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EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 992 final

2026/0274 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

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

("Skills Portabilty Act")

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

{SWD(2026) 994 final}

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

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

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

across the Union. The Charter of Fundamental Rights of the European Union recognises the

right to engage in work and to pursue a freely chosen or accepted occupation, as well as the

freedom of Union citizens to seek employment, work, exercise the right of establishment and

provide services in any Member State. The freedom of movement is further supported by the

European Pillar of Social Rights, proclaimed in 2017, whose first chapter on equal

opportunities and access to the labour market emphasises the importance of skills and

employability.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

competitiveness stress the urgency of accelerating this digital transformation and removing

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

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

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

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

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

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

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

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

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

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

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

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

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

opportunities offered by the Single Market.

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

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

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

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

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

professional qualifications and strengthening the portability of qualifications and skills across

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

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

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

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

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

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

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

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

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

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

elsewhere are understood and recognised when people return.

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

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

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

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

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

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

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

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

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

State or return to their country of origin..

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

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

third country nationals.

• Consistency with existing policy provisions in the policy area

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

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

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

more trust, and better enforcement.

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

European legislation, recommendations and tools.

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

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

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

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

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

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

issuing a digital qualification into the EUDI Wallet.

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

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

programme/commission-work-programme-2026_en

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The proposal reinforces the objectives of the European Qualifications Framework Council

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

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

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

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

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

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

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

platform contains information on qualifications and qualifications frameworks and

interconnects information on qualifications from National Qualifications Frameworks

registers and databases.

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

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

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

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

online and used in digital qualification attestations.

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

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

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

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

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

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

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

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

information on qualifications.

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

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

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

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

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

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

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

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

Portability Initiative.

• Consistency with other Union policies

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

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

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

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

to strengthen the European Labour Authority (ELA).

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

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

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

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

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

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

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

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

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

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

operating across the EU.

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

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

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

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

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

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

qualification attestations should be accessible for persons with disabilities.

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

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

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

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

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

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

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

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

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

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

• Subsidiarity (for non-exclusive competence)

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

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

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

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

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

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

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

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

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

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

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

attestations.

The added value of ensuring availability of verifiable and interoperable digitalised

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

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

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

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

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

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

legal and technical framework underpinning the digitalisation of qualifications will allow

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

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

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

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

this action will be greater portability of qualifications and skills.

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

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

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

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

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

States.

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

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

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

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

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

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

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

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

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

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

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

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

align or replace divergent solutions at a later stage.

• Proportionality

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

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

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

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

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

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

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

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

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

authenticity of and understanding qualifications from other Member States.

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

corresponding paper attestation and supports comparability of qualifications awarded under

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

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

2005/36.

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

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

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

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

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

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

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

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

Preparing the infrastructure for digitalisation of recent qualification attestations requires a

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

efficiently.

• Choice of the instrument

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

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

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

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

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

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

required to bring about freedom of movement for workers.

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

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

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

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

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

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

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

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

also aligns with the identified legal basis.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

There is no existing EU legislation specifically addressing the digitalisation of qualifications,

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

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

Qualifications Framework and the Europass Framework, which were subject of

evaluations2 in 2024.

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

implementation and impact of Decision (EU) 2018/646 of the European Parliament and of the Council

of 18 April 2018 on a common framework for the provision of better services for skills and

qualifications (Europass) and SWD(2024)142 - Commission Staff Working Document Executive

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

Qualifications Framework for lifelong learning

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

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

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

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

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

of improvement.

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

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

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

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

Register.

• Stakeholder consultations

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

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

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

feasibility, suitability and potential impacts of selected policy measures.

This comprehensive evidence-gathering exercise included the following activities:

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

2026 resulting in 785 responses;

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

call for evidence, including 126 position papers;

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

October 2025 and April 2026;

• A social partner hearing on 23 January 2026;

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

(159 responses);

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

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

140 stakeholders);

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

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

• A survey among National Academic Recognition Information Centres was carried

out in April 2026 (16 responses);

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

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

(21 responses);

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

Member States covered);

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

covered).

These consultations revealed broad support for digitalisation of qualification attestations,

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

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These positions, and the Commission's assessment of how they have been reflected in the

preferred option, are summarised in Annex 2 (Stakeholder consultation synopsis report) of the

Impact Assessment.

• Collection and use of expertise

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

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

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

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

• Impact assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

EU frameworks and projects.

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

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

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

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

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

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

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

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

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

qualifications and skills.

The following policy options were assessed for the Specific Objectives:

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

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

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

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

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

A REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL ON PORTABILITY

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

(“SKILLS PORTABILITY ACT”).

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

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

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

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

older than 10 years, within a reasonable timeframe;

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

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

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

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

State.

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

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

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

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

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

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

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

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

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

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

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

make use of available EU funding.

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

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

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

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

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

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

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

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

Member States.

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

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

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

and skills portability across the EU's labour market.

• Regulatory fitness and simplification

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

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

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

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

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

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

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

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

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

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

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

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

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

certified documents proving qualifications to be important.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

alternative options,

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

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

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

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

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

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

option of paper documents,

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

standards

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

barriers to mobility.

• Fundamental rights

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

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

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

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

effective remedy.

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

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

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

support).

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

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

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

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

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

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

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

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

when relying on enhanced physical documents.

4. BUDGETARY IMPLICATIONS

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

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

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

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

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

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

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

The estimated budgetary impact for 2028 and beyond does not pre-judge the next Multiannual

Financial Framework. The source of financing and scope of Union financial commitment in

the post-2027 period remain subject to the outcome of interinstitutional negotiations on the

MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

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

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

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

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

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

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

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

procedure in accordance with Article 5 of that Regulation.

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

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

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

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

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

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

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

and provide the necessary evidence base for a future evaluation.

• Detailed explanation of the specific provisions of the proposal

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

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

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

facilitate uniform interpretation and application.

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

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

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

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

EN 12 EN

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

awarding bodies, accreditations and qualifications included in their National Qualifications

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

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

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

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

qualifications included in national qualifications frameworks in accordance with the

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

procedures for verification by relying parties through implementing acts.

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

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

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

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

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

qualifications frameworks are referenced to the European Qualifications Framework and that

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

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

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

tool to compare qualifications in Europass.

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

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

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

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

EN 13 EN

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

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

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

implementation of the Regulation.

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

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

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

and digital qualification attestations.

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

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

Regulation shall be retained no longer than 45 years.

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

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

amend the provisions of this Regulation.

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

delegated acts.

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

accordance with Regulation (EU) No 182/2011.

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

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

qualification.

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

EN 0 EN

2026/0274 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

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

("Skills Portabilty Act")

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

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

Article 46 thereof,

Having regard to the proposal from the European Commission,

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

Having regard to the opinion of the European Economic and Social Committee6,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) [POLITICAL CONTEXT] The Single Market is a cornerstone of European integration

and a key driver of the Union’s competitiveness, prosperity and resilience. Its full

potential depends, inter alia, on enabling people to move freely across the Union and

to put their qualifications and skills to use wherever they are needed. Facilitating

mobility contributes to a better allocation of skills across the Union, helps address

labour and skills shortages and strengthens the capacity of the Union economy to

respond to changing economic and demographic needs.

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

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

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

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

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

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

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

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

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

at facilitating portability of qualifications and skills for workers and

employers through improved availability of comparable, reliable, verifiable,

interoperable and digitalised information about qualifications and skills obtained in the

Union.

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

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

EN 1 EN

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

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

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

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

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

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

qualifications obtained in another Member State. Improved portability may therefore

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

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

digitalisation of qualifications carried out by Member States individually would lead

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

functioning of the internal market, restricting opportunities to address labour

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

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

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

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

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

the lack of local opportunities.

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

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

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

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

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

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

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

standard should be established for digital qualification attestations issued within the

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

the Member States and made available to labour market actors.

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

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

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

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

however have the possibility to issue digital qualification attestations already before

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

attestations should remain under the responsibility of the Member States.

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

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

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

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

market by providing harmonised digital qualification attestations across the Union.

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

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

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

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

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

8 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on

electronic identification and trust services for electronic transactions in the internal market and

repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, p. 73,

ELI: http://data.europa.eu/eli/reg/2014/910/oj).

EN 2 EN

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

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

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

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

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

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

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

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

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

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

qualifications that are included in national qualifications frameworks should be

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

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

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

of national qualifications frameworks regulations or procedures.

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

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

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

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

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

administrative fees for the issuance of digital qualification attestations to avoid

hampering their use.

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

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

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

qualifications with labour market relevance. European Qualifications Framework level

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

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

the labour market.

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

Minimum technical and procedural requirements are necessary for the issuance of

digital qualification attestations to ensure that those attestations are interoperable and

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

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

specifications for digital qualification attestations ensures consistency,

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

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

specifications should align with good practices in digital credentialing, including

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

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

EUDI Wallet.

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

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

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

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

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

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

EN 3 EN

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

attestations should be issued digitally within a reasonable time allowing Member

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

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

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

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

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

employment in another Member State.

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

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

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

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

physical or digital qualification attestation. Therefore, digital qualification attestations

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

suspended or revoked. Arrangements for suspension and revocation are without

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

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

qualification attestations across the Union, Member States should establish tools

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

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

To facilitate verification processes and reduce administrative burdens, the Commission

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

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

employers cannot refuse a digital qualification attestation issued in accordance with

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

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

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

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

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

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

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

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

facilitate the comparison between levels and portability of qualifications awarded by

entities from different Member States. Member States have undertaken significant

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

European Qualifications Framework through a structured referencing

process. National qualifications frameworks are evolving to reflect changes in

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

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

qualifications frameworks should be included in qualifications registries and

databases. Updated national qualifications frameworks should be reflected in the

referencing to the European Qualifications Framework that should remain adequate

9 The recommendation of the European Parliament and of the Council of 23 April 2008 on the

establishment of the European Qualifications Framework for lifelong learning (OJ C 111, 6.5.2008, pp.

1–7). 10 Council recommendation of 22 May 2017 on the European Qualifications Framework for lifelong

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

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

15.6.2017, p. 15).

EN 4 EN

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

that Member States update the referencing of their national qualifications frameworks

to the European Qualifications Framework when needed.

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

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

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

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

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

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

any obligation as to how Member States design their national qualifications

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

Qualifications Framework for lifelong learning, that Recommendation should continue

to provide guidance on matters not governed by this Regulation.

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

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

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

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

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

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

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

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

those credentials across the Union.

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

national databases connected to the Europass platform12 include information on

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

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

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

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

skills terminology from the European Skills, Competences, Qualifications and

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

European Parliament and of the Council14 which facilitates the understanding of

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

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

information about qualifications for workers and employers, Member States should

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

qualifications that are part of national qualifications frameworks referenced to the

European Qualifications Framework. A comparison tool embedded in the

Europass platform will facilitate an automated comparison of qualifications listed in

national qualifications frameworks referenced to the European Qualifications

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

learning and employability (OJ C 243, 27.6.2022). 12 Decision (EU) 2018/646 of the European Parliament and of the Council of 18 April 2018 on a common

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

Decision No 2241/2004/EC (OJ L 112,2.5.2018, p. 42). 13 https://www.cedefop.europa.eu/en/publications/6222 14 Regulation (EU) 2016/589 of the European Parliament and of the Council of 13 April 2016 on a

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

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

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

EN 5 EN

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

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

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

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

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

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

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

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

force minus 10 years].

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

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

States should make publicly available relevant information. This could

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

Regulation, including the issuance of digital qualification attestations and the

availability of comparable information on qualifications.

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

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

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

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

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

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

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

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

implementation of this Regulation should comply with the data protection framework

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

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

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

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

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

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

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

qualification attestations during the whole span of professional career.

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

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

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

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

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

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

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

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

for the Commission to review and evaluate its application.

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

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

selected to meet the specific requirements on issuance of digital qualification

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

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

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

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

EN 6 EN

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

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

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

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

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

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

the W3C VCDM format are available.

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

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

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

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

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

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

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

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

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

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

European Parliament and the Council should receive all documents at the same time as

Member States' experts, and their experts systematically have access to meetings of

Commission expert groups dealing with the preparation of delegated acts.

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

implementation of this Regulation laying down detailed provisions concerning the

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

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

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

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

relying parties, implementing powers should be conferred on the Commission. Those

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

European Parliament and of the Council17.

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

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

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

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

market without incurring an unnecessary additional administrative burden, Annexes I

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

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

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

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

16 OJ L 123, 12.5.2016, p. 1, ELI: http://data.europa.eu/eli/agree_interinstit/2016/512/oj 17 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

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

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

ELI: http://data.europa.eu/eli/reg/2011/182/oj). 18 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

establishing a single digital gateway to provide access to information, to procedures and to assistance

and problem-solving services and amending Regulation (EU) No 1024/2012 (OJ L295 of 21.11.2018, p.

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

EN 7 EN

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

Regulation introduces new binding requirements affecting those cross-border digital

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

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

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

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

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

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

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

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

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

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

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

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

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

[entry into force plus 36 months].

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

42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council

and delivered its opinion on [date]20.

HAVE ADOPTED THIS REGULATION:

Chapter 1

General provisions

Article 1

Subject-matter

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

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

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

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

attestations;

(c) provision of comparable information on qualifications;

(d) mutual assistance and cooperation between Member States;

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

Article 2

Definitions

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

19 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying

down measures for a high level of public sector interoperability across the Union (Interoperable Europe

Act) (OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj). 20 OJ C , , p. .

EN 8 EN

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

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

achieved learning outcomes to given standards;

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

electronic form;

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

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

the European Qualifications Framework through a referencing process;

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

tasks and solve problems;

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

has acquired following a small volume of learning;

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

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

910/2014;

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

verified that an awarding body meets predefined quality standards;

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

State which is accredited to award a qualification;

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

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

Regulation (EU) No 910/2014;

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

awarding body.

Chapter 2

Digital Qualification Attestations

Article 3

Digital qualification attestations in the EUDI Wallets

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

Wallets as one of the following:

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

Regulation (EU) No 910/2014;

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

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

of Regulation (EU) No 910/2014.

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

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

Regulation (EU) No 910/2014;

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

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

behalf in accordance with that Article.

EN 9 EN

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

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

language to be established in accordance with paragraph 6.

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

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

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

qualifications included in their national qualifications frameworks. Those lists

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

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

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

available to the public.

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

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

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

implementing acts laying down detailed provisions concerning the agreed common

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

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

bodies, accreditations and qualifications included in national qualifications

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

examination procedure referred to in Article 15(2).

Article 4

Digital qualification attestations

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

the qualifications awarded under their jurisdictions are evidenced by digital

qualification attestations based on the Union standard specifications laid down in

Annex I.

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

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

attestations issued in accordance with Article 9.

3. Digital qualification attestations shall constitute evidence of qualifications awarded

to the holder and shall be valid across the Union.

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

qualification attestations are issued without delay upon request of the qualification

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

conditions:

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

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

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

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

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

than within two weeks from receipt of that request;

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

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

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

EN 10 EN

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

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

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

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

paragraphs 4 and 5.

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

digital qualification attestations evidencing qualifications awarded in the period

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

10 years] in accordance with Article 9.

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

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

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

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

scientific developments.

Article 5

Issuance of digital qualification attestations

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

attestation to evidence qualifications awarded to them.

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

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

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

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

in Article 3(4);

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

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

Article 6

Revocation and suspension of a digital qualification attestation

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

qualification is withdrawn or suspended.

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

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

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

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

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

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

suspension.

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

qualification attestation and make it available to relying parties.

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

of qualifications awarded to the holder.

EN 11 EN

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

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

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

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

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

(a) conditions for the recovery of the qualification;

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

Article 7

Verification by relying parties

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

verification tool that enables relying parties to verify that:

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

3(2);

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

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

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

issued;

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

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

implementing acts laying down formats and procedures for verification by relying

parties in accordance with paragraph 1. The implementing acts shall be adopted in

accordance with the examination procedure referred to in Article 15(2).

This Regulation does not oblige relying parties to request or verify digital

qualification attestations.

Article 8

Provision of comparable information on qualifications

1. Member States shall provide information on the qualifications, awarding bodies and

accreditations as referred to in Article 3(4) to the Europass online platform as

follows:

(a) the information shall be presented in the semantic model laid down in point 2

of Annex I;

(b) the minimum data requirements laid down in Annex IV shall be met;

(c) for the description of qualifications, skills terminology from the European

classification of skills and occupations (ESCO) shall be used to the extent

possible.

Member States shall submit updates of the information referred to in the first

subparagraph in real time to the extent possible, and in any case at least each month.

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

14, to amend Annex IV to take account of technical, operational or scientific

developments.

EN 12 EN

3. National qualifications frameworks shall include all qualifications awarded under the

jurisdiction of a Member State and be kept up to date. To the extent possible,

Member States shall include micro-credentials in their national qualifications

frameworks.

4. Member States shall use the European Qualifications Framework to reference

national qualifications frameworks or systems and to allow comparison of all types

and levels of qualifications in the Union that are part of national qualifications

frameworks or systems in particular by referencing their qualification levels to levels

of the European Qualifications Framework.

5. Member States shall review and update, when needed, the referencing of the levels of

the national qualifications frameworks or systems to the levels of the European

Qualifications Framework.

6. The Commission shall provide a digital tool to facilitate an

automated comparison of qualifications listed in national qualifications frameworks

referenced to the European Qualifications Framework and make it available through

the Europass platform.

Article 9

Qualifications awarded before digitalisation of qualifications

1. For the qualifications awarded in the period between [date of entry into force minus

45 years] and [date of entry into force minus 10 years], Member States shall ensure

that, upon request of a qualification holder, a digital qualification attestation is issued

within a reasonable time, and in any case no later than within two weeks from the

receipt of the request from the qualification holder, on the basis of existing evidence

verified by the issuer.

2. Member States may limit the issuance of digital qualification attestations in

accordance with paragraph 1 to cases in which a qualification holder provides

evidence that the purpose of the use of the digital qualification attestation is the

pursuit of employment in another Member State.

3. For the purposes of paragraph 1, the issuers may make use of:

(a) verification measures provided by Member States in accordance with Annex

VI to Regulation (EU) No 910/2014;

(b) procedures, assistance and problem-solving services laid down by Regulation

(EU) 2018/1724.

4. For digital qualification attestations to be issued under this Article, Member States

shall use the Union standard specifications for data fields laid down in Annex V.

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

14, to amend Annex V to take account of technical, operational or scientific

developments.

Chapter 3

Implementation

Article 10

Information on the digital qualification attestations

EN 13 EN

No later than [date of the entry into force of this Regulation plus 30 months] and in any case

no later than the date of first issuance of digital qualification attestations in accordance with

Article 4(4), each Member State shall make publicly available information concerning digital

qualification attestations .

Article 11

Qualifications Digitalisation Group

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

is established to facilitate cross-border cooperation and exchange of

information on issues related to the implementation of this Regulation,

including trust services, European Digital Identity Wallet, notified electronic

identification schemes, semantic model and digital qualification attestations, and to

take all necessary steps to ensure that the information exchanged is up-to-date.

2. The Qualifications Digitalisation Group shall be composed of representatives

appointed by each Member State. The Qualifications Digitalisation Group shall be

chaired by the Commission. The Commission shall provide the Qualifications

Digitalisation Group’s Secretariat.

3. The Qualifications Digitalisation Group shall have the following tasks:

(a) support the consistent implementation of this Regulation by facilitating

coordination and project management, the exchange of information and the

promotion of best practices across Member States as well as developing

guidelines to support enforcement;

(b) support the development and operation of electronic data exchanges in

accordance with this Regulation;

(c) provide recommendations to Member States, where appropriate, on further

digitalisation of qualifications.

4. The Qualifications Digitalisation Group shall cooperate, when relevant, with the

European Digital Identity Cooperation Group referred to in Article 46, point (e), of

Regulation (EU) No 910/2014.

5. The Qualifications Digitalisation Group shall adopt its rules of procedure and meet at

least annually until [five years after the entry into force of this Regulation].

Article 12

Data protection

1. Personal data shall be processed in the context of this Regulation only in so far as it

is necessary for issuance and verification of digital qualification attestations in

accordance with Chapter 2.

2. Personal data processed in the context of this Regulation shall be retained no longer

than [45] years.

EN 14 EN

Chapter 4

Final provisions

Article 13

Reporting and review

1. By [[48] months from the date of the entry into force of this Regulation], and every

year thereafter, Member States shall submit to the Commission the following data

concerning the past 12 months:

(a) the number of digital qualification attestations issued, revoked and suspended;

(b) the share of qualifications issued in the form of digital qualification attestations

among all qualifications awarded;

(c) the number of relying parties registered to access digital qualification attestations.

2. By [48] months from the date of the entry into force of this Regulation], and every

two years thereafter, Member States shall submit a report to the Commission on the

application of this Regulation. The report shall include:

(a) the data referred to in paragraph 1;

(b) the information on respective average processing time of a request for issuance

of a digital qualification attestation in accordance with Article 4(5) and Article

9.

Member States shall collect feedback from holders of qualifications, employers,

awarding institutions, issuers, recognition authorities for regulated professions and

other stakeholders necessary for preparing the report as laid down in this paragraph.

3. The information submitted to the Commission in accordance with paragraphs

1 and 2 shall not include personal data.

4. By [the same date as the date of application plus five years], the Commission shall

review and evaluate the application of this Regulation and shall present a report to

that effect to the European Parliament and the Council.

5. Where appropriate, the Commission shall submit relevant legislative proposals.

Article 14

Exercise of the delegation

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts referred to in Article 4(10), Article 8(2) and

Article 9(5) shall be conferred on the Commission for an indeterminate period from

[date of entry into force].

3. The delegation of power referred to in Article 4(10), Article 8(2) and Article

9(5) may be revoked at any time by the European Parliament or by the Council. A

decision to revoke shall put an end to the delegation of the power specified in that

decision. It shall take effect the day following the publication of the decision in the

Official Journal of the European Union or at a later date specified therein. It shall not

affect the validity of any delegated acts already in force.

EN 15 EN

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. A delegated act adopted pursuant to Article 4(10), Article 8(2) and Article 9(5) shall

enter into force only if no objection has been expressed either by the European

Parliament or by the Council within a period of two months of notification of that act

to the European Parliament and the Council or if, before the expiry of that period, the

European Parliament and the Council have both informed the Commission that they

will not object. That period shall be extended by two months at the initiative of the

European Parliament or of the Council.

Article 15

Committee procedure

1. The Commission shall be assisted by a committee. That committee shall be a

committee within the meaning of Regulation (EU) No 182/2011.

2. Where reference is made to this paragraph, Article 5 of Regulation (EU) No

182/2011 shall apply.

Article 16

Amendment of Regulation (EU) 2018/1724

Regulation (EU) 2018/1724 is amended as follows:

(1) In the table of Annex I at the level of 'B. Work and retirement within the Union' as

Area, in the second column, point 3 is replaced by the following: “verification,

comparison and recognition, where appropriate, of qualifications with a view to

pursue employment in another Member States”.

(2) In the table of Annex II at the level of 'Working' as Life Event, the following row is

added in the second and third columns:

‘Requesting proof of qualification for

the issuance of a digital qualification

attestation referred to in Article 9 of

Regulation (EU)…of the European

Parliament and of the Council*

Proof of a qualification

*Regulation (EU) .../... of the European Parliament and of the Council of ... on ... (OJ ...).’.

Article 17

Entry into force [and application]

This Regulation shall enter into force on the [twentieth] day following that of its publication

in the Official Journal of the European Union.

[Articles […] and 16 shall apply from [entry into force plus 36 months].

EN 16 EN

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

[...] [...]

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

Contents

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ...................................................................................... 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 3

1.3.4. Indicators of performance ............................................................................................ 3

1.4. The proposal/initiative relates to: ................................................................................. 4

1.5. Grounds for the proposal/initiative .............................................................................. 4

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 4

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 4

1.5.3. Lessons learned from similar experiences in the past .................................................. 4

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 5

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 5

1.6. Duration of the proposal/initiative and of its financial impact .................................... 6

1.7. Method(s) of budget implementation planned ............................................................. 6

2. MANAGEMENT MEASURES................................................................................... 8

2.1. Monitoring and reporting rules .................................................................................... 8

2.2. Management and control system(s) ............................................................................. 8

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed .................. 8

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them............................................................................................................ 8

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ........................................... 8

2.3. Measures to prevent fraud and irregularities ................................................................ 9

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10

EN 2 EN

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 10

3.2. Estimated financial impact of the proposal on appropriations ................................... 12

3.2.1. Summary of estimated impact on operational appropriations.................................... 12

3.2.1.1. Appropriations from voted budget ............................................................................. 12

3.2.1.2. Appropriations from external assigned revenues ....................................................... 18

3.2.2. Estimated output funded from operational appropriations......................................... 24

3.2.3. Summary of estimated impact on administrative appropriations ............................... 26

3.2.3.1. Appropriations from voted budget .............................................................................. 26

3.2.3.2. Appropriations from external assigned revenues ....................................................... 26

3.2.3.3. Total appropriations ................................................................................................... 26

3.2.4. Estimated requirements of human resources.............................................................. 27

3.2.4.1. Financed from voted budget....................................................................................... 27

3.2.4.2. Financed from external assigned revenues ................................................................ 28

3.2.4.3. Total requirements of human resources ..................................................................... 28

3.2.5. Overview of estimated impact on digital technology-related investments ................ 30

3.2.6. Compatibility with the current multiannual financial framework.............................. 31

3.2.7. Third-party contributions ........................................................................................... 31

3.3. Estimated impact on revenue ..................................................................................... 31

4. DIGITAL DIMENSIONS .......................................................................................... 32

4.1. Requirements of digital relevance .............................................................................. 32

4.2. Data ............................................................................................................................ 33

4.3. Digital solutions ......................................................................................................... 33

4.4. Interoperability assessment ........................................................................................ 34

4.5. Measures to support digital implementation .............................................................. 34

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Regulation of the European Parliament and of the Council on

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

(‘Skills Portability Act’)

1.2. Policy area(s) concerned

Internal Market: Free movement of persons, labour mobility

Digitalisation of public administrations

1.3. Objective(s)

1.3.1. General objective(s)

Facilitating portability of qualifications and skills between Member States in the

context of free movement of workers.

Ensuring access to simplified, effective and cost-efficient ways to carry, prove, read,

understand and compare qualifications and skills obtained in another Member State.

1.3.2. Specific objective(s)

Specific objective 1

Ensuring that labour market actors have access to reliable and comparable

information on skills and qualifications issued in the EU.

Specific objective 2

Ensuring that labour market actors in the EU can benefit from interoperable and

verifiable digital attestations of qualifications and skills.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.

The Skills Portability Act is expected to generate benefits by facilitating the

verification and presentation of qualifications across borders, and improving the

transparency and trustworthiness of qualifications through interoperable digital

attestations. Workers will benefit from being able to store and present verifiable

digital attestations through the European Digital Identity (EUDI) Wallet, reducing

the need for comparability statements of qualifications and making it easier and

cheaper to demonstrate their qualifications when seeking employment in another

Member State. In addition to reducing costs, the proposal is expected to simplify

administrative procedures, shorten the time needed to demonstrate qualifications

across borders and facilitate labour mobility.

Employers will benefit from faster and more reliable verification of qualifications

through EUDI Wallet-compatible digital qualification attestations, easier access to

official and comparable information on qualifications across Member States, and

lower administrative costs when recruiting workers from abroad. The proposal is

expected to be particularly valuable for Small and Medium sized Enterprises

(SMEs)s, which often lack dedicated human resources to assess non-national

qualifications and would gain access to reliable information and automated

verification tools.

EN 4 EN

Awarding bodies and issuers of qualifications will benefit from fewer requests to

verify the authenticity of qualifications, as digital attestations enable automatic

verification by employers and other labour market actors. This is expected to

generate administrative savings, reduce routine administrative workload and allow

institutions to focus resources on their core educational activities.

Indirect benefits can also be expected: as the action contributes positively to the

functioning of the internal market and EU competitiveness: it is expected to facilitate

cross-border hiring with some effect on skills mismatches and improved labour

market allocation.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

The Commission will carry out monitoring in cooperation with the Member States

designed to monitor the implementation and evaluate the initiative’s impact, ensuring

that it remains fit for purpose and achieve the intended objectives. The monitoring

framework will include output, result and impact indicators. It will rely on annual

information submitted by Member States on the number of digital qualification

attestations issued, revoked and suspended, the share of qualifications issued in the

form of digital qualification attestations in all qualifications awarded annually, and

the number of relying parties registered to access digital qualification attestations;

biennial reports by Member States on the application of the Regulation, including

information on the average processing time for requests for issuance of digital

qualification attestations and feedback collected from workers, holders of

qualifications, employers, awarding institutions, issuers, recognition authorities for

regulated professions and other relevant stakeholders.

1.4. The proposal/initiative relates to:

 a new action

a new action following a pilot project / preparatory action21

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

Member States will start the application 36 months from the date of entry into force

of the Regulation. The proposal provides for four implementing acts to be adopted by

the Commission no later than within 18 months from the date of adoption of this

Regulation. The implementing acts will lay down detailed provisions concerning the

agreed common language; interoperability of digital qualification attestation across

the Union; the lists of awarding bodies, accreditations and qualifications included in

national qualifications frameworks for issuing and verifying digital qualification

attestations; and finally the detailed rules on verification processes, verification

21 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 5 EN

features and the interface with national systems.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante)

The free movement of people is a fundamental principle of the European Union.

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

make full use of their free movement rights and to work in another Member State.

Without improved information on qualifications and skills obtained in other Member

States and tools facilitating effectively the portability of such qualifications and

skills, businesses and workers face difficulties when considering opportunities across

the EU.

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

at the EU level to allow for interoperability across Member States instead of 27

different national frameworks and systems, thereby reducing fragmentation and

administrative burdens by facilitating the cross-border use and recognition of digital

qualification attestations.

Expected generated EU added value (ex-post)

The proposal is expected to generate EU added value by enhancing the availability of

digital qualification attestations that are easily accessible to workers as holders of

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

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

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

enabling better understanding and comparison of qualifications issued in different

Member States. A common legal and technical framework underpinning the

digitalisation of qualifications will allow digital qualification attestations issued in

another Member State to become more trustworthy, easier to verify and better

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

and facilitate smoother access to jobs in all Member States. Overall, the expected

added value of this action will be greater portability of qualifications and skills.

1.5.3. Lessons learned from similar experiences in the past

The Skills Portability Act builds on existing tools such as the European

Qualifications Framework and the Europass Framework, which were the subject of

evaluations22 in 2024.

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

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

Member States have referenced their national qualifications frameworks (NQFs) or

systems to the EQF. However, ensuring that National Qualifications Frameworks and

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

implementation and impact of Decision (EU) 2018/646 of the European Parliament and of the Council

of 18 April 2018 on a common framework for the provision of better services for skills and

qualifications (Europass) and SWD(2024)142 - Commission Staff Working Document Executive

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

Qualifications Framework for lifelong learning

EN 6 EN

databases and registers of qualifications are updated and connected to the Europass

platform is mentioned as an area for improvement.

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

presenting knowledge, skills, and competences in a standardised format. However,

further efforts are needed in developing qualification and learning opportunity

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

Qualifications Dataset Register.

Moreover, to test the use of the EUDI wallet in relation to the issuance, storage and

presentation of verifiable digital credentials through wallet-based solutions for

educational qualifications and learning achievements, the Digital Credentials for the

European Union (DC4EU) was conducted as a large-scale pilot project. The pilot

confirmed the potential efficiency gains from digital credentials, while also

illustrating the risk of fragmentation if Member States proceed with different

technical solutions in the absence of common standards.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

This proposal is compatible with the Multiannual Financial Framework 2028-2034 as

proposed by the Commission.

The proposal creates synergies with existing Union instruments and policies. It

builds on the European Digital Identity framework and the eIDAS Regulation

through the use of interoparble digital attestations for qualifications and skills and the

trusted framework for exchanges. The proposal includes also an amendment of

Regulation (EU) 2018/1724 to allow for the use of solutions based on the Single

Digital Gateway and the Once-Only Technical System.

Finally, this proposal supports a proposal to review the Professional Qualifications

Directive under Skills Portability Initiative, which aims to facilitate recognition

procedures under the Professional Qualifications Directive through the provision of

interoperable digitial qualification attestations.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

This proposal builds on the financial envelope proposed under the Erasmus+

programme and European Competitiveness Fund under Heading 2 of the Multiannual

Financial Framework 2028-2034, subject to its adoption and the EU annual

budgetary procedure.

EN 7 EN

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

–  in effect from [DD/MM]YYYY to [DD/MM]YYYY

–  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

unlimited duration

– Implementation with a start-up period from 2028 to 2034,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned23

Direct management by the Commission

–  by its departments, including by its staff in the Union delegations;

– by the executive agencies

Shared management with the Member States

Indirect management by entrusting budget implementation tasks to:

–  third countries or the bodies they have designated

–  international organisations and their agencies (to be specified)

–  the European Investment Bank and the European Investment Fund

–  bodies referred to in Articles 70 and 71 of the Financial Regulation

–  public law bodies

–  bodies governed by private law with a public service mission to the extent that

they are provided with adequate financial guarantees

–  bodies governed by the private law of a Member State that are entrusted with

the implementation of a public-private partnership and that are provided with

adequate financial guarantees

–  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on

European Union, and identified in the relevant basic act

– bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance with

sector-specific rules, with the implementation of Union funds or budgetary

guarantees, to the extent that such bodies are controlled by public law bodies or

by bodies governed by private law with a public service mission, and are provided

with adequate financial guarantees in the form of joint and several liability by the

controlling bodies or equivalent financial guarantees and which may be, for each

action, limited to the maximum amount of the Union support.

Comments

23 Details of budget implementation methods and references to the Financial Regulation may be found on

the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 8 EN

This proposal is foreseen to be implemented by the Commission’s department from

2028 onwards. The additional staff needed to implement this proposal is assessed at

6 Full Time Equivalents. Part of the proposal might be implemented by an executive

agency, in particular under the proposed European Competitiveness Fund.

EN 9 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

Monitoring of performance will focus on the extent to which the proposal succeeds

in increasing the availability, uptake and use of digital qualification attestations,

improving the efficiency of issuing and accessing such attestations, and supporting

the cross-border verification and recognition of qualifications. The monitoring

framework will include output, result and impact indicators measuring. The

Commission will carry out monitoring in cooperation with the Member States.

Monitoring will rely on annual information submitted by Member States on the

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

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

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

access digital qualification attestations; biennial reports by Member States on the

application of the Regulation, including information on the average processing time

for requests for issuance of digital qualification attestations.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

Direct management, as per article 62.1(a) of the Financial Regulation, is the

preferred mode of implementation, as the actions will be carried out by the European

Commission, more specifically the Directorate-General for Employment, Social

Affairs and Inclusion (DG EMPL), which will ensure the coordination with Member

States and various stakeholders.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The controls are part of the internal control system of DG EMPL. The new activities

will be subject to the same risk identification and mitigation approach.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The controls are integrated into the internal control system of DG EMPL. The new

activities will generate negligeable additional control costs at DG level.

2.3. Measures to prevent fraud and irregularities

The Commission shall ensure that, when actions financed are implemented, the

financial interests of the Union are protected by the application of preventive

measures against fraud, corruption and any other illegal activities, by effective

checks and by the recovery of the amounts unduly paid and, if irregularities are

detected, by effective, proportional and dissuasive penalties. The Commission is

authorised to carry out checks and verifications in situ under this Decision, in

compliance with Council Regulation (Euratom, EC) No. 2185.96 of 11 November

1996 concerning on-the-spot checks and inspections carried out by the Commission

in order to protect the European Union’s financial interests against fraud and other

irregularities. If need be, investigations shall be carried out by the European Anti-

Fraud Office and shall be governed by Regulation (EC) No. 1073/1999 of the

EN 10 EN

Eureopan Parliament and of the Council of 25 May 1999 concerning investigations

conducted by the European Anti-Fraud Office.

EN 11 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

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

illustrative purposes only and does not pre-judge the 2028-2034 Multiannual

Financial Framework (MFF). The source of financing and scope of Union financial

commitment in the post-2027 period remain subject to the outcome of

interinstitutional negotiations on the 2028-2034 MFF and thereafter shall be

determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

• Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure

Contribution - to be determined at later stage for

EFTA, (potential) candidate countries and third

countries

Number

Diff./Non-

diff.24

from

EFTA

countries 25

from

candidate

countries

and

potential

candidates 26

From

other

third

countries

other assigned

revenue

2

To be determined after the adoption of the

MFF and in the context of the annual

budgetary procedure – successor of 07 03

02 – Erasmus+

Diff. YES/NO YES/NO YES/NO NO

2

To be determined after the adoption of the

MFF and in the context of the annual

budgetary procedure – European

Competitiveness Fund

Diff. YES YES YES YES

24 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 25 EFTA: European Free Trade Association. 26 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 12 EN

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

–  The proposal/initiative does not require the use of operational appropriations

–  The proposal/initiative requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework Number 2 - Competitiveness, prosperity and security

DG: EMPL

Year Year Year Year Year Year Year

TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

Operational appropriations

Erasmus+ Commitments (1a) 0.500 1.200 1.100 0.815 0.815 0.815 0.815 6.060

Payments (2a) 0.500 1.200 1.100 0.815 0.815 0.815 0.815 6.060

European Competitiveness Fund Commitments (1b) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (2b) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Appropriations of an administrative nature financed from the envelope of specific programmes27

Budget line (3) 0 0 0 0 0 0 0 0

TOTAL appropriations Commitments =1a+1b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

for DG EMPL Payments =2a+2b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

27 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

EN 13 EN

This proposal builds on two financial envelopes that work in synergy: Erasmus+ and the European Competitiveness Fund (ECF) for skills

development and for the objective of implementing the Union of Skills, including making use of EU digital identity wallets.

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

TOTAL operational

appropriations

Commitments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (5) p.m p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from the

envelope for specific programmes

(6) 0 0 0 0 0 0 0 0

TOTAL

appropriations

under HEADING 2 Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Year Year Year Year Year Year Year

TOTAL

MFF

2028-2034

2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

• TOTAL

operational

appropriations (all

operational

headings)

Commitments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

• TOTAL appropriations of an

administrative nature financed from (6) 0 0 0 0 0 0 0 0

EN 14 EN

the envelope for specific programmes

(all operational headings)

TOTAL

appropriations

Under Heading 1

to 3

Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

(Reference amount)

EN 15 EN

Heading of multiannual financial framework 4 ‘Administrative expenditure’28

DG: EMPL Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

 Human resources 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

 Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG EMPL Appropriations 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

TOTAL appropriations under HEADING 4 of

the multiannual financial framework

(Total

commitments

= Total

payments)

1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

28 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 16 EN

The staff needed to implement this proposal has been assessed at 9 full time equivalent (FTE), of which 3 AD and 2 contract agents are redeployed from existing staff in the

DG, 3 AD and1 AST are to be covered by the redeployment pool of the Commission.

EN 17 EN

EUR million (to three decimal places)

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

TOTAL

appropriations under

HEADINGS 1 to 4

Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

EN 18 EN

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indicate

objectives

and outputs



Year 2028

Year 2029

Year 2030

Year 2031

Year 2032

Year 2033

Year 2034

TOTAL

OUTPUTS

Type 29

Aver

age

cost

N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost Total

No

Total

cost

Specific objectives 1

and 2

- Output Activ

ities

funde

d

under

Eras

mus+

30

1 0.500 1 1.200 1 1.100 1 0.815 1 0.81

5

1 0.815 1 0.815 7 6.060

29 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 30 This includes mainly work on Europass (comparison tool, back office to connect databases on qualifications, accreditation and awarding bodies).

EN 19 EN

- Output Activ

ities

funde

d

under

the

Euro

pean

Com

petiti

venes

s

Fund 31

1 0 1 p.m. 1 p.m. 1 p.m. 1 1 p.m. 1 p.m. 7 p.m.

Subtotal for specific

objectives

1 p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 7 p.m.

TOTALS 1 p.m. 1 p.m. 1 0p.m. 1 p.m. 1 p.m. 1 p.m. 1 p.m. 7 p.m.

31 These include activities such as supporting Member States in setting up the trust framework needed for the digitalisation of qualifications in line

with the eIDAS Regulation under the EUDI Wallet (i.e. national registries of qualifications, awarding bodies and accreditations), putting in place the

verification software and preparing the digital issuing infrastructure for qualifications.

EN 20 EN

3.2.3. Summary of estimated impact on administrative appropriations

–  The proposal/initiative does not require the use of appropriations of an administrative nature

–  The proposal/initiative requires the use of appropriations of an administrative nature, as explained below

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year Year Year Year Year Year Year TOTAL 2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

Human resources 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

Other administrative expenditure 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal HEADING 4 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Other expenditure of an administrative

nature 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL 1.568 1.568 1.568 1.568 1.568 1.568 1.568 10.976

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from the DG that are already

assigned to management of the action and/or have been redeployed within the DG, together, if necessary, with any additional allocation which may be granted to the

managing DG under the annual allocation procedure and in the light of budgetary constraints.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the 2028-2034 Multiannual

Financial Framework (MFF). The source of financing and scope of Union financial commitment in the post-2027 period remain subject to the outcome of

interinstitutional negotiations on the 2028-2034 MFF and thereafter shall be determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

3.2.4. Estimated requirements of human resources

–  The proposal/initiative does not require the use of human resources

–  The proposal/initiative requires the use of human resources, as explained below

EN 21 EN

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs)32

VOTED APPROPRIATIONS

Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission’s

Representation Offices) 7 7 7 7 7 7 7

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (inFTEs)

20 02 01 (AC, END from the ‘global envelope’) 2 2 2 2 2 2 2

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0 0 0 0

Admin. Support line • at Headquarters 0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU Delegations 0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) - Heading 4 0 0 0 0 0 0 0

32 Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed within your DG

and what are your net needs.

EN 22 EN

Other budget lines (specify) - Outside Heading 4 0 0 0 0 0 0 0

TOTAL 9 9 9 9 9 9 9

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 4

or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts

6 AD and 1 AST

N/A N/A

External staff

(CA, SNEs, INT)

2 CA N/A N/A

*

5 staff (3 AD, 2 CA) will be redeployed from existing staff in the DG to work on the implementation of the Skills Portability Act, but the

implementation of this entirely new initiative will require 4 additional staff (3 AD, 1 AST) from the redeployment pool of the Commission

The tasks related to the implementation include the oversight and coordination of the project, the management of the Qualifications Digitalisation

Group, the digital implementation of the Regulation, the monitoring and future reporting of the Regulation, as well as the policy steer. . The

implementation of the regulation will require the drafting of several implementing acts (with the bulk of the work expected to take place within 18

months of the adoption) and the adoption of the implementing acts as soon as possible to allow Member States to prepare the entry into force of the

regulation on time. This will require also technical work (including IT development) and technical support to ensure that Member States are ready for

implementation within the legal deadline. After these initial years, staff will be needed to continue providing support in the implementation of the

Member States, updating the implementing acts and preparing delegated acts when necessary, as well as monitoring and enforcement of the

EN 23 EN

regulation’s implementation. Throughout the entire period, staff will be needed for the running of governance, communication and awareness-raising

activities, and technical support for the Member States.

The Skills Portability Act, will require investing in IT solutions that will support its implementation (e.g. supplying a reference application to verify

whether a digitalised qualification has not been forged since its issuance, improving the IMI solution to better support recognition of qualifications in

the domain of regulated professions). To support the policy units in the implementation of these IT activities, besides the requested IT budget that will

be used to procure the IT activities (e.g. acquisition of IT service providers, or full outsourcing). Additional staff is required, to cover all project

management related tasks (i.e. planning the work, drafting the project charter, managing a team of IT service providers, monitoring and controlling the

work plan and deliverables, etc.).

Description of tasks to be carried out by:

Officials and temporary staff 1 AST for IT unit to cover all project management related tasks (i.e. planning the

work, drafting the project charter, managing a team of IT service provicers, monitoring

and controlling the work plans vs deliverables, etc.).

6 AD to draft the implemention acts, to provide for technical support to Member

States, to run the Qualifications Digitalisation Grouop, to implement communication

and awareness raising activities. Oversight and coordination of the project for the

digital implementation of the Regulation, the monitoring and future reporting of the

Regulation, as well as policy steer.

External staff To second the 6 AD in all their tasks.

3.2.5. Overview of estimated impact on digital technology-related investments

Compulsory: the best estimate of the digital technology-related investments entailed by the proposal/initiative should be included in the table

below.

Exceptionally, when required for the implementation of the proposal/initiative, the appropriations under Heading 4 should be presented in the

designated line.

The appropriations under Headings 1-3 should be reflected as “Policy IT expenditure on operational programmes”. This expenditure refers to

the operational budget to be used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation of the initiative and their

associated investments (e.g. licences, studies, data storage etc). The information provided in this table should be consistent with details

presented under Section 4 “Digital dimensions”.

EN 24 EN

TOTAL Digital and IT

appropriations

Year Year Year Year Year Year Year TOTAL MFF

2028 - 2034

2028 2029 2030 2031 2032 2033 2034

HEADING 4

IT expenditure (corporate) 0 0 0 0 0 0 0 0

Subtotal HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Policy IT expenditure on operational programmes

0.5 p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Subtotal outside HEADING 4 0.5 p.m. p.m. p.m.p.m. p.m.p.m. p.m.

TOTAL 0.5 p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

–  can be fully financed through redeployment within the relevant heading of the multiannual financial framework (MFF)

–  requires use of the unallocated margin under the relevant heading of the MFF and/or use of the special instruments as defined in the

MFF Regulation

–  requires a revision of the MFF

EN 25 EN

3.2.7. Third-party contributions

The proposal/initiative:

–  does not provide for co-financing by third parties

–  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year Total

2028 2029 2030 2031 2032 2033 2034

Specify the co-financing

body EEA EFTA countries

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations

co-financed p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.3. Estimated impact on revenue

–  The proposal/initiative has no financial impact on revenue.

–  The proposal/initiative has the following financial impact:

–  on own resources

–  on other revenue

–  please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

EN 26 EN

Budget revenue line:

Appropriations available

for the current financial

year

Impact of the proposal/initiative33

Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034

Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

If the policy initiative is assessed as having no requirement of digital relevance:

Justification of why digital means cannot be used to enhance policy implementation and why the ‘digital by default’ principle is not applicable

N/A

Otherwise:

High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital solutions

and/or digital public services)

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 3 (1-3) Member States shall designate issuers

who shall issue digital qualification

attestations within the European

Issuing authorities in the

Member States:

o Qualified trust

Issuance of digital

credentials

Data

Digital public

service

33 In the case of traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 10 % for collection

costs, as proposed in COM(2025)574.

EN 27 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Digital Identity Wallet as:

• Qualified Electronic

Attestation of Attributes in

accordance with Article 45(d)

of Regulation (EU) No

910/2014;

• An electronic attestation of

attributes issued by or on

behalf of a public sector body

responsible for an authentic

source in accordance with

Article 45(f) in that

Regulation.

Digital qualification attestations shall

be issued in one or more official

languages of the Union of their choice

plus a mutually‑agreed common

language.

service providers

as defined in

Article 3, point 20

of Regulation (EU)

No 910/2014;

o Public sector

bodies responsible

for an authentic

source or other

entities acting on

their behalf.

Process

digitalisation &

automation

Digital solution

Article 3 (4)

Member States should transmit to the

Commission up‑to‑date lists of

awarding bodies, accreditations and

qualifications (covering the previous

ten years).

Member States

European Commission

Preparation, updating and

transmission of trusted lists

Data

Process

digitalisation &

automation

Digital solution

EN 28 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 3 (5)

Holders of qualifications must be able

to retrieve digital qualification

attestations electronically free of

charge upon their application for such

attestations.

EU citizens and EU

residents (Qualification

holders)

Identity check/matching of

wallet holder

Provision of the credential

(free, electronic)

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

Article 3 (6)

The Commission shall adopt

implementing acts laying down

detailed provisions concerning the

agreed common language; formats and

protocols for the issuance of digital

qualification attestations across the

Union; and the formats of and transfer

protocols for the lists of awarding

bodies, accreditations and

qualifications included in national

qualifications frameworks. Those

implementing acts shall be adopted in

accordance with the examination

procedure referred to in Article 15(2)

Member States

European Commission

Issuance of digital

credentials

Exchange of information:

lists of awarding bodies,

accreditations and

qualifications included in

the NQF

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

Article 4 (1‑3) Member States must evidence

qualifications by means of digital

qualification attestations that meet

Issuing authorities in the

Member States

Identity check/matching of

wallet holder

Issuance of digital

Data

Digital public

EN 29 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

the Union‑wide standard

specifications (Annex I).

Digital attestations shall comply with

the data fields specifications laid down

in Annex I, except for digital

qualification attestations issued in

accordance with Article 9.

Digital qualification attestations shall

constitute evidence of qualifications

awarded to the holder and shall be

valid across the Union.

Awarding bodies

EU citizens and EU

residents (Qualification

holders)

credentials

Qualifications are quality

assured as part of a Member

State’s National

Qualifications Framework

service

Process

digitalisation &

automation

Digital solution

Article 4(4‑5)

From [entry into force plus 36

months], Member States shall ensure

that digital

qualification attestations are issued

without delay upon request of the

qualification holder as the default

format for evidencing

qualifications which meet the

following conditions:

(a) they are part of a

Member State’s

national qualifications

framework;

Issuing authorities in the

Member States

Awarding bodies

EU citizens and EU

residents (Qualification

holders)

Identity check/matching of

wallet holder

Issuance of digital

credentials

Data

Digital public

service

Process

digitalisation &

automation

EN 30 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

(b) they have

been awarded after

[date of entry into force

minus 10 years].

For qualifications awarded between

[date of entry into force minus 10

years] and [date of entry into force],

Member States shall issue digital

qualification attestations upon request

of the qualification holder, to the

extent possible, without delay, and in

any case no later than within two

weeks from receipt of that request.

Article 5 (1)

Digital qualification attestations shall

be issued to the European Digital

Identity Wallets to the holders of

qualifications who meet the following

conditions:

• They have been awarded a

qualification from an awarding

body; and

• They hold an active European

Digital Identity Wallet

• They request the issuance of a

Issuing authorities in the

Member States Awarding

Bodies

EU citizens and EU

residents (Qualification

holders)

Issuance of digital

credentials

Identity check/matching of

wallet holder

Provision of the credential

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

EN 31 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

digital qualification attestation.

This includes re-issuance where the

holder no longer has access to a

previously held attestation.

Article 6 (1‑3)

Digital credentials must be refused,

revoked or suspended when the

underlying qualification has been

withdrawn or suspended in either the

issuing or a receiving Member State

by an awarding body or another

competent authority. The status is

reflected in the verification system

within 24 hours.

The information on revocation and

suspension of digital qualification

attestations should be made available

to relying parties by issuers.

Issuing authorities in the

Member States

Relying parties

EU citizens and EU

residents (Qualification

holders)

Receiving Member States

Decision to refuse issuance

Revocation or suspension

Updating of revocation lists

and making the status

available through the

verification process

Data

Digital public

service

Process

digitalisation &

automation

Article 7 (1‑2)

No later than [entry into force plus 36

months], Member States shall provide

a digital verification tool that enables

relying parties to verify that:

3. the digital qualification

attestation was issued by an

issuer referred to in Article

Relying parties (employers,

regulators, Competent

Authorities etc.)

European Commission

Verification‑software

developers

Credentials verification

process

Development/sharing of

verification tools

Compliance with procedural

rules

Data

Digital public

service

Digital solution

Process

digitalisation &

EN 32 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

3(2);

4. the qualification evidenced by

the digital qualification

attestation was awarded by an

awarding body accredited at

the time of the award;

5. the digital qualification

attestation has not been

tampered with since it was

issued;

6. the digital qualification

attestation has not been

suspended or revoked.

The Commission shall adopt

implementing acts laying down

formats and procedures for

verification by relying parties in

accordance with paragraph 1,.

The implementing acts shall be

adopted in accordance with the

examination procedure referred to in

Article 15(2).

Qualification holders automation

EN 33 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 8 (1)

Member States shall provide

information on the qualifications,

awarding bodies and accreditations to

the Europass online platform in

accordance with:

• a common semantic model laid

down in point 1, of Annex I,

• the minimum requirements

provided in Annex IV,

• for the description of

qualifications, to the extent

possible, making use of skills

terminology from the

European classification of

skills and occupations (ESCO)

based on a mapping between

Member States’ classification

systems and the European

classification.

Member States shall, to the extent

possible, submit updates of this

information in real time and in any

case at least each month.

Member States

European Commission

Comparable information on

qualifications

Data

Digital public

service

Digital solution

Process

digitalisation &

automation

EN 34 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 8 (3-5)

National Qualifications Frameworks

(NFQ) shall include all qualifications

awarded under the jurisdiction of a

Member State and be kept up to date.

To the extent possible, Member States

shall include micro-credentials in their

national qualifications frameworks.

Member States shall use the European

Qualifications Framework (EQF) to

reference national qualifications

frameworks or systems and to

compare all types and levels of

qualifications in the Union that are

part of national qualifications

frameworks or systems, in particular

by referencing their qualification

levels to levels of the European

Qualifications Framework set out in

Annex III.

Member States national

authorities

Qualification providers

Mapping to EQF and

updating NQF registers

Data

Digital public

service

Digital solution

Process

digitalisation &

automation

Article 8 (6)

The Commission shall provide a

digital tool to facilitate an

automated comparison of qualification

s listed in national qualifications

frameworks referenced to

European Commission

National authorities (for the

provision of the data)

Publication of NQFs data

on Europass

Compare two single

qualifications side-by-side

Export the comparison view

Data

Digital solution

Process

digitalisation &

EN 35 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

the European Qualifications

Framework and make it available

through Europass platform.

(for information purposes)

Find an EQF level based on

a qualification title

Compare two national

qualifications frameworks

automation

Article 9 (1‑4)

For qualifications awarded more than

ten years ago, Member States must, on

request, issue a digital credential based

on existing evidence (using eIDAS

(Regulation (EU) 910/2014) Annex VI

or OOTS common services (Single

Digital Gateway Regulation (EU)

2018/1724)) and in accordance with

the Union standard specification.

Member States shall use Union

standard specifications for data fields

laid down in Annex V, for these

digital qualification attestations.

EU citizens and EU

residents (Qualification

holders)

Issuing authorities

Retrieval of historic

evidence

Creation of a digital

credential for legacy

qualifications

Alignment with standard

specification

Data

Digital public

service

Process

digitalisation &

automation

Digital solution

Article 12 (1‑2)

Personal data shall be processed in the

context of this Regulation only in so

far as it is necessary for issuance and

verification of digital qualification

attestations in accordance

with Chapter 2.

Data controllers (issuing

authorities and verifiers)

Data Protection Officers

EU citizens and EU

residents (Qualification

Collection, storage,

retention, and deletion of

personal data related to

credential issuance and

verification

Data

EN 36 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Personal data processed in the

context of this Regulation shall be

retained no longer than [45] years.

holders)

Article 13 (1‑4)

By [[48] months from the date of the

entry into force of this

Regulation], and every

year thereafter, Member States shall

submit to the Commission the

following data concerning the past 12

months:

(a) the number of digital

qualification attestations

issued, revoked and suspended;

(b) the share of qualifications

issued in the form of digital

qualification attestations

among all qualifications

awarded;

(c) the number of relying parties

registered to and requesting access to

digital qualification attestations. By

[48] months from the date of the entry

into force of this Regulation], and

every two years thereafter, Member

National reporting units

European Commission

Evaluation bodies

Data collection for

statistical reporting,

preparation of annual and

biennial reports, and

transmission to the

Commission

Data

Process

digitalisation &

automation

EN 37 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

States shall submit a report to the

Commission on the application of this

Regulation. The report shall include:

(c) the data referred to in paragraph

1;

(d) the information on respective

average processing time of a

request for issuance of a digital

qualification attestation in

accordance with Article 4(5)

and Article 9.

Member States shall collect feedback

from holders of qualifications,

employers, awarding institutions,

issuers, recognition authorities for

regulated professions and other

stakeholders necessary for preparing

the report as laid down in this

paragraph.

The information submitted to the

Commission in accordance

with paragraphs 1 and 2 shall not

include personal data.

By [the same date as the date of

application plus five years], the

EN 38 EN

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Commission shall review and evaluate

the application of this Regulation and

shall present a report to that effect to

the European Parliament and the

Council.

EN 39 EN

4.2. Data

High-level description of the data in scope

Type of data Reference to the requirement(s) Standard and/or specification (if applicable)

Digital qualification attestations Article 3 (1-3)

Article 3 (4-6)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 7 (1‑2)

Article 8 (1)

Article 8 (3-5)

Article 9 (1‑4)

Article 12 (1‑2)

EUDI electronic attestations of attributes, standards

and processes described in Annex I, Annex II,

Annex IV and Annex V.

Revocation/suspension data Article 6 (1‑3) Revocation lists managed by Member States and

made accessible to others

Lists of awarding bodies Article 3 (4)

Article 3 (6)

Article 5 (1)

Article 8 (1-2)

Standards and processes described in Annex IV.

EN 40 EN

List of accreditations Article 3 (4)

Article 3 (6)

Article 5 (1)

Article 8 (1-2)

Standards and processes described in Annex IV.

Lists of current and past 10 years of qualifications

and data on qualifications listed in Member State’s

National Qualifications Frameworks (NQFs)

Article 3 (4)

Article 3 (6)

Article 8 (3-6)

ESCO, EQF, and ISCED classifications should be

used where possible.

Standards and processes described in Annex IV.

Annual statistical summary on numbers of digital

credentials issued/renewed/withdrawn/suspended,

processing times, user experience and stakeholder

feedback.

Article 13 (1‑4)

Personal data of qualification holdersArticle 12 (1‑2) Processed under Regulation (EU) 2016/679

(GDPR); data minimisation and storage limitation

Alignment with the European Data Strategy

Explanation of how the requirement(s) are aligned with the European Data Strategy

In terms of compliance with GDPR, the main roles and responsibilities related to personal data protection are already set out in Article 12.

Qualifications and accreditation data are already made available as Open data on the data.europa.eu portal34. Qualifications, awarding bodies,

and accreditation information does not contain any personal data.

34 https://data.europa.eu/data/datasets/european-learning-data?locale=en

EN 41 EN

The initiative supports the European Data Strategy by making qualification data interoperable, portable and reusable across borders under the

holder’s control.

Digital credentials are stored in the citizen’s EUDI Wallet, which enables selective disclosure and user-controlled sharing, in line with the

Strategy’s objective of empowering individuals over their data.

EN 42 EN

Alignment with the once-only principle

Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored

Reusing the EUDI Wallet framework will guarantee the once only principle, as it will reuse the existing wallet and the accompanying trust

framework.

Reuse of the Europass framework, in particular the Qualification Dataset Register, is foreseen, as this mechanism is already in place for the

publication of accreditation and qualifications in Europass. Furthermore, the Europass qualifications comparison tool will draw upon the

qualifications database, and upon existing functionality within Europass.

Reuse of the European Learning Model (ELM) is planned for semantic interoperability for digital qualification attestations and for information

on qualifications, awarding bodies and accreditation information.

Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

Personal data (including qualifications or information within recognition procedures) is in general not supposed to be findable or reusable.

Interoperability of attestations about qualifications is guaranteed through the use of the EUDI framework and infrastructure and by the

common standards described in the Annexes and the use of a common semantic data model. Such standards will ensure mutual understanding

of the qualifications in cross-border contexts.

Information on national qualifications frameworks will be kept up-to-date by Member States and published on Europass (according to Article

8)

EN 43 EN

Data flows

High-level description of the data flows

Type of data Reference(s) to the

requirement(s)

Actors who

provide the

data

Actors who

receive the

data

Trigger for the

data exchange

Frequency (if

applicable)

Digital Qualification Attestations Article 3 (1-3)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 7 (1-2)

Member States

Issuing

Authorities

Awarding

Bodies

EU Citizen/EU

resident

EU Citizen/EU

resident

Relying Parties

Request from the

EU citizen/EU

resident

Automatic

renewal of

credentials (e.g.

after expiry)

Request from the

relying party (e.g.

during an

application

process)

Lists of awarding bodies Article 3 (4) Member States

National

Authority

European

Commission

Update to the

awarding body

data

Lists of accreditations Article 3 (4) Member States

National

Authority

European

Commission

Update to the

accreditation data

Lists of qualifications and data on

qualifications listed in National

Article 8 (1-2)

Article 8 (3-5)

Member States

National

European

Commission

Update to the

qualifications data

EN 44 EN

Qualifications Frameworks (NQFs) Authority (Europass)

Annual statistical summary on numbers

of digital credentials

issued/renewed/withdrawn/suspended,

processing times, user experience and

stakeholder feedback.

Article 13 (1‑2) Member States

National

Authority

European

Commission

Annually

Revocation/ Suspension data Article 6 (1‑3)

Member State

issuing

authority

Other Member

States / relying

parties

Withdrawal or

suspension event

As it occurs

Comparable information on

qualifications

Article 8 (1-2)

Member States Europass

platform

European

Commission

Updates on the

information on the

qualifications,

awarding bodies

and accreditations

As the update

happens

EN 45 EN

4.3. Digital solutions

High-level description of digital solutions

Digital solution Reference(s) to the

requirement(s)

Main mandated

functionalities

Responsible

body

How is

accessibility

catered for?

How is reusability

considered?

Use of AI

technologies

(if

applicable)

Digital

Qualification

attestations

issuing and

revocation

System

Article 3 (1-3)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 9 (1‑4)

Article 12 (1‑2)

Issuance of digital

credentials to EUDI

Wallets in the form of

EUDI electronic

attestations of attributes.

Retrieval of historic

evidence by embedding

attributes in the body of

the digital credential.

Revocation list

management, and making

such lists available to

Relying Parties

Member States

issuing

authorities

Following

EUDI

specifications

By definition, the

issuing systems will

reuse EUDI

infrastructure

(including EUDI

trust framework and

relevant ETSI

standards) and

specifications

N/A

Digital

Qualification

attestations

Verification

Tool

Article 7 (1-2) Digital verification tool

to ensure that the

relying parties are able to

verify digital

qualification

attestations in accordance

with common minimum

verification requirements

Member States Article 7 (1-

2) requires

Member

States to

implement a

verification

application

suitable for

If deemed useful, the

Commission might

provide a reference

implementation of

the app to be

reused/configured by

Member States, on a

voluntary basis as

N/A

EN 46 EN

and processes use by all

their

qualification

holders.

described in the

supporting measures

(and Recital 16)

Europass System Article 8 (1)

Article 8 (6)

Storing data on

qualifications, awarding

bodies and

accreditations.

Presenting the

information on

qualifications and

accreditations.

Qualifications

information is also used

in the Europass

comparison of single

qualification tool.

In order to fully support

the SPI, the following

developments must be

carried out:

1. Support for an

awarding body

registry

2. Versioning, and

timestamping of

qualifications and

accreditations

3. Improving

European

Commission and

Member States

(data providers)

Built on

existing

Europass

tools which

already

follow Web

Content

Accessibility

Guidelines

(WCAG) 2.1

Enhancement of

existing Europass

tools

N/A

EN 47 EN

performance and

scalability

4. Adaptations

following ELM

modifications

Enhancement of the

existing qualifications

comparison tool

functionality to include:

1. Mechanism to

determine the

EQF level of a

given

qualification and

export it

Search for similar

national qualifications in

other MSs

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

EN 48 EN

Digital Qualification attestations issuing and revocation System

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act It is not foreseen to create or use any AI systems for this solution.

EU Cybersecurity framework All issuance protocols will be compliant with EUDI protocols and standards for the

digital attestation format.

No additional cybersecurity requirements will be added by the regulation.

eIDAS Since the issuing systems need to issue EUDI attestation, they need to rely on

specifications set out in EUDI regulation (by definition compliant with eIDAS).

Single Digital Gateway and IMI The Once Only Technical System can be leveraged for confirming information to

be included in a digital qualification attestation and for issuers to identify the

authentic source.

GDPR (Reg. 2016/679) Processing of personal data is limited to what is necessary for issuance (article 13);

data minimisation and storage limitation apply.

Others N/A

EN 49 EN

Digital Qualification attestations Verification Tool

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act It is not foreseen to create or use any AI systems for this solution.

EU Cybersecurity framework All verification protocols will be compliant with EUDI protocols and standards for

the digital attestation format.

No additional cybersecurity requirements will be added by the regulation.

eIDAS The verification of EUDI digital attestation will be compliant with EUDI protocols

and standards, based on eIDAS.

Single Digital Gateway and IMI No interface with the Single Digital Gateway or IMI foreseen.

Others N/A

Europass

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act It is not foreseen to create or use any AI systems for this solution.

EU Cybersecurity framework No new specific cybersecurity requirements mandated by the regulation.

eIDAS N/A

Single Digital Gateway and IMI N/A

EN 50 EN

GDPR (Reg. 2016/679) Europass publishes NQF/Qualification metadata, not personal data of individual

holders.

Others N/A

EN 51 EN

4.4. Interoperability assessment

High-level description of the digital public service(s) affected by the requirements

Digital public service or

category of digital public

services

Description Reference(s) to the

requirement(s)

Interoperable

Europe Solution(s)

Other interoperability

solution(s)

Digital Qualification

attestations issuing and

revocation service

Service provided by Member

States issuing authorities to

issue digital credentials for

qualifications to citizens.

Service provided under the

EUDI Wallet framework and

implemented by the Member

States issuing authorities to

revoke or suspend a credential

when the underlying

qualification has been

withdrawn or suspended in

either the issuing or a

receiving Member State.

Qualification life-event

procedure and Digital

Credentials output added to

the Single Digital Gateway

Article 3 (1-3)

Article 4 (1‑5)

Article 5 (1)

Article 6 (1‑3)

Article 9 (1‑4)

Article 16

N/A EUDI Wallet, EUDI trust

framework, EQF alignment,

European Learning Model35

Your Europe and the Single

Digital Gateway

Digital Qualification

attestations verification

Service provided by relying

parties in the Member States

(employers, regulators, etc.)

Article 7 (1‑2)

N/A EUDI trust framework, ELM,

Reference Implementation of the

verification service (Recital 16

35 ELM was CAMSS assessed: https://interoperable-europe.ec.europa.eu/collection/common-assessment-method-standards-and-specifications-camss/solution/camss-

assessment-elm-eif-scenario

EN 52 EN

service to accept and verify digital

credentials

(Reference to section 4.5:

Measures to support digital

implementation))

Publication of National

Qualifications data service

(Europass and EU open

data portal)

Service provided by the

European Commission (on

Europass and EU Open Data

portal)

Article 3 (4)

Article 8 (3-6)

N/A European Learning Model

EN 53 EN

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

Digital Qualification attestations issuing and revocation system

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

Alignment with existing digital and

sectorial policies

Please list the applicable digital and

sectorial policies identified

Issuance:

• EUDI Regulation for the issuing of digital

credentials which will require an

amendment to the ETSI profiles to

support W3C VCDM.

• Skills Portability Initiative Regulation

• SDG Regulation

Revocation:

• EUDI Regulation

• Skills Portability Initiative

N/A

Organisational measures for a

smooth cross-border digital public

services delivery

Please list the governance measures

foreseen

Issuance:

• Registration of issuers in the EUDI trust

framework to be recognised as an

authorised issuer

• Communication to the Commission of list

of lists of awarding bodies, accreditations

and qualifications, and publication on

Qualifications Digitalisation Group

Revocation:

Governance: separate and binding roles (the

issuer refuses issuance, revokes or suspends,

and maintains the information; relying parties

N/A

EN 54 EN

across the Union must refuse validity), with

the conditions for recovery of the

qualification left to the awarding Member

State – a national decision with Union-wide

effect.

Management: a cross-border

status/revocation service making the

information accessible within 24 hours of the

request, with a record of revocation and

suspension statuses, a distinction between

permanent and temporary states, and a re-

issuance workflow conditional on

verification of national requirements.

Measures taken to ensure a shared

understanding of the data

Please list such measures

• Data specifications described in Annex I

II, IV and V

• CAMMS assessment performed on the

ELM model

• A publicly available ELM Browser which

precisely describes the ontology, all the

application profiles, and properties.

• Futurium peer exchange group for ELM

N/A

Use of commonly agreed open

technical specifications and

standards

• Technical specifications described in

Annex I, II, IV and V.

N/A

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) 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 SWD(2026) 992 final

COMMISSION STAFF WORKING DOCUMENT

SUBSIDIARITY GRID

Accompanying the document

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

{SWD(2026) 994 final}

1

Subsidiarity Grid

1. Can the Union act? What is the legal basis and competence of the Unions’ intended action?

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative?

The proposal is based on Article 46 TFEU which provides 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, among several elements, 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).

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in nature?

The initiative concerns the functioning of the internal market, which is 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.

Subsidiarity does not apply for policy areas where the Union has exclusive competence as defined in Article 3 TFEU1. It is the specific legal basis which determines whether the proposal falls under the subsidiarity control mechanism. Article 4 TFEU2 sets out the areas where competence is shared between the Union and the Member States. Article 6 TFEU3 sets out the areas for which the Unions has competence only to support the actions of the Member States.

2. Subsidiarity Principle: Why should the EU act?

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 24: - Has there been a wide consultation before proposing the act? - Is there a detailed statement with qualitative and, where possible, quantitative indicators

allowing an appraisal of whether the action can best be achieved at Union level?

The preparation of the initiative was supported by extensive stakeholder consultation activities to gather a broad and representative evidence base on the portability of skills and qualifications across EU Member States. The stakeholder consultations showed that labour market actors lack a sufficient understanding of qualifications from other Member States to assess what the holder’s knowledge or skills. They expressed broad support for improving the availability and interoperability of qualifications information, in particular where these help make skills more visible, portable and verifiable. In addition, digitalisation through the use of verifiable digital credentials in the EUDI Wallets was strongly supported. In this context, stakeholders also supported the need to build on existing EU tools such as the European Qualifications Framework.

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN 2 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN 3 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML 4 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN

2

These consultations, the Commission's assessment of how they have been reflected in the proposal, and the explaination of why the proposed actions can best be achieved at Union level are summarised in the explanatory memorandum accompanying the draft legal act and further detailed in the impact assessment supporting the proposal.

2.2 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the conformity with the principle of subsidiarity?

The explanatory memorandum and impact assessment provide a clear justification demonstrating the conformity of the proposal with the subsidiarity principle.

Barriers related to the portability of qualifications and skills are one of the factors hindering individuals to make full use of their free movement rights and to work in another Member State. Without an EU-level action aimed at improving information on qualifications and skills obtained in other Member States and providing tools facilitating effectively the portability of such qualifications and skills, businesses and workers will continue to face difficulties when considering opportunities across the EU.

Given the cross-border nature of the 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 avoiding fragmentation and reducing administrative burdens by facilitating the cross-border use and recognition of digital qualifications attestations, without prejudice to Member States’ competence for education and training.

An EU-level action creating a common legal and technical framework underpinning the digitalisation of qualifications will allow digital qualifications attestations issued in any Member State to become more trustworthy and easier to verify for employers and, in case of regulated professions in accordance with Directive 2005/36/EC, recognition authorities in different Member States. Digital qualification attestations issued in a standardised manner will be better understood across the EU. This in turn can make job applications less cumbersome and facilitate smoother access to jobs in all Member States.

The EU-level 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 Wallet framework – the EU-level action can help 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. The EU-level action at this stage will help ensure coordinated and interoperable solutions across Member States, while ensuring alignment with existing EU initiatives. Acting now will 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.

2.3 Based on the answers to the questions below, can the objectives of the proposed action be achieved sufficiently by the Member States acting alone (necessity for EU action)?

(a) Are there significant/appreciable transnational/cross-border aspects to the problems being tackled? Have these been quantified?

3

(b) Would national action or the absence of the EU level action conflict with core objectives of the Treaty5 or significantly damage the interests of other Member States?

(c) To what extent do Member States have the ability or possibility to enact appropriate measures?

(d) How does the problem and its causes (e.g. negative externalities, spill-over effects) vary across the national, regional and local levels of the EU?

(e) Is the problem widespread across the EU or limited to a few Member States?

(f) Are Member States overstretched in achieving the objectives of the planned measure?

(g) How do the views/preferred courses of action of national, regional and local authorities differ across the EU?

The problems addressed by the proposal have a strong cross-border dimension by nature, as they relate to the use of qualifications and skills in other Member States than the one in which they were awarded. In this context, the problem is widespread across the EU, with border regions- where businesses rely more than elsewhere on daily or seasonal cross-border mobility of workers - being particularly affected. Differences in the format, content, classification and verification of qualifications affect their use across Member States.

The digitalisation of qualifications will facilitate their portability across the EU only if it is carried out in a harmonised and interoperable way across Member States. Solutions implemented at the level of a single country may not ensure the full benefits for the Single Market but rather deepen its fragmentation. While Member States can improve their national systems, they cannot individually ensure cross-border interoperability, common verification arrangements and mutual reliance on digital qualifications. Coordinated action at the EU level can help ensure that labour market actors have access to reliable and comparable information on skills and qualifications issued in the EU and can benefit from interoperable and verifiable digital attestations of qualifications and skills.

The proposal nevertheless allows for flexibility in the implementation to take account of Member States’ differences, in particular for older qualifications. While Member States will, to the extent possible, provide the same level of content description for newly awarded qualifications and use the same trust framework, for qualifications issued in the past 10 years, some flexibility will be allowed through optional data fields. Moreover, for older qualifications, automatic issuance would not be required, and issuance within a reasonable time on demand with fewer mandatory data fields would allow Member States to take account of the time needed to retrieve and verify the relevant information.

Currently, important differences between Member States exist in relation to updating the referencing of their national qualifications frameworks to the European Qualifications Framework (EQF), the state of play of national qualifications databases and the sharing of qualifications information with the EU-level platform, Europass. Furthermore, Member States are at different levels of readiness regarding digital infrastructures and the rollout of digital credentials. Although Member States are yet to use the EUDI Wallets, the requirements for digital attestations of qualifications still need to be laid down in sectoral legislation. The proposal contains measures ensuring that there is a balanced situation across Member States regarding the availability of comparable information on qualifications, which is also required to have a qualifications comparison

5 https://europa.eu/european-union/about-eu/eu-in-brief_en

4

tool in place that contains information on national qualifications framework qualifications from across the EU.

The proposal is also timely because the EUDI Wallets will come into application at the end of 2026: the EUDI framework regulates and harmonises the issuance of attestations via a trust service and public bodies, which can include education and training credentials. Moreover, some Member States have already introduced or announced the possibility to request electronic qualifications under their jurisdiction. To avoid a situation where digitalised qualifications cannot be relied on in other countries due to a lack of interoperability, it is timely for the Union to act by adopting common standards for digital qualifications across the EU. A transitional period requiring an initial investment, and support to Member States in their implementation of issuance systems for the digital qualification attestations aims to create a situation of comparable conditions in Member States.

Finally, the free movement of people is a fundamental principle of the European Union. To fully benefit from this right, individuals must be able to rely on the qualifications awarded in any Member State when they apply for, take up or pursue a professional occupation in another Member State. The digitalisation of qualifications will facilitate their portability across the EU. In the absence of an EU-level action, there is a risk that differences between Member States will deepen, further exacerbating existing obstacles (as Member States continue to rely on paper-based or fragmented digital systems when issuing qualifications) and there will be different situations across Member States with regard to the available and comparable information on qualifications.

2.4 Based on the answer to the questions below, can the objectives of the proposed action be better achieved at Union level by reason of scale or effects of that action (EU added value)?

(a) Are there clear benefits from EU level action?

(b) Are there economies of scale? Can the objectives be met more efficiently at EU level (larger benefits per unit cost)? Will the functioning of the internal market be improved?

(c) What are the benefits in replacing different national policies and rules with a more homogenous policy approach?

(d) Do the benefits of EU-level action outweigh the loss of competence of the Member States and the local and regional authorities (beyond the costs and benefits of acting at national, regional and local levels)?

(e) Will there be improved legal clarity for those having to implement the legislation?

The proposal provides clear EU added value as only a common approach will ensure that digital qualifications can be used, verified and relied upon across Member States, rather than requiring separate national solutions and arrangements. The EU-level action will provide common technical, interoperability and trust arrangements and build on existing EU investments and infrastructure, including the Single Digital Gateway, the Once Only Technical System and the EUDI framework. It will also improve the functioning of the internal market by avoiding fragmentation and reducing administrative burden and costs associated with different national approaches, thereby introducing economies of scale.

5

At the same time, the proposal respects Member States’ competence for education and training: Member States retain responsibility for determining qualifications, their content and their national qualifications frameworks, as well as the organisation of their education and training systems, while the common framework covers their digital portability, verification and interoperability, and measures for the provision of comparable information on qualifications, including through a new qualifications comparison tool. The common framework will provide greater legal certainty for Member States, issuers, employers, workers and other actors using digital qualification attestations across borders and having a better overall access to information on qualifications and skills. Overall, the benefits of a coordinated EU approach in terms of interoperability, economies of scale and greater portability of qualifications outweigh the limited constraints arising from common requirements for their digitalisation.

3. Proportionality: How the EU should act

3.1 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the proportionality of the proposal and a statement allowing appraisal of the compliance of the proposal with the principle of proportionality?

As underlined in the explanatory memorandum accompanying the Commission’s proposal, the proposal is necessary and proportionate to the objective of facilitating the portability of qualifications and skills between Member States, ensuring that they provide a consistent and reliable indication of the skills and qualifications 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 skills and qualifications issued in the EU. Without such common requirements, Member States would continue to rely on paper-based or fragmented digital systems when issuing qualifications.

The proposal does not go beyond what is necessary to achieve the objectives of ensuring an improved portability of skills and qualifications 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 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. Member States may limit the issuance of digital attestations for older qualifications to the cases where it is requested for the purpose of pursuit 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 at a later stage. Data availability is expected to be high for this ten-year period since it coincides with the time after adoption of the Council Recommendation on a European Qualifications Framework (EQF) in which archives tend to be already digital. Indeed, 25 EU Member States have had their NQFs referenced to the EQF for ten years or more. However, going further back would mean reviewing qualifications from before these frameworks existed, requiring substantially more effort. Conversely, a shorter cut-off would not proportionally reduce Member States' effort, since the core verification and mapping tasks remain largely fixed regardless of the period covered. Ten years therefore offers a proportionate balance between comprehensiveness and administrative burden. In terms of policy impact, it allows for a rapid rollout for the younger cohorts who tend to change jobs most frequently and are most likely to move to another Member State.

6

For qualifications obtained more than 10 years ago, digital qualification attestations need to be issued within a reasonable timeframe i.e. maximum two weeks. In addition, for such older qualifications, the data fields need be adapted whereby Member States need to provide the certain degree of minimum information, with some other data fields being optional. Overall, only minimum common requirements are provided for digital qualification attestations. By relying on existing EU frameworks, in particular the EUDI Wallet framework and existing transparency tools such as the EQF, the proposal complies with the principle of proportionality.

3.2 Based on the answers to the questions below and information available from any impact assessment, the explanatory memorandum or other sources, is the proposed action an appropriate way to achieve the intended objectives?

(a) Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on their own, and where the Union can do better?

(b) Is the form of Union action (choice of instrument) justified, as simple as possible, and coherent with the satisfactory achievement of, and ensuring compliance with the objectives pursued (e.g. choice between regulation, (framework) directive, recommendation, or alternative regulatory methods such as co-legislation, etc.)?

(c) Does the Union action leave as much scope for national decision as possible while achieving satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum standards or use a less stringent policy instrument or approach?)

(d) Does the initiative create financial or administrative cost for the Union, national governments, regional or local authorities, economic operators or citizens? Are these costs commensurate with the objective to be achieved?

(e) While respecting the Union law, have special circumstances applying in individual Member States been taken into account?

The proposed action is limited to aspects that require EU-level intervention, namely establishing a common framework and set of standards for digital qualification attestations that are understood, trusted, verifiable and interoperable across the Union and for the provision of comparable information on qualifications, including through a new qualifications comparison tool, while leaving Member States responsible for the organisation of their education and training systems and for determining the content and award of qualifications. Given the cross-border nature of the problem and the need to prevent regulatory fragmentation, a regulation is considered the most suitable, effective and proportionate instrument. As a directly applicable act, it ensures uniform application, legal certainty and a common set of rules and formats across Member States, in line with the identified legal basis. At the same time, the proposal leaves flexibility for national implementation, including regarding the organisation of national issuing systems and the information available for older qualifications, while common requirements are limited to what is necessary to ensure interoperability and trust. The proposal entails costs for the Union, principally related to the development and improvement of the Europass comparison tool, the reference software for digital verification, the back-office tool supporting Member States in sharing information on qualifications, governance, communication and awareness raising activities and implementation support to Member States. Member States will incur costs related to establishing and maintaining national qualification registries, integrating

7

qualifications issued over the previous ten years into the trust framework, deploying the national verification infrastructure required for the EUDI Wallet ecosystem and adapting national issuing systems. These costs are considered proportionate to the objectives pursued, as a common framework avoids the higher costs and administrative burdens associated with developing and aligning separate national solutions. Finally, the proposal is designed to apply across the Union while allowing for differences in national systems and levels of readiness, including through flexibility in the implementation of the requirements for older qualifications.

EUROPEAN COMMISSION

24.08.2026

SEC(2026) 992

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 992}

{SWD(2026) 992-994}

Impact assessment accompanying a proposal to facilitate worker mobility through improved transparency of skills and qualifications and digitalisation (Action 1 – Skills Portability Initiative)

________________________________ Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111

[email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment accompanying a proposal to facilitate worker

mobility through improved transparency of skills and qualifications and

digitalisation (Action 1 – Skills Portability Initiative)

Overall 2nd opinion: POSITIVE WITH RESERVATIONS

(A) Policy context

The initiative is part of the broader Skills Portability Initiative (SPI), which comprises

three complementary actions: improving availability of reliable, comparable and

verifiable digitalised information on qualifications and skills in the EU (action 1);

modernising and expanding the recognition of qualifications for access to regulated

professions (action 2); improving the recognition of qualifications and skills for third-

country nationals (action 3).

The aim of this action therefore is to make qualifications easier to understand and verify

for labour market actors across the Single Market and facilitate comparison of the level

and content of qualifications issued in the EU. It will notably do so by requiring

digitalisation of qualifications and giving a legal value to digital credentials.

(B) Summary of findings

The Board notes the improvements to the quality of the report. However, the report

still contains significant shortcomings. The Board gives a positive opinion with

reservations because it expects the DG to rectify the following aspects:

(1) The preferred option is not clearly defined regarding the ‘automatic issuance on

demand for the purpose of the employment in another Member States’ of

qualifications issued over the last ten years.

(2) The analysis of costs and cost savings is not clear, including regarding the

baseline as well as in relation to the digitalisation of qualifications issued in past

ten years under the preferred option. The report does not sufficiently explain

some of the key assumptions and the resulting uncertainties.

2

(C) What to improve

(1) Based on the Europass and EQF evaluations, the report should provide more

information on the use of existing tools and systems (Europass, ESCO) across Member

States and the underlying reasons for the diverse take up. The rationale for leaving out

upper secondary schools should be substantiated reflecting the evidence related to the

practices of labour market actors in different Member States. The report should explain

what share of qualifications in the scope, i.e. EQF 2 to 8, will not be covered by the

initiative and it should analyse related consequences.

(2) The report should more precisely describe the baseline and the main elements of the

preferred option, specifically regarding the digitalisation of qualifications issued in the

past ten years as well as the trust framework. It should be clear and granular enough on

which elements (including IT systems, registries, and data needed for records of

individuals) are part of the baseline and which ones are new mandatory elements

introduced by the proposed initiative, notably for Member States and for issuers. The

report should be clearer on existing gaps or delays in relation to the implementation by

MS of elements relating to other initiatives and belonging to the baseline, which are

nonetheless critical to the success of this initiative. The impact of the preferred option on

all affected issuers in national systems should be better analysed including the related

costs. The report should provide a clearer analysis of the distribution of the costs between

the private sector and public administrations as well as the differences between MS.

(3) The estimates of key parameters used for the calculation of costs and cost-savings

should be substantiated with appropriate evidence, in particular related to the digitalisation

of past qualifications to allow for an automatic issuance and the marginal costs of manual

and automatic issuance under the different options. The choice of parameters for the cost

savings quantification tables in Annex 4, in particular for how the 10-year backlog was

incorporated in this calculation, should be better explained and reflected in the main report

to the extent that it has an impact on the cost and cost saving estimates. The report should

be clear which samples used to derive input parameters are representative. For example,

the extrapolation used to quantify the costs for including micro-credentials under PO1 and

PO3, based on a survey of 69 issuers (to arrive at a total number of 45,000 providers),

seems to be based on a non-representative sample. The report should discuss the

uncertainties related to the input parameters and their impact on the calculations.

(4) The coherence of this initiative with existing legislation and/or voluntary initiatives,

in particular in the field of digitalisation, should be further developed, with a view to

clarifying what this initiative will add to elements which are already underway under those

other initiatives.

(5) The monitoring and reporting framework should provide more information on how

data would be collected, in particular for monitoring the impact indicators.

3

(D) Conclusion

The lead Service(s) may proceed with the initiative.

The lead Service(s) must revise the report and its executive summary in accordance

with the Board’s findings before launching the interservice consultation.

Full title Impact Assessment Report accompanying a Legislative Proposal

to facilitate worker mobility through improved transparency of

skills and qualifications and digitalisation. Action 1 under the

Skills Portability Initiative.

Reference number PLAN/2025/2641

Submitted to RSB on 7 August 2026

Date of RSB meeting Written Procedure

4

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment accompanying a proposal to facilitate worker

mobility through improved transparency of skills and qualifications and

digitalisation (Action 1 – Skills Portability Initiative)

Overall opinion: NEGATIVE

(A) Policy context

The Skills Portability Initiative comprises three complementary actions: (i) to facilitate

worker mobility across the EU through skills transparency and digitalisation (Action 1); (ii)

to modernise and expand the recognition of qualifications for access to regulated professions

(Action 2); and (iii) to improve the recognition of qualifications and skills of third-country

nationals (Action 3).

The aim of Action 1 is twofold. First, it aims to provide legal clarity on how to treat

qualifications and skills obtained in another EU Member State in non-regulated professions,

by requiring the use of European Qualifications Framework (EQF) levels in job postings

across the EU and adopting the legal presumption of equivalence. Second, Action 1 should

improve the availability of information on qualifications and skills obtained in the EU, which

is relevant for regulated and non-regulated professions, by requiring digitalisation of

qualifications and giving a legal value to digital credentials.

(B) Key issues

The Board notes the additional information provided.

However, the Board gives a negative opinion because the report contains the following

serious shortcomings that the lead Service must address:

(1) The report does not demonstrate the proportionality of preferred option.

(2) The report does not sufficiently demonstrate the problems to be tackled, their root

causes and their magnitude, building on appropriate evidence-base. The

intervention logic is not substantiated. The report does not establish that an

obligation to refer to EQF levels in labour market contexts can effectively support

the free movement of workers in the EU.

(3) The report does not sufficiently describe the dynamic baseline, including existing

digital tools and projects under development, and their expected effects. The

5

definition of some policy measures is not sufficiently clear for the purposes of

assessing their impacts.

(4) The coherence of this initiative with the other SPI actions as well as with other

legislation and initiatives in the field of labour, skills and qualification is not

sufficiently assessed.

(C) What to improve

(1) Based on an improved evidence-base and building on recent evaluations, including on

the EQF and Europass, the problem definition should demonstrate the direct

contribution of obstacles related to the skills and qualification portability to EU workers’

mobility and the scale of the problems that the initiative aims to address. It should

demonstrate to what extent the lack of understanding of non-national qualifications

plays a role in the workers’ and employers' decisions and to what extent fraud is

pervasive and hence constitutes an issue in relation to proof of qualification in the labour

market context.

(2) The report should consider how the findings of the EQF and Europass evaluations affect

the design of the measures and the potential impacts. In particular, the report should

assess to what extent the EQF can be considered an effective tool for facilitating

recruitments, considering that the EQF evaluation found that effects on employability,

mobility and social integration of workers and learners were less tangible. The relevant

evidence should be reflected in the intervention logic.

(3) The report should improve the description of the dynamic baseline, explaining better the

current situation, practices in Member States related to the use of qualifications

including the practise related to qualifications in job postings. For example, to the extent

possible, the report should provide an estimation of the share of job advertisements

referring to qualifications, which would be affected by the obligation to refer to EQF

levels, in large companies and SMEs. The report should describe relevant existing

initiatives, tools and projects to support labour mobility (e.g. EQF, NQF, Europass and

its certificate supplement, ESCO), including IT ones (DC4EU, EUDI Wallet etc.). It

should also provide a clear overview of the situation in Member States regarding both

the various types of different organisations and practices for issuing qualifications and

the different levels of readiness of issuers for issuing qualifications digitally,

distinguishing the qualifications issued in the past and the qualifications to be issued in

the future. It should also provide a deeper analysis on how AI-enabled solutions could

address the identified problems and/or their drivers.

(4) The report should explain the content of the options more precisely and describe how

the measures would work in practice. It should also clearly demonstrate the expected

outputs, outcomes and impacts of the proposed measures, considering the evidence base.

It should clarify whether the proposal will include supporting non-legislative measures.

(5) The costs and benefits analysis should be revised. The main report should provide a

transparent overview of the assumptions that drive the results, their rationale and

corroborating evidence, their limitations and uncertainties. It should be clear and

consistent throughout the report and its annexes as to whether cost and savings allocated

to employers include public and private entities. The report should consider recurrent

6

costs affecting employers. The report should be clear on how many entities would be

impacted under each option over the assessment period and to what extent. The report

should provide robust analysis of costs for issuers, allowing to establish the costs to

different types of issuers. Any efficiency gains estimate for enterprises as well the

increased productivity due to reduced mismatch and higher mobility should be

substantiated.

(6) The report should better justify the proportionality of the preferred option which includes

a legal presumption of equivalence; mandating the systematic inclusion of the EQF

levels in labour market situations and requiring the digitalisation of all newly issued

qualifications and those issued in the past 10 years that are part of MS NQF. The report

should assess a sufficient range of options to allow for demonstrating proportionality.

(7) The analysis of the interplay between this action and the other actions of the Skills

Portability Initiative, in particular Action 2 should be reinforced, including as regards

digital aspects. The report should also further develop the analysis of the coherence of

this initiative with on-going projects and initiatives both in the field of the Skills and

qualifications on the EU labour market or in relation to the EU digital strategy

(e.IDAS.2.0, Interoperability regulation).

(8) The report should present better how the stakeholders views have informed the design

and the analysis of the measures.

Some more technical comments have been sent directly to the author Service.

(D) Conclusion

The lead Service must revise the report and its executive summary in accordance with

the Board’s findings and resubmit it for a final RSB opinion.

Full title Impact Assessment Report accompanying a Legislative Proposal

to facilitate worker mobility through improved transparency of

skills and qualifications and digitalisation. Action 1 under the

Skills Portability Initiative.

Reference number PLAN/2025/2641

Submitted to RSB on 17 June 2026

Date of RSB meeting 15 July 2026

Electronically signed on 24/08/2026 12:36 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 993 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

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 final} - {SEC(2026) 992 final} - {SWD(2026) 992 final} - {SWD(2026) 994 final}

i

Table of contents

1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT ......................................................... 6

1.1. Overall context of the Skills Portability Initiative and the Fair Labour

Mobility package ............................................................................................. 6

1.2. Coherence of the package ............................................................................... 8

2. PROBLEM DEFINITION ................................................................................................................ 10

2.1. Background .................................................................................................... 10

2.2. What is the problem? .................................................................................... 13

2.3. What are the problem drivers? .................................................................... 17

2.4. How likely is the problem to persist? .......................................................... 26

3. WHY SHOULD THE EU ACT? ...................................................................................................... 28

3.1. Legal basis ...................................................................................................... 28

3.2. Subsidiarity: Necessity of EU action ............................................................ 28

3.3. Subsidiarity: Added value of EU action ...................................................... 28

4. OBJECTIVES: WHAT IS TO BE ACHIEVED? ........................................................................... 29

4.1. General objective ........................................................................................... 29

4.2. Specific Objectives ......................................................................................... 30

5. WHAT ARE THE AVAILABLE POLICY OPTIONS? ................................................................ 30

5.1. What is the baseline from which options are assessed? ............................. 30

5.2. Description of the Policy Options ................................................................ 37

5.3. Options discarded at an early stage ............................................................. 47

5.4. Intervention logic ........................................................................................... 47

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ..................................................... 48

6.1. Economic impacts .......................................................................................... 48

6.2. Social impacts ................................................................................................ 66

6.3. Environmental impacts ................................................................................. 68

7. HOW DO THE OPTIONS COMPARE? ........................................................................................ 68

7.1. Effectiveness ................................................................................................... 69

7.2. Efficiency ........................................................................................................ 70

7.3. Coherence ....................................................................................................... 71

7.4. Overall comparison of Policy Options ......................................................... 73

8. PREFERRED OPTION .................................................................................................................... 73

8.1. Summary of cost and benefits for the preferred Policy Option ................ 74

8.2. Application of the ‘one in, one out’ approach ............................................ 75

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ............................ 75

ANNEX 1: PROCEDURAL INFORMATION ........................................................................................ 77

1. Lead DG, Decide Planning/CWP references .............................................. 77

2. Organisation and timing ............................................................................... 77

3. Consultation of the Regulatory Scrutiny Board ......................................... 78

ii

4. Evidence, sources and quality ...................................................................... 87

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ........................................... 89

1. Consultation strategy .................................................................................... 89

2. Results of the consultation strategy ............................................................. 91

3. Summary overview of results ....................................................................... 99

ANNEX 3: WHO IS AFFECTED AND HOW? ..................................................................................... 101

1. Practical implications of the initiative ....................................................... 101

2. Summary of costs and benefits ................................................................... 101

3. Relevant Sustainable Development Goals ................................................. 104

ANNEX 4: ANALYTICAL METHODS ................................................................................................. 106

1. For the calculations of all the costs and the calculations cost-savings

for employers: The SPI Marginal Cost Model ......................................... 106

2. For the calculations of cost-savings for workers and issuers of

qualifications ................................................................................................ 121

ANNEX 5: COMPETITIVENESS CHECK ........................................................................................... 126

1. Overview of impacts on competitiveness ................................................... 126

2. Synthetic assessment ................................................................................... 126

3. Competitive position of the most affected sectors .................................... 127

ANNEX 6: SME CHECK ......................................................................................................................... 128

1. Overview of impacts on SMEs ................................................................... 128

ANNEX 7: EXPLANATION OF MAIN EU TOOLS SUPPORTING SKILLS PORTABILITY ..... 131

1. Policies and tools for improving transparency and portability of

qualifications and skills ............................................................................... 131

2. Policies and tools for assessment and recognition of qualifications and

skills for the purpose of employment ......................................................... 134

3. Instruments and legislation facilitating interoperable digitalisation of

qualifications ................................................................................................ 135

ANNEX 8: MAPPING OF INFORMATION PER MEMBER STATE ............................................... 139

1. Purpose of this Annex ................................................................................. 139

2. TABLE 1 - Non-regulated professions ...................................................... 141

3. TABLE 2 - Digital credentials .................................................................... 145

4. TABLE 3 - EQF/NQF architecture ........................................................... 151

5. Member-State Readiness for Digital Qualification Issuance .................. 157

6. TABLE 5 - Provisions in collective agreements in MS related to

qualifications ................................................................................................ 165

7. MS Education Providers - VET institutions and HE institutions ........... 171

8. MS: Annual Issuance Attestation Volume ................................................ 174

ANNEX 9: POLICY OPTIONS DISCARDED AT AN EARLY STAGE............................................ 177

ANNEX 10: DRAFT MONITORING FRAMEWORK ........................................................................ 179

Table 1: Proposed output and result indicators ............................................. 179

Table 2: Proposed impact indicators ............................................................... 180

iii

ANNEX 11: VISUALS FOR DIGITAL IMPLEMENTATION AND OVERVIEW OF THE

CONTENT OF A DIGITAL QUALIFICATION UNDER SPI .................................................. 182

1. Overview of an example of an education and training provider issuing

a digital qualification .................................................................................. 182

2. Overview of an example of an EU jobseeker using their qualification to

apply for a job in another EU Member State ........................................... 182

3. Overview of an example of an employer requesting and verifying a

digital qualification from another Member State .................................... 183

4. Data elements for a digital qualification awarded after SPI (all POs)

and in the past 10 years (PO2) ................................................................... 185

5. Data elements for a digital qualification awarded before SPI (all POs) 188

ANNEX 12: LIST OF TABLES, FIGURES AND DIAGRAMS IN THE MAIN TEXT OF THE

IMPACT ASSESSMENT ............................................................................................................... 192

ANNEX 13: COMBINED IMPACTS OF SPI PREFERRED OPTIONS UNDER ACTION 1, 2,

AND 3 ............................................................................................................................................... 194

ANNEX 14: DESCRIPTORS DEFINING LEVELS IN THE EUROPEAN QUALIFICATIONS

FRAMEWORK (EQF) – ANNEX II OF THE COUNCIL RECOMMENDATION ON THE

EQF ................................................................................................................................................... 197

iv

Glossary

Acronyms and key terms Meaning or definition

Comparability statement A document that shows how a foreign (non-national) qualification

compares with a domestic or national qualification

Competent Authority

An authority empowered by a Member State (MS) to receive

applications for recognition decisions under Directive 2005/36/EC

(Professional Qualifications Directive)

Credential A paper or digital document record of a qualification

Cross-border worker

Any person pursuing an activity as an employed or self-employed

person in a MS and who resides in another MS to which he returns as a

rule daily or at least once per week

Labour market actors

Key actors who shape how work is organised, accessed, and regulated

(such as workers and jobseekers, employers, trade unions, employer

associations, government and public authorities, Competent Authorities,

or employment agencies and intermediaries such as public and private

employment services)

Learning outcomes

Statements regarding what a learner knows, understands and is able to

do on completion of a learning process, which are defined in terms of

knowledge, skills and responsibility and autonomy

Micro-credential A record of learning outcomes acquired following a small volume of

learning. For more information see Annex 7

Mobile worker EU citizen in the labour force who resides in a MS other than their

country of citizenship

National Qualifications

Framework

An instrument for the classification of qualifications according to a set

of criteria for specified levels of learning achieved, which aims at

integrating and coordinating national qualifications subsystems and

improve the transparency, access, progression and quality of

qualifications in relation to the labour market and civil society.

National worker

In the context of this IA, the term “national worker” is used for

individuals, who have obtained the qualification in the country where

they work or look for a work.

Non-regulated profession

Profession whose access is not reserved by law to the holders of specific

professional qualifications. Those professions are not falling under the

scope of the Professional Qualifications Directive

Qualification

A formal outcome of an assessment and validation process which is

obtained when a competent authority determines that an individual has

achieved learning outcomes to given standards.

Regulated profession

Profession whose access is reserved by law to the holders of specific

professional qualifications, as defined under the Professional

Qualifications Directive

Skill The ability to apply knowledge and know-how to complete tasks and

solve problems

v

List of abbreviations

Acronyms and key terms Meaning or definition

AG Advisory Group

AI Artificial intelligence

EDC European Digital Credentials for learning (for more information see

Annex 7)

eIDAS Electronic Identification, Authentication and trust Services

ELM European Learning Model (for more information see Annex 7)

ENIC/NARIC European Network of Information Centres/National Academic

Recognition Information Centre

ESCO European multilingual classification of Skills Competences and

Occupations (for more information see Annex 7)

EUDI European Digital Identity

EQF European Qualifications Framework (for more information see

Annex 7)

GDPR General Data Protection Regulation

IA Impact Assessment

MS Member State(s)

NQF National Qualifications Framework

OO Operational Objective

OOTS Once-Only Technical System

PO Policy Option

PQD Professional Qualifications Directive

QDR Qualifications Dataset Register (for more information see Annex 7)

SDGR Single Digital Gateway Regulation

SDGs Sustainable Development Goals

SMEs Small and medium-sized enterprises

SO Specific Objective

SPI Skills Portability Initiative

TCN Third-country nationals

TFEU Treaty on the Functioning of the European Union

VET Vocational Education and Training

6

1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT

1.1. Overall context of the Skills Portability Initiative and the Fair Labour Mobility

package

While the EU’s labour market has reached record-high employment levels and shown

remarkable resilience in the post-pandemic era,1 its strong performance masks a structural

challenge: widespread skilled labour shortages that threaten business growth and the EU’s

global competitiveness.2

Critical sectors – ranging from healthcare and ICT to construction and transport – struggle to

find the talent they need to scale up and drive the twin transitions. These shortages are

structural, not cyclical, and expected to worsen due to demographics and evolving demand for

new skills and occupations.3 They are not evenly distributed across the economy and most

acutely felt by Small and Medium-sized Enterprise (SMEs), which have fewer resources

to navigate complex recruitment channels.4 Labour and skills gaps also threaten the delivery

of essential public services like healthcare, education and long-term care.5

Paradoxically, the EU also suffers from ‘skills waste’. Overqualification and the

underutilisation of skills remain structural features of the labour market. This mismatch is

significantly more pronounced among EU mobile workers and third-country nationals

(TCN).6

Uncertainty about whether qualifications and skills will be fully understood, valued, and

formally recognised (in the case of regulated professions)7 in another MS, may discourage

professionals from seeking employment opportunities outside their MS.8 It can also deter

companies, especially SMEs, from tapping into the potential pool of talent of the Single

Market.

1 The employment rate for people aged 20-64 equalled 76.3% in the Q1 of 2026. 2 With minor fluctuations, labour market slack in the EU has been decreasing steadily from 18.6% in 2015 to

10.9% in Q1 2026 while the job vacancy rate in the EU stood at 2.0% in Q4 2025. 3 The EU's working-age population is projected to shrink from 265 million in 2022 to 258 million by 2030

(ESDE 2023, based on Eurostat EUROPOP2023 projections), while job vacancy rates have more than

doubled over the past decade. Cedefop's skills forecast to 2035 further confirms that in key shortage sectors

— health, care and construction — shortages stem primarily from replacement demand. 4 51% EU firms reported that the scarcity of skilled workers was a major barrier to investment in 2024 – up from

38% in 2016. EIB 2024/2025. A 2026 Eurobarometer survey shows that 46% of SMEs are finding it difficult

or very difficult to finding staff with the right skills over the past 24 months. For SMEs, the inability to

recruit has immediate consequences. In an earlier survey, 48% of them reported that shortages lead to an

increased workload for existing staff, directly impacting productivity and the ability to innovate. 5 According to the OECD, in 2022, the EU faced a shortfall of 1.2 million health professionals, with shortages

reported by 20 MS for doctors and 15 for nurses. The crisis is driven by an ageing population increasing

demand while over one-third of doctors and a quarter of nurses approach retirement. This trend is expected to

worsen, causing a projected shortfall of around 2 million health and long-term care workers by 2030, with

demand continuing to grow thereafter due to ageing populations. Cf. OECD (2024) and European

Commission (2021). 6 In 2024, there were 14 million European citizens living in another EU MS, of which 10.1 million of working

age. In addition, there were 1.9 million cross-border commuters. In 2024, 12.8 million non-EU citizens were

employed in the EU in 2025. Cf. European Commission (2026), Eurostat LFS 2025. The overqualification

rate among EU workers employed in their own country stood at 20.8% in 2023. For mobile EU-citizens and

TCN the equivalent rate equalled 31.4% and 39.8% respectively. Eurostat LFS, lfsa_eoqgan. 7 Regulated professions are the focus of Action 2 of the Skills Portability Initiative; the definition of the concept

and its practical scope are explained in the accompanying IA. 8 In a recent Eurobarometer 18% of respondents indicated an interest in working abroad, higher than the actual

number of mobile workers. Cf. European Commission (2022).

7

Beyond economic efficiency, skills portability is a prerequisite for exercising the

fundamental rights enshrined in the Treaties, including the right to free movement (Article

21 TFEU), the freedom of movement for workers (Article 45) and the freedom of

establishment (Article 49 TFEU). While individual decisions on relocating to another EU

MS depend on many factors, limited skills portability contributes to difficulties that many

citizens experience when exercising these rights. In border regions, skills-related barriers to

mobility limit job opportunities in neighbouring countries which could be accessed without

the need for relocation.9 Improving skills portability across borders thus also contributes to

the ‘right to stay’.

The Letta report on the Single Market to theEuropean Councilhighlightedthat: “Free

movement of people has been and remains the least developed of the four freedoms”. It also

stressed that fragmented national labour markets hinder European growth and competitiveness

and that “extending the system of automatic recognition of professional qualifications and

reviewing the need for and extent of professional regulation would facilitate mobility and help

to respond to persistent labour shortages”. 10

In response, 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”.11 They also underscored the need to “support MS and companies with legal

migration based on the skills needs of our economies and our regions” and to “make it easier

to attract the right talent with harmonised rules on the recognition of qualifications”.

At its meeting on 19 March 2026, the European Council urged swifter action, calling 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”.12 On 24 April 2026, the European

institutions agreed on a roadmap to achieve 'One Europe, One Market' to strengthen

Europe’s competitiveness, with a commitment for concrete actions and targets for agreements

by end of 2027. The Skills Portability Initiative is one of the priority deliverables to

contribute to a more integrated Single Market.13

This political direction is supported by the broader institutional landscape. The European

Economic and Social Committee has called for further discussions among governments,

social partners, and stakeholders to consider expanding the list of automatically recognised

regulated professions and creating common training frameworks under Directive 2005/35/EC,

addressing barriers to its implementation.14 The Committee of the Regions has highlighted

the importance of enhancing the portability and recognition of qualifications across the EU,

which are essential for fostering labour mobility, combating brain drain and fully harnessing

the Single Market and talent within regional economies.15

As part of the Fair Labour Mobility package,16the Skills Portability Initiative aims to

empower European businesses to recruit the skilled labour force they need to remain

9 ITEM study on challenges and solutions for recognising professional qualifications in cross-border regions. 10 Letta (2024). 11 Von der Leyen (2024). 12 European Council meeting (19 March 2026) – Conclusions 13 One Europe, One Market Roadmap of the European Parliament, the Council of the European Union and the

European Commission 14 SOC/837-EESC-2025 15 CDR-1105-2025 16 For more context, see CWP 2026 Commission work programme 2026 - European Commission.

8

competitive in the global economy, effectively safeguard the right to free movement and

allow talent to flow seamlessly to where it adds most value. By simplifying and improving the

transparency of recognition, and validation, the initiative strengthens coherence between

migration pathways, labour market needs and skills systems; supporting improved labour

market matching, enhanced productivity and reduced skills underutilisation across the EU.

The initiative aligns with the 2030 Agenda for Sustainable Development, in particular SDG

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

10 (Reduced inequalities) and SDG 1 (No poverty).

1.2. Coherence of the package

Underemployment, overqualification and ‘skills waste’ stem inter alia from imperfect

information and regulatory or administrative barriers to free movement. Mobile

professionals struggle to valorise the qualifications and skills they acquired abroad because

labour market actors find it relatively more difficult to interpret and verify non-national

credentials. This putsqualifications and skills acquired in a non-national context at a

disadvantage. The Skills Portability Initiative aims to address these barriers through a set of

three distinct but interrelated actions:

Action 1: Improving availability of reliable, comparable and verifiable digitalised

information on qualifications and skills in the EU

This action aims to bring simplification for employers and workers by making qualifications

instantly understandable and verifiable for labour market actors across the Single Market and

facilitating comparison of the level and content of qualifications issued in the EU. 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 interoperable, secure, and machine-readable. This will

reduce the ‘interpretative burden’ on hiring managers and preventing further fragmentation

between MS resulting from uncoordinated investments in digitalisation.

This action is relevant for all workers using qualifications obtained in other EU MS in any

labour market context, including for access to regulated professions. In the context of

unregulated professions, which constitute 78% of EU labour force, the improved availability

of digitalised and comparable information on qualifications and skills will contribute to

decreasing the uncertainty about how to treat qualifications obtained in another MS, which at

the moment leads employers to request costly and time-consuming comparisons with national

qualifications even though these are not legally required. In regulated professions, the digital

attestations set up thanks to Action 1 are a key element of the simplification of the recognition

procedures under Action 2. The various problem drivers, Policy Options and impacts are

discussed in this IA.

Action 2: Targeted Intervention for Regulated Professions

The second action focuses specifically on improving cross-border recognition procedures for

access to regulated professions.17 There are currently over 5,700 professions regulated across

17 Article 3 of the Professional Qualifications Directive defines a regulated profession as “a professional activity

or group of professional activities, access to which, the pursuit of which, or one of the modes of pursuit of

which is subject, directly or indirectly, by virtue of legislative, regulatory or administrative provisions to the

possession of specific professional qualifications.”.

9

the EU18 covering an estimated 22% of the labour force,19 with considerable variations in how

these professions are governed and diverging access requirements between MS. This

exacerbates the issue of allocative inefficiency as imperfect information is compounded by

legal and administrative hurdles to skills mobility. Under the TFEU, regulation of access to

professions is MS competence within the limits of EU law, and in particular, non-

discrimination and proportionality.20 Consequently, there is a high variety of approaches to

regulating the access to professions between MS which creates barriers to professional

mobility within the EU. To address those barriers, the EU has established the Professional

Qualifications Directive21 (PQD) which provides a robust, legally binding framework that sets

out rules on the recognition of professional qualifications in a cross-border context. Thus, the

Directive facilitates professional mobility, ensuring that individuals who have acquired their

professional qualifications in one MS for access to a given profession, can access and pursue

the same profession in another MS under the same conditions as nationals. However, the

experience of professionals navigating the existing regulatory framework reveals that

recognition often remains a complex and time-consuming process. While the framework’s

foundations are fundamentally sound, lengthy procedures, uneven digitalisation of national

processes and procedures, and heavy documentation requirements risk undermining its

potential. Action 2 aims to facilitate cross-border recognition of professional qualifications

required to access regulated professions is organised into two primary work strands. The first

work strand focuses on applying the automatic recognition system to additional regulated

professions. Currently, automatic recognition exists for certain sectoral professions with

harmonised minimum training requirements (such as doctors and nurses). For specific

economic activities in trade and commerce there is automatic recognition based on

professional experience. The action aims to extend automatic recognition to professions

which are not currently covered using Common Training Frameworks. It is covered as part of

the baseline in the dedicated IA for action 2.22 The second work strand on Modernisation

and Digitalisation of Procedures aims to simplify and speed up recognition of professional

qualifications for regulated professions, by streamlining the existing recognition procedures

under the Directive, leveraging the potential of digital tools. Action 2 is based on articles 46,

49, 53 and 62 TFEU. The various problem drivers and Policy Options in this second work

strand are discussed in a dedicated IA.

Action 3: Attracting and Empowering Global Talent

Acknowledging that intra-EU mobility alone cannot solve all labour market needs, Action 3

focuses on making the Single Market a more attractive destination for TCN by enabling them

to have their qualifications recognised and their skills validated more easily. This will both

benefit the TCN already residing and working in the EU and those who intend to migrate to

18 According to the ECA, the combined data on professions that are regulated in the MS show that the total

increased from around 5 400 in 2016 to around 5 700 in 2023 (average per MS: 212 regulated professions).

Annex 8 of the IA accompanying Action 2 of the Skills Portability Initiative provides more background on

regulated professions in the MS, for illustrative purposes. The European Commission’s RegProf allows to

verify which professions are regulated at national level in the EU, by MS. 19 See COM (2016) 820 final. 20 Directive (EU) 2018/958 on proportionality tests obliges MS to assess, before adoption, whether new or

amended regulation of professions is justified, necessary, and proportionate to legitimate public-interest

objectives, and to document this assessment transparently: by doing so, it indirectly supports recognition by

reducing barriers and promoting consistency across MS. 21 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition

of professional qualifications. The PQD, based on articles 46, 53(1), 53(2) and 62 TFEU is part of a broader

acquis governing the free movement of professionals. The links between the PQD and other instruments on

the free movement of professionals in the Single Market are explained in more detail in Annex 7. 22 The link between this strand of work and the modernisation and digitalisation of recognition procedures is

explained in Annex 9 of the relevant IA.

10

the EU, making the Single Market a more attractive destination for global talent. Action 3 is

based on article 79 (2) points (a) and (b) TFEU. The various problem drivers and Policy

Options in this third work strand are discussed in a dedicated IA.

Actions 1, 2 and 3 are closely interlinked and coherent.

The interoperable, secure and verifiable digital attestations developed under Action 1 are a

foundation, on which actions to simplify and speed up recognition procedures in the context

of regulated professions under the PQD (Action 2) build,by reducing administrative burdens

on Competent Authorities enabling smoother, faster assessments of qualifications.

Action 3 addresses a critical gap: the PQD’s recognition procedures do not cover third-

country nationals (TCNs). TCNs and EU citizens holding non-EU qualifications do not

always benefit to the same extent from the existing EU transparency tools. This puts them at a

disadvantage compared to EU citizens holding EU qualifications, undermining the

attractiveness of the Single Market as a destination for global talent. To address these issues,

specific action to facilitate recognition of qualifications of TCN is warranted. This is the

purpose of Action 3. Just like Action 1, Action 3 uses the European Qualifications Framework

as a key tool to enable comparability and portability of qualifications across borders,

implemented in particular through comparisons between the EQF and qualifications

frameworks of third countries, such as in the context of Talent Partnerships, or other EU

partnerships.

Together the three actions form a coherent package, each addressing distinct but interlinked

dimensions of skills portability: 1) the framework for availability of digitalised information

about qualifications and skills which forms the foundation for the other actions, 2) the

recognition of qualifications for intra-EU mobility in regulated professions, and 3) the

recognition of qualifications of TCN. As such, the three actions are mutually reinforcing and

contribute to the broader objectives of supporting labour mobility, reducing skills

mismatches, and improving the functioning of the Single Market.

This IA focuses on Action 1 of the Skills PortabilityInitiative: “Improving availability of

reliable, comparable and verifiable digitalised information on qualifications and skills in the

EU”.

2. PROBLEM DEFINITION

2.1. Background

Qualifications and their signalling role on the labour market

Employability, broadly defined as the capability of an individual to secure and sustain

employment, is determined by a wide range of factors relating both to personal attributes and

the prevailing economic context. There is clear statistical evidence that that among the

personal attributes, the level of educational attainment, i.e. the successful completion of an

education programme being validated by a recognised qualification influences employability

(see Eurostat LFS).23

This does not mean that qualifications are the only element that employers consider when

recruiting people, and many internal and external factors can influence their choice. It

23 [lfsi_educ_a] Employment by educational attainment level - annual data

11

nevertheless ultimately means that a significant number of them24 take into account, at least to

a certain extent, the qualification of their potential future workers in their hiring decisions.

The role of qualifications in reducing the uncertainty of firms as regards the future

productivity25 of the recruited labour force has been long established in the literature. For

Arrow, higher education serves as a screening mechanism of the differing abilities of

individuals and in this respect conveys information to the purchasers of labour in a context of

imperfect information on workers potential job performance.26 Spence presents the level of

education as a signal on the job market for employers who cannot directly observe

productivity ex ante recruitment. Spence also underlines the existence of a feed-back loop: the

conditional probability of productivity level attached to one signal (a qualification) is adjusted

after each round of hiring which allow observing the productivity level of recruited workers

holding this qualification.27 Stiglitz further elaborates on the features of education that make

information a natural by-product of its activity of providing skills (including through the self-

selection of individuals who, if they are rational, will try and acquire qualification depending

on their ability) and explains how education reveals individual productivity in markets with

imperfect information.28

In view of the above, companies consider qualifications when selecting future employees. The

exact individual decision-making process cannot be observed, nor aggregated but one can

postulate that companies who require qualifications when advertising a vacancy and/or in the

application file will take them into consideration. An ad-hoc query on the Skills Online

Vacancy Analysis Tool for Europe yield that 23% of online vacancies include a least one

wording directly related to qualifications.29 This figure is in the same order that the

percentage (29%) of SME panel’ respondents indicating that they require a qualification when

hiring. Empirical works at national level also point toward the fact that qualifications are

requested in job applications. For instance, an analysis of the French Ministry of labour30

found that 38% of the surveyed employers were requesting candidates to include their

diplomas and training certificates in their file. A study from Poland shows that in 42%

vacancies employers ask for suitable education.31

The weakened signal of foreign qualifications

The Eurobarometer on the Thirtieth anniversary of the EU Single Market32 reports that a

recurrent theme across multiple focus groups involved the difficulties individuals faced when

their degrees and qualifications acquired in one EU country were not promptly acknowledged

or recognised in another. Some participants spoke about challenges linked to the recognition

of qualifications as an issue that they faced themselves or knew other people who did.

24 This number must represent a mass critical enough to translate into a statistical relationship observable at

macro-level through the above referred Eurostat data. 25 Productivity and quantity of factors (capital and labour) are the sole determinants of the output of the firm in

the standard economy theory used by the quoted authors. This is the reason of its mention here, however

productivty increase will not be used as an argument to justify this initiative. 26 Arrow, K.J. (1973) Higher Education as a Filter. Journal of Public Economics, 2, 193-216. 27 Spence M. (1973) Job Market Signalling; The Quarterly Journal of Economics, Vol. 87, No. 3 (Aug., 1973),

pp. 355-374. 28 Stiglitz J.E. (1975) The Theory of "Screening," Education, and the Distribution of Income. The American

Economic Review, Vol. 65, No. 3, pp. 283-300. 29 Skills-OVATE Skills Online Vacancy Analysis Tool for Europe by Cedefop: Digital Skills and Jobs Platform 30 V. Remy et M. Bergeat. « Comment les employeurs recrutent-ils leurs salariés ? », Dares Analyses N°064 31 The other elements requested being: experience (58%), availability (32%), and knowledge of a foreign

language (22%). Rynek pracy, edukacja, kompetencje (czerwiec 2025). 32 https://europa.eu/eurobarometer/surveys/detail/2962 (p. 84).

12

It is not possible to quantify the weight of the different factors that may hamper EU labour

mobility as they relate to individual decisions of workers and/or employers. Some insights can

nevertheless be drawn from a survey of the Austrian Chamber of Commerce among their

members in 2024. 59.0% view the assessment of professional qualifications as a very or

somewhat significant barrier; while 54.4% point to the high rent and housing costs in the

region. 47.5% view the evaluation of foreign educational credentials, and 40.0% view the

search for and recruitment of non-Austrian skilled workers as a very or somewhat significant

problem. The need to make foreign educational credentials more understandable and

comparable in terms of the content they cover is raised by nearly half (47%) of the Austrian

companies surveyed; 18% do not see this need, and 35% declined to give a specific answer

(“don’t know”). This example from one Member State gives an indication that employers may

have difficulties understanding qualifications acquired in another one. Answers from the SME

Panel Consultation point in the same direction: when asked about the specific challenges they

face in assessing qualifications from other EU countries, the most frequently cited challenge

was insufficient familiarity with foreign education systems.33

The signalling role of qualification has also been used in the literature addressing the

transferability of immigrants’ human capital on the American, the Swedish34 or German35

labour markets. In these cases, the authors argue, based on empirical analysis, that foreign

education has lower returns because employers refrain from hiring workers with foreign

educational credentials that they do not fully understand. Lancee and Bol36 also attribute the

wage penalty observed for non-Western degrees after controlling for different forms of skills

to the fact that employers are less likely to be familiar with them.

One can also argue that foreign qualifications as a signal benefit less from the feedback loop

described by Spence (1973). The feedback loop occurs when a firm observes the productivity

of a hired worker with a qualification and is then able to improve the information conveyed

by the said qualification. Qualifications acquired in foreign countries are likely to benefit less

from this feedback loop then the domestic qualifications as firms are still likely to recruit

fewer workers in a firm holding a qualification from a foreign country.

Policy initiatives and existing EU tools relevant for the comparison of qualifications across

the EU37

The need to improve the understanding of qualifications and skills obtained in different MS

has long been acknowledged, and the EU has invested in a number of policies and tools in

that context.

The European Qualifications Framework (EQF) aims to increase the transparency and

comparability of qualifications. It connects the national and European qualification levels.

The national qualifications are part of national qualifications frameworks (NQFs) and NQF is

33 See section 2.1. for further details and reference 40 Tibajev and Hellgen, The Effects of Recognition of Foreign Education for Newly Arrived Immigrants

European Sociological Review, 2019, Vol.35, N 4, 506-521 35 Damelang & Abraham, You CAn Take Some of It with You, Zeitschrift füt Soziologie, 2016, 45(2): 91-106 36 Lancee & Bol, The Transferability of Skills and Degrees: Why the Place of Education Affects Immigrant

Earnings, Social Forces, Volume 96, Issue 2, December 2017, Pages 691–716 37 This section briefly introduces selected relevant policy initiatives and tools, interacting with the Action 1.

More details on them is provided in relevant sections (in particular problem drivers, baseline and options) and in

the Annex 7.

13

referenced to the EQF. The EQF consists of 8 levels from basic (level 1) to advanced (level

8), based on learning outcomes (knowledge, skills, autonomy and responsibility).38

The Europass platform39 operates as a one-stop shop for different skills, qualifications and

labour mobility tools, including an e-portfolio with a smart CV, information on qualifications

(from NQF registers) and learning opportunities (from national registers/databases) and an

infrastructure for digital credentials (the European Digital Credentials for Learning).

ESCO (European Skills, Competences, Qualifications and Occupations) is the EU's

multilingual classification of skills, competences, qualifications and occupations, designed to

improve transparency and matching across EU labour markets. It enables employers and

employment services to describe vacancies and worker profiles in a common language that

crosses national boundaries.

The use of these tools is voluntary which limits their potential to fully address the lack of

understanding of a qualification acquired in another Member State (for a full description of

these limitations, see Section 2, sub-Driver 2.1). Annex 7 provides a full overview of these

tools, as well as of the various actors involved in recognition and assessment of qualifications

obtained in other MS (e.g. ENIC/NARICs) and more recent developments related to

digitalisation which have impacts on portability of qualifications (e.g. EUDI Wallet and

DC4EU pilot).

2.2. What is the problem?

The portability of qualification and skills is limited across the EU and makes it more

difficult for employers to hire, and EU mobile and cross-border workers to get hired.

Employers and other labour market actors that need to read, understand, and verify

qualifications obtained in another MS (e.g. public employment services matching jobseekers

to jobs, recognition authorities in case of regulated professions), face two interconnected

problems of information asymmetry. The first one related to uncertainty about what a

qualification contains (e.g. the learning outcomes). The second one stems from the technical

‘envelope’ (for example paper vs digital format) as well as its level of security (for example,

seal on paper or encrypted digital credential) that may lead to adverse selection (e.g. risk of

fraud).

Employers navigate a hiring process, where they may lack understanding of the language the

diploma is issued in and the type of information the qualification contains may be very

different from the national context. As shown in the consultation, labour market actors do not

understand qualifications from other MS well enough to assess what the holder truly knows or

is able to do – i.e. the qualification level and content.40 Confidence of SMEs falls significantly

when assessing qualifications from other EU countries, compared to from their own country.

In the SME Survey,41 for qualifications from other EU countries, 31 (out of 159) report

feeling very confident, 86 (out of 159) are confident, compared to 84 (out of 159) feeling very

confident and an additional 59 (out of 159) feeling confident in assessing qualifications from

their own country. The most frequently cited challenge when assessing qualifications from

other EU countries by SMEs, was insufficient familiarity with foreign education systems (70

out of 159), difficulty verifying the authenticity of qualifications (63 out of 159) and language

38 EQF is in place since 2008 and was revised in 2017. 39 Decision of 2018 (replacing the Decision of 2004) 40 SPI Consultation Social Partners; Expert workshop: Recognition of VET qualifications for the purpose of

worker mobility.

14

barriers (61 out of 159).

The Europass evaluation42 pointed out that verifying the authenticity of a candidate’s

qualifications is very important for employers when hiring (71% of respondents consider it

very important or somewhat important). 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.

As reported by stakeholders consulted in the supporting study, non-digital credentials are

subject to an increased risk of fraud. Over half of the respondents (298 out of 574) to the

survey of issuers of qualifications (strongly) agreed that paper certificates cause problems

with verification checks, and five submissions to the Call for Evidence reported that remote

verification is “impossible” with analogue systems.43 The concerns about the growth of

diploma mills and fraudulent qualifications across Europe were raised in the Council of

Europe's Recommendation on countering education fraud and the Lisbon Recognition

Convention Committee.44 Empirical analysis by CIMEA45 similarly documents a thriving

landscape of forged and fabricated credentials, distinguishing between "fake degrees" issued

by entirely fictitious institutions and "fraudulent degrees" that mimic genuine ones, and notes

that new digital tools are making both easier to produce and harder to detect.

Imperfect information about the level and content of qualifications acquired in another MS

and the format in which they are presented may reduce trust, increase transaction costs and

make acceptance and recruitment decisions more difficult. Further, they may lead to

unnecessary and burdensome procedures and to suboptimal outcomes for both workers and

employers.

The problem tree (diagram 1) illustrates the problem, main drivers, their causes and

consequences.

42 EUR-Lex - 52024SC0071 - EN - EUR-Lex 43 Call for evidence submissions, Public consultation. 44 Council of Europe Recommendation on countering education fraud - ENIC-NARIC 45 Finocchietti and Lantero, 2025 https://rivistauniversitas.it/document/r/rivista_01_2025.pdf

15

Diagram 1: Problem tree

The problem identified above has distinct implications for different stakeholders.

Employers

Employers may spend time trying to understand qualifications coming from different

education and training systems, have to invest ex-post recruitment in supplementary training

when skills cannot be verified, and face significant indirect and opportunity costs.

The determination of the exact number of employers who undertake to verify the

qualifications of the applicants acquired in another MS is not possible. No empirical study has

been identified on this matter and since this would mean a controlled experiment on a

representative sample of EU companies it was not possible to undertake such an analysis for

this impact assessment. Having said that using job scraping,46 from the CEDEFOP Skills

Online Vacancy Analysis Tool for Europe yield the result of about one quarter of the job

advertisements containing a reference to qualification(s). One can assume that EU employers

mentioning qualification when publishing a vacancy will take this into consideration and

verify the qualification at least of the selected applicant. Estimating the number of verified

qualifications to about one quarter of the flow of mobile workers per year seems a reasonable

(low range) assumption. This estimate could even be considered as conservative as it takes as

a basis only the flow of mobile workers (hence mobile workers who apply to change jobs in

the MS they already reside are not counted) and does not include cross-border workers.

In addition, reduced access to talent, in a context where many of them are already not finding

candidates with the right skillset, worsens existing labour and skills imbalances. In the

Eurobarometer 2023, skills shortages were reported as the most serious problem by 53% of

micro companies, 65% of small companies, 68% of medium-sized companies, and 72% of

46 Job scraping or automated job board scraping is a process used to collect data on job titles and descriptions.

Eurostat together with CEDEFOP are using these tools to produce skills related experimental statistics. For

methodology and limitations see WIH - OJA Data | Eurostat CROS

U n d er ly in g c au se s

D ri v er s

o n se q u en ce s ndirect:

educed professional mobility, skills waste of overqualified EU

mobile workers, untapped potential of Single Market

irect

urdensome cross border hiring processes, high transaction costs

o re

P ro b le m

. arying level of available information on qualifications across the EU

various degree of amount and quality of data, e.g. on learning outcomes

qualifications typically issued only in the local language(s)

E x te rn al

fa ct o rs anguage barriers for EU workers or language

requirements for EU workers to take up work

in another EU Member State

Diverse education and training systems in

Member States (particularly in vocational

education and training professions)

ther factors that hinder workers to move for

work to another Member State (limited

housing, costs of relocation, etc.)

abour market actors have insufficient understandin and uncertainty

about level and content of the qualifications and skills obtained in another EU

MS

abour market actors cannot verif and workers cannot

efficiently prove) the authenticity of qualifications and skills

credentials issued in another EU MS

. redential systems are diverse:

patchwork of cryptography of credentials (paper and digital)

and how credentials are composed (file format, e.g. digital,

PD , paper) leading to a patchwork of verification methods

2. Shortcomings of EU and MS landscape of comparison tools:

omparison tool at EU level not effectively working since Q database

not complete implementation of EQ and Europass is incomplete

EU MS tools incomplete and doubling efforts between MS

Portability of qualification and skills is limited across the EU

and makes it more difficult for employers to hire, and EU mobile and cross border workers to get hired

16

large companies.47 In the 2025, out of 423 occupations identified as being in shortage in at

least one country, 416 (or 98%) also appear as surplus occupations in at least one other

country. Even in case of one of the occupations most frequently reported as being in shortage

– welders and flame cutters (flagged by 22 countries), two countries reported a surplus.48

Potential EU mobile workers

The most affectedareindividuals seeking to access or exercise a regulated profession in

another MS for whom the recognition of their qualifications is compulsory. Many MS still

require physical submission of documents as fully digital procedures are not always available.

For applicants, this reliance on physical documentation increases costs, administrative burden,

and delays.49

Individuals wishing to move and work in a non-regulated profession, may also be requested

to undertake a qualification assessment procedure, not for legal reasons but to provide

prospective employers with further information on the level, content and the authenticity of

their qualifications, which are also costly and entail significant administrative burden. Around

one in three of respondents in the SME panel request some kind of qualification assessment

procedures to verify the authenticity of the qualifications (52 out of 159), or to better

understand what candidates have learnt compared to domestic equivalents (42 out of 159) in

non-regulated professions. In response to employers’ request to obtain some formal

assessment of qualifications in non-regulated professions, workers use recognition pathways

designed for other purposes, such as statements of comparability issued by ENIC-NARIC

centres.50 Most ENIC-NARIC centres were not able to estimate the percentage of statements

issued for non-regulated professions. However, in countries where estimates were submitted,

they represented more than half of all statements (see Annex 8, Table 1).

In some instances, although not required from hiring purpose, the necessity of the formal

assessment may stem from the prevailing collective bargaining agreement - determining the

working conditions. For example, in Italy, while contractual grading is determined primarily

by the tasks assigned rather than by formal qualifications, a comparability statement or

qualifications mapped to the EQF is often used to facilitate recruitment by making workers'

qualifications and skills obtained in another EU MS more transparent and understandable to

employers. In Poland, the collective agreements also link grading and remuneration to

education levels, seniority and qualification requirements for specific positions, but they

generally do not address the treatment of qualifications obtained in another MS.51

The financial burden of these processes was one of the most cited challenges in the call for

evidence, and the cost falls often on the workers themselves. While most respondents reported

spending less than EUR 250, cases around EUR 1 000 were also reported. Beyond direct

costs, nearly half of the respondents to the consultation reported processes lasting longer than

three months, generating significant lost opportunity costs (periods without income).

Such costs can be difficult to bear especially for individuals from vulnerable backgrounds and

younger workers. Young people, especially those entering the labour market, are likely to be

more affected since qualifications are likely to play a stronger role in their ability to access

47 https://europa.eu/eurobarometer/surveys/detail/2961 48 European Labour Authority (2026), EURES – Report on labour shortages and surpluses – 2025, Publications

Office of the European Union, Luxembourg. 49 ECA special report 10/2024 on the recognition of professional qualifications in the EU 50 The primary purpose of ENIC-NARIC statements is for further learning. When applied for employment in

non-regulated professions, the criteria or procedures are not changed and don’t consider labour market aspects. 51 A more comprehensive overview of how collective agreements refer to qualifications across MS is provided in

annexe 8, table 8.6: Summary of the Eurofound reports on collective agreements in MS.

17

entry-level jobs which per definition do not require professional experience. In addition, the

cost and length of the recognition procedures are likely to weigh more on them than on

workers already employed. However, the available data do not allow to estimate the extent of

this happening.

Issuers of qualifications

Issuers of qualifications are frequently contacted by third parties, such as employers,

recognition authorities or other organisations, to verify the authenticity of qualifications.

According to the Qualification Issuers Survey, 290 out of 574 respondents (50.5%) reported

having received requests from third parties to verify the authenticity of diplomas. The annual

requests per issuer are estimated in range from 16 to 30 contacts per year, with the lower and

upper values reflecting different interpretations of the open-ended “once a week or more”

category.52

2.3. What are the problem drivers?

The underlying drivers stem from market failures related to an imperfect information on

qualifications and skills. This leads to asymmetries of information on level and content of

qualifications (driver 1) and on the authenticity of the qualification (driver 2).

The two drivers are mutually reinforcing. Because of uncertainty on the level or content of a

qualification and skills (Driver 1), the same applicant may face additional hurdles about its

authenticity when presenting their qualifications to an employer in another Member State

(Driver 2). Within each MS, a highly diverse landscape of qualifications exists. The

fragmentation of IT systems being developed in an uncoordinated and un-interoperable way is

making more complex for employers to verify easily digital qualifications (Driver 2) and

access its content (Driver 1).

Driver 1: Labour market actors have insufficient understanding and uncertainty about

level and content of the qualifications and skills obtained in another EU MS

The education and training systems, as well as what credentials delivered, are organised

differently across 27 MS, since this falls under the responsibility of the EU MS.53 As a result,

when an individual with qualification from another MS applies for a job, the employer will

receive qualifications credentials that diverge in language, content, descriptions compared to a

job application from a native worker. This is a problem for all, regulated and non-regulated

professions.54

The qualifications credentials are typically written in the local language(s) and the same time

across the EU, qualifications contain various amount and quality of data, e.g. on learning

outcomes (see illustrative example).

Illustrative example:

Qualification from Bulgaria in cybersecurity (extracted from Europass):55

52 The annual frequency of such contacts was estimated by annualising the survey response categories on contact

frequency (i.e. once a week or more, several times per month, a few times per year, once a month, and less than

once a year). 53 Education and training are enshrined as supporting competence of EU in Article 6 of TFEU. 54 In regulated professions, imperfect information also affects the efficiency of recognition procedures (see IA

for Action 2 of the SPI). 55 Find a course | Europass

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Machine translated with AI-based online tool:

Thus, even with AI-translation, the “signal” of the foreign qualification is limited, if the learning outcome is

described in a generic way, not telling the employer in another MS what tasks the person can actually perform

and at which competency level this qualification was done.

A good example of learning outcomes, applying the applicable guidelines56 and enhancing the signalling role

of qualifications, could be:

Title: Cybersecurity

Awarding body: Technical University of Varna

Learning outcomes:

The qualification holder (EQF/NQF 4) is able to ensure the smooth running of IT systems. They can

develop, adapt and/or maintain these and look after users. He/she has practical knowledge from computer

science, electrical engineering and production engineering.

He/she works independently and/or as part of a team in companies that develop and offer information and

communication technology products and services or in public authorities and institutions. This is school

based initial vocational training.

Optionally, the higher education entrance qualification can be acquired.

The qualification holder can:

a) analyse, assess and optimise operational processes, workflows and framework conditions with

regard to the use of IT systems;

b) design work processes using technical and organisational aids;

c) develop and adapt application software for operational processes;

d) analyse, plan, build, commission and network IT systems;

e) analyse, build, connect to IT systems, programme and commission automation systems;

f) plan, create and maintain databases using appropriate programming languages and software

development tools;

g) secure the energy supply for IT systems and optimise energy consumption;

h) observe industry and legislative standards and regulations and use of technical rules and

regulations;

i) observe data security, data protection and copyrights;

j) responsibly shape and reflect on his/her working environment and processes;

56 Under the EQF and Europass Advisory Groups European guidelines have been developed on short

descriptions of learning outcomes in the context of publishing transparent information about qualifications,

which also help to make qualifications more comparable across the EU.

Title: Киберсигурност

Awarding body: Technical University of Varna

Learnin outcomes Придобиване на знания и умения по Киберсигурност

Thematic area: Проектиране и управление на бази данни и мрежи

Level:

Title: Cybersecurity

Awarding body: Technical University of Varna

Learning outcomes: Acquisition of knowledge and skills in: Cybersecurity

Thematic area: Database and Network Design and Management

Level:

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k) apply standards and guidelines to ensure process and product quality;

l) cooperate and communicate in teams;

m) analyse customer requirements and advise customers also in English;

n) obtain, prepare and present information and documents in English in relation to the activity

For an employer, what matters is to compare and understand how the foreign qualification

credentials/learning outcomes relate to their national system. The EU and MS have developed

transparency tools that aim to ensure reliable information on qualifications from across the

EU and allow, to a certain extent, their comparison but their implementation is incomplete.

The transparency tools are the European Qualifications Framework, Europass and ESCO,

which are closely interlinked. The backbone of this toolbox is the European Qualifications

Framework (EQF), in place since 2008 (and reviewed in 2017), aiming at enhancing the

transparency, comparability and portability of people's qualifications. The EQF is a reference

framework consisting of 8 levels of proficiency of learning outcomes (knowledge, skills,

autonomy and responsibility) that operates as a translation tool between national systems and

supports both lifelong learning and employability. MS are invited to relate their national

qualifications frameworks (NQFs) to the EQF, in order to establish a clear and transparent

relationship between their national qualification levels and the eight EQF levels, through a

process called referencing.

The referencing process uses the EQF referencing criteria as assessment benchmarks. The 10

referencing criteria include the way in which MS use the learning outcomes approach, how

qualifications are included in NQFs and how qualifications are quality assured in line with

national and international standards. National quality assurance bodies and international

experts (at least two) must sign off each referencing report, which needs the endorsement of

the EQF Advisory Group through a specific peer review process. Overall, the referencing

criteria and the governance of the EQF referencing process provide a solid foundation for

trust in NQFs and the EQF as a whole, as also confirmed in the EQF evaluation of 2024.57

However, there is diversity and unevenness across the EU in terms of the implementation of

the EQF through NQFs. While all NQFs are based on learning outcomes, which is a condition

for EQF referencing, they vary in their maturity and the amount and quality of information

they provide on qualifications.

Cedefop has provided information on the stage of development of NQFs.58 Eighteen MS

have reached the operational stage:59 their NQFs provide a map of NQF qualifications and a

reference point for development and review of standards and curricula; NQF levels are

indicated on certificates and diplomas, qualifications registers/databases are functional, and

quality assurance mechanisms are in place. Other nine MS60 are in the activation phase

meaning that the implementation structures and the criteria and procedures for allocation of

qualifications to levels have been set, and the main instruments are being put in place (e.g.

databases, quality assurance arrangements); awareness of end-users is gradually growing.

Another weakness in the use of the EQF and NQFs is the uneven updating of the original

referencing. The recommendation to update the referencing was included with the revision of

the EQF Recommendation in 2017, while mentioning that it should be done with due regard

to the national context. However, as the EQF evaluation concluded, particular focus would be

57 Evaluation of the Council Recommendation of 22 May 2017 on the European Qualifications Framework for

lifelong learning, SWD(2024)141 58 Cedefop, National Qualifications frameworks (NQFs) online tool, 59 BE(NL), CZ, DK, DE, EE, FR, IE, LU, LV, LT, MT, NL, AT, PL, PT, RO, SI, FIN 60 BE(FR), BG, EL, ES, HR, HU, IT, KY, SE, SK

20

needed by MS to ensure referenced reports are up to date. In 10 of the 13 MS that have not

updated their referencing yet, the initial referencing report dates back 10 years or more,61

while 14 MS have updated their referencing report since the EQF revision of 2017.62 While

MS agreed to possible criteria indicating the need to update referencing reports (such as a

national legislative and institutional developments in NQFs), implementation depends on

voluntary choices by MS as to when review and update their EQF referencing; decisions to

update referencing do likely depend on prioritisation and available resources at the national

level.

These weaknesses affect the usefulness of the EQF for employers, who at the same time are

interested in reinforcing the tools. Eurochambres, an EU-level association of employers

exemplified this in their written input: “Companies have an interest in ensuring that

qualifications obtained in other MS are transparent and comparable. This is particularly

relevant in border regions, where businesses rely on daily or seasonal cross-border mobility

of workers. Existing transparency instruments such as the European Qualification

Framework (EQF) and National Qualification Frameworks (NQFs) provide an important

foundation and should be further strengthened and better connected, including through

improved data exchange at EU level”.

The Europass platform intends to operate as a one-stop shop for skills and career

management, with different skills, qualifications and labour mobility tools, including an e-

portfolio, information on qualifications (from NQF registries) and learning opportunities, an

infrastructure for digital credentials (European Digital Credential for Learning infrastructure)

and Europass supplements with a common structure and template: Diploma Supplements

(higher education), Certificate Supplements (VET), and Europass Mobility (learning

mobility). Thanks to their standardised format, the supplements improve the transparency and

comparability of qualifications in an international context, supporting skills portability.

The data shared with Europass consists of an EU database on qualifications77 and the data is

also republished as open data on the EU open data portal. However, ensuring that databases

and registers of qualifications are connected to the Europass platform was still mentioned as

an area of attention by the EQF evaluation. So far 14 MS share data on qualifications with the

Europass platform,78 while an additional two MS79 are testing the system. The other MS have

either not connected their database with Europass,80 or do not have a database at all.81 Among

the 14 MS that do share qualifications data, these do mostly not cover the full scope of the

NQF (some MS share only VET or higher education qualifications), do not contain

permanently updated datasets, and regularly contain poor data quality, in particular on

learning outcomes. Differences in implementation can be explained by the voluntary nature63

of these activities and do likely depend on prioritisation and available resources at the national

level. Transparency, recognition and matching tools, have more recently been complemented

by instruments facilitating the interoperable digitalisation of information related to

qualifications and skills. These include the European Digital Credentials for Learning

(EDC)82 as a multilingual format for electronically sealed, digital presentations of learning

credentials. The EDC Infrastructure is part of the Europass platform and includes ready-to-use

tools for building, issuing and viewing these digital credentials. Issued digital credentials can

be stored directly in the My Library section of a person holding a Europass account. EDCs are

signed using an electronic seal, ensures credential integrity and which must be acquired from

Trusted Service Providers, in line with the EU legal framework for electronic seals, the

61 BE (fr), BG, CZ, DE, EE, EL, HU, LU, PL, SI, SE 62 NL, LV (2019), IE (2020), FR (2021), IT (2022), BE(nl), MT, DK (2023), LT, HR (2024) and RO (2025) 63 While the Europass Decision stipulates the tasks by the Commission and the MS, its article 7 paragraph 2

specifies that the provision of information to the Europass online platform under Article 3(2) shall not create

any additional obligations for MS.

21

eIDAS Regulation. EDCs are designed to promote cross-border recognition of credentials. To

this aim, they are based on a multilingual European standard for semantic interoperability,83

the European Learning Model (ELM). However, EDC is a voluntary tool for any organisation

wishing to issue digital credentials. It was not designed to serve as the single solution for the

digital transformation of all credentials across the Union. Moreover, it was developed before

the EUDI Wallet and is not linked to the digital identity of credential holders, nor does it

provide the same safeguards against fraud. Upgrading EDC to meet such requirements would

require substantial investment. Therefore, EDC is not currently suitable for a Union-wide

rollout.

Some MS have put in place their own measures to overcome information asymmetry on

qualifications and skills obtained in another EU MS (and beyond). Several MS have

developed databases of foreign qualifications helping the understanding and recognition of

these by employers and other stakeholders. These databases do generally have a broad

geographic scope, including EU and non-EU qualifications.64 MS databases and/or country

profiles that include EU qualifications are those of the BE French-speaking Community,

France, Germany, Greece, Ireland, Italy, Netherlands, Poland and Sweden65. For Ireland, the

Netherlands, Poland, and Sweden, - the EQF level of qualifications functions as reference

point. In Ireland an open database of foreign qualifications run by the Quality and

Qualifications Ireland (QQI) covers over 2,000 qualifications from across the world, mapped

to the Irish Q . The Polish “Qualificator” database allows users to obtain an automated

comparability statement with a Polish reference qualification, while the Swedish database

provides for comparisons between foreign qualification types (e.g. a bachelor's in science) in

relation to Swedish qualification types. According to the German Recognition Act, since 2012

all holders of a foreign professional qualification have a legal right to have their professional

qualification assessed for equivalence with a corresponding German reference qualification,

including for non-regulated professions. The German BQ Portal supports this right by

focusing on comparing curricula (learning activities), but it does not use the EQF levels as

reference point. Similarly, the Anabin database facilitates classification of foreign

qualifications for regulated professions within the German education system, also without

reference to the EQF.

While these different databases fulfil different national needs, they do not use the same terms

and definitions, they do not use the same reference points, and there is no coordination

between them. Taken together, there is fragmentation, a lack of interoperability and

duplication of work, time and resources by MS.

Driver 2: Labour market actors cannot verify (and workers cannot efficiently prove) the

authenticity of qualifications and skills credentials issued in another EU MS

As noted in the Europass evaluation, “(…) employers face difficulties when verifying the

authenticity of candidates’ qualifications or experience (59% of them consider this process to

be sometimes difficult or often difficult). erifying the authenticity of a candidate’s

qualifications is very important for employers when it comes to hiring (71% of respondents

consider it very important or somewhat important). Slightly more than half of them (54%)

consider receiving digitally certified documents proving qualifications to be important”.

64 See Cedefop National qualifications frameworks (NQF) online tool: www.cedefop.europa.eu/en/tools/nqfs-

online-tool/overview64 See Cedefop National qualifications frameworks (NQF) online tool:

https://www.cedefop.europa.eu/en/tools/nqfs-online-tool/overview. 65 Non-exhaustive list, based on preliminary findings of the ENIC Bureau and NARIC Advisory Board

Preliminary survey conducted in 2025.

22

The education and training systems are organised differently across 27 MS. Combined with

the diversity of credential systems and related verification methods across MS, it makes it

difficult for labour market actors to verify the authenticity of credentials.

This is a problem across all professions, regulated and non-regulated. In fact, for the regulated

professions, for which a recognition process is observable, authenticity verification is one of

the most resource-intensive elements of the recognition procedure, and a recurring source of

both direct and indirect delay. In regulated professions, trust between MS is the foundation on

which the recognition system built by Directive 2005/36/EC (PQD) rests. The general system,

the automatic recognition regime for sectoral professions and the various forms of

administrative cooperation established under the Directive all depend on the assumption that a

qualification document presented by an applicant genuinely corresponds to training actually

completed and genuinely awarded by the institution named on it. Where that assumption

cannot be relied upon, the whole architecture of mutual recognition is put at risk. Competent

Authorities (CA) survey evidence collected for the SPI Action 2 impact assessment confirms

that the time required for authenticity checks is cited as a distinct source of delay in

recognition procedures, and that core assessment activities, including document authenticity

checks alongside equivalence assessment and drafting of decisions, frequently require 30 or

more man-days annually. This burden is compounded by the continued reliance on paper-

based documentation in many MS and professions, since paper documents are not inherently

verifiable and require additional authenticity checks that are increasingly complex in light of

evolving fraud risks, including AI-based falsification. The consequences extend beyond CA

workload: the survey evidence also indicates that a degree of institutional caution, including

doubts about the authenticity of documents, contributes to the broader pattern of procedural

prudence that CAs apply when assessing qualifications obtained in another Member State,

even though this is not formally identified as a problem driver in the impact assessment.

The shift to interoperable, verifiable digital attestations is the single most consequential

structural response available to this problem. In case of regulated professions, for example, an

automatic authenticity checks at the point of verification thanks to the digital attestations,

rather than through a subsequent, resource-intensive process, would remove the need for the

manual, document-by-document authenticity checks that currently consume significant CA

staff time. This is reflected in the policy options considered for Action 2, which assume as a

pre-condition that as a result of Action 1 a legal obligation would be set on MS to issue

qualifications as interoperable digital attestations meeting common EU requirements on

verifiability, authenticity, trust and interoperability, and a corresponding obligation on host

MS to accept such attestations as valid evidence without further authenticity confirmation

from the home Member State.

The rollout of digital credentials has been uneven between MS so far. Based on Annex 8.3

table 2 on digital credentials66, an initial assessment of MS readiness to issue digital

credentials was developed. The variables used were the digital credentials tools that are in

use and the infrastructure that is already in place, the digitalisation status (whether digital

credentials are actually in use or not) and the digital diploma legislation (whether an enabling

legal basis exists or not for their issuance). This led to an identification of three types of MS:

• Type A: Advanced (6 MS): EE, ES, HR, IT, LT, NL. National or multi/regional

infrastructure in place and confirmed use.

• Type B: Developing (14 MS): BE, BG, CZ, DK, FI, FR, LU, LV, MT, PL, PT, RO,

SE, SI. Some infrastructure present but use limited, partial, or unconfirmed — or

partial use without stable national infrastructure.

66 Developed based on structured mapping of the study supporting the impact assessment, the survey of the EQF

NCPs, Cedefop and ReferNet survey on digital credentials.

23

• Type C: Early development (7 MS): AT, CY, DE, EL, HU, IE, SK. No national

infrastructure; where a tool type is coded, reliance is on EU-level tools only with no

confirmed national uptake.

This progressive digitalisation of qualification credentials in MS is occurring in an

uncoordinated manner. Achieving interoperability requires technical alignment67 and shared

semantics (e.g. common skills taxonomies and qualification descriptions). Many systems rely

on national standards or closed networks, which hinder EU-wide scalability. This entails the

risk of a fragmented digitalisation across MS that could ultimately make even more difficult

for employers to simply read and verify the qualification credential acquired in other MS

because they would not have at their disposal the software necessary to understand the digital

credentials.

A key development in the context of interoperable digitalisation has been the Regulation on

electronic identification, authentication and trust services (eIDAS) of 23 July 2014

(Regulation (EU) No 910/2014). The eIDAS Regulation has created standards for electronic

signatures, qualified digital certificates, electronic seals, timestamps, and other proof for

authentication mechanisms which enable electronic transactions, with the same legal standing

as transactions performed on paper. The eIDAS Regulation was reviewed in 2024. The

eIDAS 2.0 includes the European Digital Identity Wallet (EUDI Wallet), which requires that

MS have a compliant wallet available by the end of 2026, the use of which by citizens is

voluntary. Each version of the wallet will be interoperable and will work across the EU.

EUDI Wallets will be able to store and share a wide range of digital documents, including

driving licence,68 social security documents69 and the digital travel credentials70.

Qualifications are listed among the individual's attributes that could be included in an EUDI

Wallet. To this end however, specific sectoral requirements (e.g. on the trust framework, the

attestation content, the governance) need to be laid down in sectoral legislations, as it is the

case of the driving licence and will be proposed for social security documents.

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.71 The target system explored by the DC4EU project

was an integrated digital ecosystem that addresses potential fraud and credential validation

challenges, complies with European educational and professional qualification standards,

increases acceptance among all relying parties (employers, educational institutions,

professional bodies) and supports the free movement of professionals and students across the

EU. The DC4EU framework for educational and professional qualification credentials is

based on an architecture that includes the European Learning Model (ELM) as semantic

foundation, and the W3C Verifiable Credentials Data Model for technical implementation.

67 In the survey of issuers of qualifications, among the 89 respondents who already issued verifiable credentials,

14 issued W3C Verifiable Credentials, 12 issued JSON Web Tokens and JWS, 1 issued IETF SD-JWT VC, 13

another format (in particular EDCs which are W3C Verifiable Credentials and Open Badges which are

transitioning towards the W3C Verifiable Credential format or a combination of formats, including XML or

JSON metadata in a signed PDF) and 49 did not know. 68 Directive (EU) 2025/2205 69 With the upcoming ESSPASS proposal 70 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52024PC0671 71 MS involved include AT, BE, CZ, DE, DK, EL, ES, FI, FR, HU, IE, IT, LT, LU, MT, NL, PL, PT, RO, SE +

NO, CH, UA (14 MS + NO and UA were involved for the pilot on education attestations, the others piloted only

the social security use case). The types of organisations include higher education institutions (DK, EL, FR, IE,

IT, LU, PT), a combination of Higher education institutions and Ministry of education and training (ES, NL,

RO), a Ministry/agency only (FI, SE, NO, UA), a foundation working on education (MT), and the National

Information Processing Institute supervised by the Ministry of Education and Science (PL)

24

The EUDI Wallet complements the Single Digital Gateway Regulation (SDGR) (Regulation

(EU) 2018/1724) which facilitates the online access to information, administrative

procedures, and assistance services that EU citizens and businesses may need in another EU

Member State. It includes procedures for the academic recognition of diplomas, certificates or

other proof of studies or courses. There is no procedure today in the SDGR to request a

diploma for the purpose of applying for a job in another EU MS. To implement the SDGR,

the Once-Only Technical System (OOTS) was created as the core infrastructure. It aims to

save EU citizens and businesses time and money by allowing the automatic exchange of

official documents and data (such as diplomas, certifications or permits) between the

‘competent authorities’ that issue this data and the public body requesting the data. The E M

was recently complemented with new data fields to cover the education-related use cases

from the OOTS, allowing for the exchange of structured data.

In addition, paving the way for a potential inclusion of qualification in the EUDI Wallet, a

common floor of standardisation is already in place: all MS have referenced their NQFs to the

EQF. MS are aware of the European Learning Model (ELM), which provides a shared

vocabulary for describing learning outcomes. As indicated earlier, 14 MS share data on

qualifications with the Europass platform,72 while an additional two MS73 are testing the

system and are therefore able to share data in the European Learning Model (ELM)

format.74 As of July 2026, the other MS have either not connected their database with

Europass,75 or do not have a database at all.76 All MS have been invited to training sessions

on the ELM over the years and MS are kept informed and shape the changes in the data

model via the EQF AG and the Europass AG. ELM has also been discussed to become a

semantic model to be supported in OOTS for exchanging structured data for the

studying procedures. While a formal decision has not yet been made for its inclusion, there

is a strong awareness of the semantic model across the MS in the SDGR group.

All 27 MS participate in the implementation of Europass and discuss the topic of digital

credentials in the Europass AG and are familiar with verifiable digital credentials. 18

countries piloted the Europass digital credentials between 201977 and the official launch

of EDC in 2021.78 As the implementation of EDC is voluntary and open, there is no official

MS participation in its implementation. No complete data of EDC issuers exist due to the

absence of tracking of the issuers and users. Certain MS, such as MT,79 LU80 and ES81 are

among the most active EDC users.

72 AT, BE (nl), CZ, DE, EE, FR, IE, LV, LT, MT, NL, PL, SE, SI 73 BE (fr), EL 74 Two other MS (HU, PT) used to share qualifications information with Europass in legacy data formats that are

no longer supported and have not yet started to use ELM 75 DK, ES, FI, HR, HU, PT, RO, SK 76 BE (de), BG, CY, IT, LU 77 Europass Digital Credentials Infrastructure | FUTURIUM | European Commission and the Europass evaluation

report: EUR-Lex - 52024SC0071 - EN - EUR-Lex 78 Launch Event Report - European Digital Credentials for Learning | Europass 79 European Digital Credentials for Graduates - Newspoint - University of Malta 80 La formation professionnelle adopte les European Digital Credentials, des attestations de réussite numériques

reconnues en Europe - News - Education nationale, Enfance et Jeunesse - Luxembourg and a mise en œuvre

des attestations de réussite numériques dans la formation professionnelle sacrée « meilleur projet de

transformation digitale de l’année » - Actualités - Education nationale, Enfance et Jeunesse - Luxembourg 81 Proyecto CertiDigital | Credenciales Digitales para el Sistema Universitario Español

25

On the readiness regarding the implementation of the EUDI Wallet, no MS has yet certified

a production wallet compliant with eIDAS 2.0, which can be explained by the fact that the

latest specifications detailed in the Commission Implementing Regulation of 15 July 202682

are yet to enter into force and the fact that MS have until December 2026 to offer an EUDI

Wallet to their population. During the EUDI Wallets launchpad event of December 2025,83

“the demos revealed different levels of readiness across MS, alongside a powerful

opportunity: some countries are ready to lead, while others bring complementary strengths,

sectoral expertise, or user reach”.84 Figure 1 presents the overview of MS maturity and

readiness in December 2025.

Figure 1 - MS digital wallet readiness (from the 2025 EUDI Wallet launchpad event key takeaways)

The analysis of MS readiness was further refined when cross-checked with DC4EU data and

data from the EMREX network. On education credential infrastructure the ordering is

close to inverted: several of the MS operating the most mature national diploma registers,

sector agencies and student data exchange arrangements are among those least advanced on

the wallet substrate into which those credentials would have to be issued. Different

governance exists across the 27 EU MS, which also needs to be accounted for when

proposing issuance solutions of qualifications. This analysis led to the clustering of MS into

four groups (see point 5 in Annex 8 for additional information):

• Cluster A (4 MS): DE, DK, FR, IT. Wallet-ready front-runners (production or public

sandbox)

82 Implementing regulation - EU - 2026/1730 - EN - EUR-Lex 83 EUDI Wallets Launchpad - EU Digital Identity Wallet - 84https://ec.europa.eu/digital-building-

blocks/sites/download/attachments/924975727/EUDI%20Wallets%20Launchpad%20-

%20Event%20Key%20Takeways%20report.pdf

26

• Cluster B (4 MS): EE, FI, NL, SE. Education-credential leaders, slower wallet

substrate

• Cluster C (9 MS): AT, BE, EL, ES, IE, LU, MT, PL, PT. Engaged fast followers

(Tier 2 eID app or strong governance role)

• Cluster D (10 MS): BG, CY, CZ, HR, HU, LT, LV, SI, SK, RO. Building / lagging

substrate

Issuance is at the same time organised around two persistent topologies, with the trust chain

running either through a national research and education agency acting as an aggregation

layer for autonomous institutions, or through a ministry or a central diploma register,

and both are expected to coexist. The consequence for the labour market actors of the

digitalisation described above is that the ability to verify a qualification depends less on the

qualification itself than on where it was awarded and on the sequencing of national digital

programmes pursued for unrelated reasons.

In addition, there is the issue of lack of legal clarity regarding the acceptance of digital

documents from another MS, leading to a digital trust gap where even when digitally issued

credentials are available, they may not always be understandable, verifiable and trusted across

MS. The Beyond DC4EU report85 highlights the risk of fragmentation, writing that “If MS

develop divergent interpretations of which credentials must be accepted and under what

conditions, cross-border recognition risks becoming contingent on bilateral practices rather

than on the uniform application of Union law. In such a scenario, a credential that is routinely

accepted in one Member State may be questioned or rejected in another, not because of

differences in cryptographic security or issuance quality, but because national authorities have

formed different views on acceptance obligations, liability exposure, or supervisory

responsibility. Pilot experience indicates that once such interpretations are embedded in

operational systems and verifier workflows, they are difficult and costly to reverse”.

Overall, this complex landscape shows that there is a diversity of credentials systems in the

EU, complicating authenticity checks, and while digitalisation offers a way to simplify

authenticity checks and at the same time improve the availability of standardised and reliable

information on qualifications, the take up among the MS is varied, and even with tools such

as EUDI Wallet, Europass and the SDG interoperability is not possible to achieve without

sectoral legal standardisation.

Stakeholder views: When asked about concerns regarding EU-level digital credentials, 351

out of 581 public consultation respondents cited technical complexity or lack of compatibility

between systems, and 303 out of 581 pointed to data privacy or security concerns. In the

issuer survey, 228 of 574 identified limited technical capacity as the main barrier to

digitalisation.

2.4. How likely is the problem to persist?

Evidence available from across all stakeholder consultation activities indicates that the

problem and its drivers are likely to persist in the short- to medium-term without EU action.

The imperfect information on qualifications obtained in another MS will continue to

complicate hiring procedures for employers and mobile workers.

MS have made efforts to develop databases which facilitate comparability with non-national

85 https://www.3cl.org/wp-content/uploads/2026/01/Beyond-DC4EU-Final-Report-January-2026-1.pdf

27

qualifications.86 However, these national efforts would continue to duplicate work and cost

time and resources for individual MS. The only current EU level database on qualifications

is the Europass platform. However, without further measures its completion will be slow and

its effectiveness as a tool for labour market actors to compare qualifications from other MS to

national qualifications will remain limited.

Despite MS advancing in digitalisation efforts, progress remains uneven and risks

producing a growing divide between early and late adopters. In the long term, in the

absence of EU coordination and standards, fragmentation would persist and deepen as MS

would adopt non-interoperable digital solutions87 at varying speed and scope and digital

credentials would not necessarily be accepted across MS because of lack of clarity on their

legal status.

Technological developments, including AI-enabled solutions, are expected to facilitate

certain aspects of cross-border qualification recognition over time, but they are unlikely

to address the identified problems on their own. Current evidence suggests that AI is likely

to complement rather than replace existing recognition processes. The Council of Europe

survey of 138 recognition institutions88 found that AI applications are currently used mainly

for fraud detection, document verification and translation, while automated comparability

assessments remain limited. The survey also identified barriers to wider deployment,

including concerns related to data protection and security, legal certainty, technical expertise,

funding, and the availability of high-quality, structured and trusted data. As further addressed

in the section 5.1.1. of the Impact Assessment, AI relies on the availability of reliable and

trusted information and cannot replace authoritative sources of qualification information.

Consequently, official NQF databases and registers will remain essential as quality-assured

reference sources for cross-border recognition. The Council of Europe further emphasises that

AI should support, rather than replace, human decision-making in recognition procedures.

While AI is therefore expected to support certain aspects of the recognition process, it is

unlikely to remove the underlying barriers identified in this Impact Assessment.

Similarly, SPI Action 2 impact assessment's own baseline projection anticipates that the

gradual uptake of digital credentials and authentication tools may reduce fraud risks in those

MS and professions where such tools are fully integrated into administrative workflows, but

that these improvements are unlikely to translate into system-wide efficiency gains, given the

voluntary and non-binding nature of most relevant EU instruments and the continued reliance

on hybrid or paper-based procedures in many jurisdictions. Fraud techniques are, moreover,

becoming more sophisticated rather than less, with AI-based falsification identified as a

growing complicating factor for CAs' existing manual authenticity checks. Left unaddressed,

authenticity risk will therefore continue to generate both a direct administrative cost for CAs

and a broader, harder-to-measure cost in the form of continued institutional caution towards

qualifications obtained elsewhere in the Union, which in turn constrains the trust on which

faster and less document-intensive recognition procedures depend.

87 The eIDAS Regulation 910/2014 article 45e (and the annex VI) lists the elements Qualified Trust Service

Providers can ask public authorities to verify before issuing electronic attestations of attributes. This includes

educational and professional qualifications, titles and licences. However, this is not an obligation for MS to

issue such documents, and even when individual MS decide to issue qualifications into the EUDI Wallet,

other MS would still be unable to read or give legal meaning to such digital qualification attestations. 87 The eIDAS Regulation 910/2014 article 45e (and the annex VI) lists the elements Qualified Trust Service

Providers can ask public authorities to verify before issuing electronic attestations of attributes. This includes

educational and professional qualifications, titles and licences. However, this is not an obligation for MS to

issue such documents, and even when individual MS decide to issue qualifications into the EUDI Wallet,

other MS would still be unable to read or give legal meaning to such digital qualification attestations. 88 Situational Analysis Report Highlights Human-Centred AI in Qualification Recognition,

https://rm.coe.int/situational-analysis-report-ai-may-2026/48802c0145

28

Overall, if the current fragmentation of availability of digitalised, secured and interoperable

information on qualifications and skills and the underlying imperfect information persists, EU

workers are likely to continue experiencing less favourable conditions in accessing the labour

market in other MS, and business are going to continue bearing higher costs when recruiting

workers across the Single Market. The digital fragmentation in particular is estimated to

become more costly each year, as MS that start to adopt digitalisation of credential systems

will have no incentive to adopt a system which allows for full interoperability across the EU.

Despite the EUDI Wallet rollout, the EU interoperability, and, thus, seamless portability of

qualifications and skills across the EU, would not be guaranteed89.

3. WHY SHOULD THE EU ACT?

3.1. Legal basis

The initiative is based on Articles 45 and 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 MS (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).

3.2. Subsidiarity: Necessity of EU action

The free movement of people is a fundamental principle of the European Union. To fully

benefit from this right, individuals must be able to rely on the qualifications awarded in any

MS when they apply for, take up or pursue a professional occupation in another MS. The

digitalisation of qualifications will facilitate their portability across the EU only if it is

carried out in a harmonised and interoperable way across MS. Solutions implemented by

a single country will not ensure the benefits for the Single Market but rather deepen its

fragmentation. The Commission initiative in this area is timely, because the EUDI Wallet will

come into application at the end of 2026: the EUDI framework regulates and harmonises the

issuance of attestations via a trust service and via public bodies (which can include issuance

of education and training credentials). Moreover, some MS have already introduced or

announced to introduce the possibility to request electronic qualifications under their

jurisdiction (e.g. FR, FI, IT and ES). To avoid a situation where digitalised qualifications

cannot be relied on in other countries due to a lack of interoperability, it is timely for the

Union to act by adopting a measure harmonising digital qualifications across the EU. In

absence of EU-level legislation, there is a risk that the differences between MS will deepen

which could further exacerbate the existing obstacles.

3.3. Subsidiarity: Added value of EU action

Barriers related to qualifications and skills contribute to the existence of obstacles to the free

movement of people who wish to work in another MS. 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 MS and tools

facilitating effectively the portability of such qualifications and skills, businesses and workers

89 Ibid.

29

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, rather than through

individual efforts by MS.

The added value of ensuring availability of verifiable, secure, digitalised and interoperable

information on qualifications and skills obtained in the EU is that EU citizens will be

equipped with digital qualifications that are easily accessible to them as holders of

qualifications, their potential employers and in case of regulated professions in accordance

with Directive 2005/36/EC the recognition authorities in MS. Employers will also have access

to tools enabling better understanding and comparison of qualifications issued in different

MS. Thanks to the common legal and technical framework underpinning the digitalisation of

qualifications, digital qualifications issued in another MS will become more trustworthy and

easier to verify. Digital qualifications issued in a standardised manner will be understood

everywhere in the EU. This in turn will make job applications less cumbersome and facilitate

smoother access to jobs in all MS. While fully respecting MS’s responsibility for education

and training, the expected added value of this action will be greater portability of

qualifications and skills listed by MS in their national qualification frameworks and issued in

a harmonised digital format.

Creating momentum in advancing European digital policies and contributing to

transforming the EU into a modern, resource-efficient and competitive economy. An EU

action will help accelerate the digitalisation of cross-border public services90, ensure a well-

functioning, integrated digital single market, ultimately benefitting European competitiveness.

By building on and reinforcing key digital EU initiatives - such as the 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 MS. If the EU does not act now, actions

by MS would likely lead to fragmented, uncoordinated, incompatible solutions that fail to

integrate with existing EU initiatives. This could result in suboptimal outcomes and be more

costly to reverse at a later stage. An initiative in digitalising diplomas could furthermore pave

the way for the adoption of similar solutions for other documents relevant for individuals and

companies in cross-border situations.

4. OBJECTIVES: WHAT IS TO BE ACHIEVED?

4.1. General objective

The general objective of the initiative is to facilitate portability of qualifications and skills

between MS in the context of free movement of workers. In practice, this means ensuring

that labour market actors in the EU have access to simplified, effective and cost-efficient

ways to carry, prove, read, understand and compare qualifications and skills obtained in

another Member State.

This general objective builds on existing EU tools and solutions supporting the use of

qualifications and skills across borders and is aligned with several Commission priorities. It

responds directly to the agreed roadmap of the European Institutions to achieve “One

Europe, One Market” to “strengthen the portability of qualifications and skills across

national borders, including through digitalisation and interoperability”. It reinforces the

simplification agenda of the European Commission by aiming at faster, less burdensome,

digital-by-default processes for workers moving between MS. It also supports the EU

90 State of the Digital Decade 2025 - Factsheet | Shaping Europe’s digital future where the percentage of digital

services to individuals and businesses are key indicators.

30

Competitiveness Compass, which identifies retaining and mobilising talent across the EU as

key to boosting the Union’s competitive standing, by ensuring that skills and qualifications

acquired in one MS 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. Taken together, these links position the

initiative as a concrete step forward towards the completion of the Single Market, reinforcing

the free movement of workers.

4.2. Specific Objectives

Specific Objective 1. By the end of the transition period, labour market actors have access to

reliable and comparable information on skills and qualifications 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.

These Specific Objectives are further broken down into Operational Objectives (OO) in

Section 9, where, considering the preferred Policy Option (PO), the means to measure them

for a given timeframe are defined for monitoring and evaluation purposes.

The Specific Objectives 1 and 2 positively contribute to multiple SDGs:91

• SDG 8 (Decent Work and Economic Growth). Enhances labour mobility, improving

job matching and equal opportunities (Targets 8.2, 8.3, 8.5).

• SDG 10 (Reduced Inequalities). Supports cross-border qualifications acceptance and

reducing disadvantages faced by EU mobile workers (Targets 10.2, 10.3).

• SDG 9 (Industry, Innovation and Infrastructure). Strengthens digital

infrastructure, interoperability and EU innovation (Target 9.1), aiding cross-border

talent mobility.

5. WHAT ARE THE AVAILABLE POLICY OPTIONS?

5.1. What is the baseline from which options are assessed?

This section describes the most likely evolution of the current situation in the absence of

additional EU-level intervention. The baseline follows a 'no-policy-change' approach,

incorporating existing and possible future developments in national, EU-level and global

policies, as well as relevant Commission proposals not yet adopted by co-legislators. It builds

on the policy and problem contexts described in Sections 1 and 2, and accounts for expected

economic and social developments by drawing on available foresights and forecasts.

Availability of reliable and comparable information on qualifications

The EQF Council Recommendation will continue to invite MS to establish National

Qualifications Frameworks, to reference them regularly against the EQF in a peer reviewed

process, and to maintain registries of national qualifications connected to the Europass

platform. However, whether MS do so will remain entirely at their discretion, which limits the

value of the public good that aggregated, up-to-date, and comparable official information

would otherwise provide. The effectiveness of the existing qualifications comparison tool on

Europass will remain limited without continues and up-to date official information supplied

by MS.

91 See point 3 of Annex 3 for a more developed overview of relevant SDGs for the preferred options.

31

14 MS have already connected their national qualifications databases/registries with Europass

and more MS with an existing database/registry may decide to connect with Europass (e.g.

some MS are already testing the system). The update of the information, once the MS have

connected their databases/registries, depends on the willingness of MS. The accreditation

database for higher education is already connected with Europass.

The increasing role of AI in comparing qualifications

While AI-enabled tools are expected to play an increasing role in supporting the comparison,

translation and verification of qualifications, they are unlikely to eliminate the underlying

problem drivers identified in this initiative. AI systems can facilitate access to information

and improve administrative efficiency, but they remain dependent on the availability, quality

and interoperability of authoritative qualification data.92 Where official, structured and up-to-

date information is unavailable, incomplete or inconsistent across MS, AI systems are likely

to reproduce these shortcomings and may generate inaccurate or biased results.93

Moreover, AI systems cannot, on their own, establish the authenticity of a qualification or

confirm that a qualification is genuinely linked to the individual presenting it.94 The future

deployment of AI solutions in this area will also take place within the framework established

by the AI Act.95 In particular, AI systems used in education, vocational training and

employment are subject to specific requirements where they qualify as high-risk AI systems,

including obligations relating to risk management, data quality and governance, transparency,

human oversight, accuracy and record-keeping. Actually, workers whose qualifications are

issued in non-standardised formats, or whose credentials are less readily interpretable by

automated systems, may consequently be disadvantaged in digital recruitment.96 The

safeguards of the AI Act are expected to support the trustworthy deployment of AI in

qualification-related processes, but they do not remove the need for reliable, quality-assured

and interoperable qualification information and verifiable digital credentials, which remain

the primary objective of this initiative.

Interoperability of digital attestations

While digital tools hold promises for improving the comparability and verification of

qualifications, uneven and uncoordinated adoption in MS is expected to deepen rather than

resolve fragmentation across MS. Most credentials will likely remain paper-based or non-

verifiable, and without EU-level coordination on semantic frameworks, data standards, and IT

infrastructure, cross-border interoperability will remain limited as none of the MS has an

incentive to act as first. Some MS have already established digital diploma registers,

digitalising their diploma archives, while some MS may take other approaches: keeping

archives decentralised or creating digital archives for recent documents only. Please refer to

Annex 8 for a full breakdown of the information by MS. MS will continue implementing the

Single Digital Gateway Regulation (SDGR) and the Once-Only Technical System

92 Symeonidis, V. & Blomqvist, C., 2025, Policies and tools for comparing and recognising VET qualifications

in Europe: an overview, Cedefop working paper, p. 33 93 CIMEA, 2023, Artificial intelligence and recognition of qualifications: opportunities and risks from an

ENIC-NARIC perspective; Symeonidis, V. & Blomqvist, C., 2025, Policies and tools for comparing and

recognising VET qualifications in Europe: an overview, Cedefop working paper, pp. 33 and 36. 94 Finocchietti, C. & Lantero, L., 2025, Diploma mills and fraudulent credentials: The cost of fraud in education,

pp. 127–128 95 AI Act Single Information Platform | AI Act Service Desk 96 SPI study, ase study on Shipbuilding Socoliuc, . ., icolae, ., Pleșea, D. A., & Suciu, D. A., 2024, EU

maritime industry blue-collar recruitment: Sustainable digitalization; OECD, 2026, Why data matters for

shipbuilding industrial policy

32

(OOTS). It is expected that they will finalise the provision of fully online procedures for the

three studying procedures, which will lead to the connection of evidence providers related to

qualifications information between public institutions. The digitalisation of diplomas is not

explicitly covered by the SDGR97 and will likely be even more limited and fragmented. In

addition, the format of the documents is expected to remain diverse as the SDGR provides

MS the flexibility to choose their own output format (e.g., PDF, structured data), while still

adhering to certain requirements.

Independently of the SPI, MS will progressively make available standardised EU Digital

Identity wallets to all EU citizens and residents by December 202698. EUDI Wallets will

provide a safe, reliable, and private means of digital identification for everyone in Europe.

Every MS will provide at least one wallet to all its citizens and residents allowing them to

prove who they are and securely store, share, and sign important digital documents (such as

an ID card or a driving licence). This IT infrastructure is therefore considered to be part of the

baseline for this initiative. However, whilst the eIDAS 2.0 impact assessment99 highlighted

educational qualifications as a key sector benefiting from the EUDI Wallet rollout100, the

eIDAS Regulation101 only covers personal identity, the legal trust framework and the general

wallet functionality. It is not guaranteed that all MS will use it to digitalise qualifications and

skills. Furthermore, those MS that do choose to use it will have the freedom to choose the

scope, the layout, the content and the underlying technical format of their qualifications

making interoperability increasingly difficult. The DC4EU large-scale pilots clearly

demonstrated the business case for a harmonised approach across the education and training

landscape in order to facilitate cross-border use. Unilateral actions - without EU level legal

harmonisation of the sectoral use particular sectors to ensure uniformity in formats, standards

and rules - could pose challenges regarding the acceptance and verification of these

documents in other MS with consequences for individuals and employers.

The EUDI Wallet will be free of charge for citizens to use. Relying parties (the public and

private entities that wish to request or verify credentials from a citizen's wallet) will instead be

subject to a mandatory registration process. Depending on how MS implement this at national

level, this registration may involve moderate administrative costs or fees, though the precise

cost for relying parties is still being defined in several MS.

The Interoperable Europe Act establishes structured EU cooperation on interoperability,

introduces mandatory assessments to evaluate the impact of changes in IT systems, promotes

the sharing and reuse of interoperable solutions through the Interoperable Europe Portal, and

provide innovation and support measures for policy experimentation. As a horizontal

framework, its implementation alone will not resolve the cross-border sector-specific

challenges identified in the report.

The Europass EDC infrastructure already enables education and training providers to issue

digital learning credentials and allows users to store them in their Europass wallet. However,

the current uptake is not expected to improve or increase, as those who bear the burden of

97 Digitalised documents under the SDGR studying procedures are the decision on the application for financing

or acknowledgement of receipt; the confirmation of the receipt of an application to public tertiary education; and

the decision on the request for academic recognition. For these procedures, qualifications may be used as

supporting documents. 98 The impact assessment for the EUDI framework estimates the total costs for public authorities to range

between EUR 850 million and 910 million. 99 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52021SC0124 100 Educational and professional qualifications are listed in the Annex VI of the Regulation as an obligation for

MS to verify the information when requested to do so by Qualified Trust Service Providers. 101 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1183

33

issuing digital qualifications (education and training providers) are not necessarily the same

actors who benefit most from them (those who need to understand and verify the

qualifications, such as employers). As with the EUDI Wallet, it is not guaranteed that MS

which independently choose to digitalise their qualifications will select Europass as their IT

infrastructure.

Demographic ageing and labour shortages

Demographic ageing and shrinking working-age populations are increasing the pressure on

employers, particularly in shortage sectors, to recruit across borders. Many are already

responding by accepting non-national qualifications even if they do not fully understand them

and use digital tools to verify them informally. However, these ad hoc solutions are

inconsistent and unreliable in the absence of common standards. This will leave EU talent

underutilised and constrain the Single Market's capacity to match skills to labour demand,

even as demographic pressures make such matching increasingly urgent.

5.1.1. Key figures and considerations in the baseline

Different levels of digital readiness for MS

MS are assumed to have different levels of digital readiness in the baseline. This digital

readiness is expressed as a probability (from 0 to 1) and relates to issuing digital

qualifications as verifiable credentials into a wallet or a fractional percentage readiness for

database connection.

On the one hand, there is the probability of MS adopting the baseline of issuing digital

qualifications as verifiable credentials into a wallet. It is based on the analysis carried by

DC4EU as well as additional analysis on MS readiness (see section 2.3 and point 5 in Annex

8 for more details). In particular, the clustering into four groups related both to their EUDI

Wallet readiness and readiness to issue digital qualifications, the adoption of other joint IT

systems (such as EMREX), actual participation in DC4EU, the existence of diploma registers

and the MS topology of issuance contribute to the probability factor.

On the other hand, there is the database connection readiness of MS. MS which already

have a connected database in the current ELM format receives the highest level of readiness

(while not 100% as SPI will also introduce the awarding body and accreditation information,

which can be combined with the qualifications information); MS with a database not

connected to Europass receives a lower score and MS without any database receive the lowest

readiness score.

Table 1 Levels of digital readiness per Member State102

Member State

Baseline probability of MS

adopting the EUDI Wallet

for digital qualifications in

their jurisdiction (0-1)

Qualification database

connection readiness (0-

1)

Austria 0.6 0.8

Belgium 0.55 0.75

Bulgaria 0.3 0.15

Croatia 0.35 0.25

Cyprus 0.35 0.15

102 All details for the elaboration of this table can be found in Annex 8.

34

Czechia 0.4 0.8

Denmark 0.7 0.8

Estonia 0.7 0.5

Finland 0.75 0.5

France 0.65 0.8

Germany 0.6 0.8

Greece 0.7 0.6

Hungary 0.4 0.5

Ireland 0.65 0.8

Italy 0.7 0.25

Latvia 0.35 0.8

Lithuania 0.45 0.8

Luxembourg 0.5 0.25

Malta 0.45 0.8

Netherlands 0.85 0.8

Poland 0.5 0.8

Portugal 0.45 0.8

Romania 0.4 0.5

Slovakia 0.4 0.8

Slovenia 0.4 0.8

Spain 0.75 0.5

Sweden 0.8 0.8

Number of verifications of qualifications issued in another Member State

As previously underlined, the individual decision-making processes of employers cannot be

observed, nor aggregated. The number of qualifications issued in another Member State that

employers verify each year must therefore be estimated.

The annual flow of EU mobile workers is approximately 957,000103. It is assumed that

companies requiring qualifications when advertising a vacancy and/or as part of the

application process will verify at least the authenticity of the qualification of the selected

applicant.

An ad-hoc query of the Skills Online Vacancy Analysis Tool for Europe yield that 23% of

online vacancies include at least one wording directly related to qualifications. In the SME

Pannel 29% of respondents declared that they request qualifications when hiring. Applying

these percentages to the annual flow of EU workers yields an estimated range of 220,110 -

277,530 qualifications issued in another MS verified per year.

This estimate can be considered as conservative as it takes as a basis only the flow of mobile

workers (hence mobile workers who apply to change jobs in the MS they already reside are

not counted) and does not include cross-border workers104.

Number of comparability statements for qualifications issued in another Member State

The estimate is based on an ENIC-NARIC survey on the number of comparability statements

processed by MS. Since survey coverage was incomplete, responses are weighted by each

Member State's share of the inflow of other EU citizens (2019–2023), and missing values for

non-responding MS are extrapolated using the average of those that did respond. This

103 Annual report on intra-EU labour mobility - Employment, Social Affairs and Inclusion (2025) 104 For further justification of these percentages and reference, see Section 2 on problem definition

35

produces an estimated total of 196,261 comparability statements annually. Since only about

half of these concern EU citizens, the figure is halved to roughly 98,000, then rounded down

to 90,000, which is used as a deliberately conservative baseline estimate.

Number of education and training providers in the EU that issue qualifications relevant for

the labour market

Both VET and HE institutions are counted as providers issuing qualifications relevant for the

labour market. For VET institutions, two methodological approaches are used to produce the

lower and upper bounds of the range: a conservative approach and a comprehensive approach.

The conservative approach entirely excludes specialised schools and, for mixed-curriculum

institutions offering both vocational and general education, applies a 50% weighting factor to

balance the representation of programmes; this yields a baseline of 27,762 VET institutions.

The comprehensive approach includes specialised schools and counts mixed-curriculum

institutions at full (100%) capacity, yielding 39,328 VET institutions.

For VET, institutions were further categorised into Public and Non-Public, with government-

dependent private and private institutions consolidated into the non-public category; no

equivalent public/non-public distinction was made within the HE sector. VET data is drawn

from Eurydice105, while HE data is drawn from EQAR's Higher Education Institutions (HEIs)

dataset106, with both datasets relating to 2024. One exception applies to Hungary, where the

public/non-public distinction for VET schools could not be applied. Combining VET and HE

figures, the final estimated range of education and training providers considered is 32,788 -

44,354. The full matrix of education providers by VET and HE institution, including source

data and detailed methodology, is presented in Annex 8(7).

Table 2. VET and HE providers per Member State

MS Vocation Educational School

(VET) Conservative Approach

Vocation Educational School (VET)

Comprehensive Approach

Higher

Education

Public Non-

Public VET_MS Public

Non-

Public VET_MS HE_MS

AT 196 137 333 196 137 333 79

DE 1 1 2 1 2 3 7

FR 103 112 215 213 254 467 130

NL 145 330 475 327 745 1072 39

BG 1062 66 1128 1345 93 1438 135

HR 182 22 204 397 43 440 138

CY 50 48 98 54 44 98 50

CZ 491 190 681 970 376 1346 66

DK 374 1 375 374 1 375 45

EE 30 3 33 30 3 33 20

FI 55 91 146 55 96 151 46

FR 3374 598 3972 3833 706 4539 615

DE 4003 1327 5330 4003 1327 5330 507

EL 411 3 414 573 3 576 57

HU 0 0 462 0 0 462 65

IE 248 248 248 0 248 40

105 https://eurydice.eacea.ec.europa.eu/eurypedia/austria/statistics-educational-institutions) 106 https://www.eqar.eu/qa-results/download-data-sets/

36

IT 2717 818 3535 5435 1637 7072 259

LV 39 8 47 39 8 47 54

LT 47 8 55 47 8 55 43

LU 21 5 26 50 5 55 21

MT 2 0 2 10 0 10 16

NL 93 294 387 187 525 712 130

PL 3363 498 3861 3363 498 3861 545

PT 229 45 274 353 346 699 288

RO 925 21 946 926 21 947 104

SK 300 108 408 392 123 515 33

SI 71 3 74 143 6 149 105

ES 2059 1324 3383 4119 2648 6767 1341

SE 415 233 648 922 606 1528 48

Totals 21006 6294 27762 28605 10261 39328 5026

To convert institution counts to awarding-body counts, different awarding-governance models

across MS are considered, as shown in Annex 4.1, Table 23. Upper secondary schools

offering only general programmes are excluded from the institution count, as they already

share grade results electronically with the awarding body today107. Instead, they are captured

via the (mostly centralised) awarding bodies for secondary school qualifications, based on a

simplifying assumption of an average of 2 'school certificate' issuers per Member State. This

reflects the range of national governance models, from a single centralised issuing authority

(e.g. a Ministry of Education) to a split between school-level and state-level issuers (see e.g.

Eurydice, National Education Systems, 'Assessment in general upper secondary education,'

country reports108) and is used here as a working estimate rather than an empirically derived

EU-wide figure.

Number of non-NQF micro-credentials providers

The number of non-NQF micro-credential providers cannot be directly quantified, as no

official EU-level repository of private and non-formal issuers for micro-credentials currently

exists. Cedefop's mapping study109 confirms this gap, noting that EU-level data are lacking

due to the diversity of providers and national systems. In the absence of such data, the

approach taken here relies on modelling, using available proxy indicators to assess the size of

the provider landscape. As detailed in Annex 4.1.1, this draws on membership data from the

Lifelong Learning Platform (LLLP)110, whose networks represent over 60,000 organisations

across formal, non-formal and informal learning, adjusted to exclude formal education and

training institutions already captured as qualification issuers.

Given the absence of a representative dataset, the resulting estimate of 45,000 non-formal and

informal learning organisations should be treated as indicative rather than precise, while the

107 Eurypedia 108 Ibid. 109 Cedefop (2022). Microcredentials for labour market education and training: first look at mapping

microcredentials in European labour-market-related education, training and learning: take-up, characteristics

and functions. Luxembourg: Publications Office. Cedefop research paper, No

87. http://data.europa.eu/doi/10.2801/351271 110 https://www.lllplatform.eu/aboutus

37

input parameters used to derive it carry a significant degree of uncertainty. This uncertainty

stems both from the proxy nature of the underlying data (LLLP membership figures were not

designed to measure micro-credential provision specifically) and from the assumptions

applied to disaggregate that membership by provider type. Eurostat data showing that 67.4%

of EU enterprises with 10 or more employees were "training enterprises" in 2020111 further

suggest that the true pool of potential providers may extend considerably beyond this

estimate.

5.2. Description of the Policy Options

Three policy options are considered for detailed assessment. They were identified based on

the analysis of technical feasibility, Member State readiness and the state of development of

key EU level tools such as the EQF, Europass and EUDI Wallets.

Some elements to facilitate the understanding of the options

• Options refer to two categories of documents: i) ‘qualifications’ is used for any

document in an NQF as well as formal school, VET and higher education diplomas

predating the establishment of NQFs and ii) ‘other skills document’ refers todocuments

not included in the NQF which also signal a person's skills, such as micro-credentials

from non-formal training courses112, or Diploma Supplements. Any of the two categories

of documents can have EQF levels 2-8 (i.e. all formal education certificates and diplomas

from lower secondary VET education to PhD113).

• Two tools are considered to digitalise qualifications: i) the EUDI Wallet: Its introduction

will significantly improve the way electronic documents are exchanged in the EU. The

DC4EU project showed that it is a viable option for the digitalisation of qualifications;

and ii) the Europass Wallet: The European Digital credentials for Learning (EDC) is

an infrastructure that is available to issue digital credentials in the field of learning. Its use

by issuers is currently voluntary and the tool is mostly used today to issue non-formal

micro-credentials. For citizens, both EUDI Wallet and the Europass Wallet are voluntary

and free of charge. and theuse of the applications is entirely up to the individual’s

decision. The European Learning Model, which has been assessed according to the

Common Assessment Methodology for Standards and Specifications (CAMSS)114 will be

the semantic foundation for the digitalisation of qualifications and the comparison tool

under all options.

Any delays by MS in the implementation and rollout of the EUDI Wallet (by end of 2026)

would not directly affect the timeline and success of the Skills Portability Initiative. Even

if the Wallet constitutes part of the baseline infrastructure on which this initiative relies,

the Skills Portability Initiative has a transition period that would offset any

implementation delays. Nonetheless, the calculations underpinning this impact assessment

have adopted a deliberately conservative approach to the projected uptake of the EUDI

Wallet, in line with the assumptions used in the impact assessment for ESSPASS115. This

111 Share of training enterprises decreases in 2020 - News articles - Eurostat 112 Micro-credentials (records of learning outcomes from a small volume of learning) and the outputs of skills

validation procedures can also be part of an NQF (whether as a qualification or as a micro-credential). 113 EQF levels between 2 and 8 cover all qualifications that are labour market relevant. Level 1 is considered out

of scope for labour mobility. Only 6 MS include any VET qualifications at EQF level 1 (LV, LT (but none

awarded), LU, MT, NL, AT, RO), 14 MS have EQF level 1 for elementary/primary school (BE, BG, ES, CZ,

EE, EL, HR, HU, IE, KY, SI, SK, SE) and 3 MS do not include any qualifications at EQF level 1 (DK, FR, FI). 114 CAMSS Assessment of ELM - EIF Scenario | Interoperable Europe Portal 115 European Commission, Impact Assessment accompanying the proposal for a European Social Security Pass

(ESSPASS), Commission Staff Working Document, not yet published.

38

conservative approach ensures that the estimated costs and benefits of the Skills

Portability Initiative are not overly dependent on an optimistic rollout scenario and helps

mitigate the risk that gaps or delays in MS' implementation of the Wallet could undermine

the validity of the assessment's conclusions. For the Europass Wallet, this conservatism is

further reinforced by an additional factor specific to its scope: unlike the EUDI Wallet,

which will be used to hold a broad range of credentials such as national ID cards and

driving licences, the Europass Wallet is dedicated specifically to learning-related

credentials, meaning its uptake trajectory is likely to be more gradual and cannot rely on

the pull of other, more frequently encountered use cases. In addition, for both wallets, the

calculations only count Year 1 as starting after the three-year transition period foreseen for

this initiative, which further limits the projected uptake figures used across the

assessment.

Table 3 Cumulative wallets uptake (conservative assumption)

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

EUDI

Wallet 0% 0% 20% 40% 50% 60% 70% 75% 75% 75%

Europass

Wallet 0% 0% 10% 20% 25% 30% 35% 38% 38% 38%

•“Automatic” issuance of digital attestations means that the proof of qualification would

be issued into the user Wallet instantaneously, without manual processing. The “on

demand” issuance of older qualifications means that an exchange between various actors

is needed to issue a qualification, using the SDGR mechanism or a manual verification

process.

• Roles of different bodies in in issuing of digital attestations:

o the education and training providers, they provide the training and gather the results

of their learners and, share the data with awarding bodies ahead of the issuance of a

qualification (unless they carry both roles),

o the awarding bodies, the formal bodies/authorities that award the qualification to a

learner. They, either issue the qualifications directly or use an issuer (in the same way

they may rely on the national printing house) for the actual creation of the paper proof.

Some MS have also developed diploma registers to facilitate this process 116.

o the issuer of the digital document, which is in charge of creating the digital

document.

o Under all options, the organisation of the issuance process would depend on the

MS organisation, for example regional structures or chambers of commerce and

industry could continue to play a role similar to the role they play today.

• In all options newly issued qualifications would be digital by default, consistent with the

vision established in the Commission's 2030 Digital Compass Communication. This is

also coherent with SPI Action 2 which relies (1) on the swift issuance of digital

qualifications and (2) on a high level of reliability regarding the authenticity and the

identity of the awarding body and of the qualification holders. Each of the options

considered has considered this dual requirement, ensuring that speed of issuance is not

116 In several MS, a national database of learning records/students’ degrees has also been set up (e.g. with the

DUO platform, FR with Cyclades, FI with KOSKI-palvelu)

39

achieved at the expense of verifiability, or vice versa.

Design of the policy options

The policy options were formulated in a manner to allow comparison between key

parameters for the approach to digital attestations of qualifications:

• the choice of the specific tool: two options (PO1 and PO2) rely on the EUDI Wallet.

On the other hand, PO3 relies on the Europass wallet.

• the scope of digitalisation: all options include documents most relevant for the

labour market and quality assured through the NQF (EQF levels 2-8, including

some more formalised micro-credentials which have fulfilled NQF quality assurance

criteria set by the MS). Two options (PO1 and PO3) are even broader and include also

other skills documents, notably micro-credentials outside the NQF – these are of

growing importance in the labour market but are less formalised and are not quality

assured in the same way as NQF documents.117

• The time window of information covered by digitalisation: Two options (PO1 and

P 3) consider the digitalisation of all the past qualifications and skills documents “on

demand” and one option (P 2) in addition extends the automatic issuance as far as

possible to the previous 10 years on demand.118 Digitalising past documents is

important to meet objectives, as it benefits larger share of the existing workforce. In

all options past qualifications are only issued to support workers access

employment in another MS. New qualifications do not have the same limitation

because for new graduates it is more difficult to establish what the primary use of the

qualification would be (national or EU labour market or further education).

The POs are built in a complementary manner and are mutually exclusive. All retained

options are legislative, as the achievement of a standardised approach to digitalisation

requires making some elements obligatory for MS and issuers.

Table 4: Overview of Policy Options

Tool Scope Applicable Time Window

PO1 EUDI Wallet Qualifications (EQF 2-

8) and other skills

documents

New automatic + older on demand

(for cross border labour mobility)

PO2 EUDI Wallet Qualifications (EQF 2-

8)

New automatic +10 years

automatic (for cross border labour

mobility) + older on demand (for

cross border labour mobility)

PO3 Europass

Wallet

Qualifications (EQF 2-

8) and other skills

documents

New automatic + older on demand

(for cross border labour mobility)

117 DC4EU considered such a large scope in their pilot, however they proposed a different trust framework for

the different types of documents, where non-NQF micro-credentials were issued with the lowest level of

assurance in the eIDAS ecosystem and a basic trust framework. 118 This includes qualifications issued since 2017, since the entry into force of the revised EQF

Recommendation.

40

Common

elements of

all options

• Ensuring legal value of digital qualification attestations

• Mandatory comprehensive NQF, obligation for NQFs to be clearly

and regularly referenced to the EQF and for NQF qualifications

database to be linked to Europass.

• Trust framework (database of qualifications standards, awarding

bodies and accreditation)

• Provision of verifier/viewer application

• Reinforced qualifications comparison tool in Europass

• Encouragement to include micro-credentials in NQF and use the

common approach to micro-credentials as established in the relevant

Council Recommendation.

• Transition period

Supporting

measures

(non-

legislative)

• Awareness campaigns

• Encouragement to use EU funding

• Continued support to existing EU level tools

All the options share some common elements and supporting measures (proc) are

envisaged to accompany all three options. In particular, awareness of the opportunities related

to the availability of digitalised information on qualifications could be raised through

promotion campaigns at EU, national and regional levels. In addition, MS could be

encouraged to make use of available funding at EU and national levels, e.g. to fund their

digital transformation. Moreover, the Commission would continue the support to the

implementation of existing tools and initiatives (EQF, Europass, the Council

Recommendations on validation of non-formal and informal learning, and on the EU

approach to micro-credentials and the Europass Decision). These measures are not assessed

for the costs and benefits as they are either ongoing efforts or voluntary initiatives and choices

of the MS.

Detailed description of the options

PO1

This option uses EUDI Wallet as the tool to issue digital attestations of qualifications (see

visualisation in Annex 11).

It has a broad scope: qualifications (included in an NQF and covering EQF levels 2-8) and

other skills documents.

All new qualifications would need to be issued “automatically” – i.e. without delay, and

without the need for manual processing. Issuance would follow a different model between

public issuers and private issuers, having to rely on a qualified trust service provider119. They

would be issued according to the trust framework of linking qualification, accreditation and

awarding body information into the credentials.

Regarding qualifications awarded before SPI and no later than 45 years120 prior, they

would be issued digitally on request of the citizen for cross border purposes and within a

119 It is unlikely that a private education and training providers become a qualified trust service provider

considering the very high auditing costs to become (and later remain) a qualified trust service provider. In

addition, the legal responsibility this function entails are very high. 120 45 years is the assumed span of a person’s professional career. Qualifications issued more than 45 years

before the entry into force are considered of limited importance in the labour market and are therefore excluded

from all the options.

41

reasonable time allowing MS time to gather the data and check the information (no later than

two weeks when those qualifications are requested as part of a professional recognition

procedure as described under Directive 2005/36/EC). As part of the eIDAS Regulation, MS

shall already ensure that measures are taken to allow qualified trust service providers of

electronic attestations of attributes to verify by electronic means, at the request of the user, the

authenticity of the educational qualifications, titles and licences. In order to issue digitally

qualifications that have already been awarded to workers and jobseekers in a paper and/or

PDF format, MS would be able to leverage the Single Digital Gateway and the OOTS

common services to check information before issuing a digital qualification in the EUDI

Wallet121 and rely on trusted information. The content of the qualifications would differ

between the new and existing qualifications, so that MS can provide the necessary

information, with many fields being optional (see Annex 11.5).

For other skills documents outside NQFs (e.g. micro-credentials, Europass Supplements),

new ones would be issued digitally to the EUDI Wallet by default, while existing ones would

be digitalised only upon request.

Based on consultations and the DC4EU project a common framework of obligatory and

optional data fields is identified for the new qualifications and skills documents (see Annex

11.4), to facilitate common understanding and comparability of the available information. The

content of the older qualifications would be more limited, so that MS can provide the

necessary information, with many fields being optional (see Annex 11.5).

PO2

This option uses EUDI Wallet as the tool to issue digital attestations of qualifications.