority
exchanges
• send official communication to
applicants through the system
• offer applicants a language
choice
• allow non-electronic
submission only in justified
exceptional cases, with the
Member State entering the
information into the system.
Article 56f
Processing of personal data.
The article provides rules on the
processing of personal data processing
in the system, including: the purposes
of processing, the Commission as
processor for system management and
infrastructure security, host Member
State as controller for processing of
recognition applications and
declarations for provision of services,
home Member State as controller for
verifying qualifications, confirming
European Commission
Host Member State
Home Member State
Applicants-data subjects
System administrators.
Processing of
personal data
Data
Digital public services
Digital solutions
EN 24 EN
authenticity of documents, responding
to requests (supporting information,
documents) of the applicant or the host
Member State, transparency, training
and audits, obligation for the
Commission concerning the automatic
deletion after 36 months.
Article 60(1),
(1b)
Statistics and reporting from the
system.
The European Commission must
publish:
1. An annual statistical summary
to the Group of Coordinators
using information recorded in
the European Digital
Recognition Solution. This
statistical summary shall
include:
a. The number of decisions
taken, broken down
i. By Member State
ii. By profession
iii. By type of
recognition
procedure
iv. By outcome
(decision)
European Commission
Group of Coordinators
Member States indirectly, as
data providers through
system use.
Reporting of
recognition processes
statistics
Data
Digital solutions
EN 25 EN
b. The statistics on processing
times of applications and
delays
4.2. Data
High-level description of the data in scope
Type of data Reference to the requirement(s) Standard and-or specification (if applicable)
Digital qualification attestations of formal
qualification • Article 56b, 56c, 56d
• Article 56f
Electronic attestations of attributes as defined under
eIDAS Regulation and Commission Implementing
Regulation 2024/2979(EU), OOTS evidence
Non-digital evidences of formal qualification and
other supporting evidences (as listed in Annex VII) • Article 56b, 56c, 56d
• Article 56f
Annex VII
Personal information accompanying declarations
under article 7 and recognition procedures • Article 56b, 56c, 56d
• Article 56f
n/a
Annual statistical summary of recognition
procedures (includes numbers of decisions,
breakdowns, outcomes, processing times and
delays)
• Article 60(1), (1b)
n/a
Alignment with the European Data Strategy
Explanation of how the requirement(s) are aligned with the European Data Strategy
EN 26 EN
In terms of compliance with the General Data Protection Regulation, the main roles and responsibilities related to personal data protection are
already set out in Article 56f.
No data is planned to be published as open data.
Alignment with the once-only principle
Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored
The use of the once-only technical system (OOTS) has already been envisaged for the retrieval of evidences of qualifications from competent
authorities in the Member States. Additionally, the use of the EUDI Wallet as an option for uploading evidence in the central European Digital
Recognition Solution facilitates the interoperable reuse by the citizen/professional of evidences already present in his/her wallet.
Additionally, the application of the once-only principle will continue to be supported – as is the case already today – by the use IMI for
cooperation between public administrations in the Member States. This cooperation helps public administrations avoid asking citizens for
additional documents, in the cases where such information can be retrieved from other public administrations via IMI.
Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards
• Personal data (including professional qualifications or information within recognition procedures) is in general not supposed to be
findable or reusable.
• Interoperability of evidence on professional qualifications is guaranteed through the use of EUDI Wallets or OOTS evidences. Such
standard will ensure mutual understanding of qualifications between Member States. While these standards will not be used for all
evidence types, at least in an initial stage, the supporting system will be ready to adapt to new standardised evidences as soon as they
become available.
• Statistical data on recognition procedures and on the use of the EDRS system, as indicated in Article 60, will be published by the EC on
the public part of the RegProf database.
• It is worth mentioning that, as already happening today (i.e. no changes compared to current situation):
o Information on regulated professions, procedures, fees, and appeal routes will be findable and accessible by citizens on national
online sites (as mandated by article 57).
o Information on the list of regulated professions, including a general description of activities covered by each professional will
EN 27 EN
be findable and accessible by citizens on the publicly available database of regulated professions set up by the Commission (as
mandated by Article 59 (1)).
Data flows
High-level description of the data flows
Type of data Reference(s)
to the
requirement(s)
Actors who
provide the
data
Actors who
receive the data
Trigger for the
data exchange
Frequency (if
applicable)
Application information accompanying
declaration under article 7 and
recognition procedures
Development,
operation and
use of the
European
Digital
Recognition
Solution.
Processing of
personal data
Professional
(citizen)
Competent
authority in host
Member State
(via EDRS)
Submission of
declaration under
Article 7 on EDRS
by the professional
Once per
declaration
Digital qualification attestations of
formal qualifications
Development,
operation and
use of the
European
Digital
Recognition
Solution.
Digital
qualification
Professional
(citizen)
Competent
authority in host
Member State
(via EDRS)
Application
preparation for
recognition
procedure by
professional
Once per
application
EN 28 EN
attestations as
supporting
evidence.
Non-digital evidences of formal
qualifications and other supporting
evidences (as listed in Annex 7)
Development,
operation and
use of the
European
Digital
Recognition
Solution
Professional
(citizen)
Competent
authority in host
Member State
(via EDRS as
uploaded
attachments)
Application
preparation for
recognition
procedure by
professional
Annual statistical summary of
recognition procedures (includes
numbers of decisions, breakdowns,
outcomes, processing times and delays)
Statistics and
reporting from
the system.
European
Commission
Group of
Coordinators
Annually
4.3. Digital solutions
High-level description of digital solutions
Digital
solution
Reference(s)
to the
requirement(s)
Main mandated
functionalities
Responsible
body How is accessibility catered for?
How is
reusability
considered?
Use of AI
technologies
(if
applicable)
European
Digital
Recognition
Solution
(EDRS)
Article 56b
and 56c
Article 60(1),
(1b)
Key functions include:
• procedure
configuration by
competent
European
Commission
The EDRS shall be accessible for
persons with disabilities by
complying with the
relevant accessibility requirements
of the Web accessibility directive
The system will
be built on
existing (or in
the process of
being built)
An AI module
is foreseen to
support the
decision-
making in the
EN 29 EN
authorities
• applicant
creation-editing-
withdrawal-
monitoring of
applications
• submission of
supporting
evidence from
multiple sources
and formats
• integration with
SDG OOTS
• integration with
EUDI Wallets
• automated
completeness
assessment
(against
procedure
requirements) of
the application
prior to
submission
• Notifications to
applicant,
including
immediate
acknowledgeme
(Directive (EU) 2016/2102)
components,
including:
• the IMI
workflow
engine and
back-office
module for
competent
authorities
• the
upcoming IMI
front-office
for citizens
• the
existing
RegProf
database for
information
on regulated
professions
and
requirements
• the
EUDI
framework for
issuing and
presenting
digital
recognition
procedure.
Note: The AI
capabilities
will act as a
support, it will
not replace
human
oversight, the
decisions on
recognition,
including the
statement of
reasons,
should remain
the sole
responsibility
of the
competent
authorities
This will
include:
evidence
classification,
evidence
authenticity
and veracity
detection
(detection of
tampering,
forgeries,
EN 30 EN
nt of receipt
upon
submission of
the application
integration with
IMI for secure
message
exchange
between the
competent
authorities of
Member States
• requests for
missing
evidence
• deadlines for
home Member
State and host
Member State
competent
authorities
• Searches for
alternative
evidence by host
Member
competent
authority if
home Member
State’s
competent
qualification
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)
EN 1 EN
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.
EN 2 EN
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
EN 3 EN
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
EN 4 EN
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
EN 5 EN
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
EN 6 EN
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
EN 7 EN
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.
EN 8 EN
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”).
EN 9 EN
• 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
EN 10 EN
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
EN 11 EN
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.
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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
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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.
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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.
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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
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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.
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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.
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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].
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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
[...] [...]
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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
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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
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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.
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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.
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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
EN 55 EN
Please list such measures
Digital Qualification attestations verification service
Assessment Measure(s) Potential remaining barriers (if applicable)
Alignment with existing digital and
sectorial policies
Please list the applicable digital and
sectorial policies identified
• Adoption of technologies and standards
foreseen by the EUDI regulation
• EUDI Regulation for the verification of
digital credentials
• SPI regulation
N/A
Organisational measures for a
smooth cross-border digital public
services delivery
Please list the governance measures
foreseen
• Registration of relying parties in the
EUDI trust framework to be recognised as
authorised verifiers
N/A
Measures taken to ensure a shared
understanding of the data
Please list such measures
• Data specifications described in Annex I
and II, IV, V
N/A
Use of commonly agreed open
technical specifications and
standards
Please list such measures
• Technical specifications described in
Annex I
N/A
Publication of National Qualifications data service (Europass and EU open data portal)
EN 56 EN
Assessment Measure(s) Potential remaining barriers (if applicable)
Alignment with existing digital and
sectorial policies
Please list the applicable digital and
sectorial policies identified
• Europass Decision (Decision (EU)
2018/646)
• Council Recommendation on the
European Qualifications Framework
• Council Recommendation on a European
approach to micro-credentials
•
N/A
Organisational measures for a
smooth cross-border digital public
services delivery
Please list the governance measures
foreseen
• As mentioned in Article 9, Member States
have the obligation to provide information
on qualifications listed in National
Qualifications Frameworks (NQFs), to be
published on Europass. This is already
possible today, but on a voluntary basis.
N/A
Measures taken to ensure a shared
understanding of the data
Please list such measures
• As per article 9(1,2), alignment of
National Qualifications Frameworks
(NQFs) level to European Qualifications
Framework (EQF) levels
• As per article 9(6), use of common ESCO
classification for skills terminology.
• Enhancement of the existing
Qualifications Comparison Tool in
Europass
N/A
Use of commonly agreed open
technical specifications and
standards
• No new technical specifications foreseen
compared to current situation.
N/A
EN 57 EN
Please list such measures
EN 58 EN
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)
As indicated in Article 3(6), “the
Commission shall adopt implementing
acts laying down detailed provisions
concerning the agreed common language,
issuance formats and protocols for digital
qualification attestations across the Union
and the formats and protocols for
transfers of lists of awarding bodies,
accreditations and qualifications included
in national qualifications frameworks for
issuing and verifying digital qualification
attestations. Those implementing acts
shall be adopted in accordance with the
examination procedure referred to in
Article 15(2).
Article 3 (1-3)
Article 3 (4-5)
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)
Article 13 (1‑4)
Drafting and
adoption of
implementing
acts
As per Article
14, “the
Commission
shall be assisted
by a committee.
That committee
shall be a
committee
within the
meaning of
Regulation (EU)
No 182/2011”
Reference implementation of the
verification tool
To ensure trust in and interoperability of
digital qualification attestations across
the Union, Member States
should establish mechanisms and tools
Recital 16 Provision of a
reference
software
European
Commission
Member States
EN 59 EN
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 common verification
processes and reduce administrative
burdens, the Commission may support
Member States by providing a reference
software supporting secure, efficient and
non-discriminatory verification
processes.
Pilot with Member States/issuers - Run a pilot Member States
authorities,
awarding
bodies, digital
issuers (QTSPs
or PUB-Issuers),
qualification
holders
EN EN
EUROPEAN COMMISSION
Strasbourg, 15.9.2026 COM(2026) 990 final
2026/0275 (COD)
Proposal for a
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on the recognition of qualifications of third-country nationals
{SEC(2026) 990 final} - {SWD(2026) 989 final} - {SWD(2026) 990 final} - {SWD(2026) 991 final}
(Text with EEA relevance)
EN 1 EN
EXPLANATORY MEMORANDUM
1. CONTEXT OF THE PROPOSAL
• Reasons for and objectives of the proposal
The Treaties, the Charter of Fundamental Rights of the European Union and the European
Pillar of Social Rights establish a broad framework supporting access to employment, skills
development and participation in the Union labour market. While the free movement of
workers, freedom of establishment and freedom to provide services enshrined in the Treaties
are rights of Union citizens, third-country nationals who are legally resident in the Union can
also benefit from this broader framework, in accordance with the conditions and within the
scope laid down in Union law. The European Pillar of Social Rights, proclaimed in 2017,
emphasises the importance of skills and employability in its first chapter on equal
opportunities and access to the labour market. In particular, Principle 1 on education, training
and lifelong learning recognises everyone’s right to maintain and acquire skills enabling full
participation in society and the labour market, and Principle 4 provides for the right to active
support to find or change jobs, including through re-skilling and job-search assistance.
This long-standing framework is reflected in the Commission’s Political Guidelines for 2024–
2029, which emphasise the importance of skills portability and of enabling people to make
effective use of their skills in the Union. In her Political Guidelines for 2024–2029, the
President of the Commission underlined the need to ensure that the Union benefits from high-
quality skills, irrespective of where and how they were acquired, and to facilitate the
recognition of skills acquired in one country in another. These objectives are also reflected in
the ‘One Europe, One Market’ roadmap, launched in April 2026 with the objective of further
deepening and completing the Single Market by the end of 2027, including by removing
remaining barriers, reducing administrative burden and strengthening the Union’s
competitiveness.
While the EU labour market has reached record-high employment levels, it faces widespread
and structural skilled labour shortages, particularly in sectors such as healthcare, ICT,
construction, energy, and transport, driven in part by an ageing population and a shrinking
working-age workforce. These shortages coexist with persistent 'skills waste',
overqualification and the underutilisation of skills being significantly more pronounced
among third-country nationals than among the domestic workforce. This mismatch also
depresses earnings for those working below their qualification level and risks contributing to
downward wage pressure and reducing the return on skills for employers and represents a loss
of overall productivity for the Union economy at a time of skills shortages. Whether already
residing in a Member State or seeking to migrate to the Union, third-country nationals face
recognition procedures for their qualifications that are fragmented, complex and lacking in
transparency, leading to uncertain and inconsistent outcomes. Two distinct but often
interconnected types of procedure are concerned: formal recognition for access to a regulated
profession, and qualification or skills checks carried out as part of a procedure to obtain a
long-stay visa or a residence permit (for instance under the EU Blue Card or national highly-
skilled-worker schemes). The average recognition procedure is estimated to cost EUR 1,500
and to take 14.2 months, with 70.4% of third-country nationals surveyed considering the
length of the process a 'big' or 'very big' problem. Nearly half of third-country nationals who
initiated recognition procedures were seeking access to a regulated profession in healthcare, a
sector facing acute shortages across the Union. Unlike EU nationals, who benefit from the
mutual recognition mechanisms of Directive 2005/36/EC (the Professional Qualifications
Directive), third-country nationals have no comparable EU framework. This gap undermines
EN 2 EN
the effectiveness of the Union's talent-attraction ecosystem — including the EU Blue Card,
the EU Talent Pool, Talent Partnerships with priority third countries and the European Legal
Gateway Office pilot — whose value for employers and jobseekers depends on recognition
systems functioning adequately. Procedures for recognition of qualifications for access to
further learning are outside the scope of this proposal.
This proposal responds to a clear and repeated political mandate. The Political Guidelines of
Commission President von der Leyen committed to a Skills Portability Initiative 'to ensure a
skill acquired in one country is recognised in another' and to 'make it easier to attract the right
talent with harmonised rules on the recognition of qualifications'. The March 2025
Communication on the Union of Skills confirmed this commitment, and the Letta report on
the Single Market highlighted the need to extend automatic recognition of qualifications to
help address persistent labour shortages. The European Council, meeting on 19 March 2026,
called for a Commission proposal on the portability of qualifications and skills, including
third-country nationals, by autumn 2026. The proposal is part of the Skills Portability
Initiative and its general objective is to facilitate the recognition of qualifications of third-
country nationals in order to address labour and skills shortages in the Union. Three specific
objectives are pursued: (i) streamlined recognition systems within and between Member
States; (ii) reduced legal and administrative complexity for third-country national applicants,
employers and authorities; and (iii) increased trust in, and understanding of, qualifications
obtained in third countries.
• Consistency with existing policy provisions in the policy area
The proposal is complementary to, and does not overlap with, existing EU instruments. The
Professional Qualifications Directive provides a robust framework for the recognition of
professional qualifications, but its Single Market legal basis confines its personal scope to EU
nationals; it does not, and cannot, extend to third-country nationals. Existing EU migration
instruments contain only limited provisions on recognition, generally limited to equal
treatment with nationals of the Member State concerned. None of these instruments regulate
the organisation, structure or functioning of recognition procedures as such, or require
Member States to simplify or coordinate such procedures. Commission Recommendation
(EU) 2023/2611 is the only EU-level instrument specifically addressing recognition of
qualifications of third-country nationals and is non-binding and therefore cannot ensure
consistent outcomes across the Union. The proposal is one of three interlinked actions under
the Skills Portability Initiative. Action 1 addresses improving the availability of reliable,
comparable and verifiable digitalised information on qualifications and skills in the EU.
Action 2 modernises recognition procedures under the Professional Qualifications Directive
for EU citizens. Action 3 — the subject of this proposal — addresses the gap in the EU legal
and policy framework covering recognition of qualifications of third-country nationals (and is
based on Article 79(2), points (a) and (b), TFEU).
The procedural guarantees in this proposal are aligned with those applicable to Union citizens
under Directive 2005/36/EC as amended by Action 2 of the Skills Portability Initiative, and
do not place third-country nationals in a more favourable position than Union citizens
exercising free movement. The differences between the two frameworks reflect the practical
challenges of assessing qualifications from third countries, which justifies the need for an
extensive prior review of the learning programmes concerned benefitting from automatic
recognition.
• Consistency with other Union policies
The proposal forms part of the Fair Labour Mobility Package. It responds to the
Competitiveness Compass's identification of skilled labour shortages as a structural
EN 3 EN
competitiveness risk, to the Union of Skills and to the Single Market Strategy's call for
digitalisation and procedural simplification of recognition. It complements and reinforces the
effectiveness of the EU Talent Pool (established by Regulation (EU) 2026/1047), Talent
Partnerships with priority third countries, the European Legal Gateway Office pilot, the EU's
Visa Strategy, the Commission Recommendation on attracting talent for innovation, and the
Action Plan on Integration and Inclusion, all of which rely on well-functioning recognition
systems to deliver their intended results. The proposal also contributes to the objectives of the
European Asylum and Migration Strategy adopted in January 2026 which aims at making the
EU the most attractive place in the global race for talent in the next five years. The proposal is
consistent with the Union's policy on trade, in particular as regards the framework on Mutual
Recognition Agreements established in EU free trade agreements.The initiative also
contributes to the 2030 Agenda for Sustainable Development, in particular SDG 1 (No
poverty), SDG 8 (Decent work and economic growth), SDG 9 (Industry, innovation and
infrastructure) and SDG 10 (Reduced inequalities).
2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY
• Legal basis
The proposal is based on Article 79(2), points (a) and (b), TFEU, which empowers the
European Parliament and the Council, acting in accordance with the ordinary legislative
procedure, to adopt measures in the area of the conditions of entry and residence of third-
country nationals and the definition of their rights, including the conditions governing
freedom of movement and of residence in other Member States and access to employment.
Recognition of qualifications is directly linked to the conditions of entry and residence within
the meaning of Article 79(2)(a) TFEU, since access to employment — and therefore to
residence for work purposes — often depends on whether qualifications obtained in a third
country can be recognised. The proposal also supports the effective exercise of the rights of
third-country nationals legally residing in the Union under Article 79(2)(b) TFEU, by
facilitating access to employment corresponding to their qualifications and reducing the
underutilisation of their skills. This legal basis is distinct from the Single Market legal bases
(Articles 46, 49, 53 and 62 TFEU) used for Actions 1 and 2 of the Skills Portability Initiative,
which are confined in personal scope to EU nationals exercising free movement rights. In
accordance with Article 79(5) TFEU, the proposal does not affect Member States' right to
determine the volumes of third-country nationals admitted to their territory to seek work,
whether employed or self-employed.
• Subsidiarity (for non-exclusive competence)
Article 79 TFEU falls within Title V TFEU (the Area of Freedom, Security and Justice),
which Article 4(2)(j) TFEU identifies as a shared competence between the Union and the
Member States. The objectives of streamlined, simple and trusted recognition procedures for
third-country nationals cannot be sufficiently achieved by Member States acting alone.
Divergent national systems, combined with the absence of any legal framework comparable to
Directive 2005/36/EC, generate cross-border uncertainty and burden that individual Member
States cannot resolve alone; recognition procedures interact structurally with EU migration
instruments whose effectiveness depends on their functioning adequately; and the lack of trust
in third-country qualifications would best be addressed through EU-level tools that generate
economies of scale which would be inefficient to replicate separately across 27 national
systems. This necessity was confirmed in the Public Consultation, in which 95.3% of
respondents considered EU-level action very or somewhat necessary. Action at Union level is
more effective than action at national level and delivers clear added value: it would allow
EN 4 EN
third-country nationals to better understand requirements, prepare applications and anticipate
outcomes; it would lower the administrative burden faced by employers, particularly SMEs,
in navigating divergent national systems; and it would strengthen the EU's position in the
global competition for talent by supporting instruments such as the EU Blue Card, the EU
Talent Pool and Talent Partnerships. The preferred policy option is estimated to generate
aggregate administrative savings for competent authorities, employers and third-country
nationals amounting to approximately EUR 22.3 million per year, monetised time savings for
applicants of approximately EUR 300 million per year, and a reduction in employer-borne
administrative costs of approximately EUR 20 million per year — benefits that could not be
achieved as efficiently through 27 separate national approaches. The proposal does not
transfer Member States' competence over the definition of regulated professions, national
education and training systems, or migration and admission decisions.
• Proportionality
The Impact Assessment examined three policy options: a non-binding option based on soft
measures and guidance (PO1); a binding option establishing common procedural rules,
including an EU authenticity-verification service and interoperable national databases (PO2);
and a binding option combining these common rules with automatic recognition for a defined
set of professions, grounded in prior verification of third-country learning programmes (PO3,
the preferred option). Each option was assessed against the principles of subsidiarity and
proportionality: PO1 imposes no new obligations on Member States; PO2 addresses
procedural requirements without harmonising substantive assessment standards; and PO3,
while going further, remains grounded in the existing framework of minimum training
requirements under the Professional Qualifications Directive, preserves Member States'
competence over qualification standards and admission decisions, and makes participation by
third-country institutions in the automatic-recognition register voluntary. PO3 was identified
as the preferred option because it generates aggregate net benefits substantially larger than the
alternatives (an overall comparative score of 9, against 6 for PO2 and 3 for PO1, across the
criteria of effectiveness, efficiency and coherence), while remaining limited to what is
necessary: it does not create a 'once-only' EU-wide validity of recognition, does not
harmonise which professions are regulated, and does not alter or interfere with Member
States' competence over migration and admission decisions. Implementation obligations are
proportionate to the improvements it delivers and sit within the established EU legislative
tradition of minimum harmonisation in the field of recognition of qualifications. The
measures in the proposal are directly linked to the scale and persistence of the problems
associated with recognition of qualifications in the wider context of talent attraction. The
general system simplifies procedures without harmonising substantive assessment standards.
The automatic recognition system is grounded in prior programme verification. The system
preserves Member State competence over qualification standards and admission decisions;
participation by third-country institutions is voluntary and the system will expand based on
demonstrated interest by the institutions, limiting the risk of unintended effects on origin
country skills systems. The proposal does not affect Member State competence to take
recognition decisions or manage migration and admissions. Further detail on the comparative
assessment of policy options and their proportionality is set out in Sections 6 and 7 and the
Preferred Option section of the Impact Assessment (SWD) accompanying this proposal.
• Choice of the instrument
The proposal takes the form of a Directive laying down minimum requirements for the
recognition of qualifications of third-country nationals. A Directive is considered the most
appropriate instrument, as it establishes binding common rules while leaving Member States
the discretion to organise their competent authorities and to integrate the new rules within
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their own administrative and procedural traditions, consistent with the degree of
harmonisation traditionally applied in this field (including under Directive 2005/36/EC). A
Regulation was considered disproportionate and unsuitable given that the proposal lays down
only a harmonised minimum set of rights and guarantees, leaving Member States free to
introduce or maintain more favourable systems; the common rules must be integrated into the
highly diverse recognition and migration procedures currently in place across Member States;
and the common rules would not regulate the matter exhaustively.
3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER
CONSULTATIONS AND IMPACT ASSESSMENTS
• Ex-post evaluations/fitness checks of existing legislation
There is no existing EU legislation specifically addressing the recognition of qualifications of
third-country nationals, and therefore no ex-post evaluation or fitness check of such
legislation exists. The only EU-level instrument in this field, Commission Recommendation
(EU) 2023/2611, is non-binding and has not been subject to formal ex-post evaluation. The
problem analysis underpinning this proposal is instead based on extensive desk research,
primary fieldwork and stakeholder consultation, described in the Impact Assessment, which
quantifies the practical consequences of the current fragmented landscape, including the
average cost (EUR 1,500) and duration (14.2 months) of recognition procedures for third-
country nationals.
• Stakeholder consultations
A Call for Evidence covering the Skills Portability Initiative, its three actions and envisaged
policy options was published on 5 December 2025 and remained open until 27 February 2026.
A Public Consultation ran in parallel from October 2025 to April 2026. Targeted
consultations were conducted between October 2025 and April 2026 with national competent
authorities, healthcare professional organisations (including CPME, EFN and UEMO),
employers, civil society organisations and third-country national applicants, including a
dedicated third-country national survey, together with bilateral meetings and written
contributions from Member State governments. Employer, third-country national, civil-
society and professional-organisation respondents were broadly supportive of binding
common procedural rules; Member State positions were more nuanced. Some Member
States explicitly supported common rules modelled on the general system of Directive
2005/36/EC; others offered conditional support tied to avoiding new administrative burden
and maintaining alignment with existing national frameworks. These positions, and the
Commission's assessment of how they have been reflected in the preferred option, are
summarised in Annex 2 (Stakeholder consultation synopsis report) of the Impact Assessment.
• Collection and use of expertise
The Impact Assessment draws on a study conducted by an external contractor (a consortium
led by EY Italy in collaboration with the Istituto Ricerca Sociale, IRS). The call for tenders
was launched on 25 July 2025 and the study was awarded on 16 October 2025, with a kick-off
meeting on 24 October 2025, an inception report delivered on 16 December 2025, a draft
interim report on 3 March 2026 and a final report on 30 April 2026. An Inter-Service Steering
Group, comprising more than twenty Commission services, met three times to steer the
preparation of the Skills Portability Initiative, complemented by a dedicated steering group for
the external study and other bilateral meetings.
EN 6 EN
• Impact assessment
This proposal is supported by an Impact Assessment. The draft Impact Assessment was
submitted to the Regulatory Scrutiny Board on 15 June 2026 and examined by the Board on
15 July 2026. The Regulatory Scrutiny Board issued a positive opinion with comments on the
draft Impact Assessment on 17 July 2026.Three policy options were compared against a 'do-
nothing' baseline: PO1 (non-binding soft measures), PO2 (common binding procedural rules)
and PO3 (common binding procedural rules with automatic recognition for a defined set of
regulated professions, the preferred option). PO3 scored highest across all three comparative
criteria (effectiveness, efficiency and coherence), generating aggregate administrative savings
estimated at EUR 22.3 million per year, monetised time savings for applicants of
approximately EUR 300 million per year, and a reduction in employer-borne administrative
costs of approximately EUR 20 million per year, against implementation costs of EUR 28.7–
50.7 million one-off and EUR 3.7–6.0 million per year, borne mainly at EU level. The final
policy proposal reflects the preferred option identified in the Impact Assessment.
• Regulatory fitness and simplification
While this is not a REFIT initiative in the strict sense, the proposal is designed to reduce,
rather than add to, the administrative burden currently faced by third-country nationals,
employers and competent authorities. Common procedural rules are estimated to reduce
certified translation needs by around one third, while the new support services for assessment
of authenticity will reduce the burden associated with verifying documents. Mandatory
coordination between recognition and migration authorities eliminates duplicate qualification
assessments across parallel administrative procedures. In line with the simplicity by design
principles applied to this proposal, the following elements were assessed and addressed: (i)
digital-by-default delivery, (ii) the "once-only" principle for organisation of recognition
procedures, and (iii) proportionality for small administrations and employers. For the
professions covered by automatic recognition, processing times are projected to fall from 14.2
months to approximately 4 months freeing competent authority capacity for more complex
cases. Employers stand to benefit from faster recruitment and more predictable timelines, with
administrative costs for hiring a recognised professional estimated to fall by 35–50% for
sectoral professions, generating indicative aggregate savings of EUR 14–30 million per year.
No new administrative costs are expected for citizens or businesses, consistent with the 'one
in, one out' approach; the proposal does not impose compliance obligations on economic
operators, notably SMEs and micro-enterprises, and therefore does not require a specific
exemption for micro-enterprises. A dedicated SME panel survey captured the specific
experiences and views of SMEs to gather their understandings of the costs, administrative
burden and expected benefits associated with EU-level action. The SME Panel Survey (2026,
n=159) found that 68% of respondents identify reduced administrative burden during
recruitment as the primary anticipated benefit of a more common EU recognition framework,
61% identify faster recruitment processes, and 70% identify faster and more transparent
procedures as a structural factor in attracting qualified third-country professionals. Faster,
more predictable procedures are expected to generate monetised time savings for employers
of around EUR 20 million per year. The proposal is designed to be internet-ready: it requires
that all requirements, procedures and formalities in recognition procedures may also be
completed remotely and by electronic means and that relevant information is made available
on existing EU digital tools and platforms.
• Fundamental rights
The proposal reduces procedural barriers to recognition, enhancing access to occupations and
employment rights (Articles 15 and 20 of the Charter of Fundamental Rights of the European
EN 7 EN
Union; Principle 4 of the European Pillar of Social Rights). It introduces enforceable
procedural guarantees — binding timelines, defined documentation requirements and appeal
rights — giving third-country nationals an effective remedy against procedural failures
(Article 47 of the Charter) and supporting the right to good administration (Article 41). By
enabling access to regulated professions commensurate with qualifications of third-country
nationals, it improves fair and just working conditions (Article 31 of the Charter; Pillar
Principles 5 and 6). A common procedural baseline applicable irrespective of nationality
reinforces compliance with the principle of non-discrimination and promotes equal
opportunities (Articles 21 and 23 of the Charter; Pillar Principles 2 and 3); the automatic
recognition channel addresses the risk of undeclared work disproportionately borne by women
in care and nursing professions, with a direct gender-equality dimension, and tailored
information and support are provided for refugees and other vulnerable applicants. The
proposal also gives effect to the requirement of a high level of human health protection
(Article 35 of the Charter), as recognition of medical qualifications remain conditional on
meeting the applicable minimum training requirements, compensation measures and language
controls. Processing of personal data by Member States' competent authorities under this
Directive is carried out in accordance with Regulation (EU) 2016/679 (GDPR); processing by
the Commission, including for the support services for assessment of authenticity, is carried
out in accordance with Regulation (EU) 2018/1725 (EUDPR).
4. BUDGETARY IMPLICATIONS
The proposal entails budgetary implications for the Union, principally linked to the
establishment and operation of the support services for assessment of authenticity (Article
28), to be procured externally, the review architecture underpinning automatic recognition
(trusted review bodies and the associated delegated-act framework under Articles 12, 14 and
16), and the secretariat of the group of coordinators for the recognition of qualifications of
third-country nationals (Article 33).
The resources needed may be provided in the Commission’s proposal for the next MFF 2028-
2034, in particular the EU Facility under the National and Regional Partnership Plans. The
Commission assesses that part of the existing staff can be redeployed to meet the needs
generated by this proposal, and an additional three full-time equivalents will be necessary to
complement the overall needs.
The estimated impact on expenditure and staffing for 2028 and beyond is added for
illustrative purposes only and does not pre-judge the next Multiannual Financial Framework.
The source of financing and scope of Union financial commitment in the post-2027 period
remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and
thereafter shall be determined through the annual budgetary procedure. All appropriations and
staffing allocations as of 2028 are indicative.
5. OTHER ELEMENTS
• Implementation plans and monitoring, evaluation and reporting arrangements
A group of coordinators for the recognition of qualifications of third-country nationals is
established as an advisory group to the Commission (Article 33), tasked with facilitating
cooperation between Member States and the Commission, supporting implementation, and
ensuring coordination with other relevant expert groups. The existing network of national
contact points designated under Article 57 of Directive 2005/36/EC will also cover matters
arising under this Directive (Article 34). Monitoring will be based on headline indicators for
each specific objective. From the date of application, Member States will submit annual
EN 8 EN
statistics on applications, processing times, information exchanges and use of the automatic
recognition channel and the authenticity-verification service (Article 35); operational data
from the support services for assessment of authenticity will feed directly into this monitoring
without additional national reporting obligations. Member States will submit implementation
reports to the Commission, and the Commission will report to the European Parliament and
the Council no sooner than seven years after the date of transposition (Article 37), covering
processing times, outcomes, user experience and identified bottlenecks. A formal evaluation
of the Directive's effectiveness, efficiency, coherence and EU added value is envisaged no
sooner than seven years after the date of transposition, examining in particular whether
processing times and administrative costs have fallen, the uptake of the automatic recognition
channel, and whether trust in third-country qualifications has increased.
• Detailed explanation of the specific provisions of the proposal
Title I — General provisions (Articles 1–3)
Article 1 sets out the subject matter: minimum requirements for the recognition of
qualifications obtained in a third country or another Member State, held by third-country
nationals, where recognition facilitates access to a regulated profession or is part of a
procedure to obtain a long-stay visa or a residence permit. Article 2 defines the personal and
material scope, covering third-country nationals already legally residing in a Member State
and those seeking entry and residence who demonstrate a clear intention to migrate (for
instance through an ongoing procedure to obtain a long-stay visa or a residence permit, a job
offer, or registration on the EU Talent Pool). Article 3 sets out the definitions used throughout
the Directive, including 'recognition of professional qualifications', 'recognition in the context
of a procedure to obtain a long-stay visa or a residence permit', and 'digital credential'.
Title II — Recognition to access a regulated profession (Articles 4–20)
Chapter 1 (Articles 4 to 6) sets out the general effects of recognition for access to regulated
professions, the conditions for partial access, and the processing of qualifications already
obtained within the Union. Chapter 2 (Articles 7 to 10) establishes a general system for the
recognition of evidence of training issued in third countries, modelled on the general system
of Directive 2005/36/EC, including the conditions for recognition (Article 8), the
compensation measures that may be imposed where substantial differences exist (Article 9),
and the minimum training requirements applicable to certain sectoral professions (Article 10).
Chapter 3 (Articles 11 to 15) establishes the automatic recognition mechanism for a defined
set of professions (doctors, nurses responsible for general care, dental practitioners, midwives,
veterinary surgeons, pharmacists and architects) obtained in a third country, on the basis of
training programmes reviewed by a 'trusted review body' against the applicable quality-
assurance and minimum-training frameworks.Article 13 sets out the review criteria, Article
14 the methodology and the composition of the review team; Article 15 provides a right to
appeal review decisions and a Member State challenge mechanism; Article 12 defines which
bodies may act as trusted review bodies; and Article 16 empowers the Commission to
recognise third countries whose education and training systems provide sufficient guarantees,
simplifying or waiving the review requirement for institutions established there. Chapter 4
(Articles 17 to 20) sets out rules for pursuing the profession once recognised, covering
language requirements, use of academic and professional titles, and approval by health
insurance funds.
Title III — Recognition in the context of a procedure to obtain a long-stay visa or a
residence permit (Articles 21 to 26)
EN 9 EN
This Title applies where recognition or assessment of a qualification is a condition for, or
influences the outcome of a procedure to obtain a long-stay visa or a residence permit. Article
22 establishes the right to assessment of qualifications where this is part of a procedure to
obtain a long-stay visa or a residence permit. Article 23 requires that recognition procedures
under this Title be limited to what is necessary and be integrated into the relevant procedure
to obtain a long-stay visa or a residence permit wherever possible, avoiding duplicate
assessments, separate applications or additional fees. Article 24 requires that qualification
levels be assessed using the European Qualifications Framework; Article 25 sets out a
learning-outcomes approach for cases going beyond a simple level comparison, including the
compensation measures available where substantial differences are identified. Article 26 gives
applicants the option of an integrated procedure combining migration-related recognition with
recognition of qualifications for access to a regulated profession, avoiding duplication of
effort.
Title IV — Common provisions (Articles 27 to 32)
Article 27 limits the documents and formalities that competent authorities may require to
those listed in Annex VII of Directive 2005/36/EC, and provides for alternative methods of
verification where confirmation from a third country is unfeasible within the applicable
deadline. Article 28 establishes support services for assessment of authenticity, provided by
the Commission to Member States as advisory (non-binding) assessments of the authenticity
of qualifications submitted by applicants, operating in accordance with Regulation (EU)
2018/1725. Article 29 sets binding procedural deadlines for recognition decisions (in principle
three months from the submission of a complete application), together with information and
appeal rights. Article 30 requires that recognition procedures under Title II and III can be
completed remotely and electronically, and provides safeguards on residence permits during
the procedure. Article 31 sets criteria for any fees charged. Article 32 requires Member States
to provide third-country nationals with timely, comprehensive and user-friendly information
on recognition procedures, including tailored information for refugees and other vulnerable
applicants.
Title V — Reporting and final provisions (Articles 33 to 42)
Article 33 establishes a group on the recognition of qualifications of third-country nationals as
an advisory group to the Commission. Article 34 extends the role of existing assistance
centres designated under Directive 2005/36/EC to matters covered by this Directive. Article
35 extends the application of the alert mechanism of Directive 2005/36/EC to third-country
nationals. Article 36 sets out the conditions for the exercise of the delegated powers conferred
on the Commission. Article 38 sets out the conditions for the exercise of the implementing
powers conferred on the Commission. Article 39 establishes implementation and reporting
obligations. Articles 40 to 42 contain the standard final provisions on transposition, entry into
force and addressees.
EN 10 EN
2026/0275 (COD)
Proposal for a
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on the recognition of qualifications of third-country nationals
(Text with EEA relevance)
THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular
Article 79(2), points (a) and (b), thereof,
Having regard to the proposal from the European Commission,
After transmission of the draft legislative act to the national Parliaments,
Acting in accordance with the ordinary legislative procedure,
Whereas:
(1) To enhance labour market efficiency, foster fair integration, and strengthen the
Union's economic resilience and competitiveness, it is necessary to establish a clear,
common and predictable framework for the recognition of the qualifications of third-
country nationals, obtained in another Member State or in a third country, for the
purposes of access to a regulated profession in a Member State and of obtaining a
long-stay visa or a residence permit.
(2) Third-country nationals, whether already legally residing in a Member State or seeking
to enter and reside in the Union, encounter recognition procedures for their
qualifications that are often fragmented, overly complex, and lacking transparency,
resulting in uncertainty, delays, and inconsistent outcomes across Member
States. Member States have taken commitments under the Lisbon Recognition
Convention1 and the Global Convention on Higher Education2, yet national rules still
present varying requirements, procedures, and outcomes depending on the Member
State, the profession concerned, and the competent authority. Those disparities and
complexity create unnecessary barriers to labour market integration, contribute to
skills waste, and undermine the Union's ability to attract and retain the talent needed to
address persistent skills shortages.
(3) This Directive forms part of a package together with [Regulation xxxx/xx/EU
establishing a framework for portability of skills and qualifications and amending
Regulation (EU) 2018/1724 ('Skills Portability Act')] s and [Directive xx/xxx
amending Directive 2005/36]. Digital qualification attestations issued under that
Regulation should be accepted as digital credentials for the purposes of this Directive.
1 Council of Europe and UNESCO, "Convention on the Recognition of Qualifications concerning Higher
Education in the European Region", ETS No. 165, Lisbon, 11 April 1997. coe.int. 2 UNESCO, "Global Convention on the Recognition of Qualifications concerning Higher Education",
Paris, 25 November 2019. https://www.unesco.org/en/legal-affairs/global-convention-recognition-
qualifications-concerning-higher-education.
EN 11 EN
Where a third-country national holds a qualification obtained in the Union, recognition
should take place under this Directive by applying the rules of Directive 2005/36/EC
accordingly, in order to avoid parallel procedures.
(4) The Union's ability to attract and retain skilled third-country nationals is a key
determinant of its long-term competitiveness. The Union currently competes at a
disadvantage in the global market for talent, with skilled third-country nationals often
favouring other destinations, among others, due to the fragmented, complex and
unpredictable procedures they face in seeking recognition of their qualifications in the
Union.
(5) Existing Union instruments on migration, such as Council Directive 2003/109/EC3,
Directives 2014/36/EU4, 2014/66/EU5, (EU) 2016/8016, (EU) 2021/18837, and (EU)
2024/12338 of the European Parliament and of the Council, do not establish rules on
the organisation, structure or functioning of recognition systems, nor rules for Member
States to simplify, harmonise or coordinate recognition procedures, in cases where
recognition is required for migration purposes. Consequently, divergences in national
approaches persist, and the structural misalignment between migration systems and
qualification recognition frameworks remains unaddressed. Faster and more effective
recognition of qualifications would also strengthen the effectiveness of the EU Talent
Pool established by Regulation (EU) 2026/1047 of the European Parliament and of the
Council9. Once operational, the EU Talent Pool will provide the first Union-wide
platform addressing labour shortages at the Union level by facilitating the recruitment
of third-country nationals. In that regard, it is key to support employers' understanding
of the qualifications of third-country nationals, and the confidence of Member States'
competent authorities that the qualifications presented correspond to recognised levels
of skills. Streamlined and reliable recognition of qualifications therefore supports the
functioning of the EU Talent Pool by providing the necessary assurance to employers
and host Member States, and by reducing the administrative burden on third-country
nationals. By reducing the mismatch between the qualifications held by third-country
nationals and the level of employment they actually obtain, this Directive also
3 Council Directive 2003/109/EC of 25 November 2003 concerning the status of third-country nationals
who are long-term residents (OJ L 16, 23.1.2004, p. 44, ELI: http://data.europa.eu/eli/dir/2003/109/oj). 4 Directive 2014/36/EU of the European Parliament and of the Council of 26 February 2014 on the
conditions of entry and stay of third-country nationals for the purpose of employment as seasonal
workers (OJ L 94, 28.3.2014, p. 375, ELI: http://data.europa.eu/eli/dir/2014/36/oj). 5 Directive 2014/66/EU of the European Parliament and of the Council of 15 May 2014 on the conditions
of entry and residence of third-country nationals in the framework of an intra-corporate transfer (OJ L
157, 27.5.2014, p. 1, ELI: http://data.europa.eu/eli/dir/2014/66/oj). 6 Directive (EU) 2016/801 of the European Parliament and of the Council of 11 May 2016 on the
conditions of entry and residence of third-country nationals for the purposes of research, studies,
training, voluntary service, pupil exchange schemes or educational projects and au pairing (OJ L 132,
21.5.2016, p. 21, ELI: http://data.europa.eu/eli/dir/2016/801/oj). 7 Directive (EU) 2021/1883 of the European Parliament and of the Council of 20 October 2021 on the
conditions of entry and residence of third-country nationals for the purpose of highly qualified
employment, and repealing Council Directive 2009/50/EC (OJ L 382, 28.10.2021, p. 1, ELI:
http://data.europa.eu/eli/dir/2021/1883/oj). 8 Directive (EU) 2024/1233 of the European Parliament and of the Council of 24 April 2024 on a single
application procedure for a single permit for third-country nationals to reside and work in the territory
of a Member State and on a common set of rights for third-country workers legally residing in a
Member State (OJ L, 2024/1233, 30.04.2024, ELI: http://data.europa.eu/eli/dir/2024/1233/oj). 9 Regulation (EU) 2026/1047 of the European Parliament and of the Council of 29 April 2026
establishing an EU Talent Pool (OJ L, 2026/1047, 12.5.2026, ELI:
http://data.europa.eu/eli/reg/2026/1047/oj).
EN 12 EN
contributes to strengthening the labour market participation of disadvantaged groups
within the Union.
(6) For the purposes of this Directive, recognition of qualifications should be understood
as covering both recognition for the purpose of access to a regulated profession and
recognition in the context of a procedure to obtain a long-stay visa or a residence
permit. This Directive should therefore apply to third-country nationals seeking either
form of recognition, independently of whether their qualifications were obtained in a
Member State or a third country, and irrespective of whether they are already legally
residing in the Union or are seeking to migrate to it with a demonstrated intention to
do so, such as through the EU Talent Pool.
(7) The provisions of this Directive should be without prejudice to the competence of
Member States to regulate professions or determine the requirements for issuing a
long-stay visa or a residence permit regulated under national law, and, in accordance
with Article 79(5) TFEU, to their right to determine the volume of third-country
nationals admitted to their territory for the purpose of seeking work.
(8) Access to regulated professions depends on the possession of the required professional
qualifications or of professional qualifications that can be recognised as equivalent to
those qualifications required to practise in the host Member State. Third-country
nationals face significant disparities in recognition procedures across Member States.
Differences in required documentation, compensation measures and assessment
methods risk encouraging applicants to target jurisdictions with more lenient
procedures before relocating, which undermines fairness and places the Union at a
competitive disadvantage in attracting global talent.
(9) In order to ensure equal treatment and non-discriminatory access to the profession,
recognition of professional qualifications should enable third-country nationals to
access and pursue in the host Member State the same profession as that for which they
are qualified in another Member State or in a third country, under the same conditions
as nationals of the host Member State. For third-country nationals, access to the
profession should remain subject to applicable requirements relating to residence,
employment and other legal conditions, and should not create new entry or residence
rights. Access under the same conditions should also mean that, where nationals of the
host Member State are required, in order to pursue the profession, to satisfy additional
requirements, such as providing evidence of a clear criminal and professional record,
the host Member State may apply the same requirements to third-country nationals.
(10) In order to avoid imposing disproportionate requirements on applicants, where the
regulated profession in the host Member State covers activities going beyond those for
which the applicant is qualified, and full compensatory measures would in practice
amount to requiring completion of an entire training programme, the host Member
State should be able to grant partial access, provided that the relevant activity can
objectively be separated from other activities covered by the profession and subject to
the case-law of the Court of Justice of the European Union on overriding reasons of
general interest.
(11) In order to ensure the consistent treatment of qualifications obtained within the Union,
while respecting the distinction with the freedom to provide services under Article 56
TFEU, where third-country nationals hold attestations of competence, evidence of
formal qualifications or professional experience acquired in a Member State that
would enable a Union citizen to access a regulated profession under Title III of
EN 13 EN
Directive 2005/36/EC of the European Parliament and of the Council10, the relevant
provisions of that Directive concerning the right of establishment should apply mutatis
mutandis to them.
(12) To enable third-country nationals to make full use of those qualifications obtained in a
third country, while ensuring that recognition is subject to appropriate safeguards, two
complementary recognition systems should be established. First, a general system,
closely mirroring Title III, Chapter I of Directive 2005/36/EC and adapted to the
context of third-country qualifications; and, second, a system for the automatic
recognition of selected qualifications that meet Union minimum training and quality
standards, also adapted to reflect the specific challenges of assessing qualifications
obtained outside the Union.
(13) In order to ensure that all applicants have access to an appropriate assessment
pathway, qualifications acquired in a third country that do not benefit from automatic
recognition should be assessed under the general system, modelled on the general
system established by Directive 2005/36/EC but adapted to reflect the specific
difficulties of assessing qualifications and professional experience acquired outside the
Union.
(14) This Directive should also allow Member States to rely on alternative, reliable
methods of verification where the necessary documentation cannot reasonably be
obtained from a third country, so that recognition procedures are not obstructed by
circumstances outside the applicant's control.
(15) In order to prevent compensation measures from being used as a disguised or
disproportionate barrier to recognition, under the general system, compensation
measures should remain limited to cases of substantial differences between the
applicant's qualification and domestic requirements, and of justified doubts about the
quality of the third country's education system. In light of the difficulties of assessing
third-country qualifications, including variable training standards and legitimate
doubts as to the quality of education systems, Member States should be afforded
greater flexibility than under Article 14 of Directive 2005/36/EC in determining
whether and which compensation measures to impose. To ensure that doubts
concerning the quality of education and training systems of third countries are not
invoked arbitrarily or without justification, Member States should notify the
Commission of the country and profession concerned and explain the nature of the
doubts. Moreover, any compensation measure should comply with the principle of
proportionality, take due account of relevant knowledge, skills and competences
already demonstrated by the applicant, and be applied in a manner that safeguards
applicants' procedural rights and supports their effective integration into the
profession.
(16) A system of automatic recognition speeds up recognition processes by removing the
need for individual assessments, reducing administrative burdens and ensuring greater
consistency in outcomes across Member States. It also has the potential to incentivise
the development of third-country training programmes aligned with Union standards,
expanding the pool of qualified professionals eligible to practise in the Union.
10 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the
recognition of professional qualifications (OJ L 255, 30.9.2005, p. 22, ELI:
http://data.europa.eu/eli/dir/2005/36/oj).
EN 14 EN
(17) The automatic recognition system should initially cover professions for which
Directive 2005/36/EC has already established harmonised minimum training
requirements, namely doctors, nurses responsible for general care, dental practitioners,
midwives, veterinary surgeons, pharmacists and architects, given their importance for
public health and safety and the persistent labour shortages affecting them. Its scope
should also extend to any profession for which a Common Training Framework is
adopted pursuant to Article 49a of Directive 2005/36/EC, ensuring the system remains
adaptable over time.
(18) To ensure the trustworthiness of the automatic recognition system, evidence of formal
qualifications benefiting from it should be issued following completion of a training
programme reviewed by a trusted independent body and should be issued as a digital
credential ensuring authenticity, security and ease of verification. The review process,
including any negative outcome, and the underlying review report should be made
public to ensure full transparency.
(19) A training programme should be regarded as ‘reviewed’ only where a trusted review
body has confirmed its compliance with the applicable quality and content standards,
including alignment with the minimum training conditions set out in Directive
2005/36/EC or the relevant common training framework. Given the greater variability
in oversight and transparency across third-country education systems compared with
the Union, such review requires more extensive scrutiny than in the context of
qualifications obtained within the Union, so as to ensure that only qualifications
meeting Union standards are eligible for automatic recognition.
(20) In order to ensure the rigour, credibility and transparency of the automatic recognition
system, the review process should be carried out by a multidisciplinary team of
independent experts with relevant subject-matter and quality assurance expertise,
including through an on-site assessment of the training environment, delivery methods
and quality assurance practices for the training programme. The 'reviewed' status
granted to a training programme should be time-limited and subject to periodic
renewal, to ensure that training standards continue to be met over time and that any
subsequent changes to applicable minimum training requirements are properly
reflected.
(21) In order to ensure the scalability and sustainability of the review system, a review
should take place at the request of, and be funded by, the individual third-country
training institution concerned, with results published. To ensure fairness and
accountability, training institutions should have the right to appeal review decisions
under the national law of the Member State where the trusted review body is
established, which have to be resolved promptly and fairly.
(22) To further strengthen trust in the automatic recognition system, Member States should
have a means of contesting a review decision where they have justified doubts as to its
correctness, subject to appropriate safeguards against misuse of that mechanism.
(23) To ensure the reliability, independence, expertise and accountability of the review
process, only quality assurance agencies established in the Union and meeting certain
eligibility criteria should be recognised as trusted review bodies, and their authority
should be limited to specified professions.
(24) In order to facilitate the recognition procedure for qualifications obtained in third
countries whose education and training systems offer sufficient guarantees of quality,
EN 15 EN
oversight and administrative cooperation, the review requirement should be
adjusted for the institutions established in those third countries.
(25) While applicants should have the language knowledge necessary to practise their
profession in the host Member State, language controls should only be carried out after
recognition of the qualification, to avoid creating unnecessary barriers within the
recognition process itself, and should be proportionate to the profession and activity
concerned.
(26) In the context of procedures for obtaining long-stay visas and residence permits for
work purposes, Member States routinely assess the qualifications of third-country
nationals as part of the applications, yet assessment criteria and approaches vary across
Member States and legal pathways, often creating uncertainty for applicants and
disparities in outcomes. To address those challenges, a common framework for
recognition in the context of such procedures should be established, complementing
and aligning with existing Union legal migration instruments and national rules,
without adding procedural burdens or conflicting with more favourable provisions.
(27) This Directive should establish a right for third-country nationals to obtain the
assessment of their qualifications where such recognition constitutes a prerequisite or
material factor for a positive outcome of the procedures to obtain long-stay visas and
residence permits, ensuring access to a fair, efficient and non-discriminatory
procedure. Where a Member State already treats a foreign qualification as equivalent
to a domestic one without requiring formal recognition, this Directive should not
oblige that Member State to introduce an additional procedure.
(28) Formal recognition requirements should be avoided to access professions that are not
regulated, in favour of transparency and comparability tools, such as the European
Qualifications Framework11 and Europass12, which enable third-country nationals,
employers and competent authorities to understand and compare qualifications and
skills. Where a procedure to obtain a long-stay visa or a residence permit concerns
access to a profession that is not regulated, Member States should rely on such tools
rather than impose formal recognition requirements, and nothing in this Directive
should be construed as requiring Member States to introduce such requirements for
that purpose.
(29) In order to prevent gaps in the protection of applicants, a common set of minimum
procedural rules should apply to all recognition processes carried out in the context of
procedures for obtaining a long-stay visa or a residence permit, whatever their scope,
depth or complexity. Those rules should always be applied proportionately to their
purpose. Where a check is intended only to confirm that qualifications are genuine and
relevant, or to verify a qualification's level, Member States should apply simpler and
faster procedures than those used for recognition for access to regulated professions.
Nothing in this Directive should be constructed as requiring Member States to
establish new or standalone recognition procedures where the necessary assessment
can be carried out within existing migration procedures.
11 Council recommendation of 22 May 2017 on the European Qualifications Framework for lifelong
learning and repealing the recommendation of the European Parliament and of the Council of 23 April
2008 on the establishment of the European Qualifications Framework for lifelong learning (OJ C 189,
15.6.2017, p. 15). 12 Decision (EU) 2018/646 of the European Parliament and of the Council of 18 April 2018 on a common
framework for the provision of better services for skills and qualifications (Europass) and repealing
Decision No 2241/2004/EC.
EN 16 EN
(30) In order to ensure a consistent and objective basis for assessing qualification levels
across Member States, where procedures for obtaining a long-stay visa or a residence
permit require an assessment of an applicant's qualification level, that assessment
should be based on the descriptors and levels of the European Qualifications
Framework, having regard to national qualifications frameworks and, where available,
existing comparisons between third-country frameworks and the European
Qualifications Framework. Where a more detailed assessment is required, going
beyond a comparison of levels or a general classification of the field of study, a
learning outcomes approach should be applied, comparing the applicant's acquired
skills against those required in the host Member State. To avoid applicants
unnecessarily completing compensation measures before a final decision on entry or
residence, qualifications assessed under a learning outcomes approach should be
provisionally recognised for the purposes of the procedure for obtaining a long-stay
visa or a residence permit, with any compensation measure required only once entry or
residence has been granted.
(31) To avoid that third-country nationals undergo parallel and duplicative procedures,
Member States should offer applicants seeking both a long-stay visa or a residence
permit and access to a regulated profession an integrated recognition procedure, and,
where applicants do not choose that option, ensure effective coordination between the
separate procedures, including referral mechanisms and reuse of prior verifications.
(32) Recognition procedures often impose significant administrative and financial burdens
on applicants, in particular due to extensive documentation requirements, including
diplomas, transcripts and evidence of professional experience, and the associated costs
of translation. To alleviate this burden, Member States should limit the documents and
certificates they require to the types of documents listed in Annex VII of Directive
2005/36/EC. Where the procedure to obtain a long-stay visa or a residence permit does
not require recognition or assessment of qualifications that would give access to a
regulated profession in its territory, Member States should limit documentary
requirements to those directly related to the applicant’s qualifications. Since there may
be exceptional reasons, such as non-cooperation, non-responsiveness or administrative
dysfunction of a third-country authority, an applicant should be able to show that
despite reasonable efforts, they were unable to obtain the requested documents.
Member States should be able to employ reliable alternative methods to assess
qualifications, skills or other evidentiary elements.
(33) In cases of justified doubts regarding the authenticity of submitted documents, or
regarding an applicant's professional conduct or criminal record, Member States
should be able to seek confirmation from the competent authorities of the third country
or Member State where the qualification was awarded. However, in view of their
inherent security and verification mechanisms, digital credentials should be presumed
authentic, and their validity should not be challenged. Since third countries may
nonetheless fail to provide such confirmation in a timely manner due to, for example,
non-cooperation, non-responsiveness or administrative dysfunction, and in order to
ensure that recognition procedures are not delayed or obstructed by circumstances
outside the applicant's control, Member States should be able to rely on reliable
alternative methods of attestation.
(34) Doubts about the authenticity of qualifications are a major obstacle to efficient
recognition procedures. Verifying third-country qualifications often proves complex
and resource-intensive for Member States, leading to delays, administrative burdens,
and legal uncertainties. These challenges are particularly acute for documents issued in
EN 17 EN
countries with less strong institutional frameworks or conflicts, where verification is
difficult. This problem is further compounded by the prevalence of fraudulent
credentials and diploma mills, which undermine trust in qualification recognition
procedures. While Member States have introduced stringent verification measures –
such as certified translations, notarised copies, and legalisation – those measures,
though aimed at ensuring authenticity, prolong processing times and increase costs for
applicants and authorities alike. To support Member States in verifying the
authenticity of qualifications obtained in third countries, the Commission will provide
support services for the assessment of authenticity, by pooling expertise, digital tools
and through cooperation with third countries and relevant educational and professional
bodies. Since responsibility for the underlying recognition decision remains with the
competent authorities of the Member States, in providing these services the
Commission shall only have an advisory role, providing reasoned technical support
rather than binding conclusions.
(35) The exchange of requests and responses between the Commission and the competent
authorities of the Member States for the assessment of authenticity entails cross-border
exchanges of data in support of the recognition of qualifications obtained in third
countries. The authentication support services constitute a trans-European digital
public service within the meaning of Regulation (EU) 2024/903 (the Interoperable
Europe Act), given that their operation entails cross-border exchanges of data to
support the recognition of qualifications of third-country nationals. Their operation
should therefore be subject to an interoperability assessment as referred to in that
Regulation, to be carried out through a delegated act.
(36) The processing of personal data by the Commission is necessary for the performance
of a task carried out in the public interest, namely supporting Member States in
assessing the authenticity of qualifications obtained in third countries, that task being
laid down in this Directive. Such processing should therefore be based on Article 5(1),
point (a), of Regulation (EU) 2018/1725.
(37) The duration and unpredictability of qualification recognition procedures constitute
major obstacles for third-country nationals seeking to enter or integrate into the Union
labour market. Beyond decision-making times, the overall duration is further
prolonged by document collection, translation, legalisation and compensation
measures, hampering individuals' professional integration and disrupting employers'
recruitment processes. To enhance legal certainty and procedural efficiency, clear time
limits for the acknowledgement of applications and the completion of recognition
procedures should be set. Competent authorities should be required to keep applicants
informed of the progress of their application. Recognition procedures should remain
fully accessible to beneficiaries of international protection unable to provide
documentary evidence of their qualifications, in accordance with Article 30(2) of
Regulation (EU) 2024/1347 of the European Parliament and of the Council13, while
respecting the minimum training requirements provided for in Article 2(2) of Directive
2005/36/EC.
13 Regulation (EU) 2024/1347 of the European Parliament and of the Council of 14 May 2024 on
standards for the qualification of third-country nationals or stateless persons as beneficiaries of
international protection, for a uniform status for refugees or for persons eligible for subsidiary
protection and for the content of the protection granted, amending Council Directive 2003/109/EC and
repealing Directive 2011/95/EU of the European Parliament and of the Council (OJ L, 2024/1347,
22.05.2024, ELI: http://data.europa.eu/eli/reg/2024/1347/oj).
EN 18 EN
(38) The time limits applicable to the recognition procedure should be without prejudice to,
and should not extend, suspend or otherwise affect, deadlines laid down under national
or Union law for examining applications for long-stay visas or residence permits.
Member States should organise the recognition procedure so as not to undermine the
timely processing of such applications.
(39) To safeguard applicants' rights, decisions on recognition, or failures to meet prescribed
deadlines, should be subject to appeal under national law. Member States should also
allow applicants to receive communications in either an official language of the host
Member State or another language commonly used by third-country nationals there.
(40) Access to recognition procedures remains a significant challenge for third-country
nationals residing outside the Union or lacking a legal pathway to enter a Member
State solely for this purpose, particularly where procedures rely on in-person
verification or national electronic identification is unavailable prior to entry. Member
States should therefore enable applicants not yet residing in their territory but with a
demonstrated intention to do so to complete the process remotely.
(41) Since recognition may be a precondition for the issuance or renewal of a residence or
work permit, and since a residence permit may itself expire before an applicant
completes a required compensation measure, Member States should ensure that third-
country nationals already legally residing in their territory are not deprived of their
residence status as a result of undergoing a recognition procedure, including by issuing
or extending residence permits for the duration of any compensation measure.
(42) To further simplify recognition procedures, Member States should allow their
completion remotely and by electronic means, without prejudice to the ability of
competent authorities to request certified copies at a later stage where justified doubts
arise.
(43) Recognition procedures often impose significant and unpredictable financial burdens
on applicants, including application fees, translation and legalisation costs, and
charges linked to compensation measures, with particularly high costs observed in
some healthcare professions. Member States should ensure that any fees charged are
transparent, justified and proportionate.
(44) Access to clear, comprehensive and user-friendly information is essential for third-
country nationals seeking recognition of their qualifications, yet current information
mechanisms across Member States often fall short of applicants' needs. Member States
should ensure timely, accurate and user-friendly information on recognition
procedures, including through digital platforms and national assistance centres, with
particular attention to the needs of refugees, beneficiaries of international protection,
and other applicants unable to access or understand such information autonomously.
(45) Member States should take into account the risk that facilitated recognition of
qualifications obtained in third countries may contribute to the loss of skilled
personnel from sectors or regions already affected by workforce shortages, in
particular in the health sector. Member States should cooperate with third countries of
origin, including through knowledge-sharing, support for skills development, and
circular migration opportunities, so as to mitigate the risk of such losses while
facilitating the fair recognition of qualifications for third-country nationals already
present in, or seeking to move to, the Union. In the health sector specifically, Member
States should have regard to the principles set out in the World Health Organization
Global Code of Practice on the International Recruitment of Health Personnel, and to
EN 19 EN
the WHO Health Workforce Support and Safeguards List, when engaging in the
recruitment of health personnel qualified in third countries identified in that List as
facing critical health workforce shortages.
(46) To ensure effective and consistent implementation of this Directive, a group on the
recognition of qualifications of third-country nationals should be established to
support cooperation between Member States and the Commission and the exchange of
experience and best practices. The assistance centres designated by Member States
pursuant to Article 57b of Directive 2005/36/EC should also assume responsibility for
matters relating to the recognition of qualifications of third-country nationals under
this Directive, without prejudice to the responsibilities of other competent authorities
under Union or national law.
(47) In order to achieve the objectives of this Directive, the power to adopt acts in
accordance with Article 290 TFEU should be delegated to the Commission to establish
and amend a list of trusted review bodies. It is of particular importance that the
Commission carry out appropriate consultations during its preparatory work, including
at expert level, and that those consultations be conducted in accordance with the
Interinstitutional Agreement of 13 April 2016 on Better Law-Making14. In particular,
to ensure equal participation in the preparation of delegated acts, the European
Parliament and the Council receive all documents at the same time as Member States'
experts, and their experts systematically have access to meetings of Commission
expert groups dealing with the preparation of delegated acts.
(48) In order to ensure uniform conditions for the implementation of this Directive,
implementing powers should be conferred on the Commission. Those powers should
be exercised in accordance with Regulation (EU) No 182/2011 of the European
Parliament and of the Council.15
(49) To enable effective monitoring of the implementation and impact of this Directive, and
to support its continuous improvement, Member States should provide the
Commission with annual statistics on the number of applications and decisions taken,
and should report periodically on the practical application of the provisions of this
Directive, including processing times, outcomes and stakeholder feedback, on the
basis of which the Commission should report to the European Parliament and the
Council.
(50) In accordance with Articles 1 and 2 of Protocol No 21 on the position of the United
Kingdom and Ireland in respect of the area of freedom, security and justice, annexed
to the Treaty on European Union (TEU) and to the TFEU, and without prejudice to
Article 4 of that Protocol, Ireland is not taking part in the adoption of this Directive
and is not bound by it or subject to its application. [Or: In accordance with Article 3 of
Protocol No 21 on the position of the United Kingdom and Ireland in respect of the
area of freedom, security and justice, annexed to the TEU and to the TFEU, Ireland
has notified, by letter of XXX, its wish to take part in the adoption and application of
this Directive.]
14 OJ L 123, 12.5.2016, p. 1, http://data.europa.eu/eli/agree_interinstit/2016/512/oj. 15 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011
laying down the rules and general principles concerning mechanisms for control by the Member States
of the Commission's exercise of implementing powers (OJ L 55, 28.2.2011, p. 13, ELI:
http://data.europa.eu/eli/reg/2011/182/oj).
EN 20 EN
(51) In accordance with Articles 1 and 2 of Protocol No 22 on the position of Denmark,
annexed to the TEU and to the TFEU, Denmark is not taking part in the adoption of
this Directive and is not bound by it or subject to its application.
(52) Since the objectives of this Directive, namely, to establish a streamlined and trusted
framework for the recognition of third-country nationals' qualifications, cannot be
sufficiently achieved by Member States but can, by reason of scale and effects, be
better achieved at Union level, the Union may adopt measures in accordance with the
principle of subsidiarity under Article 5 of the Treaty on the European Union. In
accordance with the principle of proportionality, this Directive does not go beyond
what is necessary to achieve those objectives.
(53) The processing of personal data under this Directive by the competent authorities of
the Member States should be carried out in accordance with Regulation (EU)
2016/679 of the European Parliament and of the Council16. The processing of personal
data under this Directive by the Commission, including for the support services for
assessment of authenticity, should be carried out in accordance with Regulation (EU)
2018/1725 of the European Parliament and of the Council17.
(54) The European Data Protection Supervisor was consulted in accordance with Article
42(1) of Regulation (EU) 2018/1725 and delivered an opinion on (…) ],
HAVE ADOPTED THIS DIRECTIVE:
Title I
General provisions
Article 1
Subject matter
1. This Directive lays down minimum requirements for the recognition of qualifications
held by third-country nationals.
2. This Directive shall not affect provisions of Union law and national law which are
more favourable to third-country nationals, including provisions regarding
procedures to obtain long-stay visas or residence permits where recognition forms
part of such procedures. This Directive shall also apply without prejudice to relevant
international instruments, including future or existing mutual recognition agreements
for qualifications with third countries.
Article 2
Scope
16 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement of
such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016,
p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj). 17 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the
protection of natural persons with regard to the processing of personal data by the Union institutions,
bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No
45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI:
http://data.europa.eu/eli/reg/2018/1725/oj).
EN 21 EN
1. This Directive shall apply to the recognition of qualifications held by third-country
nationals:
(a) legally residing in a Member State;
(b) seeking entry to and residence in a Member State, and that are undergoing a
procedure to obtain a long-stay visa or a residence permit in accordance with
Title III;
(c) seeking entry and residence in a Member State, and that apply for recognition
remotely in accordance with Article 30, and who meet one of the following
conditions:
(i) they have obtained a job offer in that Member State;
(ii) they are registered as a jobseeker on the EU Talent Pool established by
Regulation EU(2026)1047 and have been selected for a job vacancy or
have been contacted by an employer to start the recruitment process for a
job in that Member State, where recognition of qualifications is required
for the role.
It does not apply to the recognition of qualifications for the purpose of access to
further learning.
2. For the purposes of paragraph 1, this Directive shall apply where the recognition of
those qualifications, whether obtained in another Member State or in a third country:
(a) is a precondition to access and pursue a regulated profession within a Member
State, on either self-employed or employed basis; or
(b) constitutes a factor determining the outcome of a procedure to obtain a long-
stay visa or a residence permit for work purposes.
3. This Directive shall not apply to third-country nationals who, under agreements
between the Union and its Member States, on the one hand, and third countries, on
the other hand, enjoy rights of free movement equivalent to those of Union citizens.
4. This Directive shall not apply to notaries who are appointed by an official act of
government.
Article 3
Definitions
For the purposes of this Directive, the following definitions apply:
(a) ‘applicants’ means third-country nationals who apply to a host Member State for the
recognition of their qualifications and/or to obtain long-stay visas or residence
permits;
(b) ‘regulated profession’ means a regulated profession as defined in Article 3(1), point
(a), of Directive 2005/36/EC;
(c) ‘professional qualifications’ means qualifications attested by evidence of formal
qualifications, an attestation of competence and/or professional experience;
(d) ‘recognition of professional qualifications’ means the recognition by the host
Member State of a professional qualification obtained in another Member State or in
a third country for the purposes of access to or pursuit of a regulated profession in
the territory of the host Member State;
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(e) ‘evidence of formal qualifications’ means diplomas, certificates and other evidence
issued by an authority in a Member State or a third country designated pursuant to
legislative, regulatory or administrative provisions of that Member State or that third
country and certifying successful completion of professional training;
(f) ‘attestation of competence’ means documentation issued by the competent authority
in a Member State or third country designated in accordance with relevant
legislative, regulatory, or administrative provisions, on the basis of one or more of
the following:
(i) A training course not forming part of a certificate or diploma;
(ii) a specific examination without prior training;
(iii) full-time pursuit of the profession in a Member State or third country for three
consecutive years or for an equivalent duration on a part-time basis during the
previous 10 years;
(iv) general primary or secondary education attesting that the holder has acquired
general knowledge;
(g) ‘recognition in the context of a procedure to obtain a long-stay visa or a residence
permit’ means the recognition or assessment, by a Member State, of qualifications or
skills obtained in a third country or in another Member State, and held by a third-
country national, where it constitutes a factor determining the outcome of a
procedure to obtain a long-stay visa or a residence permit, including within a points-
based immigration system;
(h) ‘third-country national’ means a person who is not a citizen of the Union within the
meaning of Article 20(1) TFEU;
(i) ‘competent authority’ means any authority or body empowered by a Member State or
a third country specifically to issue or receive training diplomas and other documents
or information, to receive applications, and take the decisions referred to in this
Directive;
(j) ‘professional experience’ means the actual and lawful full-time or equivalent part-
time pursuit of the profession concerned in a Member State or a third country;
(k) ‘adaptation period’ means an adaptation period as defined in Article 3(1), point (g),
of Directive 2005/36/EC;
(l) ‘aptitude test’ means a test tailored to the applicant as defined in Article 3(1), point
(h), of Directive 2005/36/EC;
(m) ‘test of professional competence’ means a standardised test, designed for a specific
profession in order to evaluate an applicant’s knowledge and skills that are essential
to pursue that profession in the host Member State;
(n) ‘bridging course’ means a targeted course designed for a defined target group of
already qualified professionals to address specific typical gaps in professional
knowledge, skills and competences and enable them to practise the regulated
profession in the host Member State;
(o) ‘quality assurance agency’ means an independent body carrying out external quality
assurance in higher education or in vocational education and training (VET);
(p) ‘European Quality Assurance Register for Higher Education (EQAR)’ means the
register of quality assurance agencies that have demonstrated substantial compliance
EN 23 EN
with the Standards and Guidelines for Quality Assurance in the European Higher
Education Area, in the applicable version at the relevant time;
(q) ‘digital credential’ means a credential issued in electronic form which provides
information on qualifications, qualification levels, skills or learning outcomes, and
which can be used to demonstrate that information in a reliable and verifiable
manner.
Title II
Recognition to access a regulated profession
Chapter 1
General provisions
Article 4
Effects of recognition
1. The recognition of professional qualifications by the host Member State shall allow
beneficiaries to gain access in that Member State to the same profession as the one
for which they are qualified in the third country or in the other Member State where
they obtained their qualifications under the same conditions as the nationals of the
host Member State, provided the beneficiaries meet all necessary legal requirements
for employment and residency.
2. For the purposes of this Directive, the profession which the applicant wishes to
pursue in the host Member State shall be considered the same as the one for which
they are qualified in a third country or in another Member State if the activities
covered are comparable.
3. By way of derogation from paragraph 1 of this Article, partial access to a profession
in the host Member State shall be granted under the conditions laid down in Article
5.
Article 5
Partial access
1. The competent authority of the host Member State shall grant partial access, on a
case-by-case basis, to a professional activity in its territory only when all the
following conditions are fulfilled:
(a) the professional is fully qualified to exercise in a third country or another
Member State the professional activity for which partial access is sought in the
host Member State;
(b) differences between the professional activity legally exercised in the third
country or in the other Member State and the regulated profession in the host
Member State as such are so large that the application of compensation
measures would amount to requiring the applicant to complete the full
programme of education and training required in the host Member State to
have access to the full regulated profession in the host Member State;
(c) the professional activity can objectively be separated from other activities
falling under the regulated profession in the host Member State.
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For the purpose of the first subparagraph, point (c), the competent authority of the
host Member State shall take into account whether the professional activity can be
pursued autonomously in the third country or in the other Member State.
2. Partial access may be rejected if such rejection is justified by overriding reasons of
general interest, suitable for securing the attainment of the objective pursued, and
does not go beyond what is necessary to attain that objective.
3. Applications for the purposes of establishment in a Member State shall be examined
in accordance with Chapter 2 of this Title and with Title IV.
4. By way of derogation from Article 19, the professional activity shall be exercised
under the professional title of the third country or of the other Member State once
partial access has been granted. The host Member State may require use of that
professional title in the languages of the host Member State. Professionals benefiting
from partial access shall clearly indicate to the service recipients the scope of their
professional activities.
5. This Article shall not apply to professionals benefiting from automatic recognition of
their professional qualifications under Chapter 3 of this Title, and in cases where
Chapter II, III or IIIa of Title III of Directive 2005/36/EC have been applied to third-
country nationals in accordance with Article 6 of this Directive.
Article 6
Evidence of professional qualifications obtained in the Union
Where third-country nationals hold an attestation of competence, evidence of formal
qualifications, or professional experience obtained in the Union, and such qualifications or
experience would allow a Union citizen to access or pursue a regulated profession in the host
Member State pursuant to Title III of Directive 2005/36/EC, the provisions of that Directive
shall apply to those third-country nationals accordingly when they seek recognition to access
and pursue that profession in the host Member State.
Chapter 2
General system for the recognition of evidence of training issued
in third countries
Article 7
Scope
This Chapter applies to situations which are not covered by Article 6, or by Chapter 3 of this
Title or where the applicant does not satisfy the conditions laid down in Chapter 3 of this
Title.
Article 8
Conditions for recognition
1. If access to or pursuit of a regulated profession in a host Member State is contingent
upon possession of specific professional qualifications, the competent authority of
that Member State shall permit applicants to access and pursue that profession, under
the same conditions as apply to its nationals, if they possess an attestation of
competence or evidence of formal qualifications, issued by a competent authority in
EN 25 EN
a third country, and required by a third country in order to gain access to and pursue
that profession on that country’s territory.
2. Access to, and pursuit of, a profession as referred to in paragraph 1 shall also be
granted to applicants who have pursued the profession concerned on a full-time basis
for one year or for an equivalent overall duration on a part-time basis during the
previous 10 years in a third country which does not regulate that profession, and who
possess one or more attestations of competence or evidence of formal qualifications
issued by that third country which does not regulate the profession.
Attestations of competence and evidence of formal qualifications shall satisfy both of
the following conditions:
(a) they are issued by a competent authority in a third country;
(b) they attest that the holder has been prepared for the pursuit of the profession
concerned.
3. By way of derogation from paragraphs 1 and 2 of this Article, the competent
authority of the host Member State may refuse access to, and pursuit of, the regulated
profession to applicants who only possess an attestation of competence, where access
to or pursuit of that regulated profession in the host Member State requires a diploma
certifying successful completion of a post-secondary course of at least four years, or
for an equivalent duration on a part-time basis, which may in addition be expressed
with an equivalent number of ECTS credits, at a university or establishment of
higher education or another establishment of equivalent level.
4. When the applicant duly documents that, despite reasonable efforts, they were unable
to obtain the attestation of competence referred to in paragraphs 1, 2 and 3, the host
Member State shall assess the feasibility of, and where appropriate, employ
alternative methods to assess qualifications, skills or other evidentiary elements.
Those methods may include affidavits, third-party assessments, professional
interviews or reputable evaluation frameworks like qualifications passports, designed
for refugees and vulnerable migrants. The host Member State shall ensure that
applicants are not unduly disadvantaged due to those circumstances and shall base its
decisions on available and reasonable evidence.
Article 9
Compensation measures
1. Article 8 shall not preclude the host Member State from imposing on the applicant a
compensation measure among those listed in paragraph 2 of this Article in one of the
following cases:
(a) the training that the applicant has received covers substantially different
matters from those covered by the evidence of formal qualifications required in
the host Member State;
(b) the regulated profession in the host Member State comprises one or more
regulated professional activities which do not exist in the corresponding
profession in the third country where the applicant obtained the attestation of
competence or evidence of formal qualifications, and the training required in
the host Member State covers substantially different matters from those
covered by the applicant’s attestation of competence or evidence of formal
qualifications;
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(c) the Member State has justified doubts as to the quality of the education,
training or qualification system under which the evidence of formal
qualifications has been awarded.
For the purpose of this Article, ‘substantially different matters’ means matters in
respect of which knowledge and skills acquired are essential for pursuing the
profession and with regard to which the training received by the applicant shows
significant differences in terms of content from the training required by the host
Member State.
In case a Member State decides to impose compensation measures on the basis of
justified doubts according to point (c), it shall notify the Commission of the country
and profession concerned and the nature of the doubts.
2. If the host Member State makes use of the option provided for in paragraph 1, it shall
indicate to the applicant which of the following compensation measures they are
required to complete:
(a) an adaptation period, not exceeding three years, where the applicant undergoes
supervised practice and, if necessary, additional training;
(b) an aptitude test;
(c) a test of professional competence;
(d) a bridging course, with a duration of up to one year.
3. Paragraphs 1 and 2 shall be applied with due regard to the principle of
proportionality. In particular, if the host Member State intends to require the
applicant to complete a compensation measure, it shall first ascertain whether the
knowledge, skills and competences acquired by the applicant in the course of the
applicant’s professional experience or through lifelong learning, and formally
validated to that end by a relevant body, in any Member State or in a third country, is
of such nature as to cover, in full or in part, the substantially different matters.
4. The decision imposing a compensation measure shall be duly justified. In particular,
the applicant shall be provided with the reasons for the compensation measure,
information on the substantial differences, and, where relevant, why those
differences cannot be compensated by knowledge, skills and competences acquired
in the course of prior experience or other qualifications through lifelong learning
formally validated to that end by a relevant body.
5. Member States shall ensure that an applicant who fails the aptitude test or test of
professional competence referred to in paragraph 2, points (b) and (c), or one or more
tests forming part of a bridging course or adaptation period, referred to in paragraph
2, points (a) and (d), is given the opportunity to retake the respective tests. Member
States shall ensure that feedback detailing assessment results and areas for
improvement is provided to applicants, and ensure that applicants are entitled to at
least two further attempts to pass each test that they have failed.
6. Member States shall ensure that an applicant has the possibility of taking the aptitude
test or the test of professional competence referred to in paragraph 2, points (b) and
(c), not later than six months after the initial decision imposing an aptitude test or test
of professional competence on the applicant. Member States shall also ensure that an
applicant has the possibility to start a bridging course referred to in paragraph 2,
point (d), no later than six months after the initial decision imposing the completion
of a bridging course on the applicant.
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Article 10
Minimum training requirements for certain professions
Where Articles 24, 25, 28, 31, 34, 35, 38, 40 and 44 of Directive 2005/36/EC set out
minimum conditions on the training for certain professions, under this Chapter any
recognition of evidence of formal qualifications in one of those professions shall be
contingent upon fulfilment of those minimum conditions.
Chapter 3
Recognition on the basis of reviewed training programmes in
accordance with minimum training conditions
Article 11
Principle of automatic recognition based on reviewed training programmes in third
countries
1. Each Member State shall recognise evidence of formal qualifications giving access to
the professional activities of doctor with basic training or specialised doctor, as nurse
responsible for general care, as dental practitioner, as specialised dental practitioner,
as midwife, as veterinary surgeon, as pharmacist, and as architect, obtained in a third
country, and shall for the purposes of access to and pursuit of those professional
activities, give such evidence the same effect on its territory as the evidence of
formal qualifications which it itself issues, provided that all of the following
conditions are met:
(a) the evidence of formal qualifications has been obtained following successful
completion of a training programme which has been reviewed in accordance
with Articles 13 and 14 by a trusted review body within the meaning of Article
12;
(b) the trusted review body has publicly disclosed the result of the review process
and a review report;
(c) the evidence of formal qualifications is issued as a digital credential.
2. Each Member State shall, for the purpose of access to and pursuit of a regulated
profession that is covered by a common training framework pursuant to Article 49a
of Directive 2005/36/EC, and where that Member State is not exempted from the
obligation of introducing a common training framework in accordance with Article
49a(5) of Directive 2005/36/EC, give evidence of formal qualifications acquired in
third countries the same effect in its territory as the evidence of formal qualifications
which it itself issues, provided that all of the following conditions are met:
(a) the evidence of formal qualifications has been obtained following successful
completion of a training programme which has been reviewed in accordance
with Articles 13 and 14 by a trusted review body as referred to in Article 12;
(b) the trusted review body has publicly disclosed the result of the review process
and a review report;
(c) the evidence of formal qualifications is issued as a digital credential.
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Article 12
Trusted review bodies
1. A quality assurance agency established in the Union may apply to the Commission to
be listed as a trusted review body for higher education programmes if it fulfils all of
the following criteria:
(a) it is registered in the European Quality Assurance Register for Higher
Education (EQAR) without interruption for a period of at least 10 years;
(b) it has documented prior experience in conducting external quality assurance
reviews, as a quality assurance agency, in at least three different third
countries.
2. A quality assurance agency established in the Union may apply to the Commission to
be listed as a trusted review body for vocational education and training (VET)
programmes if it fulfils all of the following criteria:
(a) it is competent, under national law, in the Member State in which it is
established, for the quality assurance of VET programmes;
(b) it has documented prior experience in conducting external quality assurance
reviews, as a quality assurance agency, in at least three different third
countries.
3. The Commission is empowered to adopt a delegated act supplementing this Directive
by listing the trusted review bodies in accordance with Article 36. It shall list all
quality assurance agencies that applied to be listed in accordance with paragraphs 1
and 2, and that comply with the requirements set out in those paragraphs.
4. Only trusted review bodies listed in the delegated act referred to in paragraph 3 shall
be considered trusted review bodies for the purposes of this Directive, and only in
relation to the professions indicated therein.
Article 13
Reviewed training programmes
For the purposes of Article 11, only training programmes that have been reviewed in
accordance with Article 14 and found to fulfil the following criteria shall be considered as
reviewed training programmes:
(a) The training programme is compliant with the Standards and Guidelines for Quality
Assurance in the European Higher Education Area (ESG), in the version applicable
at the relevant time, in case the training programme is delivered through a higher
education institution;
(b) Quality assurance measures comprising independent assessment, a competence-
based assessment methodology, transparent outcomes, periodic external review, and
an appeal or complaint mechanism have been implemented for the delivery of the
programme, in case the training programme is delivered through vocational training;
(c) The institution delivering the programme is lawfully established in the third country
concerned and authorised under the law of that country to award the qualification in
question;
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(d) For the professions listed in Article 11(1), the training programme is compliant with
the minimum conditions on the training applicable to the relevant profession as set
out in Articles 24, 25, 28, 31, 34, 35, 38, 40, 44, and 46 of Directive 2005/36/EC;
(e) In the cases of Article 11(2), the training programme is compliant with the applicable
common training framework.
Article 14
Review of training programmes in third countries
For the purposes of Article 11, Member States shall ensure that the review of training
programmes is carried out as follows:
(a) Upon request by a training institution in higher education or in vocational training
outside the Union, a trusted review body pursuant to Article 12 assesses compliance
with the criteria set out in Article 13.
(b) To this end, the trusted review body forms a review team which carries out the
assessment of the training programme. For that purpose, the review team shall
consist of:
(i) between five and nine reviewers selected by the trusted review body. Those
reviewers shall include subject matter experts of the relevant discipline or
disciplines, and specialists in quality assurance and evaluation methodologies;
and
(ii) up to three reviewers that Member States appoint for the review following an
invitation to all Member States by the trusted review body. For that purpose,
each Member State shall appoint only one reviewer. Where more than three
Member States intend to appoint a reviewer, a randomised process shall apply
for the selection of the three reviewers.
Each of the reviewers selected pursuant to points (i) and (ii) shall declare, prior to
participating in the review, the absence of any conflict of interest in relation to the
institution under review, including any consultancy, advisory or other remunerated
relationship with that institution within the preceding three years. A reviewer unable
to make that declaration shall not participate in the review of the institution
concerned.
(c) The trusted review body organises at least one on-site visit of the review team as an
integral part of the assessment of the training programme.
(d) The trusted review body communicates its decision on the outcome of the assessment
to the institution organising the reviewed training programme and to the
Commission.
(e) Following a positive assessment of a training programme, the trusted review body
grants the status of ‘reviewed’ on the basis that the applicable requirements laid
down in Article 13 are satisfied. The status of ‘reviewed’ shall be valid for a period
of five years or until the transposition deadline of any Commission delegated act,
adopted pursuant to Article 21(6), second subparagraph of Directive 2005/36/EC,
which updates the knowledge and skills referred to in Articles 24(3), 31(6), 34(3),
38(3), 40(3), 44(3), or 46(4) of Directive 2005/36/EC.
(f) After each assessment the trusted review body makes the result of the review process
publicly available in a dedicated, clearly identifiable and easily accessible section of
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its website or other publicly accessible online interface, no matter if the outcome of
the review was positive or negative.
(g) If requested by the training institution with a reviewed programme, the trusted
review body carries out a new review following the submission of a renewal
application at least six months before the expiration of the current status of
‘reviewed’. The training institution shall present detailed reports demonstrating
continuous compliance with the training standards since the last review, alongside
documentation outlining enhancements in training methodologies, assessment
processes, and quality assurance practices. The trusted review body shall review the
renewal application and communicate its decision to the institution organising the
reviewed training programme and to the Commission within three months of
application submission. The review team under point (b)(i) shall not be the same as
the review team for the institution's immediately preceding review.
(h) Any fee or charge levied by the trusted review body for the review shall be
transparent and proportionate to the costs of the service provided, and shall be
commensurate with the complexity, scope and duration of the review carried out by
the trusted review body. This shall not preclude the trusted review body from
including in its fees a reasonable margin over its costs, provided that such margin
does not render the fee disproportionate to the service provided.
Article 15
Right to appeal or contest review decisions
1. Training institutions whose training programmes received a negative result
following the review in accordance with Article 14 shall be allowed to appeal that
result under the national law of the Member State where the trusted review body is
established. Member States shall establish procedures ensuring that such appeals are
resolved fairly and promptly.
2. If a Member State has justified doubts on the review carried out pursuant to Article
14, that Member State may communicate its concerns in writing to the Commission.
Within 15 working days after receipt of that communication, the Commission shall
provide its views and invite the other Member States to express their views. In case
at least 5 Member States express support for this concern to the Commission within
two months following that invitation, the Commission shall inform all Member
States in writing that they shall only consider the given training programme as
reviewed once a second review has been carried out pursuant to Article 14.
3. If following the second review pursuant to paragraph 2 the training programme is
granted the status of ‘reviewed’, the validity period referred to in Article 14, point (e)
shall start from the date of that result.
4. If the result of the second review is negative, the programme shall not be considered
as a reviewed training programme in the meaning of Article 13 and cannot benefit
from recognition pursuant to Article 11.
Article 16
Listed third countries
1. For qualifications obtained in a third country listed in the delegated acts referred to in
paragraph 2 of this Article, Member States shall ensure that trusted review bodies
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automatically consider the criteria laid down in Article 13, points (a) and (b) as being
fulfilled.
2. The Commission is empowered to adopt delegated acts in accordance with Article 36
to supplement this Directive by establishing and amending a list of third countries for
which the learning quality assurance systems provide guarantees as regards all of the
following elements:
(a) public oversight or equivalent supervision of qualifications;
(b) quality assurance or accreditation of the relevant institutions or training
programmes;
(c) authenticity, reliability and verifiability of the qualifications issued;
(d) comparability and consistency of the intended learning outcomes or
qualification standards relevant to the application of this Directive;
(e) administrative cooperation with the competent authorities of the Member
States and the Commission.
3. The Commission shall monitor whether the third countries listed in the delegated acts
referred to in paragraph 2 continue to fulfil the conditions laid down in paragraph 2,
points (a) to (e). Where the Commission has well-founded concerns that the
conditions for the inclusion of a third country in the list are no longer fulfilled, it may
adopt a decision suspending the application of paragraph 1 in respect of that third
country. The Commission shall inform the third country concerned and the Member
States of the suspension and the reasons without delay.
4. The suspension referred to in paragraph 3 of this Article shall apply until the
Commission, following its assessment, either lifts it or adopts a delegated act in
accordance with Article 36 removing the third country concerned.
Chapter 4
Rules for pursuing the profession
Article 17
Knowledge of languages
1. Professionals benefiting from the recognition of professional qualifications shall
have a knowledge of languages necessary for practising the profession in the host
Member State.
2. A Member State shall ensure that any controls carried out by, or under the
supervision of, the competent authority for controlling compliance with the
obligation under paragraph 1 shall be limited to the knowledge of one official
language of the host Member State, or one administrative language of the host
Member State provided that it is also an official language of the Union.
3. Controls carried out in accordance with paragraph 2 may be imposed if the
profession to be practised has patient safety implications. Controls may be imposed
in respect of other professions in cases where there is a serious and concrete doubt
about the sufficiency of the professional’s language knowledge in respect of the
professional activities that that professional intends to pursue.
Controls may be carried out only after the recognition of a professional qualification.
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4. Any language controls shall be proportionate to the activity to be pursued. The
professional concerned shall be allowed to appeal such controls under national law.
Article 18
Use of academic titles
Without prejudice to Article 19, the host Member State shall ensure that the right shall be
conferred on the persons concerned to use academic titles awarded to them in another
Member State or in a third country, and possibly an abbreviated form thereof, in the language
of that other Member State or that third country. The host Member State may require that title
to be followed by the name and address of the establishment or examining board which
awarded it. Where an academic title of another Member State or of a third country is liable to
be confused in the host Member State with a title which, in the latter Member State, requires
supplementary training not acquired by the beneficiary, the host Member State may require
the beneficiary to use the academic title of the Member State or third country where it has
been issued in an appropriate form, to be laid down by the host Member State.
Article 19
Use of professional titles
1. If, in a host Member State, the use of a professional title relating to one of the
activities of the profession in question is regulated, third-country nationals who are
authorised to practise a regulated profession on the basis of this title shall use the
professional title of the host Member State, which corresponds to that profession in
that Member State, and make use of any associated initials.
2. Where a profession is regulated in the host Member State by an association or
organisation within the meaning of Article 3(2) of Directive 2005/36/EC, third-
country nationals shall not be authorised to use the professional title issued by that
organisation or association, or its abbreviated form, unless they furnish proof that
they are members of that association or organisation.
If the association or organisation makes membership contingent upon certain
qualifications, it may do so only under the conditions laid down in this Directive, in
respect of third-country nationals who possess professional qualifications.
Article 20
Approval by health insurance funds
Member States which require persons who acquired their professional qualifications in their
territory to complete a preparatory period of in-service training and/or a period of professional
experience in order to be approved by a health insurance fund, shall waive this obligation for
the holders of evidence of professional qualifications of doctor and dental practitioner
acquired in other Member States or in other third countries.
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Title III
Recognition in the context of a procedure to obtain a long-stay
visa or a residence permit
Article 21
Scope
This Title applies where the recognition by the host Member State of a qualification or skills
obtained in another Member State or in a third country, and held by a third-country national,
constitutes a factor determining the outcome of a procedure to obtain a long-stay visa or a
residence permit for work purposes, including within a points-based immigration system.
Article 22
Right to assessment of qualifications and skills in the context of a procedure to obtain a
long-stay visa or a residence permit
1. Member States shall ensure that, where the recognition or assessment of
qualifications or skills constitutes a factor determining the outcome of a procedure to
obtain a long-stay visa or a residence permit for work purposes, applicants have the
right to have assessed and taken into account the following for the purposes of that
procedure:
(a) their formal qualifications obtained in another Member State or in a third
country;
(b) their skills acquired through professional or other experience.
2. Where relevant to that procedure, that assessment may take into account information
provided by a current or prospective employer of the applicant, in particular
concerning the tasks, responsibilities and skills required for the position offered.
3. Member States shall ensure that qualifications and skills referred to in paragraph 1
are not refused solely on the ground that they were obtained in another Member State
or in a third country.
4. Member States shall ensure that the recognition and assessment procedure is fair,
does not impose unnecessary burdens on applicants, and is designed to facilitate the
efficient processing of applications for a long-stay visa or a residence permit.
5. Member States shall ensure that the recognition or assessment results are presented
to the applicant in a reasoned decision. That decision shall determine whether the
qualifications or skills of the third-country national are:
(a) recognised and thus treated as equivalent to the qualification level or other
qualification requirements applicable in the context of the procedure to obtain a
long-stay visa or a residence permit;
(b) recognised provisionally, contingent upon the applicant completing
compensation measures in accordance with Article 25(3);
(c) not recognised.
Article 23
Procedural requirements
EN 34 EN
1. Member States shall ensure that any recognition or assessment referred to in Article
22 is carried out within the procedure to obtain a long-stay visa or a residence permit
and in accordance with the principles of necessity, proportionality and simplification.
2. Where the procedure to obtain a long-stay visa or a residence permit does not require
recognition or assessment of qualifications that would give access to a regulated
profession in its territory, the host Member State shall assess qualifications or skills
within the procedure to obtain a long-stay visa or a residence permit and shall not
require a separate recognition or assessment procedure outside that procedure. In
particular, that Member State shall:
(a) not duplicate previous assessments or the requirement to submit evidence that
is already available to, or capable of being obtained by, the competent
authorities of that Member State;
(b) integrate any request for information or supporting evidence to carry out the
recognition or assessment in the application to obtain a long-stay visa or a
residence permit, and not require a separate application for recognition of
qualifications;
(c) limit documentary requirements to those that are necessary for the assessment
and reasonably available to the applicant or, with the applicant’s consent, to a
current or prospective employer submitting evidence on the applicant’s behalf;
(d) not charge any separate or additional fees for the assessment or recognition of
qualifications or skills, other than fees that may be charged for the procedure to
obtain a long-stay visa or a residence permit;
(e) ensure that the assessment or recognition of qualifications or skills is carried
out within the time limits of the procedure to obtain a long-stay visa or a
residence permit and does not cause delay in the processing of the relevant
long-stay visa or residence permit application.
Article 24
Recognition of qualification levels
1. Where, for the purposes of recognition in the context of a procedure to obtain a long-
stay visa or a residence permit, Member States establish the level of a qualification,
they shall apply the levels and descriptors of the European Qualifications Framework
(EQF) as set out in [Annex III of Regulation xxxx/xx/EU establishing a framework
for portability of skills and qualifications and amending Regulation (EU) 2018/1724
('Skills Portability Act')].
For that purpose, Member States shall take into account any relevant existing
comparison of qualification levels or frameworks of third countries to the EQF.
2. The level of the qualification shall not constitute the only element of the assessment
but shall be considered together with the qualification’s intended learning outcomes,
duration, content, workload, practical training, professional experience and, where
relevant, the scope of professional activities to which it gives access in another
Member State or the third country in which it was awarded.
Article 25
Recognition of qualifications without access to regulated professions
EN 35 EN
1. Where Member States evaluate qualifications for the purpose of recognition in the
context of a procedure to obtain a long-stay visa or a residence permit, and where
that evaluation goes beyond a comparison of qualification levels as provided for in
Article 24 and a general classification of the field of study, they shall ensure that a
learning outcomes approach is applied, focusing primarily on comparing the
applicant’s acquired skills to the relevant reference qualification. Where possible, the
assessment shall also consider experiences gained through non-formal learning and
skills acquired through professional or other experience. Where provided, and with
the applicant’s consent, information from a current or prospective employer relevant
to the skills required for the position offered may also be taken into account.
2. Member States shall recognise a qualification in the context of a procedure to obtain
a long-stay visa or a residence permit if all of the following conditions are met:
(a) there are no substantial differences in qualification level;
(b) there are no substantial differences in the intended learning outcomes;
(c) there are no justified doubts on the quality of the education, training or
qualification system under which the evidence of formal qualifications has
been awarded in a third country.
3. If substantial differences in intended learning outcomes or levels of qualification are
established, or if the Member State has justified doubts on the quality of the
education, training or qualification system under which the evidence of formal
qualifications has been awarded in a third country, provisional recognition shall be
granted, contingent upon the applicant completing suitable compensation measures
within a clearly defined timeframe laid down by the host Member State. For the
purpose of the procedure to obtain a long-stay visa or a residence permit, the
provisionally recognised qualification shall be treated as finally recognised. The host
Member State shall, at the time provisional recognition is granted, inform the
applicant in writing of the compensation measures required, the timeframe within
which they shall be completed, and the consequences of failing to complete them
within that timeframe. The successful completion of the compensation measures
shall only be required if the applicant is subsequently granted a long-stay visa or a
residence permit.
4. The compensation measures shall be designed to address identified gaps and shall be
selected from one of the following:
(a) an aptitude test;
(b) a test of professional competence;
(c) a bridging course, with a duration of up to one year.
5. By way of derogation from paragraph 3, if substantial differences in the learning
outcomes or the level of qualification cannot be adequately remedied through
compensation measures, Member States may refuse recognition of qualifications for
the purpose of the procedure to obtain a long-stay visa or a residence permit. A
decision to refuse recognition of qualifications shall not automatically result in the
rejection of the application for a long-stay visa or a residence permit.
6. For the purposes of paragraphs 2, 3 and 4:
(a) 'substantial difference in intended learning outcomes' means instances where
the essential knowledge and skills, necessary for practising a given profession,
EN 36 EN
are not among the intended learning outcomes of the third-country
national’s training, resulting in significant differences in terms of the essential
knowledge and skills obtained compared with those required by the host
Member State;
(b) ‘substantial difference in qualification levels’ means instances where the
qualification level of a third-country national is assessed to be two or more
levels below the level of the training required by the host Member State, as
determined by the descriptors of the EQF.
Article 26
Integrated procedure with the recognition of professional qualifications
1. Member States shall offer applicants seeking recognition of qualifications in the
context of a procedure to obtain a long-stay visa or a residence permit, who also wish
to access a regulated profession, the possibility of choosing an integrated recognition
procedure. That procedure shall satisfy the requirements laid down in this Title and
in Title II. Upon successful completion of the integrated recognition procedure, the
applicant shall receive a recognition of qualifications for the purposes of the
procedure to obtain a long-stay visa or a residence permit as referred to in Article
22(5), point (a), and for the access to the regulated profession, as provided for in
Article 4.
2. For applicants not opting for an integrated recognition procedure, Member States
shall ensure that recognition procedures in the context of the procedure to obtain a
long-stay visa or a residence permit, and recognition procedures for access to
regulated professions are coherent. Authorities shall take into account all prior
assessments and verifications of the provided evidence that have already been carried
out in previous procedures and shall not require applicants to resubmit documents
that have already been provided in those procedures.
3. Member States shall ensure that information on both integrated and separate
recognition procedures is readily available to applicants to support informed
decision-making.
4. With the applicant’s consent, Member States may inform a current or prospective
employer of the outcome of the recognition or assessment referred to in paragraph 1,
in particular where that outcome is relevant to a procedure for employment-based
admission.
Title IV
Common provisions
Article 27
Documentation and formalities
1. Where the competent authorities of the host Member State decide on the recognition
of a qualification by virtue of Title II or Article 26, those authorities may require
solely the types of documents and certificates listed in Annex VII of Directive
2005/36/EC. Where the competent authorities of the host Member State decide on
the recognition of a qualification by virtue of Articles 24 and 25 as part of a
procedure to obtain a long-stay visa or a residence permit, for the purpose of the
EN 37 EN
recognition of the qualification those authorities may demand solely the types of
documents listed in Annex VII of Directive 2005/36/EC, point 1(b). This limitation
on the documents that can be required for the purpose of recognising a qualification
is without prejudice to any other document requirements applicable under Union or
national law for the part of the examination of the application for a long-stay visa or
a residence permit that is unrelated to the recognition of the qualification.
2. For the purposes of this Directive, where the documents requested are to be provided
by another Member State or a third country, the references to “home Member State”
or “the Member State from which the foreign national comes” in Annex VII of
Directive 2005/36/EC shall be understood as referring to the other Member State or
the third country, as applicable.
3. Where the host Member State imposes requirements as to the date of issue of the
documents referred to in Annex VII of Directive 2005/36/EC, point 1(d), (e) and (f),
it shall accept documents issued within the three months preceding the date on which
they are submitted.
The Member States, bodies and other legal persons involved in the process shall
guarantee the confidentiality of the information which they receive.
4. In cases of justified doubts, the host Member State may, after obtaining agreement
from the applicant, require from the competent authorities of a Member State or a
third country confirmation of the authenticity of the attestations and evidence of
formal qualifications awarded in that other Member State or the third country.
5. Where a digital credential is issued under a trusted framework provided in
Regulation (EC) No 910/2014 it shall be presumed authentic unless the competent
authority has concrete and specific indications that the credential is not authentic.
6. In cases of justified doubt, where evidence of formal qualifications, as defined in
Article 3(e), has been issued by a competent authority in a Member State and
includes training received in whole or in part in an establishment legally established
in the territory of another Member State, the host Member State shall be entitled to
verify with the competent body in the Member State of origin of the award all of the
following:
(a) whether the training course at the establishment which gave the training has
been formally certified by the educational establishment based in the Member
State of origin of the award;
(b) whether the evidence of formal qualifications issued is the same as that which
would have been awarded if the course had been followed entirely in the
Member State of origin of the award;
(c) whether the evidence of formal qualifications confers the same professional
rights in the territory of the Member State of origin of the award.
7. In cases of justified doubts, the host Member State may require from the competent
authorities of a third country or of a Member State confirmation of the fact that the
applicant is not suspended or prohibited from the pursuit of the profession as a result
of serious professional misconduct or conviction of criminal offences relating to the
pursuit of any of their professional activities.
8. Where the applicant duly documents that, despite reasonable efforts, he was unable
to obtain the documents referred to in paragraph 1, or the host Member State cannot
obtain the confirmations referred to in paragraph 4 or paragraph 7 of this Article,
EN 38 EN
from the third country, the host Member State shall assess the feasibility of, and
where appropriate, employ alternative methods to assess qualifications, skills or
other evidentiary elements. Those methods may include affidavits, third-party
assessments, professional interviews, or reputable evaluation frameworks, like
qualifications passports designed for refugees and vulnerable migrants. The host
Member State shall ensure that applicants are not unduly disadvantaged due to those
circumstances and shall base its decisions on available and reasonable evidence.
9. Where a host Member State requires its nationals to swear a solemn oath or make a
sworn statement in order to gain access to a regulated profession, and where the
wording of that oath or statement cannot be used by a third-country national, the host
Member State shall ensure that the person concerned can use an appropriate
equivalent wording.
10. Member States shall accept the documents referred to in paragraph 1 in any of the
official languages of the Union.
Article 28
Support Services for the Assessment of Authenticity
1. The Commission shall provide support services for the assessment of authenticity.
2. In providing these services, the Commission shall support Member States in the
recognition of qualifications obtained in a third country by offering assessments on
the authenticity of submitted evidence of formal qualifications.
3. At the request of a competent authority of a Member State, the Commission shall
assess the authenticity of qualifications, diplomas, certificates or other evidence of
formal qualifications issued in a third country and submitted in the context of an
application falling within the scope of this Directive, in particular by utilising digital
tools, international databases and through cooperation with third countries and
educational and professional bodies. Requests shall be submitted electronically and
be accompanied by the documents necessary for the assessment and proof of
payment of any applicable fee referred to in paragraphs 7 and 8.
4. The Commission shall provide the requesting Member State with a substantiated
assessment of authenticity, including detailed explanations of the evaluation process
and findings. That assessment shall be advisory in nature and shall not be binding on
competent authorities of the Member States who shall remain solely responsible for
the recognition decision.
5. For the purposes of paragraph 3, the Commission is empowered to conclude
administrative arrangements, aimed at facilitating the exchange of information
necessary for the assessment of authenticity, with the competent authorities of third
countries and with international or professional bodies responsible for the issuance or
accreditation of qualifications. The Commission shall cooperate, where relevant,
with Union delegations to third countries and EU agencies. Such arrangements shall
not create binding obligations under international law on the Union.
6. The Commission shall respond to a request submitted pursuant to paragraph 3 within
three weeks of receipt of the complete documentation referred to in that paragraph.
Where the Commission is unable to provide an assessment within that period, in
particular due to the need to obtain information from a third-country authority or
body referred to in paragraph 3, it shall inform the requesting competent authority
EN 39 EN
without delay, indicating the reasons for the delay and the anticipated timeframe for
completion.
7. The Commission may charge a cost-recovery fee to the requesting competent
authority for the provision of the assessment referred to in paragraph 3.
8. The Commission shall, by means of implementing acts, adopt uniform rules
regarding:
(a) the calculation methodology for determining cost recovery;
(b) the applicable fee amounts and payment modalities;
(c) specific cases where fee exemptions or reductions apply, in particular for
beneficiaries of international protection or applicants in demonstrably
vulnerable situations.
Those implementing acts shall be adopted in accordance with the examination
procedure referred to in Article 38.
9. In relation to personal data processed for the provision of support services for the
assessment of authenticity, the Commission shall act as controller within the
meaning of Article 3(8) of Regulation (EU) 2018/1725 and shall ensure, in
accordance with Article 33 of that Regulation, the security of the processing by
implementing appropriate technical and organisational measures, taking into account
the nature of the personal data processed, including where submitted documents may
incidentally contain special categories of personal data, referred to in paragraph 10.
10. For the purpose of carrying out the tasks referred to in paragraph 3, the Commission
may process the following categories of personal data, to the extent strictly necessary
for a given assessment:
(a) the applicant's identification data as contained in the evidence of formal
qualifications submitted;
(b) data relating to the submitted qualifications, diplomas, certificates or other
evidence of formal qualifications issued in a third country, including the
awarding institution, date of issue, field and level of study, and any identifiers
or security features of the document.
The Commission shall not process special categories of personal data within the
meaning of Article 10 of Regulation (EU) 2018/1725. Where documentation
submitted by a competent authority incidentally contains such data, the Commission
shall ensure that those data are not retained and are deleted without delay.
11. Personal data processed for the purpose of assessing authenticity shall be retained
only for as long as necessary for that purpose and, in any event, for no longer than
12 months from the date on which the assessment is provided to the requesting
competent authority, unless a longer period is necessary for the purposes of an
ongoing appeal, audit or investigation, in which case the data shall be erased without
delay thereafter.
12. The Commission shall periodically report on the support services for the assessment
of authenticity to ensure transparency and continued improvement. Member States
are encouraged to provide feedback to facilitate enhancements in service delivery.
13. The Commission is empowered to adopt delegated acts in accordance with Article 36
laying down the organisational and technical measures necessary for the provision of
EN 40 EN
the support services, and for the security of processing of personal data, including as
regards the systems used for the exchange of requests and supporting documents
between the Commission and the competent authorities of the Member States, access
to such systems, the interfaces made available to competent authorities of the
Member States, the data sources to be consulted and arrangements for keeping them
up to date, and the administrative and operational management of these services.
Article 29
Recognition procedure
1. For procedures under Title II and under Article 26, the host Member State shall
ensure that:
(a) the competent authority acknowledges receipt of the application for recognition
of professional qualifications within one month of receipt and informs the
applicant of any missing document;
(b) the procedure for examining an application for the recognition of professional
qualifications is completed as quickly as possible and leads to a duly
substantiated decision by the competent authority in the host Member State
within three months after the date on which the applicant submitted the
complete application with the required evidence.
The deadline provided for in the first subparagraph, point (b), may be extended by
one month except in cases falling under Title II, Chapter 3.
2. For procedures under Title III, except those covered by Article 26, recognition shall
not extend, suspend or otherwise affect, any time limits or procedural deadlines
applicable under Union or national law to the examination of and decision on the
application for a long-stay visa or a residence permit. Member States shall ensure
that the organisation of the recognition procedure does not undermine the effective
processing of the application for a long-stay visa or a residence permit within the
applicable time limits.
3. The decision on the application for recognition of professional qualifications, or
failure to reach a decision, within the deadline, shall be subject to appeal under
national law.
4. Applicants shall receive regular updates regarding the progress and current status of
their application, including information on the specific stage within the procedural
process.
5. The host Member State shall offer applicants the choice to receive communications,
such as acknowledgments of receipt, decisions and any other information related to
the procedure, in an official language of that Member State, or in at least one other
language commonly spoken by incoming third-country nationals or third-country
nationals already legally residing in that Member State.
Article 30
Access to recognition procedures
1. The host Member State shall ensure that recognition procedures can be completed
remotely and by electronic means, and that third-country nationals who are not
residing in that Member State can access and complete recognition under Titles II
EN 41 EN
and III remotely from their country of residence. Such a possibility shall not prevent
the competent authorities of the host Member State from requesting certified copies
at a later stage in the event of justified doubts and where strictly necessary.
2. The host Member State shall grant or extend the validity of residence permits to
third-country nationals who fulfil all of the following conditions:
(a) they are legally residing in the host Member State;
(b) they can demonstrate an ongoing effort to secure employment in the profession
concerned, such as registration with a public employment service, submission
of job applications, or a conditional offer of employment;
(c) they have applied for recognition of their professional qualifications under
Title II or Article 26 at least four months before their long-stay visa or
residence permit expires.
Member States shall ensure that the residence permit remains valid during the
recognition procedure, including where procedural delays occur that are not
attributable to the applicant.
3. Member States shall grant or extend the validity of residence permits for the period
needed for completing compensation measures required pursuant to Article 9 to
third-country nationals legally residing in the Member State, unless it can be
established at the time of the application for recognition of their professional
qualifications that the third-country national does not satisfy the other conditions for
the issuance of such a permit.
Article 31
Fees and charges
1. A host Member State shall either waive fees for recognition procedures and
compensation measures or, except for the cases referred to in Article 23(2), point (d),
ensure that any fees charged do not exceed the actual cost incurred in providing the
service to applicants.
2. By way of derogation from paragraph 1, Member States may impose flat-rate charges
if they can be justified by the average cost of providing the service to applicants.
3. Member States shall ensure that detailed information on the structure of the fee and
justification for any charges imposed as part of the recognition process is publicly
available and easily accessible and shall actively inform applicants of this
information before the recognition process begins.
Article 32
Information provision
1. Member States shall ensure that third-country nationals, irrespective of whether they
reside within or outside their territory, have access to timely, comprehensive and
user-friendly information and support concerning procedures for the recognition of
qualifications under this Directive.
2. The information referred to in paragraph 1 shall cover the following aspects:
(a) applicable legal and administrative requirements;
EN 42 EN
(b) procedural steps, expected timelines and applicable costs;
(c) the rights and obligations of applicants;
(d) available remedies, appeal mechanisms and complaint procedures.
3. Member States shall ensure that the information they provide in accordance with
paragraph 2 clearly distinguishes and explains the different procedures laid down
in Titles II and III.
4. Where applicable, Member States shall provide comprehensive information on
compensation measures, including adaptation periods, aptitude tests, tests of
professional competence and bridging courses, as referred to in Articles 9 and 25,
covering their organisation, conditions, obligations for applicants, and other relevant
practical arrangements.
5. Where applicable, Member States shall provide comprehensive information on any
complementary measures available to third-country nationals, including language
courses and integration support, reskilling or upskilling pathways, and links to
employment services.
6. Member States shall ensure that refugees, beneficiaries of subsidiary protection in
accordance with Regulation (EU) 2024/1347 have access to tailored information,
assistance and support services, considering their specific legal status, needs and
vulnerabilities.
7. To facilitate a coherent and user-friendly experience, Member States shall, where
appropriate, organise information provision through coordinated or streamlined
arrangements, including digital platforms, and activities of the national assistance
centres as laid down in Article 34.
8. Member States shall ensure that the information referred to in this Article is also
made available on existing Union tools and platforms.
9. Member States shall ensure that the information provided pursuant to this Article is
regularly reviewed and kept up to date. They shall put in place mechanisms to collect
and analyse feedback from third-country nationals, with a view to improving the
quality, clarity, accessibility and coherence of the information and of the support
services.
10. Member States and the competent authorities involved shall ensure the
confidentiality of personal and sensitive information obtained in the context of
information provision and assistance, in accordance with applicable Union and
national law.
Title V
Reporting and final provisions
Article 33
Group on the recognition of qualifications of third-country nationals
1. Member States shall assist one another in the implementation of this Directive.
2. A group on the recognition of qualifications of third-country nationals (‘the Group’)
is established as an advisory group to the Commission.
3. The Group's tasks shall be the following:
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(a) promoting uniform application of this Directive;
(b) contributing to the effective cooperation between Member States’ authorities
and the Commission with regards to matters covered by this Directive;
(c) advising the Commission, as appropriate, in the early preparations of draft
implementing acts to be adopted pursuant to this Directive;
(d) contributing to the smooth cooperation with other relevant expert groups;
(e) facilitating the exchange of experience and best practices for an efficient and
effective organisation of recognition of qualifications of third-country
nationals, including through outreach to professionals, their representative
organisations and social partners, quality assurance agencies and qualifications
recognition networks.
4. Each Member State shall appoint one representative and one alternate representative
to the Group.
5. The Group shall be chaired by the Commission. The Commission shall provide the
Group’s Secretariat.
On a proposal by the Commission, the Group shall adopt its rules of procedure.
6. The Group shall meet at regular intervals that allow the Group to effectively perform
its tasks provided for in this Directive.
Article 34
Assistance centres
The assistance centres designated by Member States pursuant to Article 57b of Directive
2005/36/EC shall provide assistance on the recognition of qualifications relating to third-
country nationals provided for in this Directive, for the benefit of third-country nationals
including through cooperation, where appropriate, with employers, other contact points, and
authorities in other Member States and third countries.
The assistance centres shall operate without prejudice to the responsibilities of other
competent authorities under Union or national law.
Article 35
Alert mechanism
Where a third-country national is restricted or prohibited, including on a temporary basis, by a
national authority or court from pursuing, in whole or in part, on the territory of a Member
State, any of the professional activities referred to in Article 56a(1) of Directive 2005/36/EC,
the competent authority of that Member State shall inform the competent authorities of all
other Member States. For this purpose Article 56a of Directive 2005/36/EC shall apply
mutatis mutandis.
Article 36
Exercise of the delegation
EN 44 EN
1. The power to adopt delegated acts is conferred on the Commission subject to the
conditions laid down in this Article.
2. The power to adopt delegated acts referred to in Article 12(3) and Article 16(2) shall
be conferred on the Commission for a period of five years from the entry into force
of this Directive. The Commission shall draw up a report in respect of the delegation
of power not later than nine months before the end of the five-year period. The
delegation of power shall be tacitly extended for periods of an identical duration,
unless the European Parliament or the Council opposes such an extension not later
than three months before the end of each period.
3. The delegation of power referred to in Article 12(3) and Article 16(2) may be
revoked at any time by the European Parliament or by the Council. A decision to
revoke shall put an end to the delegation of the power specified in that decision. It
shall take effect on the day following the publication of the decision in the Official
Journal of the European Union or at a later date specified therein. It shall not affect
the validity of any delegated acts already in force.
4. Before adopting a delegated act, the Commission shall consult experts designated by
each Member State in accordance with the principles laid down in the
Interinstitutional Agreement of 13 April 2016 on Better Law-Making.
5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to
the European Parliament and to the Council.
6. A delegated act adopted pursuant to Article 12(3) and Article 16(2) shall enter into
force only if no objection has been expressed either by the European Parliament or
the Council within a period of two months of notification of that act to the European
Parliament and the Council or if, before the expiry of that period, the European
Parliament and the Council have both informed the Commission that they will not
object. That period shall be extended by two months at the initiative of the European
Parliament or the Council.
Article 37
Statistics
1. By [31 May of the year following the third year of entry into force], and annually
thereafter, Member States shall report to the Commission statistics on the
implementation of this Directive. Those statistics shall cover the previous calendar
year and include the following information:
(a) the number of applications received and handled, and decisions taken,
disaggregated by:
(i) citizenship;
(ii) occupation;
(iii) status (i.e. the residence or migration status under which the third-
country national is present or seeking to be present in the Union);
(iv) type of procedure (procedures under Article 6; Title II, Chapter 2; Title
II, Chapter 3; Article 24, Article 25 and Article 26);
(v) outcome of the decision (positive, positive with partial access; positive
with compensation measure, broken down by type of compensation
measure; negative);
EN 45 EN
(b) the proportion of applications that are complete at first submission;
(c) the average duration of processing applications;
(d) the average number of information exchanges per case;
(e) the number of authenticity checks requested.
2. The Commission shall make a summary of the information provided in accordance
with paragraph 1 publicly available.
Article 38
Committee procedure
1. The Commission shall be assisted by the Committee on the Recognition of
Professional Qualifications established by Article 58(1) of Directive 2005/36/EC.
That committee shall be a committee within the meaning of Regulation (EU) No
182/2011.
2. Where reference is made to this paragraph, Article 5 of Regulation (EU) No
182/2011 shall apply.
Article 39
Reports
1. By 31 May [of the year following the third year of entry into force], and every
five years thereafter, Member States shall submit a report to the Commission on the
application of this Directive. The report shall contain the following information
regarding the recognition of qualifications in the context of procedures for access to
regulated professions and for obtaining a long-stay visa or residence permit:
(a) processing times of applications;
(b) outcomes;
(c) user experience;
(d) results of the review of the procedures, including constraints and areas
requiring improvement identified.
As part of preparing the report, Member States shall collect feedback from
employers, professional bodies, third-country nationals, and other stakeholders.
2. No sooner than seven years after the date of transposition of this Directive,
the Commission shall carry out an evaluation of this Directive and present a report
on the main findings to the European Parliament and the Council. Member States
shall provide the Commission with the information necessary for the preparation of
that report.
Article 40
Transposition
1. Member States shall bring into force the laws, regulations and administrative
provisions necessary to comply with this Directive by [2 years after entry into force]
at the latest. They shall forthwith communicate to the Commission the text of those
provisions.
EN 46 EN
When Member States adopt those provisions, they shall contain a reference to this
Directive or be accompanied by such a reference on the occasion of their official
publication. Member States shall determine how such reference is to be made.
2. Member States shall communicate to the Commission the text of the main provisions
of national law which they adopt in the field covered by this Directive.
Article 41
Entry into force
This Directive shall enter into force on the twentieth day following that of its publication in
the Official Journal of the European Union.
Article 42
Addressees
This Directive is addressed to the Member States in accordance with the Treaties.
Done at Strasbourg,
For the European Parliament For the Council
The President The President
[...] [...]
EN 47 EN
LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE
1.1. Title of the proposal/initiative
Proposal for a Directive of the European Parliament and of the Council on the
recognition of qualifications of third-country nationals
1.2. Policy area(s) concerned
Employment, social affairs and inclusion. The initiative is also relevant to the
internal market policy area (recognition of professional qualifications) and to the
migration and home affairs policy area (legal migration and integration of third-
country nationals), given its interaction with Directive 2005/36/EC and with the
Union's legal migration acquis.
1.3. Objective(s)
1.3.1. General objective(s)
To facilitate the recognition of qualifications held by third-country nationals so as to
help address labour and skills shortages in the Union.
1.3.2. Specific objective(s)
Specific objective No
1. Streamlined recognition systems within and between Member States: Improved
alignment and consistency between national recognition systems across the EU, and
coherence within Member States, between recognition procedures for access to
regulated professions and those embedded in migration regimes.
2. Reduced legal and administrative complexity for recognition of qualifications of
third-country nationals: Clearer and less burdensome requirements, documentation
and procedural steps for third-country national applicants, employers and authorities,
including, reduced administrative steps and enhanced user-friendliness.
3. Increased trust and understanding of qualifications obtained in third countries:
Improved transparency, comparability and trust of third-country qualifications within
the EU, through enhanced information availability and mechanisms that support the
assessment of foreign qualifications and skills.
1.3.3. Expected result(s) and impact
Specify the effects which the proposal/initiative should have on the
beneficiaries/groups targeted.
For third-country national applicants: shorter and more predictable recognition
procedures, clearer information on requirements, and a genuine prospect of
recognition for qualifications obtained outside the Union, with an associated increase
in the probability of employment matched to their qualification level and a reduction
in the incidence of overqualification. For employers, including SMEs: faster access
to recognised professionals, reduced administrative costs linked to hiring, and
improved ability to fill vacancies in sectors facing structural shortages, including
healthcare. For competent authorities and Member States: reduced administrative
burden and duplication of effort, more consistent decision-making, and stronger
evidence and cooperation channels through which to identify and act on fraudulent
documentation. For the Union as a whole: a measurable contribution to addressing
EN 48 EN
labour and skills shortages and to the coherence of the Union's approach to legal
migration.
1.3.4. Indicators of performance
Specify the indicators for monitoring progress and achievements.
General objective
(a) Share of third-country nationals in qualification-matched employment within 12
months of arrival
(b) Number of recognition procedures initiated and completed per year by third-
country nationals
Specific objective 1
(a) Share of cases requiring parallel submissions (duplicate qualification checks
across recognition and migration procedures)
(b) Number of cases requiring re-submission or additional information, as a share of
total applications
(c) Share of recognition applications submitted digitally
Specific objective 2
(a) Average end-to-end processing time per recognition procedure, by Member States
and procedure type
(b) Average number of documents requested per application, including certified
translations
(c) Estimated applicant-side cost per recognition procedure Share of complete
applications at first submission
Specific objective 3
(a) Number of authenticity checks processed via the EU-level service per year
(b) Share of CA reporting sufficient information on third-country qualification
systems to make timely decisions without requesting additional documentation or
compensation measures
(c)Processing time for sectoral professions under automatic recognition channel
1.4. The proposal/initiative relates to:
☑ a new action
☐ a new action following a pilot project/preparatory action (1)
☐ the extension of an existing action
☐ a merger or redirection of one or more actions towards another/a new
action
1.5. Grounds for the proposal/initiative
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative
(1) As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.
EN 49 EN
In the short term, Member States will need to transpose the Directive's common
procedural rules (timeframes, information requirements, single points of contact)
within the transposition deadline of 2 years. The Commission will need to establish
the authentication service and make it operational and adopt any implementing
measures needed to specify the professions eligible for automatic recognition. In the
longer term, full-scale operation of the automatic recognition channel and of the
authentication service will require ongoing coordination with Member States,
competent authorities and third countries, periodic review of the list of professions
covered, and monitoring of implementation.
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone.
Reasons for action at EU level (ex-ante) Recognition of third-country qualifications
is currently handled through divergent national procedures, with no common Union
framework equivalent to Directive 2005/36/EC for intra-EU mobility. This
fragmentation generates duplicated authenticity checks across Member States,
inconsistent outcomes for applicants with comparable qualifications, and an absence
of the trust infrastructure needed to support automatic recognition for professions
facing acute shortages. Individual Member States acting alone cannot replicate the
economies of scale of a shared authenticity-verification service, nor secure the cross-
border consistency needed to build mutual trust between competent authorities.
Expected generated EU added value (ex-post) A common Union framework is
expected to reduce duplication and verification costs across Member States, increase
the consistency and speed of recognition decisions, and strengthen the Union's
collective ability to address labour and skills shortages, in a manner that no
individual Member State could achieve acting alone.
1.5.3. Lessons learned from similar experiences in the past
The experience of Directive 2005/36/EC demonstrates that a common Union
framework for recognition, combined with structured administrative cooperation
(competent authority networks, the Internal Market Information system), can
substantially reduce recognition timeframes and improve consistency, while showing
that purely voluntary cooperation (as tested under Policy Option 1 in the impact
assessment) is insufficient to achieve comparable results at Union level. The
Directive's existing minimum training requirements for a number of professions offer
a further lesson, showing that agreement on common substantive standards, and not
only procedural rules, can itself be a basis for building trust and cooperation between
competent authorities, a precedent relevant to the design of the automatic recognition
channel under this initiative. The Council Recommendation of 22 December 2020 on
a comprehensive approach to the recognition of qualifications of third-country
nationals offers a related lesson, in that its non-binding, voluntary approach has not
resulted in the level of convergence or consistency needed across Member States,
reinforcing the case for the more binding measures proposed under this initiative.
The German Federal Recognition Act experience shows that formalised recognition
procedures for foreign qualifications are associated with a measurable increase in the
probability of qualification-matched employment.
EN 50 EN
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments
This proposal is compatible with the Commission’s proposal for the Multiannual
Financial Framework 2028-2034. It generates synergies with Action 1 of the Skills
Portability Initiative, with Directive 2005/36/EC as amended under Action 2, and
with instruments under the Fair Labour Mobility Package and the EU Talent Pool.
1.5.5. Assessment of the different available financing options, including scope for
redeployment
The preferred financing option is direct financing from the Union budget, as the
initiative requires the development, deployment and operation of a common
European authentication system that will be used across all Member States. A
centrally financed solution ensures economies of scale, avoids duplication of costs,
and guarantees interoperability and consistent implementation across the Union.
Alternative approaches based on separate national developments or decentralised
financing would require multiple parallel investments, increase integration costs and
create risks of fragmentation and inconsistent implementation. Financing through
existing Union programmes and budgetary resources allows the initiative to build on
existing digital infrastructure and expertise while ensuring efficient use of Union
funds. Where appropriate, existing resources will be redeployed to support the
implementation of the initiative.
The current proposal entails additional staff costs under Heading 4 of the proposal
for the 2028-2034 multiannual financial framework, as it is a new action. For
operational costs, it builds on the Commission proposal for National and Regional
Partnership Plans and its EU Facility under Heading 1 of the 2028-2034 multiannual
financial framework, subject to its adoption, and the EU annual budgetary procedure.
1.6. Duration of the proposal/initiative and of its financial impact
☐ limited duration
☐ in effect from [DD.MM]YYYY to [DD.MM]YYYY
☐ financial impact from YYYY to YYYY for commitment appropriations
and from YYYY to YYYY for payment appropriations.
☑ unlimited duration
Implementation with a start-up period from YYYY to YYYY,
followed by full-scale operation.
1.7. Method(s) of budget implementation planned(2)
☐ Direct management by the Commission
☑ by its departments, including by its staff in the Union delegations;
☐ by the executive agencies
☐ Shared management with the Member States
(2) Details of budget implementation methods and references to the Financial Regulation may be found on
the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-
implementation/Pages/implementation-methods.aspx.
EN 51 EN
☐ Indirect management by entrusting budget implementation tasks to:
☐ third countries or the bodies they have designated;
☐ international organisations and their agencies (to be specified);
☐ the European Investment Bank and the European Investment Fund;
☐ bodies referred to in Articles 70 and 71 of the Financial Regulation;
☐ public law bodies;
☐ bodies governed by private law with a public service mission to the
extent that they are provided with adequate financial guarantees;
☐ bodies governed by the private law of a Member State that are entrusted
with the implementation of a public-private partnership and that are
provided with adequate financial guarantees;
☐ bodies or persons entrusted with the implementation of specific actions in
the common foreign and security policy pursuant to Title V of the Treaty
on European Union, and identified in the relevant basic act
☐ bodies established in a Member State, governed by the private law of a
Member State or Union law and eligible to be entrusted, in accordance
with sector-specific rules, with the implementation of Union funds or
budgetary guarantees, to the extent that such bodies are controlled by
public law bodies or by bodies governed by private law with a public
service mission, and are provided with adequate financial guarantees in
the form of joint and several liability by the controlling bodies or
equivalent financial guarantees and which may be, for each action,
limited to the maximum amount of the Union support.
Comments
[...]
2. MANAGEMENT MEASURES
2.1. Monitoring and reporting rules
The Commission will monitor implementation on a continuous basis through the
indicators set out in section 1.3.4, drawing on administrative data reported by
Member States' competent authorities, authentication service caseload and
processing-time data, and periodic surveys of competent authorities. Member States
will report on transposition and on the functioning of national recognition procedures
in accordance with the reporting obligations set out in the Directive. The
Commission will carry out an evaluation in accordance with the Better Regulation
Guidelines within 7 years of the deadline for transposition, assessing effectiveness,
efficiency, coherence, relevance and EU added value against the general and specific
objectives.
2.2. Management and control system(s)
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed
Direct management, as per article 62.1(a) of the Financial Regulation, is the
preferred mode of implementation, as the actions will be carried out by the European
EN 52 EN
Commission, specifically Directorate-General for Employment, Social Affairs and
Inclusion (DG EMPL), which will ensure the coordination with Member States and
the various stakeholders.
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them
The controls are part of the internal control system of DG EMPL. The new activities
will be subject to the same risk identification and mitigation approach.
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between
the control costs and the value of the related funds managed), and assessment of the
expected levels of risk of error (at payment & at closure)
The controls are integrated into the internal control system of DG EMPL. The new
activities will generate negligeable additional control costs at DG level.
2.3. Measures to prevent fraud and irregularities
The Commission shall ensure that, when actions financed are implemented, the
financial interests of the Union are protected by the application of preventive
measures against fraud, corruption and any other illegal activities, by effective
checks and by the recovery of the amounts unduly paid and, if irregularities are
detected, by effective, proportional and dissuasive penalties. The Commission is
authorised to carry out checks and verifications in situ under this Decision, in
compliance Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996
concerning on-the-spot checks and inspections carried out by the Commission in
order to protect the European Communities financial interests against fraud and other
irregularities. If need be, investigations shall be carried out by the European Anti-
Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the
European Parliament and of the Council of 25 May 1999 concerning investigations
conducted by the European Anti-Fraud Office.
EN 53 EN
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE
3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s) affected
Existing budget lines
In order of multiannual financial framework headings and budget lines.
The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and
does not pre-judge the next Multiannual Financial Framework. The source of financing and scope of Union financial
commitment in the post-2027 period remain subject to the outcome of interinstitutional negotiations on the MFF
2028-2034 and thereafter shall be determined through the annual budgetary procedure. All appropriations and staffing
allocations as of 2028 are indicative.
Heading of multiannual
financial framework
Budget line
Type of
expendit
ure
Contribution
Number Diff./No
n-diff. (3)
from
EFTA
countries (4)
from
candidat
e
countries
and
potential
candidat
es (5)
from
other
third
countrie
s
other assigned
revenue
1
To be determined after the
adoption of the MFF and
in the context of the
annual budgetary
Diff./No
n-diff. YES/NO YES/NO YES/NO NO
(3) Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. (4) EFTA: European Free Trade Association. (5) Candidate countries and, where applicable, potential candidates from the Western Balkans.
EN 54 EN
procedure for the EU
Facility – Successor of 07
02 04 00 – ESF+ EaSI
strand
New budget lines requested
In order of multiannual financial framework headings and budget lines.
Heading
of
multiannu
al
financial
framework
Budget
line
Type of
expenditur
e
Contribution
Number Diff./non-
diff.
from
EFTA
countries
from
candidate
countries
and
potential
candidates
from other
third
countries
other
assigned
revenue
3.2. Estimated financial impact of the proposal on appropriations
3.2.1. Summary of estimated impact on operational appropriations
☐ The proposal/initiative does not require the use of operational appropriations
EN 55 EN
☑ The proposal/initiative requires the use of operational appropriations, as explained below:
3.2.1.1. Appropriations from voted budget
The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the
next Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period
remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the
annual budgetary procedure. All appropriations and staffing allocations as of 2028 are indicative
EUR million (to three decimal places)
Heading of multiannual financial framework Number 1 - Economic, social and territorial cohesion,
agriculture, rural and maritime prosperity and security
DG: EMPL Year
2028
Year
2029
Year
2030
Year
2031
Yea
r 2
032
Year 2
033
2034
and
subsequ
ent
years
TOTAL MFF
2028-2034
Operational appropriations
Budget line – successor 07
02 04
Commit
ments (1a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payment
s (2a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Appropriations of an administrative nature financed from the envelope of specific programmes (6)
Budget line (3) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
(6) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,
direct research.
EN 56 EN
TOTAL appropriations
for DG EMPL
Commit
ments
=1a+1
b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payment
s
=2a+2
b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Heading 1 Year
2028
Year
2029
Year
2030
Year
2031
Yea
r 203
2
Year
2033
2034
and
subsequ
ent
years
TOTAL MFF
2028-2034
TOTAL operational
appropriations
Commit
ments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payment
s (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
TOTAL appropriations of an
administrative nature financed from
the envelope for specific programmes
(6) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations
under HEADING 1
of the multiannual financial
framework
Commit
ments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payment
s =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Heading of multiannual financial
framework Number
DG: <.......> Year
2024
Year
2025
Year
2026
Year
2027
TOTAL MFF
2021-2027
EN 57 EN
Operational appropriations
Budget line Commitments (1a) 0.000
Payments (2a) 0.000
Budget line Commitments (1b) 0.000
Payments (2b) 0.000
Appropriations of an administrative nature financed from the envelope of specific programmes (7)
Budget line (3) 0.000
TOTAL appropriations
for DG <.......>
Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000
Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000
DG: <.......> Year
2024
Year
2025
Year
2026
Year
2027
TOTAL MFF
2021-2027
Operational appropriations
Budget line Commitments (1a) 0.000
Payments (2a) 0.000
Budget line Commitments (1b) 0.000
Payments (2b) 0.000
(7) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,
direct research.
EN 58 EN
Appropriations of an administrative nature financed from the envelope of specific programmes (8)
Budget line (3) 0.000
TOTAL appropriations
for DG <.......>
Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000
Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000
Heading 1 Year
2028
Year
2029
Year
2030
Year
2031
Yea
r 2
032
Year 2
033
2034
and
subsequ
ent
years
TOTAL MFF
2021-2027
TOTAL operational
appropriations
Commit
ments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payment
s (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
TOTAL appropriations of an
administrative nature financed from
the envelope for specific programmes
(6) 0 0 0 0 0 0 0 0
TOTAL appropriations
under HEADING 1
of the multiannual financial
framework
Commit
ments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payment
s =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
(8) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,
direct research.
EN 59 EN
Year
2028
Year
2029
Year
203
0
Year
2031
Year
2032
Year
2033
2034
and
subsequ
ent
years
TOTAL MFF
2021-2027
TOTAL operational
appropriations (all
operational headings)
Com
mitme
nts
(4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Paym
ents (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
TOTAL appropriations of an
administrative nature financed from
the envelope for specific
programmes (all operational
headings)
(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
TOTAL appropriations
Under Heading 1 to 3
of the multiannual financial
framework
(Reference amount)
Com
mitme
nts
=4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Paym
ents =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Heading of multiannual financial framework 4 ‘Administrative expenditure’ (9)
DG: EMPL Year
2028
Year
2029 Year
203
Year
2031
Year
2032
Year
2033 2034
and
TOTAL MFF
2021-2027
(9) The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.
EN 60 EN
0 subsequ
ent
years
Human resources 0.582 0.582 0.58
2 0.582 0.582 0.582 0.582 4.074
Other administrative expenditure 0 0 0 0 0 0 0 0
TOTAL DG EMPL Appropriations 0.582 0.582 0.58
2 0.582 0.582 0.582 0.582 4.074
TOTAL appropriations under HEADING
4 of the multiannual financial framework
(Total
commitme
nts = Total
payments)
0.582 0.582 0.582 0.582 4.074
EUR million (to three decimal places)
Year
2028
Year
2029
Year
2030
Year
2031
Year
2032
Year
2033
2034
and
subs
eque
nt
year
s
TOTAL MFF
2021-2027
TOTAL appropriations under
HEADINGS 1 to 4
of the multiannual financial
framework
Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
EN 61 EN
The staff needed to implement this proposal has been assessed at 3 full time equivalent (FTE), of which 1 are redeployed from existing
staff in the DG and 2 are to be covered by the redeployment pool of the Commission.
3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)
Commitment appropriations in EUR million (to three decimal places)
Indi
cate
obje
ctive
s
and
outp
uts
⇓
Year
2028
Year
2029
Year
2030
Year
2031
Enter as many years as necessary to show
the duration of the impact (see Section 1.6) TOTAL
OUTPUTS
Type (10)
Aver
age
cost
No Cost No Cost No Cost No Cost No Cost No Cost No Cost Total
No
Total
Cost
SPECIFIC
OBJECTIVE No 1 (11): [...]
Outp
ut p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Outp
ut
Outp
ut
(10) Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.). (11) As described in point 1.4.2. 'Specific objective(s)...'
EN 62 EN
Subtotal for specific
objective No 1 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
SPECIFIC
OBJECTIVE No 2
...
Outp
ut
Subtotal for specific
objective No 2
SPECIFIC
OBJECTIVE No. 3
Outp
ut p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
Subtotal for specific
objective No. 3
TOTALS p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
3.2.3. Summary of estimated impact on administrative appropriations
☐ The proposal/initiative does not require the use of appropriations of an administrative nature
☑ The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:
3.2.3.1. Appropriations from voted budget
VOTED APPROPRIATIONS Year
2028
Year
2029
Year
2030
Year
2031
Year
2032
Year
2033 2034 and
subsequent
TOTAL MFF
2021-2027
EN 63 EN
years
HEADING 4
Human resources 0.582 0.582 0.582 0.582 0.5
82
0.5
82
0.5
82 4.074
Other administrative expenditure 0.000 0.000 0.000 0.000 0.0
00
0.0
00
0.0
00 0.000
Subtotal HEADING 4 0.582 0.582 0.582 0.582 0.5
82
0.5
82
0.5
82 4.074
Outside HEADING 4
Human resources 0.000 0.000 0.000 0.000 0.0
00
0.0
00
0.0
00 0.000
Other expenditure of an administrative
nature 0.000 0.000 0.000 0.000
0.0
00
0.0
00
0.0
00 0.000
Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.0
00
0.0
00
0.0
00 0.000
TOTAL 0.582 0.582 0.582 0.582
0.582
0.5
82
0.5
82 4.074
The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next
Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to
the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure
and the steering mechanism. All appropriations and staffing allocations as of 2028 are indicative.
EN 64 EN
3.2.3.3. Total appropriations
The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative
purposes only and does not pre-judge the next Multiannual Financial Framework. The source of
financing and scope of Union financial commitment in the post-2027 period remain subject to the
outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined
through the annual budgetary procedure and the steering mechanism. All appropriations and staffing
allocations as of 2028 are indicative.
The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from
the DG that are already assigned to management of the action and/or have been redeployed within the DG, together, if necessary, with
any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary
constraints.
3.2.4. Estimated requirements of human resources
☐ The proposal/initiative does not require the use of human resources
☑ The proposal/initiative requires the use of human resources, as explained below
3.2.4.1. Financed from voted budget
Estimate to be expressed in full-time equivalent units (FTEs) (12)
VOTED APPROPRIATIONS Year
2028
Year
2029
Year
2030
Year
2031
Year
203
2
Year 2033 2034 and
subsequent years
Establishment plan posts (officials and temporary staff)
20 01 02 01 (Headquarters and Commission's
Representation Offices) 3 3 3 3 3 3 3
(12) Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed within
your DG and what are your net needs.
EN 65 EN
20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0
01 01 01 01 (Indirect research) 0 0 0 0 0 0 0
01 01 01 11 (Direct research) 0 0 0 0 0 0 0
Other budget lines (specify) 0 0 0 0 0 0 0
External staff (in FTEs)
20 02 01 (AC, END from the 'global envelope') 0 0 0 0 0 0 0
20 02 03 (AC, AL, END and JPD in the EU
Delegations) 0 0 0 0 0 0 0
Admin.
support line
[XX.01.YY.Y
Y]
at Headquarters 0 0 0 0 0 0 0
in EU Delegations 0 0 0 0 0 0 0
01 01 01 02 (AC, END - Indirect research) 0 0 0 0 0 0 0
01 01 01 12 (AC, END - Direct research) 0 0 0 0 0 0 0
Other budget lines (specify) - Heading 7 0 0 0 0 0 0 0
Other budget lines (specify) - Outside Heading 7 0 0 0 0 0 0 0
TOTAL 3 3 3 3 3 3 3
This proposal is a new action and no current staff is assigned to this new task. The three FTE mentioned above are additional staff needed to
implement the proposal, to be covered by the redeployment pool of the Commission.
3.2.4.2. Financed from external assigned revenues
EN 66 EN
3.2.4.3. Total requirements of human resources
The staff required to implement the proposal (in FTEs):
To be covered by
current staff
available in the
Commission
services
Exceptional additional staff*
To be financed
under Heading
7 or Research
To be financed
from BA line
To be financed
from fees
Establishment
plan posts 3 0 N/A N/A
External staff
(CA, SNEs,
INT)
0 0 N/A N/A
The staff needed to implement this proposal has been assessed at 3 full time equivalent (FTE), of which 1 are redeployed from existing
staff in the DG and 2 are to be covered by the redeployment pool of the Commission.
Description of tasks to be carried out by:
Officials and temporary staff
Outsource the authentication services to an external entity by public
procurement, writing the specifications for the tendering procedure;
monitor the work of the selected entity; ensure the functioning of the
authentication services.
External staff
3.2.5. Overview of estimated impact on digital technology-related investments
EN 67 EN
Compulsory: the best estimate of the digital technology-related investments entailed by the proposal/initiative should be included in the
table below.
Exceptionally, when required for the implementation of the proposal/initiative, the appropriations under Heading 7 should be presented
in the designated line.
The appropriations under Headings 1-6 should be reflected as "Policy IT expenditure on operational programmes". This expenditure
refers to the operational budget to be used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation of the
initiative and their associated investments (e.g. licences, studies, data storage etc). The information provided in this table should be
consistent with details presented under Section 4 "Digital dimensions".
TOTAL Digital and IT
appropriations
Year
2024
Year
2025
Year
2026
Year
2027
TOTAL
MFF
2021-2027
HEADING 4
IT expenditure (corporate) 0.000 0.000 0.000 0.000 0.000
Subtotal HEADING 4 0.000 0.000 0.000 0.000 0.000
Outside HEADING 4
Policy IT expenditure on
operational programmes 0.000 0.000 0.000 0.000 0.000
Subtotal outside HEADING
4 0.000 0.000 0.000 0.000 0.000
TOTAL 0.000 0.000 0.000 0.000 0.000
EN 68 EN
3.2.6. Compatibility with the current multiannual financial framework
The proposal/initiative:
☑ can be fully financed through redeployment within the relevant heading of the
multiannual financial framework (MFF).
☐ requires use of the unallocated margin under the relevant heading of the MFF
and/or use of the special instruments as defined in the MFF Regulation.
☐ requires a revision of the MFF.
EN 69 EN
3.2.7. Third-party contributions
The proposal/initiative:
☑ does not provide for co-financing by third parties
☐ provides for the co-financing by third parties estimated below:
Appropriations in EUR million (to three decimal places)
Year
2028
Year
2029
Year
2030
Year
2031
Year
2032
Year
2033
Year
2034 Total
Specify the co-financing
body (EFTA, (potential)
candidate countries, third
countries)
p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
TOTAL appropriations co-
financed p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.
3.3. Estimated impact on revenue
☑ The proposal/initiative has no financial impact on revenue.
☐ The proposal/initiative has the following financial impact:
☐ on own resources
☐ on other revenue
☐ please indicate, if the revenue is assigned to expenditure lines
EUR million (to three decimal places)
EN 70 EN
Budget revenue line:
Appropriations
available for the
current financial year
Impact of the proposal/initiative (13)
Year
2024
Year
2025
Year
2026
Year
2027
Article ..........
For assigned revenue, specify the budget expenditure line(s) affected.
[...]
Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).
[...]
4. DIGITAL DIMENSIONS
4.1. Requirements of digital relevance
If the policy initiative is assessed as having no requirement of digital relevance:
Justification of why digital means cannot be used to enhance policy implementation and why the ‘digital by default’ principle is not
applicable
[...]
Otherwise:
High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital
solutions and/or digital public services)
Reference to the
requirement
Requirement
description
Actors affected or
concerned by the
requirement
High-level Processes Categories
(13) As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20% for
collection costs.
EN 71 EN
Article 11
Paragraph 1c: Member
States shall recognise
evidence of formal
qualifications for
doctors (with basic and
specialised training),
nurses responsible for
general care, dental
practitioners, specialised
dental practitioners,
midwives, veterinary
surgeons, pharmacists,
and architects obtained
in a third country,
provided the following
conditions are met: (c)
The evidence of formal
qualifications is issued
as a digital credential,
ensuring authenticity,
security, and ease of
verification.
Member States Third
countries’ institutions
Issuance of
qualifications Data/ Digital solutions
Article 28 (1-3)
The Commission shall
provide support services
for the assessment of
authenticity.
1. In providing
these services, the
Commission shall shall
support Member States
in the recognition of
European Commission
provides the system for
Member States upload
evidence provided by
the applicant in the
system
Processing, assessment
and recognition of
evidence authenticity
Data/Digital
Solutions/Digitalisation-
automation of
activities/Digital Public
Services
EN 72 EN
qualifications obtained
in a third country by
offering assessments on
the authenticity of
submitted evidence of
formal qualifications.
2. At the request of
a competent authority of
a Member State, the
Commission shall assess
the authenticity of
qualifications, diplomas,
certificates or other
evidence of formal
qualifications issued in a
third country and
submitted in the context
of an application falling
within the scope of this
Directive, in particular
by utilising digital tools,
international databases
and through cooperation
with third countries and
educational and
professional bodies.
Requests shall be
submitted electronically
and be accompanied by
the documents necessary
for the assessment and
proof of payment of any
EN 73 EN
applicable fee referred
to in paragraph 8.
3. The Commission
shall provide the
requesting Member
State with a
substantiated assessment
of authenticity,
including detailed
explanations of the
evaluation process and
findings. That
assessment shall be
advisory in nature and
shall not be binding on
competent authorities of
the Member States who
shall remain solely
responsible for the
recognition decision.
Article 28 (8-11)
The processing of
personal data by the
Commission for the
purposes of the support
services for assessment
of authenticity shall
comply with Regulation
(EU) 2018/1725 and be
limited to what is
necessary and
proportionate for the
European Commission Processing of personal
data Data/ Digital solutions
EN 74 EN
performance of a task
carried out in the public
interest as laid down in
Article 5(1)(a) of
Regulation (EU)
2018/1725. The
Commission shall
ensure that personal data
is processed lawfully,
securely, and with the
necessary safeguards to
protect individuals’
privacy rights, including
data minimisation,
transparency, and access
rights for data subjects.
The Commission shall
periodically report on
the activities and
effectiveness of support
services to ensure
transparency and
continual improvement.
Member States are
encouraged to provide
feedback to facilitate
enhancements in service
delivery.
Article 30
Access to recognition
procedures Member
States shall ensure that
all requirements,
Member States
Applicants professionals
(users)
Recognition procedure Data/Digital public
services/Digital
Solutions/Digitalisation-
EN 75 EN
procedures and
formalities in
recognition procedures
may be easily
completed, remotely and
by electronic means.
This shall not prevent
competent authorities of
Member States from
requesting certified
copies at a later stage in
the event of justified
doubts and where
strictly necessary.
automation of activities
Article 36
Statistics Member States
shall communicate to
the Commission
statistics on the
implementation of this
Directive. Those
statistics shall cover the
previous calendar year
and include information
on the number of
applications received
and handled and
decisions taken, and
shall be disaggregated
by citizenship, by
occupation, status
(beneficiaries of
international protection,
European Commission
Member States
Statistics on the
recognition processes
Data/Digital
Solutions/Digitalisation-
automation of activities
EN 76 EN
beneficiaries of the right
to free movement, etc),
type of procedure
(Article 6; Title II,
Chapter 2; Title II,
Chapter 3; Article 23;
Article 24 or Article 25),
and outcome of the
decision (positive,
positive with partial
access; positive with
compensation measure,
broken down by type of
compensation measure;
negative). They shall
also include the share of
complete applications at
first submission, average
processing times,
average information
exchanges per case, and
number of authenticity
checks requested.
Article 38
Reports Member States
shall send a report to the
European Commission
on the application of this
Directive. To this end,
Member States shall
collect data on
processing times,
outcomes, and user
European Commission
Member States
Reporting on the
recognition processes
Data/Digital public
services/Digital
Solutions
EN 77 EN
experience across both
procedures for access to
regulated professions
and for migration
purposes, and include
this information in the
report. They shall also
review the procedures to
report on identified
bottlenecks and
opportunities for
improvement. Member
States shall collect
feedback from
employers, professional
bodies, third-country
nationals, and other
stakeholders as part of
this exercise.
4.2. Data
High-level description of the data in scope
Type of data Reference to the requirement(s) Standard and/or specification (if
applicable)
Digital qualification attestations
Article 11 – Formal qualifications issued
as digital credentials by Third country
institutions/Article 28 – Support services
for assessment of authenticity, provided by
the Commission
N/A
Non-digital evidence of formal Article 28 – Support Services for Documents listed in Annex VII of
EN 78 EN
qualification and other supporting
evidence
Assessment of Authenticity Directive 2005/36/EC; accepted in any
official language of the Union
Personal information used for the support
services for assessment of authenticity,
provided by the Commission
Article 28 – Processing of personal data
by the Commission to provide support
services for assessment of authenticity
EUDPR (Reg. (EU) 2018/1725); data
minimisation, transparency and data-
subject access rights (Art. 28)
Annual statistical summary of recognition
procedures (includes number of
applications received and decisions,
breakdowns, outcomes, processing times
and delays)
Article 36
Report on the application of the Directive.
Member States shall send a report to the
European Commission with data regarding
the processing times, outcomes,
procedures on the recognition processes.
Moreover, this report should also include
the identification of bottlenecks and
opportunities for improvement. The
European Commission shall submit a
report to the European Parliament and the
Council on the application of the
Directive.
Article 38
Alignment with the European Data Strategy
Explanation of how the requirement(s) are aligned with the European Data Strategy
[...]
Alignment with the once-only principle
Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored
EN 79 EN
[...]
Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards
[...]
Data flows
High-level description of the data flows
Type of data Reference(s) to the
requirement(s)
Actors who
provide the data
Actors who receive
the data
Trigger for the
data exchange
Frequency (if
applicable)
Type of data #1
Type of data # 2
4.3. Digital solutions
High-level description of digital solutions
Digital solution
Reference(s) to
the
requirement(s)
Main mandated
functionalities
Responsible
body
How is
accessibility
catered for?
How is
reusability
considered?
Use of AI
technologies (if
applicable)
Digital solution
#1
Digital solution
#2
EN 80 EN
For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments
Digital solution #1
Digital and/or sectorial policy
(when these are applicable) Explanation on how it aligns
AI Act
EU Cybersecurity framework
eIDAS
Single Digital Gateway and IMI
Others
Digital solution #2
Digital and/or sectorial policy
(when these are applicable) Explanation on how it aligns
AI Act
EU Cybersecurity framework
EN 81 EN
eIDAS
Single Digital Gateway and IMI
Others
4.4. Interoperability assessment
High-level description of the digital public service(s) affected by the requirements
Digital public service
or category of digital
public services
Description Reference(s) to the
requirement(s)
Interoperable Europe
Solution(s)(NOT
APPLICABLE)
Other interoperability
solution(s)
Support services for
assessment of
authenticity
The support services
will be tasked with
supporting Member
States in the recognition
of qualifications
obtained outside the
Union by offering
assessments on the
authenticity of
submitted evidence of
formal qualifications.
Requests to the service
shall be submitted
electronically. The
service might use digital
tools and international
databases to perform its
tasks.
Article 28 (1-3)
EN 82 EN
As mentioned in Article
28(12), delegated acts
will be prepared by the
Commission to set out
the organisational and
technical measures
required for the
operation of the service.
The interoperability
assessment of the
service will be carried
out in the context of
these delegated acts.
Impact of the requirement(s) as per digital public service on cross-border interoperability
Digital public service #1
Assessment Measure(s) Potential remaining barriers (if
applicable)
Alignment with existing digital and
sectorial policies. Please list the
applicable digital and sectorial policies
identified
Digital or sectorial policy #1 Digital or
sectorial policy #2 Digital or sectorial
policy #3
Barrier #1 Barrier #2 Barrier #3
Organisational measures for a smooth
cross-border digital public services
delivery. Please list the governance
measures foreseen
Governance measure #1 Governance
measure #2 Governance measure #3 Barrier #1 Barrier #2 Barrier #3
EN 83 EN
Measures taken to ensure a shared
understanding of the data. Please list
such measures
Measure #1 Measure #2 Measure #3 Barrier #1 Barrier #2 Barrier #3
Use of commonly agreed open technical
specifications and standards. Please list
such measures
Measure #1 Measure #2 Measure #3 Barrier #1 Barrier #2 Barrier #3
4.5. Measures to support digital implementation
High-level description of measures supporting digital implementation
Description of the
measure
Reference(s) to the
requirement(s) of
digital relevance that it
supports
Commission role (if
applicable)
Actors to be involved
(if applicable)
Expected timeline (if
applicable)
Measure #1
Measure #2
Measure #3
EN EN
EUROPEAN COMMISSION
Strasbourg, 15.9.2026
COM(2026) 992 final
ANNEXES 1 to 5
ANNEXES
to the
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}
EN 1
EN
Annex I
Union standard specifications for digital qualification attestations
1. The digital qualification attestation and the tools and systems relevant for its
issuance and verification shall comply with W3C Verifiable Credential Data Model
and with Regulation (EU) No 910/2014.
2. The digital qualification attestation and information on the awarding body,
accreditation and qualification shall use a common semantic model which is the
European Learning Model(1).
(1) https://op.europa.eu/en/web/eu-vocabularies/dataset/-
/resource?uri=http://publications.europa.eu/resource/dataset/snb-model
EN 2
EN
Annex II
Specifications for data fields in digital qualification attestations referred to in Article
4(2)
1. Mandatory data fields:
FIELD NAME DESCRIPTION
Given Name The holder's given name
Family Name The holder's family name
Date of Birth The holder's date of birth
Birthplace
The country as an alpha-2 country code as specified ISO
3166-1, or the state, province, district, or local area or the
municipality, city, town, or village where the user to
whom the holder's data relates was born
Nationality
One or more alpha-2 country codes as specified in ISO
3166-1 representing the nationality (or nationalities) of
the holder
Qualification Title The official title of the qualification provided in at least
one specified language
Qualification Title in
commonly agreed
language
The official title in commonly agreed language
Field of Education
and/or Training
The field of study, classified in accordance with the
International Standard Classification of Education Fields
of Education and Training (ISCED-F-2013)
Valid From The date and time when the digital qualification
attestation was issued
Valid Until The date and time the digital qualification attestation
ceases to be valid
EQF Level The applicable level of the European Qualifications
Framework
NQF Level The qualification level as specified in the national
qualifications framework
Issuer
The legal identifier, name and location of the issuing
organisation which issued the digital qualification
attestation
Awarding Body/Bodies The legal identifier, name and location of the awarding
EN 3
EN
body/bodies that awarded the qualification
Country/countries of
Award
The Member State(s) in which the qualification was
awarded
Where applicable,
Region of Award
The code of the region in which the qualification was
awarded, where applicable
Date of Award The date on which the qualification was officially
awarded
Learning
Outcomes(1) OR
Description of the
Qualification(2)
Summary of learning outcomes OR description of the
qualification composed of knowledge, skills and
responsibility and autonomy
Accreditation Details
Information on the accreditation of the awarding body,
including jurisdiction and the relevant regulatory
framework
Professional Experience,
where applicable Professional experience gained to obtain the qualification
Professional Title,
where applicable
Professional title obtained as a result of qualification
being awarded
Access Rights, where
applicable
A statement on the access rights to regulated professions
conferred by the qualification
2. Optional data fields:
FIELD NAME DESCRIPTION
Holder's National ID
and the country National ID and country issuing it
Uniform resource
Identifier (URI)
to qualification standard
URI to qualification standard published in a qualification
database such as Europass established by Decision (EU)
2018/646 of the European Parliament and of the
Council1
(1) To be provided for qualifications issued as of [date of entry of application of the Regulation] or, if
available in Member State's NQF, before that date. Leaning outcomes shall be described in accordance with the
European Guidelines for the development and writing of short, learning outcomes-based descriptions of
qualifications, see https://www.cedefop.europa.eu/files/6222_en.pdf (2) Description shall be provided where no Learning Outcome is available. However, for digital
qualification attestations awarded between [date of adoption date of this regulation minus 10 years], the
description of qualification may become an optional data field. (3) 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, pp. 42–50), ELI: https://eur-
lex.europa.eu/eli/dec/2018/646/oj )
EN 4
EN
ESCO Skills reference Reference to European Skills, Competences, and
Occupations classification
Duration of Study
The official duration of the learning programme
expressed in time or credits of the European Credit
Transfer and Accumulation System2
Grades / Marks The grades or marks achieved, accompanied by an
explanation of the grading scale used
Mode of Learning The mode of delivery, such as full-time, part-time,
distance learning
Main subjects / modules A list of the main subjects or modules covered by the
programme of study
Practical Training Details of a mandatory practical training that
was completed
Assessment Methods Information on the methods used for assessment (e.g.
examination, project work)
Language of Study The primary language(s) in which the programme was
taught
Thesis/ Final Project
Title The title of the final thesis or project, if applicable
International Mobility Information on any international mobility periods
undertaken as a part of the programme
3. Data fields covered in this Annex can be supplemented by additional data only as far
as it is necessary for the functioning of the relevant data in the EUDI Wallet system.
Otherwise, no other data fields than those covered by this Annex shall be included in
digital qualification attestation referred to in Article 4(2).
(4) https://education.ec.europa.eu/education-levels/higher-education/inclusive-and-connected-higher-
education/european-credit-transfer-and-accumulation-system
EN 5
EN
Annex III
European Qualifications Framework
Each of the 8 levels is defined by a set of descriptors indicating the learning
outcomes relevant to qualifications at that level in any system of qualifications.
Knowledge Skills Responsibility and
autonomy
Knowledge
is described
as
theoretical
and/or
factual.
skills are described as
cognitive (involving the
use of logical, intuitive
and creative thinking)
and practical (involving
manual dexterity and
the use of methods,
mate rials, tools and
instruments).
responsibility and
autonomy is
described as the
ability of the learner
to apply knowledge
and skills
autonomously and
with responsibility
Level 1 The
learning outcomes
relevant to Level 1
are
basic
general
knowledge
basic skills required to
carry out simple tasks
work or study under
direct supervision in
a structured context
Level 2 The
learning outcomes
relevant to Level 2
are
basic
factual
knowledge
of a field of
work or
study
basic cognitive and
practical skills required
to use relevant
information in order to
carry out tasks and to
solve routine problems
using sim ple rules and
tools
work or study under
supervision with
some autonomy
Level 3 The
learning outcomes
relevant to Level 3
are
knowledge
of facts,
principles,
processes
and general
concepts, in
a field of
work or
study
a range of cognitive and
practical skills required
to accomplish tasks and
solve problems by
selecting and applying
basic methods, tools,
materials and
information
take responsibility
for completion of
tasks in work or
study adapt own
behaviour to
circumstances in
solving problems
Level 4 The
learning outcomes
relevant to Level 4
are
factual and
theoretical
knowledge
in broad
con texts
within a
a range of cognitive and
practical skills required
to generate solutions to
specific problems in a
field of work or study
exercise self-
management within
the guidelines of
work or study
contexts that are
usually predictable,
EN 6
EN
Knowledge Skills Responsibility and
autonomy
field of
work or
study
but are subject to
change supervise the
routine work of
others, taking some
responsibility for the
evaluation and
improvement of
work or study
activities
Level 5 (*) The
learning outcomes
relevant to Level 5
are
comprehens
ive,
specialised,
factual and
theoretical
knowledge
within a
field of
work or
study and
an
awareness
of the
boundaries
of that
knowledge
a comprehensive range
of cognitive and
practical skills required
to develop creative
solutions to abstract
problems
exercise management
and supervision in
con texts of work or
study activities
where there is
unpredictable change
review and develop
performance of self
and others
Level 6 (**) The
learning outcomes
relevant to Level 6
are
advanced
knowledge
of a field of
work or
study,
involving a
critical
understandi
ng of
theories and
principles
advanced skills,
demonstrating mastery
and innovation,
required to solve
complex and
unpredictable problems
in a specialised field of
work or study
manage complex
technical or
professional
activities or projects,
taking responsibility
for decision-making
in unpredictable
work or study
contexts take
responsibility for
managing
professional
development of
individuals and
groups
Level 7 (***) The
learning outcomes
relevant to Level 7
are
highly
specialised
knowledge,
some of
specialised problem-
solving skills required
in research and/or
innovation in order to
manage and
transform work or
study contexts that
are complex,
EN 7
EN
Knowledge Skills Responsibility and
autonomy
which is at
the
forefront of
knowledge
in a field of
work or
study, as the
basis for
original
thinking
and/or
research
critical
awareness
of
knowledge
issues in a
field and at
the interface
between
different
fields
develop new knowledge
and procedures and to
integrate knowledge
from different fields
unpredictable and
require new strategic
approaches take
responsibility for
contributing to
professional knowled
ge and practice
and/or for reviewing
the strategic
performance of
teams
Level 8 (****) The
learning outcomes
relevant to Level 8
are
knowledge
at the most
advanced
frontier of a
field of
work or
study and at
the interface
between
fields
the most advanced and
specialised skills and
techniques, including
synthesis and
evaluation, required to
solve critical problems
in research and/or
innovation and to
extend and redefine
existing knowledge or
professional practice
demonstrate
substantial authority,
innovation,
autonomy, scholarly
and professional
integrity and
sustained
commitment to the
development of new
ideas or processes at
the forefront of work
or study contexts
including research
Compatibility with the Framework for Qualifications of the European Higher
Education Area
The Framework for Qualifications of the European Higher Education Area provides
descriptors for three cycles agreed by the ministers responsible for higher education
at their meeting in Bergen in May 2005 in the framework of the Bologna process.
Each cycle descriptor offers a generic statement of typical expectations of
achievements and abilities associated with qualifications that represent the end of
that cycle.
EN 8
EN
(*) The descriptor for the short cycle developed by the Joint Quality Initiative as part
of the Bologna process, (that can be within or linked to the first cycle), corresponds
to the learning outcomes for EQF level 5.
(**) The descriptor for the first cycle corresponds to the learning outcomes for EQF
level 6.
(***) The descriptor for the second cycle corresponds to the learning outcomes for
EQF level 7.
(****) The descriptor for the third cycle corresponds to the learning outcomes for
EQF level 8.
EN 9
EN
Annex IV
Minimum data requirements referred to in Article 8(1) point (b)
1. Minimum data requirements for information on qualifications:
DATA Mandatory / Optional
Title of qualification Mandatory
Field(1) Mandatory
Country(countries)/Region(s) (code) Mandatory
EQF Level Mandatory
NQF level Mandatory
Description of learning outcomes Mandatory
Awarding body/bodies3 Mandatory
Credit points/ notional workload needed
to achieve the learning outcomes Optional
Internal quality assurance processes Optional
External quality assurance / regulatory
body Optional
Further information on the qualification Optional
Identifier of related degrees for the same
study programme Optional
Source of information Optional
Link to relevant supplements Optional
Uniform Resource Identifier (URI) of the
qualification Mandatory
Entry requirements to obtain a
qualification Optional
Expiry date (if relevant) Optional
Ways to acquire qualification Optional
(1) ISCED FoET2013 (2) The minimum required information on the awarding body/bodies should facilitate to find information
about it, which would include its name, or if applicable the name of the group of awarding completed with a URI
or contact information.
EN 10
EN
Relationship to occupations or
occupational fields Optional
2. Minimum data requirements for information on awarding bodies:
PROPERTY DESCRIPTION MANDATORY/OPTION
AL
Unique Identifier Unique identifier for the
awarding body record Mandatory
Legal Name
The organisation's legal
name (multilingual, one
per language)
Mandatory
Address The identifiable address of
the organisation Mandatory
Registration Identifier
Legal registration
identifier with the
registering authority
Optional
Accreditation URI Link to associated
Accreditation record(s) Optional
Type Nature/genre of the
organisation Optional
Status Publication status Optional
Contact Information Contact Information Optional
Publisher Entity responsible for
publishing the record Optional
Historical Awarding Body
Reference
Link to another awarding
body in case of succession Optional
3. Minimum data requirements for information on accreditations
PROPERTY DESCRIPTION MANDATORY/OPTION
AL
Unique Identifier A unique identifier for the
accreditation record Mandatory
Title
A name given to the
resource (multilingual,
one per language)
Mandatory
EN 11
EN
Accrediting Agent
The Quality Assuring
Authority issuing the
accreditation decision
Mandatory
Awarding Body URI
The awarding body whose
activities are being
accredited, expressed as a
URI
Mandatory
Type
The nature/genre of the
accreditation (controlled
vocabulary)
Mandatory
Jurisdiction
Administrative territories
where the accreditation is
valid
Mandatory
Description A free-text account of the
resource Mandatory
Decision The decision issued by the
quality assuring authority Mandatory
Report Date of formal issuance Mandatory
Date of Issuance
Period in which the
accreditation is/was
applicable
Optional
EQF Level EQF levels the
accreditation covers Optional
[Abstract] Programme
Specific
programme/qualification
the accreditation applies to
Optional
Supplementary Document Additional public
documentation Optional
Publisher Entity responsible for
publishing the record Optional
EN 12
EN
Annex V
Specification for data fields in digital qualification attestations referred to in Article 9(4)
1. Minimum mandatory data fields
FIELD NAME DESCRIPTION
Given Name The holder's given name
Family Name The holder's date of birth
Date of Birth
The country as an alpha-2 country code as
specified ISO 3166-1, or the state, province,
district, or local area or the municipality, city,
town, or village where the user to whom the
holder's data relates was born
Birthplace
The country as an alpha-2 country code as
specified ISO 3166-1, or the state, province,
district, or local area or the municipality, city,
town, or village where the user to whom the
holder's data relates was born
Nationality
One or more alpha-2 country codes as specified in
ISO 3166-1 representing the nationality
(nationalities) of a holder
Qualification Title The official title of the qualification provided in at
least one language
Valid From The date and time when the digital
qualification attestation was issued
Valid Until The date and time the digital qualification
attestation ceases to be valid
EQF Level (if applicable)
If available, and only for qualifications awarded
after 2008 and in accordance with the relevant
national qualifications framework referencing to
the European Qualifications Framework: the
applicable level of the European Qualification
Framework
NQF Level (if applicable) If available, for the qualification specified in the
national qualifications framework
Issuer
The legal identifier, name and location of the
issuing organisation which issued the digital
qualification attestation
Awarding Body/Bodies The legal identifier, name and location of the
EN 13
EN
awarding body/bodies that awarded the
qualification
Country/countries of Award The Member State(s) in which the qualification
was awarded
Where applicable, Region of
Award
The code of the region in which the qualification
was awarded, where applicable
Date of Award The date on which the qualification was officially
awarded
Accreditation Evidence
Formal evidence of the awarding body's
accreditation at the time of award, including,
where the awarding body no longer exists in its
original legal form, evidence of succession
establishing the chain of continuity to the entity
providing the evidence
Professional Experience, where
applicable
Professional experience gained to obtain the
qualification
Professional Title, where
applicable
Professional title obtained as a result of
qualification being awarded
Access Rights, where
applicable
A statement on the access rights to regulated
professions conferred by the qualification
2. Optional data fields:
FIELD NAME DESCRIPTION
Holder's National ID and the
country National ID and country issuing it
Qualification Title in a
commonly agreed language The official title in commonly agreed language
Field of Education and/or
Training
The field of study, classified according to the
ISCED fields of Education and Training (ISCED-
F-2013)
Description of the
Qualification
Description of the qualification composed of
knowledge, skills and responsibility and autonomy
ESCO Skills reference Reference to European Skills, Competences, and
Occupations classification
Duration of Study
The official duration of the learning programme
expressed in time or credits of the European Credit
Transfer and Accumulation System
EN 14
EN
Grades / Marks The grades or marks achieved, accompanied by an
explanation of the grading scale used
Copy of Original Qualification
Document
An embedded image or scan of the original
physical qualification issued to the holder, where
available 4
Mode of Learning The mode of delivery, such as full-time, part-time,
distance learning
Main subjects / modules A list of the main subjects or modules covered by
the programme of study
Practical Training Details of a mandatory practical training that was
completed
Assessment Methods Information on the methods used for assessment
(e.g. examination, project work)
Language The primary language(s) in which the programme
was taught
Thesis/ Final Project Title The title of the final thesis or project, if applicable
International Mobility Information on any international mobility periods
undertaken as a part of the programme
3. Data fields covered in this Annex can be supplemented by additional data only as far
as it is necessary for the functioning of the relevant data in the EUDI Wallet system.
Otherwise, no other data fields than those covered by this Annex shall be included in
digital qualification attestations referred to in Article 9(4).
4 https://education.ec.europa.eu/education-levels/higher-education/inclusive-and-connected-higher-
education/european-credit-transfer-and-accumulation-system
EN EN
EUROPEAN COMMISSION
Strasbourg, 15.9.2026 COM(2026) 995 final
ANNEX
ANNEX
to the
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 No
(EU) 1024/2012
{SEC(2026) 995 final} - {SWD(2026) 995 final} - {SWD(2026) 996 final} - {SWD(2026) 997 final}
EN 1 EN
ANNEX
Annex VII to Directive 2005/36/EC is amended as follows:
(1) point 1 is amended as follows:
(a) point (b) is replaced by the following:
‘(b) Copies of the attestations of professional competence or of the evidence of formal
qualifications giving access to the profession in question, or corresponding digital
qualification attestations, and an attestation of the professional experience of the person
concerned, where applicable.
The competent authorities of the host Member State may invite the applicant to provide
information concerning the applicant’s training to the extent necessary in order to determine
the existence of potential substantial differences with the required national training, as laid
down in Article 14. Where it is impossible for the applicant to provide this information, the
competent authorities of the host Member State shall address the contact point, the competent
authority or any other relevant body in the home Member State.’;
(b) points (d) and (e) are replaced by the following:
‘(d) Where the competent authority of a host Member State requires of persons wishing to
take up a regulated profession proof that they are of good character or repute or that they have
not been declared bankrupt, or suspends or prohibits the pursuit of that profession in the event
of serious professional misconduct or a criminal offence, that Member State shall accept as
sufficient evidence, in respect of nationals of Member States wishing to pursue that profession
in its territory, the production of documents issued by competent authorities in the home
Member State or the Member State from which the foreign national comes, showing that
those requirements are met.
Where the competent authorities of the home Member State or of the Member State from
which the foreign national comes do not issue the documents referred to in the first
subparagraph, such documents shall be replaced by a declaration on oath, or, in States where
there is no provision for declaration on oath, by a solemn declaration, made by the person
concerned before a competent judicial or administrative authority or, where appropriate, a
notary or qualified professional body of the home Member State or the Member State from
which the person comes; such authority or notary shall issue a certificate attesting the
authenticity of the declaration on oath or solemn declaration.
(e) Where a host Member State requires of its own nationals wishing to take up a regulated
profession, a document relating to the physical or mental health of the applicant, that Member
State shall accept as sufficient evidence thereof the presentation of the document required in
the home Member State. Where the home Member State does not issue such a document, the
host Member State shall accept a certificate issued by a competent authority in that State.’;
(2) point 2 is replaced by the following:
‘2. Certificates
To facilitate the application of Title III, Chapter III, of this Directive, Member States may
prescribe that, in addition to evidence of formal qualifications that is not presented in the form
EN 2 EN
of a digital qualification attestation, the person who satisfies the conditions of training
required must provide a certificate from the competent authorities of that person’s home
Member State stating that this evidence of formal qualifications is that covered by this
Directive.’
Resolutsiooni liik: Riigikantselei resolutsioon Viide: Haridus- ja Teadusministeerium / / ; Riigikantselei / / 2-5/26-01918
Resolutsiooni teema: Kvalifikatsioonide ja oskuste tunnustamise ning liikuvuse parandamine
Adressaat: Haridus- ja Teadusministeerium Ülesanne: Tulenevalt Riigikogu kodu- ja töökorra seaduse § 152` lg 1 p 2 ning Vabariigi Valitsuse reglemendi § 3 lg 4 palun valmistada ette Vabariigi Valitsuse seisukohtade ja otsuste eelnõud järgmiste algatuste kohta, kaasates seejuures olulisi huvigruppe ja osapooli:
- Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the recognition of qualifications of third-country nationals, COM(2026)990
- 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"), COM(2026)992
- 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, COM(2026) 995
EISi toimiku nr: 26-0423 Tähtaeg: 13.11.2026
Adressaat: Justiits- ja Digiministeerium, Majandus- ja Kommunikatsiooniministeerium, Regionaal- ja Põllumajandusministeerium, Siseministeerium, Sotsiaalministeerium Ülesanne: Palun esitada oma sisend Haridus - ja Teadusministeeriumile seisukohtade kujundamiseks antud eelnõu kohta (eelnõude infosüsteemi (EIS) kaudu). Tähtaeg: 13.10.2026
Lisainfo: Eelnõusid on kavas arutada valitsuse 26.11.2026. aasta istungil ning Vabariigi Valitsuse reglemendi § 6 lg 6 kohaselt sellele eelneval nädalal (18.11.2026) EL koordinatsioonikogus. Esialgsed materjalid EL koordinatsioonikoguks palume esitada hiljemalt 13.11.2026.
Kinnitaja: Merli Vahar, Euroopa Liidu asjade direktori asetäitja Kinnitamise kuupäev: 29.09.2026 Resolutsiooni koostaja: Sandra Metste [email protected],
.