EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 995 final

2026/0273 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and Regulation (EU)

No 1024/2012

{SEC(2026) 995 final} - {SWD(2026) 995 final} - {SWD(2026) 996 final} -

{SWD(2026) 997 final}

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The free movement of workers, freedom of establishment and freedom to provide services are

fundamental freedoms enshrined in the Treaties, underpinning the ability of Union citizens to

pursue professional and economic activities across the Union. These Treaty freedoms are

complemented by the Charter of Fundamental Rights of the European Union, which

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

as well as the freedom of Union citizens to seek employment, work, exercise the right of

establishment and provide services in any Member State. They are further supported by the

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

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

employability. In particular, Principle 1 on education, training and lifelong learning

recognises everyone’s right to maintain and acquire skills enabling full participation in society

and successful transitions in the labour market, while Principle 4 provides for the right to

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

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

2029, which place skills portability and the effective use of skills acquired across borders

among the priorities for strengthening labour mobility and enabling people to make full use of

their skills throughout the Union. In her Political Guidelines for 2024–2029, the President of

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

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

skills acquired in one country in another. These objectives are also reflected in the ‘One

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

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

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

competitiveness.

This proposal forms part of the Skills Portability Initiative (SPI), which is a key component of

the Fair Labour Mobility Package (FLMP). The SPI was announced under the Union of

Skills, adopted in March 2025 as the Commission’s strategy to strengthen Europe’s human

capital and competitiveness, including by improving the portability of skills and qualifications

across the Union. The present proposal implements Action 2 of the SPI. It aims at further

facilitating and modernising the recognition of professional qualifications in regulated

professions by leveraging digital tools to streamline, accelerate and make recognition

procedures more efficient, while strengthening administrative cooperation between competent

authorities and improving the monitoring of the implementation and functioning of the

recognition system.

By amending the Directive, this proposal aims to reduce the time and cost required to have a

professional qualification recognised in another Member State, making recognition more

transparent and digital.

For regulated professions, Directive 2005/36/EC on the recognition of professional

qualifications (‘the Directive’) is a cornerstone of the Union framework for professional

mobility. It facilitates the free movement of professionals by establishing rules for the

recognition of professional qualifications, while taking account of Member States’

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competence to regulate professions and to lay down requirements for their pursuit in order to

safeguard relevant public interests.

The need for action is supported by the Commission's report on the implementation of the

Directive covering the period 2020–2024, as well as by the studies and stakeholder

consultations underpinning the impact assessment accompanying this proposal. This evidence

points to persistent shortcomings in the availability and quality of information provided to

applicants, inefficiencies and unnecessary burdens in recognition procedures, and challenges

affecting administrative cooperation between competent authorities.

The proposal therefore introduces targeted amendments to simplify and accelerate recognition

procedures, to improve the availability, completeness and reliability of information on

recognition requirements and procedures, and to strengthen administrative cooperation

between competent authorities. Across these areas, it promotes the use of interoperable digital

tools to support more efficient, transparent and user-friendly recognition processes throughout

the Union. The proposal does not alter the conditions under which Member States regulate

professions or the national arrangements for taking recognition decisions.

The other two legislative initiatives under the Skills Portability Initiative concern digital

qualification attestations and recognition of professional qualifications obtained outside the

EU (in a third country). The former relies on the measures developed under the proposal for

the Regulation establishing a framework for portability of skills and qualifications (SPI

Action 1, “Skills Portability Act”). The latter refers to a proposal of the Directive establishing

a framework for the recognition of third-country qualifications held by third-country

nationals, to ensure that holders of such qualifications who are EU nationals are not treated

less favourably than third country nationals (SPI Action 3). When applicable, all three

proposals under the SPI refer to each other to avoid repetitions and ensure coherence.

• Consistency with existing policy provisions in the policy area

This proposal is fully consistent with the existing EU framework governing the recognition of

professional qualifications. Directive 2005/36/EC remains the central Union instrument in this

area, without prejudice to the limited number of sector-specific rules laid down in other Union

legal acts. It also continues to govern both establishment and the temporary and occasional

provision of services in regulated professions. As recognised by Article 3 of Directive

2006/123/EC on services in the internal market, where the provisions of the two Directives

overlap, Directive 2005/36/EC prevails. This proposal does not affect that relationship.

• Consistency with other Union policies

This proposal is consistent with the Union's broader policy and legislative framework on the

digital transformation of public administration. In particular, it complements the Single

Digital Gateway Regulation (EU) 2018/1724 and the Once-Only Technical System

established thereunder, Regulation (EU) No 910/2014 (eIDAS) as amended by Regulation

(EU) 2024/1183 establishing the European Digital Identity framework, and the Interoperable

Europe Regulation (EU) 2024/903 in particular as regards the principle of interoperability by

design and the requirements applicable to binding requirements affecting cross-border

interoperable digital public services. By promoting interoperable digital credentials, trusted

electronic exchanges of information and interoperable public services, the proposal

contributes to the common objective of delivering more efficient, user-friendly and seamless

cross-border administrative procedures across the Union.

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2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The proposal is based on the same legal basis as Directive 2005/36/EC, namely, Articles 46,

53(1) and 62 of the Treaty on the Functioning of the European Union (TFEU). These

provisions empower the Union to adopt measures facilitating the free movement of workers,

the freedom of establishment and the freedom to provide services, including through the

mutual recognition of diplomas, certificates and other evidence of formal qualifications and

the coordination of national provisions governing access to and the pursuit of regulated

professions.

• Subsidiarity (for non-exclusive competence)

The initiative concerns the functioning of the internal market, an area of shared competence

between the Union and the Member States pursuant to Article 4(2)(a) TFEU. Accordingly, the

principle of subsidiarity applies.

EU-level action is this area has been established as necessary and appropriate since the

adoption of the original framework in 2005, and subsequent updates to this common

framework can only be achieved through action at Union level.

Coordinated action is necessary because professional recognition inherently requires cross-

border interaction between competent authorities, including information exchange,

qualification validation, and document verification. Because these challenges are structural

and transnational, isolated national measures cannot ensure reciprocity, establish common

operational rules, or eliminate heterogeneous practices. Furthermore, integrating digital tools

to streamline these procedures requires a unified approach; developing such solutions

independently at the national level risks fragmentation, duplication, and lack of

interoperability.

Union action is also essential to strengthen transparency and enforcement. Current monitoring

relies heavily on complaints by individual applicants and Member States’ self-reported data,

which fail to provide a comprehensive basis for identifying systematic non-compliance.

Action at EU level is required to establish consistent, comparable data to enable more timely

and more accurate monitoring, supporting targeted corrective measures. By streamlining

information requirements, deadlines, and cooperation practices, a coordinated framework

reduces administrative effort, lowers reporting costs, and minimizes divergent assessments.

Ultimately, only coordinated national systems can achieve this level of transparency; Union

intervention is necessary to resolve persistent administrative burdens and legal uncertainty,

ensuring the existing framework operates as intended and Treaty-conferred rights can be

effectively exercised in practice.

EU-level action also offers clear economies of scale. A single, streamlined framework is

significantly more cost-effective than multiple, parallel national systems requiring complex

technical interfaces. While national administrations will incur initial adaptation costs, these

will be well offset by long-term efficiency gains, reduced reporting burdens, and lower error

rates. Ultimately, uncoordinated national approaches cannot achieve the required consistency

or scale, making Union intervention the most effective way to ensure Treaty rights are able to

be meaningfully exercised.

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• Proportionality

The proposal concerns the revision of Directive 2005/36/EC, an area where the need for

Union action is already established. The proposed amendments are limited to addressing

specific implementation shortcomings, namely fragmented information, unnecessarily

burdensome recognition procedures, uneven levels of digitalisation and inefficiencies in

administrative cooperation between competent authorities.

The proposal does not harmonise the substantive rules governing regulated professions or the

conditions for the recognition of professional qualifications. Member States remain fully

responsible for regulating professions, determining professional qualifications, assessing

applications and taking recognition decisions. Rather, the focus of the proposed measures is

on procedural improvements, such as clarifying certain procedural obligations, strengthening

administrative cooperation and facilitating the use of interoperable digital tools.

The proportionality of these measures was thoroughly evaluated across all policy options in

the impact assessment, balancing expected benefits against implementation effort.

Proportionality was assessed in the comparison of the policy options considered in the impact

assessment. The assessment also examined whether the scope, intensity and implementation

requirements of the proposed measures were commensurate with the objectives pursued. The

preferred option was selected as the most effective response while remaining strictly

necessary and proportionate. Although it entails a greater degree of intervention than

alternative options, this reflects the magnitude and persistence of the problems addressed and

remains confined to procedural aspects of the recognition framework, fully respecting

Member States' competence over the regulation of professions or substantive recognition

decisions as well as their competence in safeguarding public health, safety and the quality of

services.

• Choice of the instrument

As this proposal amends Directive 2005/36/EC, the appropriate legal instrument is a directive.

A coordinating amendment concerning Regulation 1024/2012 is ancillary to the amendment

of Directive 2005/36/EC.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

No ex-post evaluation was carried out specifically for the preparation of this proposal. The

most recent evaluation of the Directive was conducted in the context of its 2013 revision.

Subsequently, the main innovations introduced by Directive 2013/55/EU, namely the

European Professional Card and the Alert Mechanism, were subject to a dedicated assessment

in 2018. The decision not to undertake a further evaluation was based on the availability of a

recent and comprehensive implementation report for the years 2020-20241, published only a

few months before the preparation of this proposal. That report and the accompanying Staff

Working Document (SWD)2 provide an extensive assessment of the functioning of the

Directive, drawing on a broad range of evidence, including data from the Regulated

Professions Database, targeted surveys of competent authorities, national coordinators and

professional organisations, as well as other stakeholder input. It offers a detailed analysis of

1 COM(2026) 86 final 2 SWD(2026)64 final

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the implementation of the existing framework, identifies the main challenges encountered in

practice and provides a robust evidence base for the preparation of this proposal.

• Stakeholder consultations

As detailed in the impact assessment accompanying this proposal, the preparation of the

initiative was supported by extensive stakeholder consultation activities.

In addition to the consultations carried out in the context of the recent implementation report,

the Commission conducted an open public consultation as part of the Skills Portability

Initiative as well as a series of targeted stakeholder consultations. Furthermore, a range of

targeted consultation activities were organised with competent authorities, national

coordinators, professional organisations and representatives of regulated professions, as well

as targeted surveys of competent authorities and citizens who had undergone recognition

procedures.

These consultation activities provided valuable evidence on the practical functioning of the

current framework, the challenges encountered by applicants and competent authorities, and

stakeholders' views on possible policy responses. Together with the other sources of evidence

supporting the impact assessment, they informed both the identification of the problems the

development of the measures included in this proposal.

The consultation activities revealed broad agreement among stakeholders on the main

challenges affecting the functioning of the current recognition system. In particular,

stakeholders consistently identified shortcomings in the information available to applicants,

inefficiencies in recognition procedures and scope for improving administrative cooperation

between competent authorities. There was also broad support for further digitalisation and

simplification of recognition procedures as a means of reducing administrative burden and

improving efficiency. Stakeholders further emphasised the need to support competent

authorities in implementing the Directive through common tools, clearer rules and

strengthened cooperation.

These views are reflected in the proposal, which addresses both shortcomings in the design of

the current framework and challenges relating to its implementation. On the one hand, it

introduces new common structural elements, most notably a mandatory European digital

workflow supporting recognition procedures across the Union. On the other hand, it

strengthens the implementation of the existing framework by clarifying procedural rules to

apply the Directive more consistently. Together, these measures are intended to remove the

main obstacles identified by stakeholders and improve the efficiency, predictability and

consistency of recognition procedures across the Union.

• Collection and use of expertise

The Impact assessment accompanying this legislative proposal was support by an external

study commissioned from EY Advisory Services S.p.A and Istituto per la Ricerca Sociale.

• Impact assessment

An impact assessment was carried out in support of this proposal and was informed by an

external study prepared for the Commission.

The impact assessment examined three policy options aimed at improving the consistent

implementation and effectiveness of the Directive. The first option focused on promoting

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greater administrative convergence through non-legislative measures, such as guidance,

recommendations, peer learning and the exchange of good practices. The second option

combined targeted legislative amendments with increased digitalisation by proposing a

common European digital solution while allowing Member States to continue using

interoperable national systems. The third and preferred option complemented the digital

transformation of recognition procedures with a broader package of legislative measures

addressing additional sources of administrative burden and inefficiency, including the quality

of information provided to applicants, administrative cooperation between competent

authorities, document requirements, fees, paper-based procedures and procedural deadlines.

The third option was selected as the preferred one because it is expected to achieve the

objectives of the initiative most effectively while ensuring cost-effectiveness. It combines a

common European digital recognition solution, developed and financed by the Commission,

with legislative amendments designed to improve the operation of the recognition system. By

providing a common digital infrastructure at Union level, the preferred option reduces

implementation costs for Member States, creates economies of scale, and supports a more

consistent implementation of the Directive.

The impact assessment concludes that the preferred option will generate significant economic

and social benefits. It is expected that the preferred option will reduce the administrative costs

incurred by applicants and competent authorities in recognition procedures, while shortening

processing times and enabling professionals to enter the labour market more quickly.

Employers are also expected to benefit from faster and less cumbersome recruitment, reduced

vacancy durations and improved access to skilled workers.

Beyond these direct benefits, the proposal is expected to improve the functioning of the

internal market for professional services by facilitating the more efficient allocation of skills

across Member States. This is expected to contribute to addressing labour and skills shortages,

improving labour market matching, increasing labour productivity and strengthening the

resilience and competitiveness of the European economy. The proposal is also expected to

generate positive social impacts by improving employment opportunities, supporting upward

career mobility and enhancing income security for professionals seeking to exercise their

profession in another Member State.

• Regulatory fitness and simplification

The proposal contributes to the objectives of regulatory fitness by simplifying the recognition

of professional qualifications and reducing administrative burdens for applicants, competent

authorities and employers. It directly addresses the procedural complexities and inefficiencies

identified in the current framework, while preserving the core principles of the Directive and

Member States' responsibility for recognition decisions.

For applicants, the proposal makes it simpler to request and quicker to obtain a recognition

decision. Reducing reliance on paper-based processes, promoting the use of digital

attestations, limiting documentary requirements and providing more complete and

standardised information on recognition procedures should make recognition procedures more

predictable, reduce the number of incomplete applications and requests for additional

information, and lower the time and costs associated with preparing and submitting

applications.

For competent authorities, the proposal introduces a common digital workflow, integrating

artificial intelligence support, strengthens administrative cooperation and provides clearer

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procedural rules. These measures are expected to reduce administrative effort, avoid

duplication of work, streamline the handling of recognition procedures and improve the

consistency and efficiency of decision-making across Member States.

For employers, faster and more predictable recognition procedures are expected to facilitate

recruitment, improve workforce planning and accelerate access to qualified professionals,

including in sectors experiencing labour and skills shortages.

The proposal contributes to the Union’s competitiveness by shortening the time needed to fill

vacancies in regulated professions. Small and medium enterprises are expected to benefit

proportionately more, while no new obligations are imposed on businesses.

Although the implementation of the new digital infrastructure will require initial investment

in IT systems, training and organisational adjustments, these transitional costs are expected to

be outweighed by lasting reductions in administrative burden, shorter processing times and a

more efficient and coherent recognition system across the Union.

• Fundamental rights

By facilitating the recognition of professional qualifications across Member States, the

proposal supports the effective exercise of the freedoms of movement, namely establishment

and the provision of services within the internal market and freedom of movement for

workers. By reducing administrative and regulatory barriers, the proposal enables mobile

professionals to pursue their profession on the basis of their qualifications and merits,

irrespective of their nationality and the Member State in which they obtained their

qualifications. In doing so, it contributes to the principles of equal treatment and non-

discrimination, as enshrined in Article 21 of the Charter of Fundamental Rights, and

facilitates the effective exercise of the rights conferred by the Treaties. It also promotes the

right to engage in work and to pursue a freely chosen occupation, as enshrined in Article 15 of

the Charter of Fundamental Rights, in particular paragraph 2, which guarantees Union citizens

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

provide services in any Member State.

4. BUDGETARY IMPLICATIONS

The proposal has budgetary implications for the Union budget related to the development,

deployment and operation of the European Digital Recognition Solution (EDRS), which will

be developed, financed and operated by the Commission, within three years after entry into

force of this Directive.

The EDRS will provide a common digital workflow for the recognition of professional

qualifications across the Union and will include interfaces for applicants and competent

authorities, AI-assisted functionalities to support the processing of recognition applications,

interoperability with relevant Union systems, including the Single Digital Gateway Once-

Only Technical System and the European Digital Identity Wallet, analytical and statistical

functionalities, and integration with the enhanced Regulated Professions Database.

For 2027, the resource of the deployment of the system will come from EaSI. This initiative

should be financed within the agreed envelope of the programme For the following years, the

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

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

Commission assesses that the HR needs will be covered by redeployment to meet the needs

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generated by this proposal. The estimated impact on expenditure and staffing for 2028 and

beyond is added for illustrative purposes only and does not pre-judge the next Multiannual

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

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

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

All appropriations and staffing allocations as of 2028 are indicative.

The Commission will keep Member States informed about the development of EDRS,

allowing them to prepare for its deployment. In any case, the EDRS must be made operational

ahead of the date for the transposition of the corresponding procedural obligations of the

Member States under this proposal. Member States are not required to bear costs for

developing or adapting national solutions supporting recognition processes, as the EDRS

together with other EU solutions such as IMI will fully cover the functionality that competent

authorities need to process applications for recognition of professional qualifications.

By providing and financing a common Union-wide digital infrastructure, the proposal avoids

the need for Member States to develop and maintain separate national solutions, thereby

reducing implementation costs, creating economies of scale and supporting the consistent

implementation of the Directive across the Union. The detailed budgetary implications of the

proposal are set out in the accompanying financial statement.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

The Commission will monitor implementation in close cooperation with the national

coordinators and competent authorities. Monitoring will focus on the extent to which the

proposal succeeds in simplifying recognition procedures, reducing administrative burden and

costs, and improving administrative cooperation.

Monitoring will be based on two complementary sources: biennial reporting by Member

States, coordinated by the national coordinators, and annual data generated through the

EDRS. The first data collection will take place before the deployment of the new system to

establish a baseline, followed by regular monitoring after implementation.

The monitoring framework includes indicators measuring the quality and completeness of

information provided to applicants, the efficiency and timeliness of recognition procedures,

the administrative burden associated with recognition applications, and the effectiveness of

administrative cooperation between competent authorities. A detailed set of indicators,

together with the data sources and collection methods, is set out in the Impact Assessment

accompanying this proposal. The Commission will carry out an evaluation of the Directive

approximately five years after the expiry of the transposition deadline.

• Explanatory documents (for directives)

Pursuant to Article 3 of this Directive, Member States are required to transpose its provisions

into national law and to notify the Commission of the corresponding national measures. When

notifying those measures, Member States should provide sufficient information to enable the

Commission to assess the completeness and correctness of transposition. This information

should clearly indicate how the provisions of the Directive have been implemented in national

law.

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• Detailed explanation of the specific provisions of the proposal

Article 1 sets out the amendments to Directive 2005/36/EC. Article 2 contains an amendment

of the provisions referred to in the annex of Regulation (EU) No 1024/2012 on administrative

cooperation through the Internal Market Information System (‘the IMI Regulation’). Article 3

contains the provisions on transposition, Article 4 concerns the entry into force of the

amending Directive, and Article 5 specifies its addressees.

The substantive amendments introduced by Article 1 are organised around the following main

themes:

Digitalisation of recognition procedures: The proposal replaces the existing European

Professional Card framework with a European Digital Recognition Solution established by

new Article 56b. While recognition decisions remain the responsibility of Member States, the

entire administrative workflow will be carried out through a common digital infrastructure

used by all competent authorities. The proposal also introduces a digital-only principle

through Article 56c.

Faster and more predictable recognition procedures: The proposal introduces, through

Article 56d, deadlines for each key procedural step, creating a structured workflow from the

submission of an application to the final recognition decision. This replaces the current

approach, under which only the overall duration of the procedure is defined, and substantially

reduces the maximum duration of recognition procedures under both the automatic

recognition system and the general system. For temporary and occasional provision of

services, Article 7(4) similarly shortens the duration of prior checks. To reinforce compliance,

the new Article 56e introduces a financial compensation mechanism for applicants affected by

excessive delays in the administrative handling of their recognition applications.

Simplification of procedural requirements: The proposal further harmonises the procedural

framework by clarifying, through amendments to Article 50, that competent authorities may

request only the documents expressly provided for by the Directive. Article 50(8) requires

Member States to accept those documents in any official language of the Union, while Article

56c(3) establishes rules on communication with applicants. A new Article 51a introduces

common principles governing recognition fees. Together, these measures reduce unnecessary

administrative burdens, improve legal certainty and promote more consistent application of

the Directive.

Modernisation of notifications and reporting: The proposal modernises the notification

framework by amending Article 59(1), requiring Member States to submit notifications

concerning regulated professions through the Internal Market Information System. It also

strengthens the Commission's role in monitoring the implementation of the Directive through

amendments to Article 60, enabling reporting to rely on statistical information generated by

the European Digital Recognition Solution and thereby improving the quality, comparability

and availability of implementation data.

Strengthened cooperation and governance: The proposal introduces a more structured

governance framework through new Article 60a, strengthening cooperation between the

Commission and the Member States within the Group of Coordinators on the Recognition of

Professional Qualifications. Annual work programmes will provide a clearer framework for

monitoring implementation, identifying common challenges, exchanging good practices and

preparing future developments of the recognition system. The strengthened governance

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framework is also intended to facilitate and streamline the use of the Directive's delegated

powers, in particular with regard to the establishment of Common Training Frameworks.

Equal treatment of EU nationals and third-country nationals: Amendments to Articles

2(2), 3(3) and 10(g) of Directive 2005/36/EC align the Directive with [Directive xxxx/xxx/EU

on the recognition of qualifications of third-country nationals], which establishes a framework

for the recognition of third-country qualifications held by third-country nationals. The

existing provisions are replaced by new rules on recognition of qualifications obtained outside

the Union in Title Va, ensuring coherence between the two legal frameworks while preserving

the distinction between the general system and automatic recognition under Directive

2005/36/EC as well as the main features underlying each of those systems.

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2026/0273 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and Regulation (EU)

No 1024/2012

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

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

Article 46, Article 53(1) and Article 62 thereof,

Having regard to the proposal from the European Commission,

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

Having regard to the opinion of the European Economic and Social Committee3,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) The Single Market is a cornerstone of European integration and a key driver of the

Union’s competitiveness, prosperity and resilience. Its full potential depends, inter

alia, on enabling people to move freely across the Union and to put their skills and

qualifications to use wherever they are needed. Facilitating mobility contributes to a

better allocation of skills across the Union, helps address labour and skills shortages

and strengthens the capacity of the Union economy to respond to changing economic

and demographic needs. Therefore, remaining barriers to the mobility of professionals

should be reduced. This is particularly important in the field of regulated professions,

where access to or pursuit of a professional activity is subject to the possession of

specific professional qualifications. Differences in national qualification requirements

may raise obstacles to the mobility of qualified professionals between Member States.

(2) Directive 2005/36/EC of the European Parliament and of the Council4 sets out the

rules governing the recognition of professional qualifications for access to and pursuit

of regulated professions and is a crucial instrument supporting the mobility of workers

and services within the Single Market. It establishes a Union framework for the

recognition of professional qualifications and thereby plays a central role in enabling

professionals to exercise their right to free movement while ensuring that the

requirements governing access to regulated professions in the host Member State are

appropriately taken into account. In order to further facilitate professional mobility

within the Single Market, that framework should be modernised and made simpler,

3 OJ C […], […], p. […]. 4 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the

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

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

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faster and more efficient, in particular by making better use of digital tools,

streamlining recognition procedures and strengthening administrative cooperation

between competent authorities.

(3) Directive 2005/36/EC, which lays down rules governing the recognition of

professional qualifications of Union citizens, already contains specific rules

concerning qualifications obtained in third countries. In particular, its Article 2(2)

provides that each Member State may, in accordance with its national rules, permit

Member State nationals holding evidence of professional qualifications obtained in a

third country to pursue a regulated profession on its territory and that, in the case of

professions covered by Title III, Chapter III, that recognition is to respect the

minimum training conditions laid down in that Chapter. In addition, Article 3(3) of

Directive 2005/36/EC, first sentence, read in conjunction with Article 10, point (g),

ensures that, where a Member State national has obtained recognition of their third-

country qualification in one Member State and has three years of certified professional

experience in that profession within the same Member State, their third-country

qualification is to be regarded as evidence of formal qualifications under that

Directive, which should entitle them to recognition of their evidence of professional

qualifications under the general system when seeking access to the profession in

another Member State. With the adoption of [Directive xxxx/xxx/EU on the

recognition of qualifications of third-country nationals5], establishing a framework for

the recognition, for the purpose of establishment, of third-country qualifications held

by third-country nationals, it is appropriate to ensure that Directive 2005/36/EC also

establishes a coordinated approach to the recognition of qualifications obtained by

Member State nationals outside the Union.

(4) To that end, the necessary adjustments should be made to Directive 2005/36/EC to

ensure coherence between the two legal acts. It is therefore necessary to include a new

Title Va of Directive 2005/36/EC so as to ensure that each Member State develops

appropriate procedures for the recognition of professional qualifications obtained

outside the Union held by nationals of a Member State. Such procedures should ensure

that nationals of a Member State seeking recognition of their professional

qualifications in a host Member State for the purposes of establishment are not subject

to rules that are less favourable than those applicable to the third-country nationals

seeking recognition of their professional qualifications in that Member State.

(5) The distinction between, and underlying logic of, the general system of recognition

and the system of automatic recognition established by Directive 2005/36/EC should

be preserved, while taking due account of the specificities of qualifications awarded

outside the Union to ensure that the conditions required for access to and pursuit of the

profession in the host Member State are met.

(6) In its Special Report 10/24 on the recognition of professional qualifications in the

Union,6 the European Court of Auditors considered that, while Directive 2005/36/EC

is an essential mechanism, it is used sparsely and inconsistently. To improve the

system of recognition of professional qualifications, it notably recommended annual

updating of Annex V to that Directive, reducing the deadline for recognition through

the automatic system that benefits professions for which mandatory minimum training

5 […] 6 Special report 10/2024: The recognition of professional qualifications in the EU – An essential

mechanism, but used sparsely and inconsistently

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requirements are set under the Directive, as well as ensuring reliable and consistent

information for citizens.

(7) Procedures for the recognition of professional qualifications can come with a high

burden for applicants. Professionals seeking recognition of qualifications acquired in

another Member State are required to submit multiple supporting documents,

including certified copies and translations, sometimes in paper form, and to bear fees

which vary considerably between Member States. Such requirements may discourage

professionals from pursuing opportunities in other Member States. Reducing the

reliance on physical documents while ensuring access to underlying information is

therefore key to facilitate the free movement of professionals within the Union.

(8) While most procedures for the recognition of professional qualifications under

Directive 2005/36/EC are completed within the applicable timeframes, persistent

delays in some cases continue to affect applicants and may hinder the timely access to

regulated professions. Such delays can entail significant costs or lost opportunities for

applicants while also affecting employers awaiting the recruitment of qualified

professionals, particularly in sectors facing labour and skills shortages. It is therefore

necessary to modernise, simplify and improve the efficiency of procedures for the

recognition of professional qualifications by laying down precise deadlines for the

exchange of information and for mutual assistance between the competent authorities

of the host Member State and those of the home Member State.

(9) To be able to submit complete recognition applications, applicants should be provided

with reliable information to support them in the process of recognition of their

qualifications. They should be able to understand, at an early stage, whether and under

which conditions they may access a regulated profession in another Member State. It

is therefore necessary to ensure that clear, trustworthy and up-to-date information is

available for applicants before starting a procedure and that they are appropriately

guided towards the relevant profession, applicable national rules and required

supporting documents.

(10) The European Professional Card introduced by Directive 2013/55/EU of the European

Parliament and of the Council7 has remained confined to a limited number of

professions and, given its case-specific design, has not proven capable of being scaled

up into a broader or more comprehensive solution for the recognition of professional

qualifications. To ensure a smooth and orderly transition to that solution, the European

Professional Card (EPC) should therefore be phased out gradually. To that end,

Member States should, during a limited transitional period, continue issuing the EPC.

(11) To facilitate the recognition of professional qualifications, a common Union IT

solution, the European Digital Recognition Solution, should be established at Union

level to support the digitalisation of procedures for the recognition of professional

qualifications. That system should provide a common digital infrastructure enabling

applicants to submit applications and supporting documents, including by reusing

relevant data from national identity or credential systems, and to receive information

on the status and outcome of their applications. It should facilitate secure and efficient

cooperation between competent authorities, reduce administrative burden and undue

7 Directive 2013/55/EU of the European Parliament and of the Council of 20 November 2013 amending

Directive 2005/36/EC on the recognition of professional qualifications and Regulation (EU)

No 1024/2012 on administrative cooperation through the Internal Market Information System ( ‘the IMI

Regulation’ ) OJ L 354, 28.12.2013, pp. 132–170,ELI: http://data.europa.eu/eli/dir/2013/55/oj

EN 14 EN

delays, and simplify procedures for applicants and competent authorities. It should

also contribute to the consistent application and uniform implementation of Directive

2005/36/EC across Member States, while fully respecting data protection requirements

and the organisation and functioning of national administrative systems.

(12) The introduction of stricter procedural timeframes for the exchange of information and

mutual assistance between the competent authorities should be accompanied with

measures that support Member States in making that cooperation more efficient

through a common digital workflow. The European Digital Recognition Solution

should therefore support secure communication, full traceability of procedural steps,

legal certainty and the timely handling of applications.

(13) The use of digital solutions should contribute to the more efficient organisation of

procedures for the recognition of professional qualifications. To that end, based on the

digital qualification attestations made available under [Regulation(EU)XXX

establishing a framework for portability of skills and qualifications and amending

Regulation (EU) 2018/1724]8, applicants should be able to obtain, by digital means,

formal evidence of qualifications issued by the competent authorities of the home

Member State and to verify, prior to submission, whether their application is complete,

including as regards the adequacy of supporting documents and translations. Digital

tools should also support competent authorities in the assessment of applications,

including the examination of supporting evidence, facilitate the secure exchange of

information with authorities in other Member States, and improve communication

with the applicants. These improvements should contribute to shorter processing times

for applications and to a reduction in the applicable deadlines.

(14) The Internal Market Information System (‘IMI’), established by Regulation (EU) No

1024/2012 of the European Parliament and of the Council9, is a tool supporting

administrative cooperation between competent authorities in the recognition of

professional qualifications under Directive 2005/36/EC. The European Digital

Recognition Solution established under Directive 2005/36/EC should build on and

interoperate with IMI, avoiding duplication of communication channels and preserving

the accumulated functionality of the existing tool. The Annex to that Regulation

should be amended in accordance with the amendments to the provisions of this

Directive.

(15) Regulation (EU) 2018/1724 of the European Parliament and of the Council10

established the Single Digital Gateway and the Once-Only Technical System, enabling

the cross-border exchange of evidence between competent authorities without

requiring users to resubmit documents already held by another public authority. Its

continued implementation can support more efficient recognition procedures by

allowing supporting documents exchanged through the Once-Only Technical System

to be used within the European Digital Recognition Solution, reducing the burden on

applicants to obtain and submit certified copies of evidence already available through

public registers or authorities in another Member State.

8 […] 9 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on

administrative cooperation through the Internal Market Information System and repealing Commission

Decision 2008/49/EC, OJ L 316, 14.11.2012, p.1, ELI: http://data.europa.eu/eli/reg/2012/1024/oj 10 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

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

and problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p.

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

EN 15 EN

(16) The publicly available database of regulated professions referred to in Article 59(1) of

Directive 2005/36/EC set up and maintained by the Commission provides a centralised

overview of professions that are regulated in each Member State, the applicable legal

provisions, and the competent authorities responsible. To ensure legal certainty and

consistency, that database should constitute the single authoritative source of

information on the regulatory status of professions across the Union, and Member

States should keep the information they notify complete, accurate and up to date.

(17) Language barriers can complicate and delay recognition procedures. Recent advances

in machine translation, including the Commission's eTranslation service, make it

possible to process documents submitted in another official language of the Union by

facilitating understanding of their content. The continuous improvement in the quality

of machine translation is steadily increasing confidence in translated documents and is

reshaping the contribution of human translators towards quality assurance and

verification. Competent authorities should therefore be able to rely on machine

translation integrated into the European Digital Recognition Solution to facilitate the

handling of applications, while preserving the possibility of requesting a certified

human translation where appropriate.

(18) To support the digitalisation of procedures under Directive 2005/36/EC, the European

Digital Recognition Solution, which would be built on a Union-wide infrastructure for

digital qualification attestations should allow applicants to use and share trusted digital

evidence across borders more efficiently. The European Digital Recognition Solution

established by this Directive constitutes a cross-border digital public service within the

meaning of Regulation (EU) 2024/903 of the European Parliament and of the Council

(Interoperable Europe Act)11 and is subject to the requirements laid down in that

Regulation, including the obligation to carry out an interoperability assessment. In

accordance with the requirements applicable to European Digital Identity Wallets

under Regulation (EU) 910/2014 of the European Parliament and of the Council12, the

European Digital Recognition Solution should be interoperable with the EU Digital

Identity Wallet so that applicants can submit, reuse and securely share, under their

control, pre-authenticated digital documents stored therein, including evidence of

formal qualifications. By relying on standardised digital qualification attestations and

interoperable systems, such a framework should help competent authorities access

reliable and up-to-date information more quickly, accelerate verification, reduce

repeated requests for the same evidence, and support faster, more consistent

recognition decisions across Member States.

(19) To support the digitalisation of recognition procedures under Directive 2005/36/EC,

Member States should ensure the secure receipt and verification of credentials, as well

as their use in the digital processing of recognition requests and the issuance of

recognition decisions. The European Digital Recognition Solution should further

reinforce confidence of applicants and employers in the use of digital evidence in

cross-border recognition procedures for regulated professions. Digital qualification

attestations issued in accordance with [Regulation(EU)XXX establishing a framework

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

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

Act), OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj 12 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on

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

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

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

EN 16 EN

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

should enable competent authorities to rely on their authenticity without carrying out

further checks. For other documents submitted in support of recognition requests,

where checks of authenticity are necessary, greater digitalisation should enable

competent authorities to carry out such checks more efficiently and consistently,

helping to detect irregularities and prevent fraudulent submissions.

(20) To guarantee equal treatment and effective access, applicants who are unable to

undergo the procedure by electronic means only, including due to limited digital skills,

should not be disadvantaged in the exercise of their rights under Directive

2005/36/EC. Member States should make appropriate arrangements to enable such

applicants to pursue the relevant procedures by non-electronic means, while ensuring

that their applications are handled with the same diligence, without undue delay and

subject to the same procedural safeguards as applications submitted through the digital

solution. In this context, documents submitted in the course of such procedures may be

provided in different formats, including paper documents that have been scanned and

converted into electronic form, as well as electronic documents including electronic

attestations of attributes set out in Commission Implementing Regulation (EU)

2024/297913. The use of different formats should not lead to discrimination against the

applicant provided that the authenticity, integrity and, where relevant, origin of the

documents can be appropriately assessed. Where an applicant makes use of non-

electronic means for justified reasons, Member States should ensure that the

competent authority, or another designated body, enters the necessary data and

documents into the digital system without undue delay and keeps the applicant

appropriately informed of the progress of the procedure. Member States should also

provide adequate technical and digital support to applicants using the digital solution,

in particular to those with limited digital skills, to ensure effective access on an equal

basis.

(21) Competent authorities may, in the examination of applications for the recognition of

professional qualifications, be assisted by the European Digital Recognition Solution.

Such assistance could entail the assessment of the completeness of applications with

respect to the appropriate information and relevant evidence provided, the authenticity

of documents submitted, the identification of substantial differences between the

training evidenced by the applicant and the national training requirements, the

indication of possible compensation measures (aptitude tests or adaptation periods) in

accordance with Directive 2005/36/EC, and the identification of similar previously

assessed cases with a view to promoting consistency in decision-making.

(22) The Commission and Member States, in their respective capacities as processor and

controllers, within the meaning of Article 29(3) of Regulation (EU) 2018/1725 of the

European Parliament and of the Council14 and Article 28(3) of Regulation (EU)

13 Commission Implementing Regulation (EU) 2024/2979 of 28 November 2024 laying down rules for the

application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards

the integrity and core functionalities of European Digital Identity Wallets, OJ L, 2024/2979, 4.12.2024,

ELI:http://data.europa.eu/eli/reg_impl/2024/2979/oj 14 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

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

bodies, offices and agencies and on the free movement of such data, OJ L 295, 21.11.2018, p. 39, ELI:

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

EN 17 EN

2016/679 of the European Parliament and of the Council15, should implement

appropriate technical and organisational measures to safeguard personal data against

unauthorised access, accidental loss, or unlawful processing.

(23) Where an excessive delay is attributable to the competent authority and not to the

applicant, it should entitle the latter to an appropriate and proportionate compensation

for the economic disadvantage caused by the delay.

(24) The benefits of automatic recognition could be further extended to additional

professions through fuller use of the mechanism established by Directive 2005/36/EC

for the development of common training frameworks. Where a common set of

minimum knowledge, skills and competences necessary for the pursuit of a specific

profession can be identified and is shared by at least one third of the Member States,

common training frameworks can provide an effective means of promoting

professional mobility while respecting national regulatory approaches and training

systems. To attain this objective, a strengthened cooperation among competent

authorities is needed through the Group of Coordinators established by Commission

Decision 2007/172/EC16. While contributing to the overall consistent and effective

implementation of Directive 2005/36/EC, including through the preparation of annual

work programmes and the exchange of experience and best practices, the Group

should also serve as a forum for outreach to and exchange with professionals, their

representative organisations and social partners, including on labour market needs,

quality standards and professional autonomy. In particular, it should contribute to

identifying emerging common sets of knowledge, skills and competences, assessing

needs and expectations in the professions, and exploring opportunities for the

development of common training frameworks in accordance with this Directive.

(25) To ensure coherence, transparency and proportionality, and to avoid duplicative

reporting obligations, the additional monitoring and evaluation requirements linked to

the digitalisation and simplification measures introduced by this Directive should be

integrated into the reporting framework established by Article 60 of Directive

2005/36/EC. Evaluation should in particular assess the functioning of the European

Digital Recognition Solution, its effect on administrative burdens and procedure

duration, and its impact on the mobility of professionals and addressing labour and

skills shortages in the internal market.

(26) Directive 2005/36/EC and Regulation (EU) 1024/2012 should therefore be amended

accordingly.

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

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

and delivered its opinion on [date]17.

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

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

such data, OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj

16 Commission Decision 2007/172/EC of 19 March 2007 setting up the group of coordinators for the

recognition of professional qualifications, OJ L 79, 20.3.2007, pp. 38–39 (BG, ES, CS, DA, DE, ET,

EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, RO, SK, SL, FI, SV), OJ L 219M, 24.8.2007, pp. 367–368

(MT), ELI: http://data.europa.eu/eli/dec/2007/172/oj 17 OJ C , , p. .

EN 18 EN

HAVE ADOPTED THIS DIRECTIVE:

Article 1

Amendments to Directive 2005/36/EC

Directive 2005/36/EC is amended as follows:

(1) Article 1 is replaced by the following:

'Article 1

Subject matter

1. This Directive establishes rules according to which a Member State which makes access to

or pursuit of a regulated profession in its territory contingent upon possession of specific

professional qualifications (‘the host Member State’) shall recognise professional

qualifications obtained in one or more other Member States (‘the home Member State’) and

which allow the holder of the said qualifications to access and pursue the said profession in

the host Member State.

2. This Directive also establishes rules concerning partial access to a regulated profession and

recognition of professional traineeships pursued in another Member State.

3. This Directive also lays down rules under which a host Member State shall recognise

professional qualifications obtained in a third-country for the purpose of establishment in that

Member State and which allow the holder of the said qualifications to access and pursue the

profession in that Member State under conditions that are not less favourable than those for

third-country nationals.';

(2) Article 2 is amended as follows:

(a) the first subparagraph of paragraph 1 is replaced by the following:

'1. This Directive shall apply to all nationals of a Member State wishing to pursue a

regulated profession in a Member State, including those belonging to the liberal

professions, on either a self-employed or employed basis, and who obtained their

professional qualifications in another Member State or in a third country';

(b) paragraph 2 is deleted;

(3) Article 3 is amended as follows:

(a) paragraph 1 is amended as follows:

(i) point k is deleted;

(ii) the following point o is added:

'(o) ‘digital qualification attestation’ an attestation of a qualification that is

awarded in a digital format in accordance with Regulation (EU) xxxx/xxx on

portability of skills and qualifications and amending Regulation (EU)

2018/172418';

(b) paragraph 3 is deleted;

18 […]

EN 19 EN

(4) Article 4 is amended as follows:

'Article 4

Effects of recognition

1. The recognition of professional qualifications by the host Member State shall allow

beneficiaries to gain access in that Member State to the same profession as the one for which

they are qualified in the home Member State or in the third country where they obtained their

qualifications under the same conditions as its nationals.

2. For the purposes of this Directive, the profession which the applicant wishes to pursue in

the host Member State shall be considered the same as the one for which they are qualified in

their home Member State or in the third country if the activities covered are comparable.

3. By way of derogation from paragraph 1 of this Article, partial access to a profession in the

host Member State shall be granted under the conditions laid down in Article 4f.';

(5) Articles 4a, 4b, 4c, 4d and 4e are deleted;

(6) Article 4f is amended as follows:

'Article 4f

Partial access

1. The competent authority of the host Member State shall grant partial access, for the purpose

of establishment, on a case-by-case basis, to a professional activity in its territory only when

all the following conditions are fulfilled:

(a) the professional is fully qualified to exercise in the home Member State or in

the third country the professional activity for which partial access is sought in

the host Member State;

(b) differences between the professional activity legally exercised in the home

Member State or in the third country and the regulated profession in the host

Member State as such are so large that the application of compensation

measures would amount to requiring the applicant to complete the full

programme of education and training required in the host Member State to

have access to the full regulated profession in the host Member State;

(c) the professional activity can objectively be separated from other activities

falling under the regulated profession in the host Member State.

For the purpose of the first subparagraph, point (c), the competent authority of the

host Member State shall take into account whether the professional activity can be

pursued autonomously in the home Member State or in the third country.

2. The competent authority of the host Member State shall grant partial access, for the purpose

of temporary and occasional services in the host Member State, on a case-by-case basis, to a

professional activity in its territory only when all the following conditions are fulfilled:

(a) the professional is fully qualified to exercise in the home Member for the

professional activity for which partial access is sought in the host Member

State;

(b) differences between the professional activity legally exercised in the home

Member State and the regulated profession in the host Member State as such

are so large that the application of compensation measures would amount to

requiring the applicant to complete the full programme of education and

EN 20 EN

training required in the host Member State to have access to the full regulated

profession in the host Member State;

(c) the professional activity can objectively be separated from other activities

falling under the regulated profession in the host Member State.

For the purpose of the first subparagraph, point (c), the competent authority of the

host Member State shall take into account whether the professional activity can be

pursued autonomously in the home Member State or in the third country.

3. Partial access may be rejected if such rejection is justified by overriding reasons of general

interest, suitable for securing the attainment of the objective pursued, and does not go beyond

what is necessary to attain that objective.

4. Applications for the purposes of establishment in a Member State shall be examined in

accordance with Chapters I and IV of Title III for professionals seeking partial access based

on professional qualifications obtained in their home Member State and in accordance with

Title Va for professionals seeking partial access based on the professional qualifications

obtained in a third country.

5. Applications for the purposes of providing temporary and occasional services in the host

Member State concerning professional activities that have public health or safety implications

shall be examined in accordance with Title II.

6. By way of derogation from Article 52 of this Directive, the professional activity shall be

exercised under the professional title of the third country or of the other Member State once

partial access has been granted. The host Member State may require use of that professional

title in the languages of the host Member State. Professionals benefiting from partial access

shall clearly indicate to the service recipients the scope of their professional activities.

7. This Article shall not apply to professionals benefiting from automatic recognition of their

professional qualifications under the provisions referred to under Title Va of this Directive.';

(7) Article 7 is amended as follows:

(a) paragraph 1 is replaced by the following:

'1. Member States may require that, where the service provider first moves from one

Member State to another in order to provide services, the service provider shall inform

the competent authority in the host Member State in a written declaration to be made

in advance including the details of any insurance cover or other means of personal or

collective protection with regard to professional liability. Such declaration shall be

renewed once a year if the service provider intends to provide temporary or occasional

services in that Member State during that year.';

(b) in paragraph 4, the second subparagraph is replaced by the following:

'Within two weeks of informing the applicant that the declaration referred to in

paragraphs 1 and 2 of this Article is complete, as stipulated in Article 56d(4), the

competent authority shall notify the service provider of its decision which may be one

of the following:

(a) not to check the professional qualifications;

(b) where the professional qualifications have been checked:

(i) to require the service provider to take an aptitude test; or

(ii) to allow the provision of services';

EN 21 EN

(8) in Article 8, paragraph 1 is replaced by the following:

'1. The competent authorities of the host Member State may ask the competent authorities of

the Member State of establishment, in the event of justified doubts, to provide any

information relevant to the legality of the service provider’s establishment and good conduct,

as well as the absence of any disciplinary or criminal sanctions of a professional nature. In the

event that the competent authorities of the host Member State decide to check the service

provider’s professional qualifications, they may ask the competent authorities of the Member

State of establishment for information about the service provider’s training courses to the

extent necessary to assess substantial differences likely to be harmful to public health or

safety. The competent authorities of the Member State of establishment shall provide that

information in accordance with Articles 56 and 56d. In the case of non-regulated professions

in the home Member State, the assistance centres referred to in Article 57b may also provide

such information.';

(9) in Article 10, point (g) is deleted;

(10) Article 14 is amended as follows:

(a) in paragraph 3, the second subparagraph is replaced by the following:

'This applies also to the cases provided for in Article 10 points (b) and (c), in Article

10 point (d) concerning medical doctors and dental practitioners, in Article 10 point (f)

when the migrant seeks recognition in another Member State where the relevant

professional activities are pursued by nurses responsible for general care or specialised

nurses holding evidence of formal qualifications as a specialist who have taken part in

the training leading to the possession of the titles listed in Annex V, point 5.2.2.';

(b) the following paragraph 8 is added:

'8. Member States shall ensure that applicants who fail an aptitude test, or one or more

tests forming part of an adaptation period, are given the opportunity to retake the

respective tests. Member States shall ensure that feedback detailing assessment results

and areas for improvement is provided to applicants, and that applicants are entitled to

at least two further attempts to pass each test that they have failed.';

(11) in Article 21, paragraph 1 is replaced by the following:

'1. Each Member State shall recognise evidence of formal qualifications as doctor giving

access to the professional activities of doctor with basic training and specialised doctor, as

nurse responsible for general care, as dental practitioner, as specialised dental practitioner, as

veterinary surgeon, as pharmacist and as architect, listed in Annex V, points 5.1.1, 5.1.2,

5.2.2, 5.3.2, 5.3.3, 5.4.2, 5.6.2 and 5.7.1 respectively, which satisfy the minimum training

conditions referred to in Articles 24, 25, 31, 34, 35, 38, 44 and 46 respectively, and shall, for

the purposes of access to and pursuit of the professional activities, give such evidence the

same effect on its territory as the evidence of formal qualifications which it itself issues.

Such evidence of formal qualifications shall be issued by the competent bodies in the Member

States and accompanied, where appropriate, by the certificates listed in Annex V, points 5.1.1,

5.1.2, 5.2.2, 5.3.2, 5.3.3, 5.4.2, 5.6.2 and 5.7.1 respectively.

Member States shall ensure that any person to whom they award the evidence of formal

qualifications in that Member State referred to in Annex V, points 5.1.1, 5.1.2, 5.2.2, 5.3.2,

5.3.3, 5.4.2, 5.6.2, and 5.7.1, may request that the relevant certificate accompanying that

evidence of formal qualification, listed in Annex V, be issued as a digital qualification

attestation in accordance with [Regulation(EU)XXX establishing a framework for portability

of skills and qualifications and amending Regulation (EU) 2018/1724]. Any person holding

EN 22 EN

such evidence of formal qualifications and, where appropriate, the relevant certificate listed in

Annex V, which was issued in a non-digital form, may request from the issuing Member State

a digital qualification attestation of that certificate in accordance with [Regulation(EU)XXX

establishing a framework for portability of skills and qualifications and amending Regulation

(EU) 2018/1724].

The provisions of the first and second subparagraphs shall not affect the acquired rights

referred to in Articles 23, 27, 33, 37, 39 and 49.

The provisions of the third and fourth subparagraphs are without prejudice to the provisions

of [Regulation(EU)XXX establishing a framework for portability of skills and qualifications

and amending Regulation (EU) 2018/1724] concerning digital qualification attestation.';

(12) in Article 25, the following paragraph 6 is inserted:

'6. In order to reflect generally acknowledged changes in the medical terminology across the

Union, the Commission is empowered to adopt delegated acts in accordance with Article 57c

in order to update the generic name of specialties in points 5.1.3 and 5.3.3 of Annex V. ';

(13) Articles 50 and 51 are replaced by the following:

'Article 50

Documentation and formalities

1. Where the competent authorities of the host Member State decide on an application for

authorisation to pursue the regulated profession by virtue of this Title, those authorities may

require solely the documents and certificates listed in Annex VII.

Where the host Member State decides to impose a requirement as to the date of issue of the

documents referred to in Annex VII, points 1(d), (e) and (f), it shall accept documents issued

within a specific period that may not be shorter than the three months preceding the date on

which they are submitted.

The Member States, bodies and other legal persons shall guarantee the confidentiality of the

information which they receive.

2. In cases of justified doubts, the host Member State may require from the competent

authorities of a Member State confirmation of the authenticity of the attestations and evidence

of formal qualifications awarded in that other Member State, as well as, where applicable,

confirmation of the fact that the beneficiary fulfils, for the professions referred to in Chapter

III of this Title, the minimum training conditions set out respectively in Articles 24, 25, 28,

31, 34, 35, 38, 40, 44 and 46.

3. By way of derogation from paragraph 2, Member States shall not require confirmation of

authenticity where evidence of formal qualifications is submitted as a digital qualification

attestation or where attestations or evidence are obtained through the technical system for the

cross-border automated exchange of evidence, as established under Regulation (EU)

2018/1724 of the European Parliament and of the Council19. This shall be without prejudice to

the possibility for Member States to verify compliance with the minimum training

requirements applicable under Chapter III of this Title.

19 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

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

and problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p.

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

EN 23 EN

4. In cases of justified doubt, where evidence of formal qualifications has been issued by a

competent authority in a Member State and includes training received in whole or in part in an

establishment legally established in the territory of another Member State, the host Member

State shall be entitled to verify with the competent body in the Member State of origin of the

award:

(a) whether the training course at the establishment which gave the training has

been formally certified by the educational establishment based in the Member

State of origin of the award;

(b) whether the evidence of formal qualifications issued is the same as that which

would have been awarded if the course had been followed entirely in the

Member State of origin of the award;

(c) whether the evidence of formal qualifications confers the same professional

rights in the territory of the Member State of origin of the award.

5. In cases of justified doubts, the host Member State may require from the competent

authorities of a Member State confirmation of the fact that the applicant is not suspended or

prohibited from the pursuit of the profession as a result of serious professional misconduct or

conviction of criminal offences relating to the pursuit of any of their professional activities.

6. Exchange of information between competent authorities of different Member States under

this Article shall take place through the Internal Market Information system (IMI) established

by Regulation (EU) 1024/2012 of the European Parliament and of the Council20.

7. Where a host Member State requires its nationals to swear a solemn oath or make a sworn

statement in order to gain access to a regulated profession, and where the wording of that oath

or statement cannot be used by nationals of the other Member States, the host Member State

shall ensure that the persons concerned can use an appropriate equivalent wording.

8. Member States shall accept the documents referred to in paragraph 1 in any of the official

languages of the Union.

Article 51

Procedure for the mutual recognition of professional qualifications

1. The competent authority in the host Member State shall examine an application for

authorisation to practise a regulated profession without undue delay and shall adopt a duly

substantiated decision within two weeks after the date on which the applicant is informed in

accordance with Article 56d(4) that the application is complete and no additional information

is required. That deadline may be extended by four weeks in cases falling under Chapters I

and II of this Title.

2. The decision of the competent authority, or failure to reach a decision within the period

laid down in paragraph 1, shall be subject to appeal under national law.';

(14) the following Article 51a is inserted:

'Article 51a

Fees and charges

20 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on

administrative cooperation through the Internal Market Information System and repealing Commission

Decision 2008/49/EC, OJ L 316, 14.11.2012, p.1, ELI: http://data.europa.eu/eli/reg/2012/1024/oj

EN 24 EN

1. A host Member State shall either waive fees for recognition procedures and compensation

measures or ensure that any fees charged do not exceed the actual costs incurred in providing

the service to applicants.

2. By way of derogation from paragraph 1, Member States may impose flat-rate charges if

they can be justified by the average cost of providing the service to applicants.

3. Any potential or actual damage claims or compensations that could be derived from the

non-respect of the deadlines laid down in Article 56d shall not be considered in the

calculation of costs of service or costs of processing applications.

4. Member States shall ensure that detailed information on the structure of the fee and

justification for any charges imposed as part of the recognition process is publicly available

and easily accessible.

5. Through IMI or another electronic interface that the Commission shall make available for

that purpose, each Member State shall notify the Commission of the fees charged for

recognition procedures and for compensation measures for each profession. Through the same

interface, each Member State shall notify any changes to these fees before these changes take

effect.';

(15) in Article 53(3), the second subparagraph is replaced by the following:

'Controls may be carried out only after the recognition of a professional qualification.';

(16) in Article 56, paragraph 2 is replaced by the following:

'2. The competent authorities of the home and the host Member States shall exchange

information regarding disciplinary action or criminal sanctions taken or any other serious,

specific circumstances which are likely to have consequences for the pursuit of activities

under this Directive.

The competent authorities of the home Member State shall examine the veracity of the

circumstances and shall decide on the nature and scope of the investigations which need to be

carried out and shall inform the competent authorities of the host Member State of the

conclusions which the competent authorities of the home Member State draw from the

information available to them.';

(17) the following Articles 56b, 56c, 56d, 56e and 56f are inserted:

'Article 56b

European Digital Recognition Solution

1. The Commission shall establish and maintain a comprehensive European Digital

Recognition Solution ('the EDRS'), available in all official languages of the Union, which

shall provide a platform for the submission of declarations made in accordance with Article 7

and for applications for recognition of professional qualifications under Title III.

2. The EDRS shall provide the following functions:

(a) allow competent authorities to configure the evidence that a professional is

required to provide when applying for the recognition of professions notified

pursuant to Article 59(1), and the evidence that a professional must provide for

prior checks pursuant to Article 7(4);

(b) allow applicants to create, edit, withdraw, and monitor any declarations made

in accordance with Article 7 or any applications for recognition under Title III;

EN 25 EN

(c) allow applicants to provide all required supporting evidence from a range of

sources and in various formats, including scanned paper documents, electronic

attestations of attributes stored in a European Digital Identity Wallet in

accordance with Regulation (EU) No 910/2014 of the European Parliament and

of the Council21, and documents requested through the technical system for the

cross-border automated exchange of evidence established under Regulation

(EU) 2018/1724 of the European Parliament and of the Council;

(d) perform an initial automated assessment of the completeness of the application

and accompanying supporting evidence before the applicant submits the

declaration or application;

(e) make applications and declarations with supporting evidence accessible to the

host Member State;

(f) acknowledge receipt of the application to the applicant.

For the purposes of the first subparagraph, point (a), the solution shall allow

competent authorities to configure the required supporting evidence for each

procedure type and profession. It shall also ensure that, for applications under Title

III, the required evidence does not exceed that set out in Article 50 read in

conjunction with Annex VII, and that, for the declarations made in accordance with

Article 7, the required evidence does not exceed that specified in that Article.

3. The EDRS shall build on and interoperate with IMI. It shall allow direct use of the

functionality of IMI for secure communication between competent authorities, and it shall

facilitate secure communication of competent authorities with the applicant.

4. In the development and operation of EDRS the Commission shall ensure that it is designed

to support competent authorities in their work to assess applications and to take decisions on

recognition, including through machine translation of documents, and to support the

verification of authenticity of evidence.

5. The EDRS shall ensure that the applicant is informed without undue delay of the

completion of each stage of the procedure, and of any compensation that is due in accordance

with Article 56d.

6. The Commission shall publish on its website the formats and standards the EDRS uses for

the issuance, in the form of digital qualification attestations, of recognition decisions taken by

Member States.

Article 56c

Digital processing of applications

1. Member States shall ensure that declarations made under Article 7 and requests for

recognition under Title III are submitted through EDRS.

In cases where the applicant is not able to use EDRS, Member States shall provide the

applicant with the option to submit declarations and applications in non-electronic format. In

such exceptional circumstances, the Member State shall upload without undue delay the

submitted information into EDRS, ensuring all submissions are processed within this EDRS,

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

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

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

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

EN 26 EN

and regularly informing the applicant on the progress of the processing of the application or

declaration.

2. Competent authorities shall use IMI and EDRS to exchange information that is needed for

the processing of applications and declarations with the competent authorities of other

Member States or with applicants.

3. Member States shall ensure that any official communication to applicants is made in all

official languages of that Member State that are also official languages of the Union, and at

least one other official language of the Union. Member States shall ensure that any official

communication to applicants, such as acknowledgement of receipts, decisions and any other

information related to the procedure, shall be transmitted through EDRS.

Article 56d

Procedure for the digital processing of applications

1. Competent authorities of the host Member State shall assess the completeness of the

application and of the evidence provided and inform the applicant through EDRS of any

missing documents no later than one week after submission of the application or declaration.

2. Competent authorities of the host Member State shall communicate to the home Member

State any justified doubts they have on the supporting evidence issued by that Member State

and identify any need for information or attestations to be provided by that Member State.

To this end, no later than one week after the submission of the complete file of the application

or declaration, the host Member State shall request the home Member State to provide

through EDRS the required information, confirmation or attestations needed to proceed with

the application or to dispel any justified doubts.

3. Competent authorities of the home Member State shall provide any evidence or attestations

that are requested through EDRS within two weeks. For procedures under Article 7(4), and

Chapters I and II of Title III, this period may be extended by two additional weeks upon

request of the home Member State.

4. After having access to the complete file, and having received, if required, any other

supporting evidence in accordance with paragraphs (1) to (3), the host Member State shall

without undue delay inform the applicant through EDRS that the application file for

recognition made in accordance with Title III or the declaration made in accordance with

Article 7(4) is complete and no additional information is required from the applicant or the

home Member State to process the application or to perform the required prior checks.

5. For declarations made under Article 7, with the exception of those requiring a prior check

pursuant to paragraph 4 of that Article, the host Member State shall inform the applicant via

EDRS without undue delay after receipt of the declaration that the execution of services in its

territory may start immediately.

6. In relation to procedures under Title III and to the outcome of prior checks carried out in

accordance with Article 7(4), point (b), the final decision taken by the host Member State

shall be issued in the form of a digital qualification attestation through EDRS.

EN 27 EN

Article 56e

Non-respect of deadlines

1. If the home Member State exceeds the deadlines set out in Article 21(1) or Article 56d(3)

by more than five calendar days, it shall ensure that applicants are entitled to claim and

receive compensation for the delay. The compensation shall take the form of a lump sum for

each day of non-respect of the deadline, starting on the first day after the expiry of the

relevant deadline and ending on the date the home Member State treated all open requests for

evidence or attestations related to the application.

2. If the host Member State exceeds the deadlines set out in Article 51 or Article 56d by more

than ten calendar days, it shall ensure that applicants are entitled to claim and receive

compensation for the delay. The compensation shall take the form of a lump sum for each day

of non-respect of the deadline, starting on the first day after the expiry of the relevant deadline

and ending on the date of receipt of the final decision by the applicant. No compensation shall

accrue in respect to any period between a request made by the host Member State and the date

on which the home Member State or, under Title Va, the third country issuing the

qualification provides the evidence or the attestations requested. Such periods shall be taken

into account for the purposes of paragraph 1.

3. Member States may set a maximum amount for the total compensation payable under

paragraphs 1 and 2 expressed as a specific number of daily lump sum compensations.

4. At the request of the applicant and without prejudice to paragraph 5, Member States shall

pay the compensation referred to in paragraphs 1 and 2 as soon as the recognition procedure

or the processing of the declaration is completed.

5. Member States shall ensure that applicants have the right to seek, in accordance with

national law, compensation in respect of any damage or loss suffered exceeding the lump sum

compensation due to the non-respect of deadlines by that Member State.

Article 56f

Processing of personal data

1. Processing of personal data through the EDRS shall be carried out only to the extent that is

necessary for for carrying out tasks laid down in paragraphs 3, 4, 5 and 6.

2. Each Member State shall designate one or more competent authorities responsible for

operating its connection to the EDRS.

3. Where the competent authorities of the home and host Member States exchange personal

data through the EDRS for the purposes of this Directive, they shall act as joint controllers,

within the meaning of Article 26 of Regulation (EU) 2016/679 of the European Parliament

and of the Council22, solely in respect of the cross-border processing operations that are

strictly necessary for that exchange, including the transmission, routing, receipt, consultation

and technical provision of the personal data concerned through the EDRS, as well as the

management of related access rights, logging, security measures and incident handling.

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

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

such data, OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj

EN 28 EN

4. The Commission shall act as a processor, within the meaning of Article 3, point (12), of

Regulation (EU) 2018/1725 of the European Parliament and of the Council23, on behalf of the

joint controllers referred to in paragraph 3 of this Article, for the processing of personal data

carried out through the EDRS. In that capacity, it shall provide, technically maintain and

operate the solution, and ensure its interoperability, security, and supervision in accordance

with this Directive. The processing operations carried out by the Commission on behalf of the

joint controllers and the respective responsibilities of the Commission and those joint

controllers shall be governed by arrangements concluded in accordance with Article 29(3) of

Regulation (EU) 2018/1725 and, where applicable, Article 28(3) of Regulation (EU)

2016/679. This paragraph is without prejudice to the responsibilities of the competent

authorities of the Member States, acting as controllers or joint controllers, for processing

operations falling within their respective competence under this Directive.

5. The competent authority of the host Member State shall be the controller, within the

meaning of Article 4, point (7), of Regulation (EU) 2016/679 for the processing of personal

data necessary for the following:

(a) the handling of applications for recognition of professional qualifications;

(b) the assessment of applications, including the verification of supporting

information;

(c) the adoption of decisions and the management of redress procedures;

(d) the handling of personal data related to declarations for provision of services.

6. The competent authority of the home Member State shall be the controller, within the

meaning of Article 4 point (7), of Regulation (EU) 2016/679 for the processing of personal

data necessary for the following:

(a) verifying qualifications or confirming the authenticity of documents;

(b) providing supporting information or documents to the applicant or to the host

Member State;

(c) responding to requests for information made by the applicant and/or the host

Member State, pursuant to this Directive.

7. Where the processing of personal data by the competent authorities of the host or the home

Member State involves automated individual decision-making concerning the applicant,

including profiling, within the meaning of Article 22 of Regulation (EU) 2016/679 of the

European Parliament and of the Council, Member States shall ensure appropriate safeguards

ensuring that decisions affecting the recognition of professional qualifications are taken in a

lawful, fair and transparent manner. These safeguards shall at least include:

(a) the right of the data subject (applicant) to obtain meaningful information on the

use of automated processing in the examination of the application;

(b) the right of the data subject (applicant) to request that the decision be reviewed

by a natural person competent to assess the application;

(c) the right of the data subject (applicant) to express his or her point of view and

to submit observations or additional evidence;

23 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

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

bodies, offices and agencies and on the free movement of such data, OJ L 295, 21.11.2018, p. 39, ELI:

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

EN 29 EN

(d) the right of the data subject (applicant) to contest the decision by means of the

remedies available under national law.

8. Access to personal data processed pursuant to this Directive shall be limited to:

(a) the Commission, to the extent necessary for the operation, maintenance,

security and supervision of the solution;

(b) the competent authorities of the host and home Member States, to the extent

necessary for the performance of their tasks under paragraphs 3, 5 and 6 of this

Article.

9. Personal data shall be shared between the Commission and the competent authorities of the

Member States, or between the competent authorities of the host and home Member States,

only to the extent necessary for the purposes of paragraphs 3, 5 and 6 of this Article. Such

sharing shall not affect the responsibility of each controller for the processing operations

falling within its competence.

10. Each controller referred to in paragraphs 5 and 6 shall determine, within the limits of

applicable Union and national law, the retention periods for personal data applicable to the

processing operations for which it is responsible. Those periods shall be proportionate and

limited to what is necessary for the purposes of processing. The Commission shall ensure the

automatic deletion, 36 months after the completion of the recognition procedure, of the record

of that procedure and of the documents used therein from the solution, without affecting the

availability of those documents through the technical system for the cross-border automated

exchange of evidence established under Regulation (EU) 2018/1724 of the European

Parliament and of the Council, for their subsequent reuse.

11. The Commission and the competent authorities of the Member States shall cooperate,

within the scope of their respective responsibilities, to ensure the secure and lawful processing

of personal data under this Directive, including as regards:

(a) access management and logging;

(b) incident handling and personal data breach notification;

(c) data quality and accuracy;

(d) the handling of requests from data subjects and supervisory authorities.';

(18) in Article 57(1), point (b) is deleted;

(19) Article 57a is deleted;

(20) Article 57c is amended as follows:

(a) paragraph 2 is replaced by the following:

'2. The power to adopt delegated acts referred to in the third subparagraph of Article

3(2), Article 20, the second subparagraph of Article 21(6), Article 21a(4), Article

25(5), Article 25(6), the second paragraph of Article 26, the second subparagraph of

Article 31(2), the second subparagraph of Article 34(2), Article 35(4) and (5), the

second subparagraph of Article 38(1), the third subparagraph of Article 40(1), the

second subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) shall be

conferred on the Commission for a period of five years from 17 January 2014. The

Commission shall draw up a report in respect of the delegation of power not later than

nine months before the end of the five-year period. The delegation of power shall be

tacitly extended for periods of an identical duration, unless the European Parliament or

EN 30 EN

the Council opposes such extension not later than three months before the end of each

period.';

(b) paragraph 3 is replaced by the following:

'3. The power to adopt delegated acts referred to in the third subparagraph of Article

3(2), Article 20, the second subparagraph of Article 21(6), Article 21a(4), Article

25(5), Article 25(6), the second paragraph of Article 26, the second subparagraph of

Article 31(2), the second subparagraph of Article 34(2), Article 35(4) and (5), the

second subparagraph of Article 38(1), the third subparagraph of Article 40(1), the

second subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) may be

revoked at any time by the European Parliament or by the Council. A decision to

revoke shall put an end to the delegation of the power specified in that decision. It

shall take effect the day following the publication of the decision in the Official

Journal of the European Union or at a later date specified therein. It shall not affect

the validity of any delegated acts already in force.';

(c) paragraph 5 is replaced by the following:

'5. A delegated act adopted pursuant to the third subparagraph of Article 3(2), Article

20, the second subparagraph of Article 21(6), Article 21a(4), Article 25(5), Article

25(6), the second paragraph of Article 26, the second subparagraph of Article 31(2),

the second subparagraph of Article 34(2), Article 35(4) and (5), the second

subparagraph of Article 38(1), the third subparagraph of Article 40(1), the second

subparagraph of Article 44(2), Article 49a(4) and Article 49b(4) shall enter into force

only if no objection has been expressed either by the European Parliament or the

Council within a period of two months of notification of that act to the European

Parliament and the Council or if, before the expiry of that period, the European

Parliament and the Council have both informed the Commission that they will not

object. That period shall be extended by two months at the initiative of the European

Parliament or of the Council.';

(21) Article 59 is replaced by the following:

'Article 59

Transparency

1. Member States shall notify to the Commission a list of existing regulated professions,

specifying the activities covered by each profession, and a list of regulated education and

training, and training with a special structure, referred to in Article 11, point (c)(ii), in their

territory. Any change to those lists shall also be notified to the Commission via IMI before its

entry into force. The Commission shall set up and maintain a publicly available database of

regulated professions, including a general description of activities covered by each profession.

2. By 18 January 2016, Member States shall notify to the Commission the list of professions

for which a prior check of qualifications is necessary under Article 7(4). Member States shall

provide the Commission with a specific justification for the inclusion of each of those

professions on that list. Member States shall notify any changes to that list to the Commission

via IMI.

3. Member States shall examine whether requirements under their legal system restricting the

access to a profession or its pursuit to the holders of a specific professional qualification,

including the use of professional titles and the professional activities allowed under such title,

are compatible with the following principles:

EN 31 EN

(a) they shall not directly nor indirectly discriminate on the basis of nationality or

residence;

(b) they shall be justified by overriding reasons of general interest;

(c) they shall be suitable for securing the attainment of the objective pursued and

shall not go beyond what is necessary to attain that objective.

4. Paragraph 1 of this Article shall also apply to professions regulated in a Member State by

an association or organisation within the meaning of Article 3(2) and any requirements for

membership of those associations or organisations.

5. Before introducing any new requirements referred to in paragraph 3, Member States shall

inform the Commission and shall indicate the reasons for considering that those requirements

comply with points (a), (b) and (c) of that paragraph.';

(22) the following Title Va is inserted:

'TITLE Va

RECOGNITION OF QUALIFICATIONS OBTAINED IN A THIRD COUNTRY

Article 59a

Applicable provisions

1. Member States shall establish procedures for the recognition of professional qualifications

obtained in a third country. For that purpose, Chapter 2 of Title II, Article 11, Article 27,

Article 29(1) and (3) to (5), Article 30(1), Article 31, Article 32(1), (2), (4) and (7) to (10) and

Article 37 of [Directive xxxx/xxx/EU on the recognition of qualifications of third-country

nationals 24] shall apply mutatis mutandis.

2. For the purposes of this Title, Article 3(1) point (c) of this Directive shall be understood as

referring to diplomas, certificates and other evidence, issued by an authority in a third country

designated pursuant to legislative, regulatory or administrative provisions of that third

country, certifying successful completion of professional training.

3. For the purposes of paragraph 1 of this Article, Title III of this Directive shall not apply,

except Article 52(1) and (2), as provided in paragraph 4 of this Article.

4. For the purposes of paragraph 1 of this Article, Article 52(1) and (2), Title IV and Title V

of this Directive shall apply mutatis mutandis to the recognition of professional qualifications

obtained in a third country , with the exception of Article 55a.

Article 59b

Minimum training requirements for certain professions

Where Articles 24, 25, 28, 31, 34, 35, 38, 40 and 44 of this Directive set out minimum

conditions on the training for certain professions, the recognition of professional

qualifications under this Title shall be contingent upon fulfilment of those minimum

conditions.

Article 59c

Use of services for the assessment of authenticity

24 […]

EN 32 EN

For the purposes of assessing an application within the scope of this Directive, the competent

authority of a Member State may request from the Commission to assess the authenticity of

qualifications, diplomas, certificates or other evidence of formal qualifications issued in a

third country, pursuant to Article 28 of [Directive xxxx/xxx/EU on the recognition of

qualifications of third-country nationals].';

(23) Article 60 is replaced by the following:

'Article 60

Evaluation, statistics and reporting

1. From [the date falling 4 years after the adoption of this Directive] Member States shall,

every two years, send a report to the Commission on the application of the system. The report

shall contain general observations and a description of the main problems arising from the

application of this Directive.

2. The Commission shall, every year, provide the Group of Coordinators established under

Commission Decision 2007/172/EC with a statistical summary of the processing of

applications through the solution referred to in Article 56b. This summary shall include the

number of decisions taken, broken down by Member State, by profession, by type of

procedure and by outcome, as well as statistics on processing times and delays. This statistical

summary shall not include any personal data.

3. Every five years from [the date falling 8 years after the adoption of this Directive] the

Commission shall publish a report on the implementation of this Directive.

4. With a view to evaluating the functioning of EDRS referred to in Article 56b of this

Directive, the first report published in accordance with paragraph 3 of this Article shall carry

out an evaluation of this Directive. The Commission shall present a report on the main

findings of that evaluation to the European Parliament, the Council, the European Economic

and Social Committee and the Committee of the Regions regarding the use of digital tools, the

reduction of administrative burden and costs, the availability of relevant information to

applicants, and the duration of recognition procedures.

5. Member States shall provide all the necessary information for the preparation of the reports

referred to in paragraph 3 and 4.';

(24) the following Article 60a is inserted:

'Article 60a

Cooperation between the Commission and the Member States

1. The Commission shall cooperate with the Group of Coordinators established under

Decision 2007/172/EC25, on matters related to the implementation of this Directive with a

view to sharing best practices, identifying the need for guidance and promoting convergence

among Member States.

2. The Commission shall adopt an annual work programme for the Group of Coordinators. It

shall make that work programme, together with the relevant preparatory documents, publicly

available.

25 Commission Decision 2007/172/EC of 19 March 2007 setting up the group of coordinators for the

recognition of professional qualifications, OJ L 79, 20.3.2007, pp. 38–39 (BG, ES, CS, DA, DE, ET,

EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, RO, SK, SL, FI, SV), OJ L 219M, 24.8.2007, pp. 367–368

(MT), ELI: http://data.europa.eu/eli/dec/2007/172/oj

EN 33 EN

3. The annual work programme shall include:

(a) priority topics and issues to be addressed;

(b) appropriate tools and methods to be applied;

(c) expected outputs and deliverables, including those deriving from potential

work on common training frameworks in accordance with Article 49a, together

with indicative timelines, where appropriate;

(d) the subgroups to be established, maintained or discontinued, together with their

mandates.

4. The Commission shall submit the draft annual work programme to the Group of

Coordinators for endorsement no later than at the final meeting of the preceding year.

5. The Group of Coordinators shall establish a subgroup for the digitalisation of recognition

procedures. The subgroup’s tasks shall be the following:

(a) to establish cooperation between Member States’ authorities and the

Commission on questions relating to the digitalisation of procedures for the

recognition of professional qualifications;

(b) to facilitate the implementation of Articles 56b(4), 56c to 56e of this Directive;

(c) to liaise with other relevant recognition networks and expert groups on

digitalisation, in particular the Digitalisation Group established on the basis of

[Regulation(EU)XXX establishing a framework for portability of skills and

qualifications and amending Regulation (EU) 2018/1724], to ensure synergies

are fully exploited.

6. The Commission may adopt work programmes for the subgroups of the Group of

Coordinators upon submitting the draft work programme for endorsement by the subgroup

concerned. It shall make those work programmes, together with the relevant preparatory

documents, publicly available.';

(25) Annex VII is amended in accordance with the Annex to this Directive.

Article 2

Amendment to Regulation (EU) No 1024/2012

Point 2 of the Annex to Regulation (EU) No 1024/2012 is replaced by the following:

‘2. Directive 2005/36/EC of the European Parliament and of the Council on the

recognition of professional qualifications: Article 8, Article 21a, Article 50, Article

51a(5), Article 56, Article 56a to 56f and Article 59(1), (2) and (5) and Article 60(1)

of Directive 2005/36/EC, and in Article 11(1) of Directive (EU) 2018/958.’

Article 3

Transposition

1. Member States shall bring into force the laws, regulations and administrative provisions

necessary to comply with this Directive by 2 years after entry into force at the latest. They

shall forthwith communicate to the Commission the text of those provisions.

EN 34 EN

When Member States adopt those provisions, they shall contain a reference to this Directive

or be accompanied by such a reference on the occasion of their official publication. Member

States shall determine how such reference is to be made.

2. Member States shall apply the measures referred to in paragraph 1:

(a) from 2 years after entry into force of this Directive as regards Article 1,

paragraphs 3(a)(i), 5, 12, 15, 18, 20 and 24;

(b) from [the date of application of Directive xxxx/xxx/EU on the recognition of

qualifications of third-country nationals] as regards Article 1, paragraphs 1, 2,

3(b), 4, 6, 9, 10, 22 and 25;

(c) from [3 years after entry into force] of this Directive as regards Article 1,

paragraphs 3(a)(ii), 7, 8, 11, 13, 14, 15, 16, 17, 19, 21, 23 and Art. 2.

3. Member States shall communicate to the Commission the text of the main provisions of

national law which they adopt in the field covered by this Directive.

Article 4

Entry into force

This Directive shall enter into force on the […] day following that of its publication in the

Official Journal of the European Union.

Article 5

Addressees

This Directive is addressed to the Member States.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ...................................................................................... 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 3

1.3.4. Indicators of performance ............................................................................................ 3

1.4. The proposal/initiative relates to: ................................................................................. 4

1.5. Grounds for the proposal/initiative .............................................................................. 4

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 4

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 4

1.5.3. Lessons learned from similar experiences in the past .................................................. 4

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 5

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 5

1.6. Duration of the proposal/initiative and of its financial impact .................................... 6

1.7. Method(s) of budget implementation planned ............................................................. 6

2. MANAGEMENT MEASURES................................................................................... 8

2.1. Monitoring and reporting rules .................................................................................... 8

2.2. Management and control system(s) ............................................................................. 8

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed .................. 8

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them............................................................................................................ 8

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ........................................... 8

2.3. Measures to prevent fraud and irregularities ................................................................ 9

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 10

EN 2 EN

3.2. Estimated financial impact of the proposal on appropriations ................................... 12

3.2.1. Summary of estimated impact on operational appropriations.................................... 12

3.2.1.1. Appropriations from voted budget ............................................................................. 12

3.2.1.2. Appropriations from external assigned revenues ....................................................... 17

3.2.2. Estimated output funded from operational appropriations......................................... 22

3.2.3. Summary of estimated impact on administrative appropriations ............................... 24

3.2.3.1. Appropriations from voted budget .............................................................................. 24

3.2.3.2. Appropriations from external assigned revenues ....................................................... 24

3.2.3.3. Total appropriations ................................................................................................... 24

3.2.4. Estimated requirements of human resources.............................................................. 25

3.2.4.1. Financed from voted budget....................................................................................... 25

3.2.4.2. Financed from external assigned revenues ................................................................ 26

3.2.4.3. Total requirements of human resources ..................................................................... 26

3.2.5. Overview of estimated impact on digital technology-related investments ................ 28

3.2.6. Compatibility with the current multiannual financial framework.............................. 28

3.2.7. Third-party contributions ........................................................................................... 28

3.3. Estimated impact on revenue ..................................................................................... 29

4. DIGITAL DIMENSIONS .......................................................................................... 29

4.1. Requirements of digital relevance .............................................................................. 30

4.2. Data ............................................................................................................................ 30

4.3. Digital solutions ......................................................................................................... 31

4.4. Interoperability assessment ........................................................................................ 31

4.5. Measures to support digital implementation .............................................................. 32

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Directive of the European Parliament and of the Council amending

Directive 2005/36/EC on the recognition of professional qualifications as regards the

digitalisation of recognition procedures and recognition of professional qualifications

issued outside the Union and Regulation (EU) No 1024/2012.

1.2. Policy area(s) concerned

People, society and social model, Free movement of persons, labour mobility

Freedom of establishment, freedom to provide services

Digitalisation of public administrations

1.3. Objective(s)

1.3.1. General objective(s)

Improve the functioning of the EU system for the recognition of professional

qualifications by amending Directive 2005/36/EC

1.3.2. Specific objective(s)

Improve the availability, completeness and reliability of information on recognition

requirements and procedures.

Simplify and accelerate recognition procedures.

Strengthen administrative cooperation between competent authorities.

These objectives will be pursued through the increased use of interoperable digital

tools and workflows, supporting more efficient, transparent and user-friendly

recognition processes across the Union.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.

Professionals seeking recognition of their qualifications will benefit from faster,

simpler and more predictable recognition procedures, improved access to

information on recognition requirements and procedures, and quicker access to

employment in another Member State.

Competent authorities will benefit from more efficient and interoperable digital

workflows, reduced administrative burden and costs, improved administrative

cooperation, and more consistent implementation of the Directive across the Union.

Employers will benefit from faster recruitment processes, shorter vacancy durations

and improved access to skilled workers, helping to address labour and skills

shortages.

The economy is expected to benefit from a better-functioning internal market for

professional services, supported by a common European digital recognition solution

that creates economies of scale, reduces implementation costs, facilitates a more

efficient allocation of skills across Member States, improves labour market matching

and productivity, and strengthens resilience and competitiveness.

EN 4 EN

Society is expected to benefit from enhanced labour mobility, improved employment

opportunities, greater upward career mobility and increased income security for

professionals exercising their profession in another Member State. By improving the

allocation of skills across the Union, the proposal will also help address labour and

skills shortages and reinforce the delivery of services in sectors of particular

importance to society, including healthcare and education.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

Progress towards the specific objectives will be monitored through the following

indicators:

Availability and quality of information for applicants:

Presence and completeness of the information required under the Directive on

national portals.

Consistency between information provided through national portals and the RegProf

database.

Share of incomplete or incorrectly prepared applications attributable to information

gaps.

User satisfaction with the clarity and accessibility of information provided on

recognition procedures.

Efficiency of recognition procedures:

Average processing time for recognition procedures.

Average number of documents, translations and certified copies requested per

application.

Administrative effort required by competent authorities to process applications.

Share of recognition decisions adopted within the deadlines laid down in the

Directive.

Administrative cooperation between competent authorities:

Average response time to requests for administrative cooperation.

Average number of information requests and confirmation exchanges required per

recognition case.

Satisfaction of competent authorities with the quality and usefulness of the

information received from their counterparts.

1.4. The proposal/initiative relates to:

✓a new action

a new action following a pilot project / preparatory action26

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

26 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 5 EN

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

The Commission will start developing and testing the European Digital Recognition

Solution during the transposition period. Member States will have to transpose the

Directive and initiate the necessary legal, administrative and technical preparations.

After the expiry of the transposition deadline, the European Digital Recognition

Solution should be operational and Member States should have completed the

implementation and technical preparations necessary to apply the revised recognition

framework.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante)

The initiative concerns the functioning of the internal market, an area of shared

competence. Since the recognition of professional qualifications inherently involves

cross-border interactions between competent authorities, including the exchange of

information, validation of qualifications and verification of documents, effective

action requires a common Union framework. Member States acting individually

cannot establish common operational rules, ensure reciprocity or prevent divergent

administrative practices. Likewise, the deployment of interoperable digital solutions

cannot be achieved through isolated national initiatives without creating

fragmentation, duplication and a lack of interoperability. Union action is therefore

necessary to improve the functioning of the existing framework, enhance

transparency and monitoring, strengthen administrative cooperation, and ensure that

professionals can effectively exercise their Treaty rights to free movement.

Expected generated EU added value (ex-post)

The proposal is expected to generate EU added value by improving the legal

framework for the recognition of professional qualifications across the Union and

supporting it with unified digital tools. It will increase legal certainty and the

consistency of implementation, reduce administrative burdens and compliance costs

for both competent authorities and applicants, and improve the efficiency and

transparency of cross-border recognition procedures. The common European digital

recognition solution will create significant economies of scale by replacing the need

for multiple parallel national solutions and facilitating interoperability across

Member States. The proposal will also strengthen monitoring and enforcement

through the availability of comparable Union-wide data, enabling the Commission

and Member States to identify implementation problems more effectively and

support the consistent application of Union law. Together, these benefits will

contribute to a better-functioning internal market, more efficient labour mobility and

a more effective exercise of the Treaty rights of citizens and professionals

1.5.3. Lessons learned from similar experiences in the past

The experience gained from the implementation of the 2013 revision of Directive

2005/36/EC demonstrates the benefits of introducing digital elements into

EN 6 EN

recognition procedures, while also highlighting the limitations of an approach based

primarily on voluntary and decentralised implementation. Although digital tools have

improved certain aspects of administrative cooperation and information exchange,

their uptake has been uneven across Member States and they have not resulted in a

scalable, end-to-end digital recognition process. These lessons point to the need for a

more integrated and interoperable approach based on a common digital workflow at

Union level, while preserving Member States' competence for decisions on the

recognition of professional qualifications.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

The proposal is compatible with the current Multiannual Financial Framework. The

development, deployment and operation of the European Digital Recognition

Solution will be financed from existing Union programmes and budgetary resources

dedicated to digital public administration and the functioning of the internal market,

without requiring the creation of new financial instruments.

The initiative creates important synergies with existing Union instruments and

policies. It builds on the European Digital Identity framework and the eIDAS

Regulation through the use of interoperable digital credentials and trusted electronic

exchanges. It is fully consistent with the Interoperable Europe framework, the Single

Digital Gateway and the Once-Only Technical System by promoting interoperable

public services, reducing repetitive requests for documents and enabling more

efficient cross-border administrative cooperation. It also complements the

digitalisation of qualifications under the Skills Portability Initiative, where the

digitalisation of qualifications (Action 1) facilitates recognition procedures, while the

European Digital Recognition Solution (Action 2) provides concrete large-scale use

cases that support the uptake of digital qualifications. Together, these initiatives

contribute to the broader objective of delivering interoperable, user-friendly and

efficient digital public services across the Union.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The preferred financing option is direct financing from the Union budget, as the

initiative requires the development, deployment and operation of a common

European Digital Recognition Solution that will be used across all Member States. A

centrally financed solution ensures economies of scale, avoids duplication of

development and maintenance costs, and guarantees interoperability and consistent

implementation across the Union.

Alternative approaches based on separate national developments or decentralised

financing would require multiple parallel investments, increase integration costs and

create risks of fragmentation and inconsistent implementation. Financing through

existing Union programmes and budgetary resources allows the initiative to build on

existing digital infrastructure and expertise while ensuring efficient use of Union

funds. Where appropriate, existing resources will be redeployed to support the

implementation of the initiative.

The current proposal does not entail additional resources as compared to the situation

in the 2021-2027 multiannual financial framework and it builds on the current staff

assigned to the implementation of Directive 2005/36/EC. From 2028 on, the costs

linked to the proposal will be borne by the EU Facility under Heading 1 of the 2028-

EN 7 EN

2034 multiannual financial framework, subject to its adoption and the EU annual

budgetary procedure.

EN 8 EN

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

–  in effect from [DD/MM]YYYY to [DD/MM]YYYY

–  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

✓unlimited duration

– Implementation with a start-up period from YYYY to YYYY,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned

✓Direct management by the Commission

– ✓ by its departments, including by its staff in the Union delegations;

–  by the executive agencies

Shared management with the Member States

Indirect management by entrusting budget implementation tasks to:

–  third countries or the bodies they have designated

–  international organisations and their agencies (to be specified)

–  the European Investment Bank and the European Investment Fund

–  bodies referred to in Articles 70 and 71 of the Financial Regulation

–  public law bodies

–  bodies governed by private law with a public service mission to the extent that they

are provided with adequate financial guarantees

–  bodies governed by the private law of a Member State that are entrusted with the

implementation of a public-private partnership and that are provided with adequate financial

guarantees

–  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on European Union, and

identified in the relevant basic act

– bodies established in a Member State, governed by the private law of a Member

State or Union law and eligible to be entrusted, in accordance with sector-specific rules, with

the implementation of Union funds or budgetary guarantees, to the extent that such bodies are

controlled by public law bodies or by bodies governed by private law with a public service

mission, and are provided with adequate financial guarantees in the form of joint and several

liability by the controlling bodies or equivalent financial guarantees and which may be, for

each action, limited to the maximum amount of the Union support.

Comments

EN 9 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

Monitoring of performance will focus on the extent to which the proposal succeeds

in improving the availability, completeness and reliability of information on

recognition requirements and procedures, simplifying and reducing the cost and

administrative burden of recognition procedures, and strengthening administrative

cooperation between competent authorities.

The Commission will carry out monitoring in cooperation with the national

coordinators and competent authorities in the Member States. Monitoring will rely

on Monitoring will rely on statistics generated by the digital recognition system,

collected annually by the Commission; biennial reporting by competent authorities,

consolidated by National Coordinators; biennial reviews and surveys conducted by

the Commission.

The monitoring framework will include indicators measuring the completeness and

consistency of information on recognition requirements and procedures, the share of

incomplete or incorrectly prepared applications attributable to information gaps, user

satisfaction with the clarity and accessibility of information, the average processing

time for recognition procedures, the average number of documents, translations and

certifications requested, the administrative effort required to process applications,

compliance with procedural deadlines, the average response time to requests for

administrative cooperation, the average number of information requests and

confirmation exchanges per recognition case, and competent authorities' satisfaction

with the quality and usefulness of the responses received.

A pre-implementation benchmark will be established through a first data collection

in 2028. The baseline year for monitoring will be 2029, when the benefits of the

initiative are expected to begin materialising following the deployment of the

European Digital Recognition Solution. The monitoring framework will provide the

evidence necessary to support the evaluation of the initiative approximately five

years after the expiry of the transposition deadline.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

Direct management, as per article 62.1(a) of the Financial Regulation, is the

preferred mode of implementation, as the actions will be carried out by the European

Commission, specifically Directorate-General for Employment, Social Affairs and

Inclusion (DG EMPL), which will ensure the coordination with Member States and

the various stakeholders.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The controls are part of the internal control system of DG EMPL. The new activities

will be subject to the same risk identification and mitigation approach.

EN 10 EN

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The controls are integrated into the internal control system of DG EMPL. The new

activities will generate negligeable additional control costs at DG level.

2.3. Measures to prevent fraud and irregularities

The Commission shall ensure that, when actions financed are implemented, the

financial interests of the Union are protected by the application of preventive

measures against fraud, corruption and any other illegal activities, by effective

checks and by the recovery of the amounts unduly paid and, if irregularities are

detected, by effective, proportional and dissuasive penalties. The Commission is

authorised to carry out checks and verifications in situ under this Decision, in

compliance Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996

concerning on-the-spot checks and inspections carried out by the Commission in

order to protect the European Communities financial interests against fraud and other

irregularities. If need be, investigations shall be carried out by the European Anti-

Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the

European Parliament and of the Council of 25 May 1999 concerning investigations

conducted by the European Anti-Fraud Office.

EN 11 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

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

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

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

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

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

procedure. All appropriations and staffing allocations as of 2028 are indicative.

Under reserve of adoption of the Draft Budget 2027 for this budget line as proposed

by the Commission, the 2027 work programme a total of EUR 3.5 million has been

programmed under 07.020400: ESF+ - Employment and Social Innovation strand, in

order to support the business analysis, management of data quality, and IT

development of digital systems to support processes for the recognition of

professional qualifications, in particular EDRS.

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure

Contribution – to be determined at later stage for

EFTA, (potential) candidate countries and third

countries

Number

Diff./Non-

diff.27

from

EFTA

countries 28

from

candidate

countries

and

potential

candidates 29

From

other

third

countries

other assigned

revenue

To be determined after the adoption of the

MFF and in the context of the annual

budgetary procedure for the EU Facility –

Successor of 07 02 04 00 – ESF+ EaSI

strand

Diff./Non

-diff. YES/NO YES/NO YES/NO NO

07.020400: ESF+ - Employment and

Social Innovation strand

Diff./Non

-diff. YES/NO YES/NO YES/NO YES/NO

27 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 28 EFTA: European Free Trade Association. 29 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 12 EN

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

–  The proposal/initiative does not require the use of operational appropriations

–  The proposal/initiative requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework Number 1 - Economic, social and territorial cohesion, agriculture, rural and maritime

prosperity and security

DG: EMPL

Year Year Year Year Year Year Year

TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

Operational appropriations

Budget line – successor 07 02 04 Commitments (1a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (2a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Appropriations of an administrative nature financed from the envelope of specific programmes30

Budget line (3) n.a. n.a.n.a.n.a.n.a.n.a.n.a.n.a.

TOTAL appropriations Commitments =1a+1b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

for DG EMPL Payments =2a+2b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Total Heading 1 Year Year Year Year Year Year Year TOTAL

30 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

EN 13 EN

2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

MFF 2028-

2034

TOTAL operational

appropriations

Commitments (4)

p.m. p.m. p.m. p.m. p.m. p.m. p.m.

p.m.

Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from the

envelope for specific programmes

(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

TOTAL

appropriations

under HEADING 1

Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

• TOTAL

operational

appropriations (all

operational

headings)

Commitments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

• TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(all operational headings)

(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

TOTAL

appropriations

Under

Heading 1 to 3

Commitments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

EN 14 EN

of the multiannual

financial framework Payments =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

(Reference amount)

For 2027, the resource of the deployment of the system will come from EaSI. This initiative should be financed within the agreed envelope of the

programme.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

Heading of multiannual financial framework 4 ‘Administrative expenditure’31

DG:EMPL

Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

 Human resources 0.388 0.388 0.3880 0.3880 0.3880 0.388 0.388 2.716

 Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG

EMPL Appropriations 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

31 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 15 EN

TOTAL appropriations under HEADING 4 of

the multiannual financial framework

(Total

commitments =

Total payments) 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

EUR million (to three decimal places)

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

TOTAL

appropriations under

HEADINGS 1 to 4

Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

of the multiannual

financial framework Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indicate

objectives

and outputs

Year

2028

Year

2029

Year

2030

Year

2031

Enter as many years as necessary to show

the duration of the impact (see Section1.6) TOTAL

OUTPUTS

EN 16 EN

ò Type

32

Aver

age

cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost

N o

Cost Total

No

Total

cost

SPECIFIC OBJECTIVE No

1 33

…

- Output p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

- Output

- Output

Subtotal for specific objective

No 1

SPECIFIC OBJECTIVE No 2 ...

- Output

Subtotal for specific objective

No 2

TOTALS p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

32 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 33 As described in Section 1.3.2. ‘Specific objective(s)’

EN 17 EN

3.2.3. Summary of estimated impact on administrative appropriations

–  The proposal/initiative does not require the use of appropriations of an

administrative nature

–  The proposal/initiative requires the use of appropriations of an administrative

nature, as explained below

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS

Year Year Year Year Year Year Year TOTAL

2028 -

2034 2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

HEADING 4

Human resources 0.388 0.388 0.388 0.388 0.3880.3880.388 2.716

Other administrative expenditure 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal HEADING 4 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Other expenditure of an administrative nature

0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

3.2.4. Estimated requirements of human resources

–  The proposal/initiative does not require the use of human resources

–  The proposal/initiative requires the use of human resources, as explained

below

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs) 34

VOTED

APPROPRIATIONS

Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033

2034 and

subsequent

years

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and

Commission’s Representation

Offices)

2 2 2 2 2 2 2

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (inFTEs)

20 02 01 (AC, END from the

‘global envelope’) 0 0 0 0 0 0 0

34 Please specify below the table how many FTEs within the number indicated are already assigned to the

management of the action and/or can be redeployed within your DG and what are your net needs.

EN 18 EN

20 02 03 (AC, AL, END and

JPD in the EU Delegations) 0 0 0 0 0 0 0

Admin. Support

line

• at

Headquarte

rs

0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU

Delegation

s

0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) -

Heading 4 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 4

0 0 0 0 0 0 0

TOTAL 2 2 2 2 2 2 2

Considering the overall strained situation in Heading 4, in terms of both staffing and the level of

appropriations, the human resources required will be met by staff from the DG who are already

assigned to the management of the action and/or have been redeployed within the DG or other

Commission services.

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 4

or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts

2 N/A N/A N/A

External staff

(CA, SNEs, INT)

0 N/A N/A N/A

Description of tasks to be carried out by:

Officials and temporary staff Tasks will include overseeing the development and ensuring the legal and

technical compliance of the European Digital Recognition Solution (EDRS);

coordinating the transition from existing EU recognition tools to the EDRS,

including the necessary adaptations required for a smooth replacement of

current systems in cooperation with Member States; establishing and managing

the monitoring and reporting framework, including the collection of statistics

and performance indicators; and ensuring the continuous review and evolution

of the system so that it remains fit for purpose and adapts to future legal,

technical and policy developments.

External staff N/A

EN 19 EN

3.2.5. Overview of estimated impact on digital technology-related investments

Compulsory: the best estimate of the digital technology-related investments entailed

by the proposal/initiative should be included in the table below.

Exceptionally, when required for the implementation of the proposal/initiative, the

appropriations under Heading 4 should be presented in the designated line.

The appropriations under Headings 1-3 should be reflected as “Policy IT expenditure

on operational programmes”. This expenditure refers to the operational budget to be

used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation

of the initiative and their associated investments (e.g. licences, studies, data storage

etc). The information provided in this table should be consistent with details

presented under Section 4 “Digital dimensions”.

TOTAL Digital

and IT

appropriations

Year Year Year Year Year Year Year TOTAL

MFF

2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

IT expenditure (corporate)

0 0 0 0 0 0 0 0

Subtotal

HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Policy IT expenditure on operational programmes

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Subtotal outside

HEADING 4 p.m.p.m.p.m.p.m.p.m.p.m.p.m.p.m.

TOTAL p.m.p.m.p.m.p.m.p.m.p.m.p.m.p.m.

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

–  can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF)

The proposal builds on the Commission’s proposal for the MFF 2028-2034, subject

to its adoption and to the EU annual budgetary procedure, and in particular on the

EU Facility under Heading 1.

–  requires use of the unallocated margin under the relevant heading of the MFF

and/or use of the special instruments as defined in the MFF Regulation

–  requires a revision of the MFF

3.2.7. Third-party contributions

The proposal/initiative:

EN 20 EN

–  does not provide for co-financing by third parties but might be interesting for

EEA EFTA countries or (potential) candidate countries

–  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year

Total 2028 2029 2030 2031 2032 2033 2034

Specify the co-

financing body

(EFTA,

(potential)

candidate

countries, third

countries

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL

appropriations

co-financed

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.3. Estimated impact on revenue

–  The proposal/initiative has no financial impact on revenue.

–  The proposal/initiative has the following financial impact:

–  on own resources

–  on other revenue

–  please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

Budget revenue line:

Appropriations

available for

the current

financial year

Impact of the proposal/initiative 35

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

N/A

Other remarks (e.g. method/formula used for calculating the impact on revenue or

any other information).

N/A

35 In the case of traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts,

i.e. gross amounts after deduction of 10 % for collection costs, as proposed in COM(2025)574.

EN 21 EN

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital solutions and-

or digital public services)

Reference to the

requirement Requirement description

Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 56b, 56c

and 56d

Development, operation and use of

the European Digital Recognition

Solution.

The Commission must develop and

operate a European Digital

Recognition Solution for declarations

under Article 7 and recognition

procedures under Title III. Key

functions include:

• procedure configuration by

competent authorities

• applicant creation-editing-

withdrawal-monitoring of

applications

• submission of supporting

evidence from multiple sources

and formats (including digital

European Commission:

develops and operates the

system

Home and Host competent

authorities (users)

Applicants professionals

(users)

Application

processing and

decision on

recognition

Data

Digital public services

Digital solutions

Process digitalisation or

automation

EN 22 EN

qualification attestation format)

• integration with SDG OOTS

for retrieval of evidences

• automated assessment of

completeness

• Notifications to applicant,

including immediate

acknowledgement of receipt

upon submission of the

application

• integration with IMI

• requests for missing evidence

• deadlines for home-host

authorities

• alternative evidence if home

authority delays

• secure communication with

applicants

• decision-making support for

authorities through machine

translation and authenticity

verification

• transparent status information

on application progress

• issuing final decisions as digital

qualification attestations.

EN 23 EN

Member States must:

• ensure all declarations and

recognition requests are

submitted through the system

• use only the system and its IMI

integration for inter-authority

exchanges

• send official communication to

applicants through the system

• offer applicants a language

choice

• allow non-electronic

submission only in justified

exceptional cases, with the

Member State entering the

information into the system.

Article 56f

Processing of personal data.

The article provides rules on the

processing of personal data processing

in the system, including: the purposes

of processing, the Commission as

processor for system management and

infrastructure security, host Member

State as controller for processing of

recognition applications and

declarations for provision of services,

home Member State as controller for

verifying qualifications, confirming

European Commission

Host Member State

Home Member State

Applicants-data subjects

System administrators.

Processing of

personal data

Data

Digital public services

Digital solutions

EN 24 EN

authenticity of documents, responding

to requests (supporting information,

documents) of the applicant or the host

Member State, transparency, training

and audits, obligation for the

Commission concerning the automatic

deletion after 36 months.

Article 60(1),

(1b)

Statistics and reporting from the

system.

The European Commission must

publish:

1. An annual statistical summary

to the Group of Coordinators

using information recorded in

the European Digital

Recognition Solution. This

statistical summary shall

include:

a. The number of decisions

taken, broken down

i. By Member State

ii. By profession

iii. By type of

recognition

procedure

iv. By outcome

(decision)

European Commission

Group of Coordinators

Member States indirectly, as

data providers through

system use.

Reporting of

recognition processes

statistics

Data

Digital solutions

EN 25 EN

b. The statistics on processing

times of applications and

delays

4.2. Data

High-level description of the data in scope

Type of data Reference to the requirement(s) Standard and-or specification (if applicable)

Digital qualification attestations of formal

qualification • Article 56b, 56c, 56d

• Article 56f

Electronic attestations of attributes as defined under

eIDAS Regulation and Commission Implementing

Regulation 2024/2979(EU), OOTS evidence

Non-digital evidences of formal qualification and

other supporting evidences (as listed in Annex VII) • Article 56b, 56c, 56d

• Article 56f

Annex VII

Personal information accompanying declarations

under article 7 and recognition procedures • Article 56b, 56c, 56d

• Article 56f

n/a

Annual statistical summary of recognition

procedures (includes numbers of decisions,

breakdowns, outcomes, processing times and

delays)

• Article 60(1), (1b)

n/a

Alignment with the European Data Strategy

Explanation of how the requirement(s) are aligned with the European Data Strategy

EN 26 EN

In terms of compliance with the General Data Protection Regulation, the main roles and responsibilities related to personal data protection are

already set out in Article 56f.

No data is planned to be published as open data.

Alignment with the once-only principle

Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored

The use of the once-only technical system (OOTS) has already been envisaged for the retrieval of evidences of qualifications from competent

authorities in the Member States. Additionally, the use of the EUDI Wallet as an option for uploading evidence in the central European Digital

Recognition Solution facilitates the interoperable reuse by the citizen/professional of evidences already present in his/her wallet.

Additionally, the application of the once-only principle will continue to be supported – as is the case already today – by the use IMI for

cooperation between public administrations in the Member States. This cooperation helps public administrations avoid asking citizens for

additional documents, in the cases where such information can be retrieved from other public administrations via IMI.

Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

• Personal data (including professional qualifications or information within recognition procedures) is in general not supposed to be

findable or reusable.

• Interoperability of evidence on professional qualifications is guaranteed through the use of EUDI Wallets or OOTS evidences. Such

standard will ensure mutual understanding of qualifications between Member States. While these standards will not be used for all

evidence types, at least in an initial stage, the supporting system will be ready to adapt to new standardised evidences as soon as they

become available.

• Statistical data on recognition procedures and on the use of the EDRS system, as indicated in Article 60, will be published by the EC on

the public part of the RegProf database.

• It is worth mentioning that, as already happening today (i.e. no changes compared to current situation):

o Information on regulated professions, procedures, fees, and appeal routes will be findable and accessible by citizens on national

online sites (as mandated by article 57).

o Information on the list of regulated professions, including a general description of activities covered by each professional will

EN 27 EN

be findable and accessible by citizens on the publicly available database of regulated professions set up by the Commission (as

mandated by Article 59 (1)).

Data flows

High-level description of the data flows

Type of data Reference(s)

to the

requirement(s)

Actors who

provide the

data

Actors who

receive the data

Trigger for the

data exchange

Frequency (if

applicable)

Application information accompanying

declaration under article 7 and

recognition procedures

Development,

operation and

use of the

European

Digital

Recognition

Solution.

Processing of

personal data

Professional

(citizen)

Competent

authority in host

Member State

(via EDRS)

Submission of

declaration under

Article 7 on EDRS

by the professional

Once per

declaration

Digital qualification attestations of

formal qualifications

Development,

operation and

use of the

European

Digital

Recognition

Solution.

Digital

qualification

Professional

(citizen)

Competent

authority in host

Member State

(via EDRS)

Application

preparation for

recognition

procedure by

professional

Once per

application

EN 28 EN

attestations as

supporting

evidence.

Non-digital evidences of formal

qualifications and other supporting

evidences (as listed in Annex 7)

Development,

operation and

use of the

European

Digital

Recognition

Solution

Professional

(citizen)

Competent

authority in host

Member State

(via EDRS as

uploaded

attachments)

Application

preparation for

recognition

procedure by

professional

Annual statistical summary of

recognition procedures (includes

numbers of decisions, breakdowns,

outcomes, processing times and delays)

Statistics and

reporting from

the system.

European

Commission

Group of

Coordinators

Annually

4.3. Digital solutions

High-level description of digital solutions

Digital

solution

Reference(s)

to the

requirement(s)

Main mandated

functionalities

Responsible

body How is accessibility catered for?

How is

reusability

considered?

Use of AI

technologies

(if

applicable)

European

Digital

Recognition

Solution

(EDRS)

Article 56b

and 56c

Article 60(1),

(1b)

Key functions include:

• procedure

configuration by

competent

European

Commission

The EDRS shall be accessible for

persons with disabilities by

complying with the

relevant accessibility requirements

of the Web accessibility directive

The system will

be built on

existing (or in

the process of

being built)

An AI module

is foreseen to

support the

decision-

making in the

EN 29 EN

authorities

• applicant

creation-editing-

withdrawal-

monitoring of

applications

• submission of

supporting

evidence from

multiple sources

and formats

• integration with

SDG OOTS

• integration with

EUDI Wallets

• automated

completeness

assessment

(against

procedure

requirements) of

the application

prior to

submission

• Notifications to

applicant,

including

immediate

acknowledgeme

(Directive (EU) 2016/2102)

components,

including:

• the IMI

workflow

engine and

back-office

module for

competent

authorities

• the

upcoming IMI

front-office

for citizens

• the

existing

RegProf

database for

information

on regulated

professions

and

requirements

• the

EUDI

framework for

issuing and

presenting

digital

recognition

procedure.

Note: The AI

capabilities

will act as a

support, it will

not replace

human

oversight, the

decisions on

recognition,

including the

statement of

reasons,

should remain

the sole

responsibility

of the

competent

authorities

This will

include:

evidence

classification,

evidence

authenticity

and veracity

detection

(detection of

tampering,

forgeries,

EN 30 EN

nt of receipt

upon

submission of

the application

integration with

IMI for secure

message

exchange

between the

competent

authorities of

Member States

• requests for

missing

evidence

• deadlines for

home Member

State and host

Member State

competent

authorities

• Searches for

alternative

evidence by host

Member

competent

authority if

home Member

State’s

competent

qualification

attestations

• the

OOTS system

for retrieving

evidences

from

competent

authorities

etc.),

translation,

matching of

evidence

against

national

procedure

requirements

(including

analysis of

substantial

difference in

training

requirements),

the

identification

of similar

previously

assessed cases

with a view to

promoting

consistency in

decision-

making

EN 31 EN

authority delays

in providing

requested

evidence

• secure

communication

with applicants

• support for

authorities

through

machine

translation,

completeness

assessment in

line with

national

requirements,

and authenticity

verification of

provided

evidence

• transparent

status

information on

the progress of

application

• issuing final

decisions as

digital

qualification

EN 32 EN

attestations.

• Statistical

reporting on the

implementation

of the directive

(including the

number of

decisions taken,

broken down by

Member State,

by profession,

by type of

procedure and

by outcome, as

well as statistics

on processing

times and

delays)

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

EDRS

Digital and-or sectorial policy (when these are

applicable)

Explanation on how it aligns

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

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

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

EN 33 EN

narrow procedural tasks, namely document classification and the detection of

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

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

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

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

documented as required before deployment. Compliance with the transparency

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

information provided to applicants where those obligations apply. Should the

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

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

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

applicable requirements will be verified accordingly.

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

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

order to allow applicant to store digital qualification attestations of formal

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

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

used for this purpose.

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

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

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

the Wallet of the applicant.

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

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

integrated with IMI message exchange module.

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

format of the EUDI digital qualification attestations to be issued by

EN 34 EN

competent institutions in the Member States and uploaded by the citizen

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

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

classification of professions in the RegProf database and the ESCO

classification is foreseen.

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

interface. Applicants could retrieve information already stored in Europass to

populate their application and prepare and submit their recognition request

directly through the platform.

4.4. Interoperability assessment

High-level description of the digital public service(s) affected by the requirements

Digital public

service or category

of digital public

services

Description Reference(s) to the

requirement(s)

Interoperable

Europe Solution(s)

Other interoperability solution(s)

European Digital

qualification

recognition service

Service used by applicants and

competent authorities to manage

the overall recognition process.

Article 56b and 56c

Article 60(1), (1b)

n/a IMI, EUDI Wallets

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

Digital recognition service

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

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

EN 35 EN

sectorial policies

Please list the applicable digital and

sectorial policies identified

with the eIDAS Regulation and its

implementing acts in order to support

retrieval and storage of digital

qualification attestations in the format

of electronic attestations of attributes

as set out in the Commission

Implementing Regulation (EU)

2024/2979.

• Provision included in the AI act will

also need to be reviewed and verified

during the design and implementation

phase of the service, and appropriate

measures and safeguards put in place

to ensure transparency, personal data

protection and the prevailing of

human oversight over AI

recommendations and outputs in the

recognition decision process

• The IMI regulation will also apply as

the system will be mainly based on

IMI components.

• SPI Action 1: Action 1 of the Skills

Portability Initiative will define the

format of the EUDI digital

qualification attestations to be issued

by competent institutions in the

Member States and uploaded by the

citizen during the recognition process.

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

EN 36 EN

smooth cross-border digital public

services delivery

Please list the governance measures

foreseen

responsibility of the European

Commission, including its operations,

and leverages on the existing IMI

organisation and governance.

• The service will provide multilingual

support to make sure that it can be

smoothly used by applications and

administrations in all MSs.

• Article 56c mandates Member States

to ensure that all declarations and

requests for recognition are submitted

through the system (apart from

exceptional case).

Measures taken to ensure a shared

understanding of the data

Please list such measures

• Information on regulated professions

(included in the RegProf database,

part of IMI) will be standardised

across Member States and reused by

the EDRS. This measure will include

a mapping between the current

taxonomies used in RegProf to

classify professions and the ESCO

classification.

• Qualifications in digital qualification

attestations format will also be

standardised, in synergy with the

work being carried out by SPI action

1.

• Non-standard qualifications and other evidences

(e.g. manually scanned documents) might continue

to pose an interoperability problem. Complete

standardisation of all possible documentation (e.g.

in digital qualification attestation format),

including documents not strictly related to the

professional qualification process, is not realistic in

the short-term. However, all standardisation efforts

will be supported where necessary, and the service

will be adapted to support new digital evidence in

standard format.

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

EN 37 EN

technical specifications and

standards

Please list such measures

will be integrated and related

specifications (e.g. on evidence

format) used for interoperability.

• The EUDI framework, including

technical specifications and reference

standards, will be reused to support

digital qualification attestations for

professional qualifications and (where

possible) other documents. The SPI

action 1 will define the exact format

of the digital qualification attestations

for qualifications.

4.5. Measures to support digital implementation

High-level description of measures supporting digital implementation

Description of the measure Reference(s) to the requirement(s) Commission

role

(if applicable)

Actors to be

involved

(if applicable)

Expected timeline

(if applicable)

Pilot project for the use of AI in

application assessment for the

applicant

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

being considered to support applicants during the

application preparation stage. This functionality

would assist applicants by answering questions

related to their application for the recognition of

professional qualifications or to a declaration

under Article 7 for the provision of services.

Where necessary, it would also direct applicants to

Commission

(EMPL.B5) and/

or contractor

Before end of

2026/Q1 2027

EN 38 EN

the relevant national assistance centres for further

support in resolving their queries. A pilot project

would be needed to assess this use case and

evaluate how it should function in practice.

Setting up of sub-groups to assist

in the work of the GoC (Group of

Coordinators)

In accordance with Article 5 (3) of Commission

decision of 19 March 2007 setting up the group of

coordinators for the recognition of professional

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

set up when the Commission’s representative

deems that the involvement of experts or

observers with specific competence on a subject

on the agenda of the Group of Coordinators is

necessary.

Support and

facilitation

Commission

Setting up working groups in

Member States for acceptance and

roll-out of EDRS

Working groups would need to be set up in the

Member States to coordinate the testing activities

during the delivery phases of the project

Support and

facilitation

Commission,

Member States

Data Protection Impact

Assessment (DPIA)

Under Regulation (EU) 2018/1725, a data

protection impact assessment (DPIA) is required

before processing where a type of processing is

likely to result in a high risk to the rights and

freedoms of natural persons, in particular when

using new technologies and taking into account

the nature, scope, context and purposes of the

processing.

In the context of EDRS, a DPIA would be

required due to the following reasons:

Controller Commission

(EMPL.B5,

EMPL.A4, DPC

of EMPL,

DPO), EDPS

(optional)

EN 39 EN

1. Systematic and extensive evaluation of

personal aspects based on automated

processing, including profiling, where

decisions are based on that processing and

those decisions produce legal effects

concerning the person or similarly

significantly affect them;

2. Use of new or innovative technologies;

3. Processing on a large scale of special

categories of data referred to in Article 10;

For EDRS, the special category of data under

Article 10 that would apply are for cases when:

a. The processing is necessary for the

purposes of carrying out the

obligations and exercising specific

rights of the controller or of the data

subject in the field of employment and

social security and social protection

law

b. The processing is necessary for

reasons of substantial public interest,

on the basis of Union law which shall

EN 40 EN

be proportionate to the aim pursued,

respect the essence of the right to data

protection

c. the processing is necessary for the

purposes of preventive or

occupational medicine, for the

assessment of the working capacity of

the employee, medical diagnosis, the

provision of health or social care or

treatment or the management of health

or social care systems and services on

the basis of Union law

d. the processing is pursuant to contract

with a health professional

e. the processing is necessary for reasons

of public interest in the area of public

health, such as protecting against

serious cross-border threats to health

or ensuring high standards of quality

and safety of healthcare and of

medicinal products or medical

devices, on the basis of Union law

4. Processing of personal data relating to criminal

convictions and offences referred to in Article 11

EN 41 EN

Contents of a DPIA:

According to Article 39 (7), the DPIA must

contain at least:

1. A systematic description of the envisaged

processing operations and the purposes of

the processing, including where applicable,

the legitimate interest pursued by the

controller

2. An assessment of the necessity and

proportionality of the processing

operations in relation to the purposes

3. An assessment of the risks to the rights and

freedoms of data subjects

4. The measures envisaged to address the

risks, including safeguards (e.g.,

encryption, pseudonymisation, incident

response procedures, logging and audit

trails, etc.) , security measures and

mechanisms to ensure the protection of

personal data and to demonstrate

compliance with this Regulation taking

into account the rights and legitimate

interests of data subjects and other persons

EN 42 EN

concerned.

EDPS prior consultation If the DPIA indicates that the processing would

result in a high risk in the absence of measures

taken to mitigate the risk, the controller

(Commission in the case of EDRS) must consult

the EDPS prior to processing. This is covered by

Article 40 of Regulation (EU) 2018/1725.

When consulting the European Data Protection

Supervisor, 1, the controller shall provide the

European Data Protection Supervisor with:

a. the respective responsibilities of the

controller, joint controllers (where

applicable) and processors involved in the

processing;

b. the purposes and means of the intended

processing;

c. the measures and safeguards provided to

protect the rights and freedoms of data

subjects pursuant to this Regulation;

d. the contact details of the data protection

officer;

Controller Commission

(EMPL.B5,

DPC of EMPL,

DPO), EDPS

EN 43 EN

e. the data protection impact assessment

provided;

f. any other information requested by the

European Data Protection Supervisor.

Accessibility assessment of the

digital platform • Ensure equal access and inclusion for use

of the tool by all individuals, including

persons with disabilities, thereby

supporting non-discrimination

• Improve overall usability and user

experience

• Identify potential accessibility issues at an

early stage

• Reduce operational, compliance and

reputational risks

• Ensure compatibility with relevant

assistive technologies, such as screen

readers, magnification software, voice

recognition tools, and keyboard-only

navigation.

Commission Before roll-out of

EDRS tool

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 995 final

ANNEX

ANNEX

to the

Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and Regulation No

(EU) 1024/2012

{SEC(2026) 995 final} - {SWD(2026) 995 final} - {SWD(2026) 996 final} - {SWD(2026) 997 final}

EN 1 EN

ANNEX

Annex VII to Directive 2005/36/EC is amended as follows:

(1) point 1 is amended as follows:

(a) point (b) is replaced by the following:

‘(b) Copies of the attestations of professional competence or of the evidence of formal

qualifications giving access to the profession in question, or corresponding digital

qualification attestations, and an attestation of the professional experience of the person

concerned, where applicable.

The competent authorities of the host Member State may invite the applicant to provide

information concerning the applicant’s training to the extent necessary in order to determine

the existence of potential substantial differences with the required national training, as laid

down in Article 14. Where it is impossible for the applicant to provide this information, the

competent authorities of the host Member State shall address the contact point, the competent

authority or any other relevant body in the home Member State.’;

(b) points (d) and (e) are replaced by the following:

‘(d) Where the competent authority of a host Member State requires of persons wishing to

take up a regulated profession proof that they are of good character or repute or that they have

not been declared bankrupt, or suspends or prohibits the pursuit of that profession in the event

of serious professional misconduct or a criminal offence, that Member State shall accept as

sufficient evidence, in respect of nationals of Member States wishing to pursue that profession

in its territory, the production of documents issued by competent authorities in the home

Member State or the Member State from which the foreign national comes, showing that

those requirements are met.

Where the competent authorities of the home Member State or of the Member State from

which the foreign national comes do not issue the documents referred to in the first

subparagraph, such documents shall be replaced by a declaration on oath, or, in States where

there is no provision for declaration on oath, by a solemn declaration, made by the person

concerned before a competent judicial or administrative authority or, where appropriate, a

notary or qualified professional body of the home Member State or the Member State from

which the person comes; such authority or notary shall issue a certificate attesting the

authenticity of the declaration on oath or solemn declaration.

(e) Where a host Member State requires of its own nationals wishing to take up a regulated

profession, a document relating to the physical or mental health of the applicant, that Member

State shall accept as sufficient evidence thereof the presentation of the document required in

the home Member State. Where the home Member State does not issue such a document, the

host Member State shall accept a certificate issued by a competent authority in that State.’;

(2) point 2 is replaced by the following:

‘2. Certificates

To facilitate the application of Title III, Chapter III, of this Directive, Member States may

prescribe that, in addition to evidence of formal qualifications that is not presented in the form

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of a digital qualification attestation, the person who satisfies the conditions of training

required must provide a certificate from the competent authorities of that person’s home

Member State stating that this evidence of formal qualifications is that covered by this

Directive.’

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 995 final

COMMISSION STAFF WORKING DOCUMENT

Subsidiarity Grid

Accompanying the document

Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and the Regulation

(EU) No 1024/2012

{COM(2026) 995 final} - {SEC(2026) 995 final} - {SWD(2026) 996 final} - {SWD(2026) 997 final}

1

Subsidiarity Grid

- As proposed by the Committee of the Regions with guidance in blue

- Obviously, the answers to the questions below, the explanatory memorandum and – if

applicable – the impact assessment should be consistent. This may require some iterations.

- Please try to stay under 10 pages.

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 the same legal basis as Directive 2005/36/EC, namely Articles 46, 53(1) and 62 of the Treaty on the Functioning of the European Union (TFEU). These provisions empower the Union to adopt measures facilitating the free movement of workers, the freedom of establishment and the freedom to provide services, including through the mutual recognition of diplomas, certificates and other evidence of formal qualifications and the coordination of national provisions governing access to and the pursuit of regulated professions.

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. The evolution of an EU legal framework since 2005, incuding its amending and modernising in 2013, with further modernisation now proposed through SPI Action 2, demonstrates that EU-level action in this area is necessary and appropriate.

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. In addition to the consultations carried out in the context of the recent report on the implementation of the Professional Qualifications Directive, the Commission conducted a public consultation as part of the Skills Portability Initiative and targeted stakeholder consultations. Furthermore, the external

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

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contractor supporting the preparation of the impact assessment organised a range of targeted consultation activities with competent authorities, national coordinators, professional organisations and representatives of regulated professions, as well as targeted surveys of competent authorities and citizens who had undergone recognition procedures. These are described 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?

Yes, the explanatory memorandum and impact assessment explain that 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. The current initiative aims to improve this existing legal framework for recognition at EU level. Changes to the EU framework can only be done through EU level action. Recognition procedures inherently require interaction between competent authorities in different MS, including the exchange and verification of information, validation of qualifications, and clarification of documentation. Unilateral efforts by MS to streamline their own procedures do not resolve these issues, as they neither ensure reciprocity nor establish common operational rules for cooperation. These issues are structural and cross-border in nature and cannot be adequately addressed through isolated national measures Without coordinated action at Union level, the system remains dependent on heterogeneous practices and ad hoc communication, limiting the potential for simplification and efficiency gains. Moreover, the integration of digital tools to facilitate recognition procedures requires a common framework to be effective. If developed separately at national level, such tools would risk fragmentation, duplication and lack of interoperability.

Union action is also necessary to strengthen transparency and enforcement of the existing rules. At present, the monitoring of recognition procedures relies largely on MS’ self-reported data and individual complaints, which does not provide a comprehensive or reliable basis for assessing compliance and to enforce the rules in the event of systematic incompliance. Action at EU level is needed to ensure consistent and comparable data to support both national and EU-level corrective measures. Such transparency cannot be achieved through uncoordinated national systems. In the absence of Union intervention, the identified problems are likely to persist, resulting in continued delays, administrative burdens and legal uncertainty for applicants and CA A further coordinated EU framework would lead to more consistent and reliable recognition decisions across MSby streamlining information requirements, deadlines and cooperation practices. This can also facilitate the availability of reliable and comparable data, reduce administrative effort, lower reporting costs, and minimise risks of errors or inconsistencies, while enabling more timely and accurate monitoring. EU-level action also offers economies of scale and avoids duplication of efforts. A common EU approach to key aspects of the recognition process is more cost-effective than multiple parallel national solutions, which may be incompatible or require complex interfaces. EU-level intervention ensures interoperability, thereby maximising the benefits of digitalisation and preventing fragmentation. While Union action requires initial adaptation efforts by national administrations, these costs are expected to be offset by long-term efficiency gains, reduced administrative burden, and improved service delivery. Overall, EU action provides a more efficient and coherent solution than uncoordinated national approaches, delivering benefits that cannot be achieved at the same scale or consistency by MS acting alone.

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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?

(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 proposal addresses an inherently cross-border issue. The recognition of professional qualifications involves a qualification obtained in one Member State being assessed for the purpose of exercising a regulated profession in another Member State. Recognition procedures therefore require cooperation between competent authorities across national borders. The procedure itself generates direct administrative costs for both applicants and competent authorities through the preparation, submission and processing of recognition applications. The accompanying impact assessment quantifies these administrative costs and the savings expected from the proposal. It also quantifies the monetised benefits of shorter recognition procedures, reflecting faster labour market integration of mobile professionals, as well as broader economic and social benefits, including improved recruitment opportunities for employers, better matching of skills to labour market needs, higher labour productivity, reduced overqualification, greater labour market resilience and improved employment opportunities for professionals.

The proposal contributes directly to the effective exercise of the freedom of establishment and the freedom to provide services, which are core objectives of the Treaties. While Member States remain fully responsible for deciding which professions to regulate and for taking individual recognition decisions, unilateral national action cannot establish a coherent framework for cross-border recognition. Divergent procedures, incompatible digital solutions and differing administrative practices would continue to create obstacles to mobility and reduce the effective functioning of the internal market. Coordinated Union action is therefore necessary to establish common procedural rules and common digital infrastructure for recognition procedures.

At the same time, the proposal fully respects Member States' competences and administrative autonomy. Member States remain free to organise their administrative systems and implement the provisions of the Directive in accordance with their national legal and administrative traditions. The proposal does not affect their competence to regulate professions or to decide individual recognition cases. Rather, it is limited to those aspects where coordinated Union action provides clear added value. In particular, the Commission will develop, finance and operate the European Digital Recognition Solution, providing Member States with a common digital infrastructure that

5 https://europa.eu/european-union/about-eu/eu-in-brief_en

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reduces implementation costs, avoids duplication of effort and ensures interoperability. This supporting tool is complemented by clearer procedural rules, implementation guidance, training and strengthened administrative cooperation, enabling Member States to implement the Directive more efficiently and consistently.

Complexity of recognitoon procedures exists throughout the Union, but their practical manifestation varies depending on national administrative structures, regulatory systems and patterns of professional mobility. In some Member States, the regulation of professions is organised centrally, while in others competences are exercised at regional level. Recognition procedures may be particularly important in cross-border regions, where geographical proximity encourages labour mobility but access to regulated professions remains subject to national recognition requirements. More generally, Member States differ in the number and organisation of regulated professions, the volume of recognition applications, the level of digitalisation of competent authorities and the administrative resources available. Nevertheless, the underlying challenges—administrative burden, procedural complexity, delays and uneven digitalisation—have been consistently identified across the Union through the implementation report and stakeholder consultations.

The proposal has been designed to accommodate these differences. While Member States will need to adapt certain procedures, they are supported through a Commission-funded digital infrastructure, common workflows, implementation guidance, training and structured cooperation within the Group of Coordinators. These measures are expected to reduce, rather than increase, the administrative burden on national authorities. The benefits of the proposal will naturally differ in size according to the scale of recognition activity and the level of existing digital maturity. Member States processing large numbers of recognition applications are expected to benefit most immediately from simplification and economies of scale, while those with lower case volumes or less developed digital systems may require greater adjustments during the transition. In the longer term, however, all Member States are expected to benefit from greater legal clarity, improved administrative cooperation, lower implementation costs and a more efficient and coherent framework for the recognition of professional qualifications across the Union.

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 added value at Union level by reducing the administrative burden associated with the recognition of professional qualifications and improving the functioning of the internal market. The accompanying impact assessment demonstrates significant benefits for

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applicants, competent authorities and employers through lower administrative costs, faster recognition procedures and shorter recruitment times. These direct benefits are complemented by broader economic and social gains, including improved labour market matching, increased labour productivity, better employment opportunities for mobile professionals and a stronger capacity to address labour and skills shortages in key sectors. The proposal also delivers substantial economies of scale. Its central element is the European Digital Recognition Solution, which will be developed, financed and operated by the Commission. A single common digital infrastructure is considerably more cost-effective than multiple national solutions, avoiding duplication of investment, reducing implementation costs for Member States and ensuring interoperability across the Union. As demonstrated in the impact assessment, a common European solution delivers greater benefits at a lower overall cost than fragmented national approaches. The proposal does not replace national policies on the regulation of professions or the organisation of national administrations. Member States remain fully responsible for determining which professions are regulated and for taking individual recognition decisions. Rather than harmonising these areas, the proposal modernises and enhances the implementation of the established common procedural rules through common implementation tools to promote greater consistency in the application of the existing framework, while preserving the flexibility inherent in a directive. Accordingly, the proposal does not entail a transfer of competences from Member States to the Union. It supports national authorities in exercising their existing responsibilities more efficiently by providing common digital infrastructure, clearer procedural rules and enhanced administrative cooperation. The resulting benefits—in terms of lower administrative costs, faster recognition, improved labour mobility and a more effective internal market—clearly outweigh the limited procedural adjustments required at national level. Finally, the proposal significantly improves legal certainty by clarifying a number of provisions of Directive 2005/36/EC. It provides greater precision on procedural requirements, documentation, deadlines, fees, administrative cooperation and processes, thereby facilitating a more consistent implementation of the Directive and reducing uncertainty for competent authorities, applicants and other stakeholders.

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?

Yes, the explanatory memorandum and impact assessment contain an adequate justification regarding the proportionality of the proposal. The proposal concerns the revision of Directive 2005/36/EC, an area where the need for Union action is already established. The proposed amendments are limited to those necessary to address shortcomings identified through the implementation of the Directive, including fragmented information, unnecessarily burdensome recognition procedures, uneven levels of digitalisation and inefficiencies in administrative cooperation between competent authorities.

The proposal does not harmonise the substantive rules governing regulated professions or the conditions for the recognition of professional qualifications. Member States remain fully responsible for determining professional qualifications, regulating professions, assessing applications and taking recognition decisions. The proposed measures focus instead on improving the functioning of the

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recognition framework by clarifying certain procedural obligations, strengthening administrative cooperation and facilitating the use of interoperable digital tools.

Proportionality was assessed in the comparison of the policy options considered in the impact assessment. Each option was evaluated in light of the balance between its expected benefits and the implementation efforts required. The assessment also examined whether the scope, intensity and implementation requirements of the proposed measures were commensurate with the objectives pursued. The preferred option was selected because it provides the most effective response to the identified shortcomings while remaining limited to what is necessary. Although it entails a greater degree of intervention than the alternative options, this reflects the scale and persistence of the problems addressed and remains confined to procedural aspects of the recognition framework, without affecting Member States' competence over the regulation of

professions or substantive recognition decisions.

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 og 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 proposal is limited to those aspects of the recognition framework where coordinated Union action can provide clear added value, while fully respecting Member States' competences. It does not affect Member States' responsibility for regulating professions, determining access conditions or taking individual recognition decisions. Instead, it focuses on those procedural aspects that can be better addressed at Union level, including improving recognition procedures, facilitating exchanges between competent authorities, providing common digital tools and workflows, and ensuring that applicants receive clear, complete and comparable information throughout the recognition process. The proposal therefore concentrates on the interactions between applicants and competent authorities, cooperation between competent authorities and the operation of the recognition procedures themselves. The choice of a directive is appropriate and justified, as the proposal amends Directive 2005/36/EC and therefore necessarily takes the same legal form. A directive also remains the most suitable instrument because it allows Member States to implement the common framework in accordance with their national legal and administrative traditions. While preserving this flexibility, the proposal

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increases adds detail where experience has shown that the current provisions are insufficiently precise to ensure consistent implementation. It therefore introduces more detailed rules on issues such as documentation, translations, communication with applicants, fees and procedural deadlines, without altering the nature of the instrument. The proposal leaves the maximum possible scope for national decision-making consistent with achieving its objectives. It does not seek to regulate exhaustively every aspect of recognition procedures. Rather, it addresses those issues where greater convergence is necessary to improve the functioning of the internal market, while leaving all other aspects to the discretion of the Member States. The proposal entails budgetary implications for the Union, notably for the development, operation and maintenance of the European Digital Recognition Solution, as set out in the accompanying Financial Statement and Impact Assessment. Member States will incur certain transitional costs associated with adapting their administrative procedures and implementing the revised framework. However, these costs are expected to be limited and temporary, as the Commission will develop, finance and operate the common digital infrastructure. The resulting economies of scale, together with the expected reductions in administrative burden and processing costs, make these implementation costs proportionate to the objectives pursued. Finally, the proposal is designed to be applicable across the Union without requiring different regulatory solutions for individual Member States. While it can be implemented within diverse national administrative structures, its objective is precisely to promote greater convergence in the operation of recognition procedures by establishing common procedural rules and shared digital infrastructure, thereby significantly reducing the fragmentation of current recognition procedures. .

EUROPEAN COMMISSION

17.07.2026

SEC(2026) 995

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 995}

{SWD(2026) 995-997}

Impact assessment / Skills Portability Initiative Action 2 - modernise and expand recognition processes for regulated professions

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

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 / Skills Portability Initiative Action 2 - modernise and expand recognition processes for regulated professions

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context This initiative is part of the Skills Portability Initiative (SPI), which aims to contribute to a more integrated Single Market by supporting the free movement of professionals and help address skills shortages. This initiative (Action 2) interacts with two other actions, which are the subject of separate impact assessments:

• facilitating worker mobility across the EU through skills transparency and digitalisation (Action 1);

• improving the recognition of qualifications and skills of third-country nationals (Action 3).

This initiative focuses on access to regulated professions. It aims to improve the implementation of the Professional Qualifications Directive (2005/36/EC) by modernising and digitalising its procedures. This Directive sets out rules on the recognition of professional qualifications in a cross-border context. The actual regulation of professions falls within the competence of Member states.

(B) Key issues The Board notes the additional information provided and commitments to make changes to the report. However, the report still contains significant shortcomings. The Board gives a positive opinion with reservations because it expects the lead Service to rectify the following aspects: (1) The scope of the initiative is not sufficiently clear. Information on the regulated

professions, at EU and Member States level is insufficient and not detailed enough.

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(2) The problem analysis is not sufficiently complete nor detailed on the implementation shortcomings of the Professional Qualifications Directive (PQD) and the experience with its enforcement, to better justify why a further legislative initiative is required. Given the variety of regulated professions and related barriers, the report does not provide sufficient granular analysis of the problems.

(3) The report does not provide sufficient detail on the digitalisation measures and on how the digital solution is expected to work in practice and what risks or unintended consequences could arise from its implementation.

(4) The report is not sufficiently detailed in the assessment of coherence and proportionality of the preferred option. It does not sufficiently explain to what extent the preferred option is supported by stakeholders and what would be the practical issues possibly hampering its feasibility, notably in the light of the difficulties encountered so far by Member States’ authorities to implement the current Directive.

(C) What to improve (1) The report should clarify what constitutes (a) a professional qualification, (b)

‘automatic recognition’ and how the process under the PQD applies to it for cross- border purposes, and (c) ‘regulated professions covered by other recognition systems’, also explaining what these systems are. It should provide indicative examples of respective professions and explain to what extent the scope of the initiative covers activities in the areas of craft, commerce and industry, and professionals willing to provide services in another Member State on a temporary or occasional basis. It should explain to what extent it excludes professions covered by other EU legislation and, if so, which ones.

(2) The report should explain to what extent the findings of the 2011 PQD evaluation differ from those of the 2020-2024 PQD implementation report. It should explain what measures were taken since 2011 to address those shortcomings, including regarding the alignment between information available at EU and national levels. Based on available evidence and the latest reports, the report should discuss the extent to which the PQD has been effective in reaching its objectives. It should further analyse the root causes of the identified problems, and particularly the root causes of process inefficiencies, regarding for example workflow inefficiencies, capacities of the authorities of Member States, etc. Given that the report claims that the problem “exacerbates the issue of allocative inefficiency”, it should provide a more granular analysis of the regulated professions, the barriers hampering their mobility as well as assess the link related to obstacles with qualifications and their economic importance, using more recent data as far as possible.

(3) The measures should be better described. In particular, the report should explain the proposed digital solution and what is going to be part of the solution, (e.g. workflow management, exchange of information between Member States and document managements). The report should provide practical examples on how such system would work. It should better explain to what extent this initiative aims replacing the respective national IT systems, how the integration with national systems will be

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ensured, and who will be responsible for different parts of the digital solution. The report should be clear on who is responsible for the infrastructure and operation of the solution. Also, it should explain what interoperability is needed and how it will be ensured.

(4) The coherence with other initiatives should be better analysed. The report should further explain to what extent this initiative uses the same IT elements as in SPI action 1 and inform on the possible synergies as well as risks or unintended consequences that could arise from its implementation. The report should explain the coherence with relevant EU initiatives such as RegProf (Regulated Professions Database), IMI (Internal Market Information System), Single Digital Gateway, Digital passport, European Professional Card etc. fall into the scope of this analysis. It should better substantiate the respective conclusions and discuss how this initiative (action 2) will interact with the skill portability initiative (on third country nationals - action 3), as they both share the objective of facilitating labour mobility and remedy skill shortages, and build on the PQD processes.

(5) The report should explain in more detail how the practical implementation of the preferred option would take place. Given the difficulties encountered so far by the Member States’ authorities to implement the current legislation (PQD), the report should explain how the preferred option would be practically feasible.

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 before launching the interservice consultation. Full title Impact Assessment on Skills Portability Initiative Action 2 -

modernise and expand recognition processes for regulated professions

Reference number PLAN/2025/2645

Submitted to RSB on 17 June 2026

Date of RSB meeting 15 July 2026

Electronically signed on 17/07/2026 11:35 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 996 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

amending Directive 2005/36/EC as regards the digitalisation of procedures and

recognition of professional qualifications issued outside the Union and Regulation (EU)

No 1024/2012

{COM(2026) 995 final} - {SEC(2026) 995 final} - {SWD(2026) 995 final} -

{SWD(2026) 997 final}

EN EN

Action 2 – Skills Portability Initiative

Table of Contents

1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 1

1.1. Overall context of the Skills Portability Initiative ............................................ 1

1.2. Coherence of the package.................................................................................. 3

1.3 Skills portability and regulated professions ...................................................... 6

2. PROBLEM DEFINITION ..................................................................................................................... 8

2.1. What is the problem? ....................................................................................... 10

2.2. What are the problem drivers? ........................................................................ 14

2.3. How likely is the problem to persist? .............................................................. 20

3. WHY SHOULD THE EU ACT? ......................................................................................................... 21

3.1. Legal basis ....................................................................................................... 21

3.2. Subsidiarity: Necessity and added value of EU action ................................... 22

4. OBJECTIVES: WHAT IS TO BE ACHIEVED?................................................................................ 23

4.1. General objective ............................................................................................. 23

4.2. Specific objectives ........................................................................................... 24

5. WHAT ARE THE AVAILABLE POLICY OPTIONS? ..................................................................... 25

5.1. What is the baseline from which options are assessed? .................................. 25

5.2. Description of the policy options .................................................................... 28

5.2.1. Option 1 – Convergence of administrative practices through shared

standards ......................................................................................................... 28

5.2.2. Option 2 – Targeted procedural reforms for improved interoperability ........ 30

5.2.3. Option 3 – Unified EU workflow and enhanced enforcement ....................... 31

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 36

6.1. Direct cost impacts .......................................................................................... 38

6.1.1. Administrative cost savings and monetised time savings .............................. 38

6.1.2. Implementation costs ...................................................................................... 44

6.1.3. Costs related to expected volume increases ................................................... 46

6.2. Broader economic impacts .............................................................................. 47

6.3. Social impacts ................................................................................................. 49

6.4. Summary overview of impacts ........................................................................ 51

7. HOW DO THE OPTIONS COMPARE? ............................................................................................ 52

7.1. Effectiveness ................................................................................................... 52

7.2. Efficiency ........................................................................................................ 53

7.3. Coherence ........................................................................................................ 54

7.4. Comparative overview .................................................................................... 55

8. PREFERRED OPTION ....................................................................................................................... 56

8.1. Option 3: Unified EU workflow and enhanced enforcement .......................... 56

8.2. REFIT (simplification and improved efficiency) ............................................ 60

8.3. Application of the ‘one in, one out’ approach ................................................. 61

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 61

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 63

ANNEX 2: STAKEHOLDER CONSULTATION ....................................................................................... 64

ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................... 74

ANNEX 4: ANALYTICAL METHODS ...................................................................................................... 86

ANNEX 5: COMPETITIVENESS CHECK ............................................................................................... 102

ANNEX 6: SME CHECK ........................................................................................................................... 108

ANNEX 7: THE PQD AND THE REST OF THE SINGLE MARKET ACQUIS .................................... 114

ANNEX 8: THE LANDSCAPE OF REGULATED PROFESSIONS IN THE EU ................................... 116

ANNEX 9: EXPANSION OF AUTOMATIC RECOGNITION THROUGH CTFS ................................. 124

ANNEX 10: USER JOURNEY OF APPLICANTS TO REGULATED PROFESSIONS ......................... 125

ANNEX 11: MEASURES CONSIDERED ................................................................................................ 127

ANNEX 12: DISCARDED MEASURES ................................................................................................... 145

ANNEX 13: DIRECT COST IMPACTS .................................................................................................... 149

ANNEX 14: DIVERGING TERRITORIAL IMPACTS OF POLICY OPTIONS ..................................... 163

ANNEX 15: COMPARISON OF POLICY OPTIONS .............................................................................. 168

ANNEX 16: MONITORING INDICATORS ............................................................................................. 172

ANNEX 17: COMBINED IMPACTS OF SPI PREFERRED OPTIONS UNDER ACTION 1, 2, AND 3174

ANNEX 18: RESOURCES – REFERENCES ............................................................................................ 178

Glossary

Term or acronym Meaning or definition

ACs Assistance Centres

CA Competent Authorities

CTFs Common Training Frameworks

ECA European Court of Auditors

EDRS European Digital Recognition System

EPC European Professional Card

EQF European Qualifications Framework

GoC Group of Coordinators on professional qualifications

IA Impact Assessment

IMI Internal Market Information system

MS Member State(s)

PO Policy Option

PQD Professional Qualifications Directive

PSCs Points of Single Contact

RegProf Regulated Professions Database

SPI Skills Portability Initiative

SMEs Small and medium-sized enterprises

TCN Third-country nationals

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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

As underlined in the Competitiveness Compass, 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 channels4.

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.

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. While this represents a slight

dip from previous peaks, it signals an enduring difficulty for employers to find the right talent to sustain growth.

Structural factors, such as demographic change and skills demands from the twin transition, as well as poor

working conditions in some sectors are likely to sustain shortages in the foreseeable future. 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.

2

Uncertainty about whether qualifications and skills will be fully understood, valued, and

formally recognised (in the case of regulated professions7) 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.

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 relocation9. Improving skills portability across borders thus also contributes to

the ‘right to stay’.

Against this background, the so-called 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 The European Council underlined the need for decisive and swift action in the

area of skills as a key competitiveness driver, referring to “reskilling/upskilling and lifelong

learning, tackling skills and labour gaps in the context of wider demographic trends,

including talent mobility to and within the European Union, and ensuring equal

opportunities.”11

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.”12 They also underscored the need to “support Member States 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.”

In March 2025, the European Commission Communication on the Union of Skills

followed up on this commitment, announcing a “Skills Portability Initiative to open up more

opportunities for workers and businesses to fully capture the potential of the single market.”13

The Single Market Strategy further highlighted that lengthy and complex recognition

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). 9 ITEM study on challenges and solutions for recognising professional qualifications in cross-border regions. 10 Letta (2024). 11 EUCO 12/24. 12 Von der Leyen (2024). 13 COM (2025) 90 final.

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procedures hinder mobility and labour market functioning, and that TCN face particularly

significant barriers, identifying digitalisation and procedural simplification as key levers.14

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.”15 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.16

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 2005/36/EC,

addressing barriers to its implementation.17 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.18

As part of the Fair Labour Mobility package19,the Skills Portability Initiative aims to

empower European businesses to recruit the skilled labour force they need to remain

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 qualification and skills they acquired abroad because

labour market actors find it relatively more difficult to interpret and verify non-national

14 COM (2025) 500 final. 15 European Council meeting (19 March 2026) – Conclusions 16 One Europe, One Market Roadmap of the European Parliament, the Council of the European Union and the

European Commission 17 SOC/837-EESC-2025 18 CDR-1105-2025 19 For more context, see CWP 2026 Commission work programme 2026 - European Commission.

4

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: Removing barriers to workers’ mobility in non-regulated professions and

improving availability of verifiable, secure, digitalised and interoperable information on

qualifications and skills.

The first work strand of this action looks at the remaining barriers related to qualifications

and skills in non-regulated professions, which constitute 78% of EU labour force. In non-

regulated professions, uncertainty about how to treat qualifications obtained in another MS

leads employers to request comparisons with national qualifications even though these are not

legally required. These processes are often costly and time-consuming. Action 1 aims

to improve clarity and thus avoid time consuming case-by-case assessments and bring

simplification for employers and workers. The second work strand tackles the information

gap across MS, with the aim of facilitating access to both regulated and non-regulated

professions and any other use of qualifications and skills in the labour market. It aims to make

all qualifications instantly understandable and verifiable for labour market actors across the

Single Market by building on existing tools and setting common standards for digital

credentials to be interoperable, secure, machine-readable, and allow for instant verification of

authenticity and learning outcomes (knowledge, skills), thereby reducing the ‘interpretative

burden’ on hiring managers, and prevent further fragmentation between MS resulting from

uncoordinated investments in digitalisation. Action 1 is based on Article 46 TFEU.

Action 2: Targeted Intervention for Regulated Professions

The second action focuses specifically on improving cross-border recognition procedures for

access to regulated professions.20 There are currently over 5 700 professions regulated across

the EU21 covering an estimated 22% of the labour force22, 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 proportionality23. Consequently, there is a high variety of approaches to

20 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.”. 21 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 this IA 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. 22 See COM (2016) 820 final. 23 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.

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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 Directive24 (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 and 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 this IA.25 The second workstrand 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 this 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

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.

These three actions are closely interlinked. The interoperable, secure and verifiable digital

credentials developed under Action 1 will simplify and speed up recognition procedures in

the context of regulated professions under the PQD (Action 2) by reducing administrative

burdens on Competent Authorities enabling smoother, faster assessments. Action 3 addresses

24 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. 25 The link between this strand of work and the modernisation and digitalisation of recognition procedures is

explained in Annex 9 of the relevant IA.

6

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 actions to

facilitate recognition of qualifications of TCN is warranted. This is the purpose of Action 3.

1.1. Skills portability and regulated professions

This IA focuses on the modernisation and digitalisation of procedures under the PQD

(Workstrand 2 of Action 2).26

The regulation of professions, namely the requirement by law of specific qualifications in

order to have access to professional practice, falls within the competence of MS. Justified and

proportionate professional regulation serves important public interest objectives, including the

protection of public health, public safety, consumers, and the natural and built environment.

However, diverging access requirements to regulated professions limit professional

mobility across borders, creating legal and practical barriers for professionals wishing to

work in another MS and exacerbating shortages in professions.27

In principle, cross-border recognition of qualifications for all professions where specific

professional qualifications are required by law is covered by the PQD. As an exception, the

PQD does not apply to notaries (Article 2(4)) and to very few professions for which other EU

legislation sets out specific recognition arrangements that exclude the application of the PQD

or exhaustively regulate recognition matters. For example, Directive (EU) 2022/993 on

seafarers explicitly excludes the application of Directive 2005/36/EC, while specific

directives on lawyers (Directives 77/249/EEC and 98/5/EC) do not explicitly exclude it and

Directive 2005/36/EC could still apply on a subsidiary basis.28 The PQD provides definitions

of both a regulated profession and a professional qualification (Article 3). A regulated

profession is defined as a professional activity, or group of professional activities, for which

access, pursuit, or one of the modes of pursuit is subject, directly or indirectly, by virtue of

legislative, regulatory or administrative provisions, to the possession of specific professional

qualifications. A professional qualification is defined as a qualification attested by evidence

of formal qualifications (diplomas, certificates and other evidence certifying successful

completion of professional training), competence (for a training course not forming part of a

certificate or diploma) or professional experience.

Professional regulation spans a wide range of sectors across the European economy.29 The

diversity of regulated professions demonstrates that regulation may be driven either by the

26 Since the possibility to extend automatic recognition to additional regulated professions by means of CTFs is

already enshrined in the PQD, Workstrand 1 of Action 2 is covered as part of the baseline. 27 EURES (2023). 28 Other specific professions, to which the application of PQD is limited or excluded are, e.g., air traffic

controllers, statutory auditors, and train drivers. 29 Approximately 5 700 professions are regulated across the Member States. It is estimated that 22% of the EU

labour force works in these professions, either as employees or as self-employed persons. Cf COM(2016) 820

final.

7

economic importance of a profession or by the need to protect public interests such as public

health and safety, consumer protection, and the quality and continuity of essential services.

Regulated professions are found both in high-value-added activities, such as engineering and

other technical professions, and in sectors that are critical for societal resilience and the

functioning of public services, including healthcare and education. Obstacles to the mobility

of professionals in these sectors can therefore generate allocative inefficiencies by preventing

labour from moving where it is most needed, while also exacerbating labour shortages and

constraining the provision of essential services. Health and care professions account for by far

the largest share of professional recognition procedures (around 70% of establishment cases),

reflecting the importance of cross-border mobility in this sector. Education represents a

further 12% of establishment cases, followed by transport and machinery (6%), construction

and trades (5%), and technical and engineering professions (4%). These sectors coincide with

areas experiencing persistent labour shortages across the Union: four of the ten most

widespread shortage occupations are in healthcare (nurses, medical specialists, nursing

assistants and physiotherapists), two in transport and machinery (heavy truck and lorry

drivers, sheet metal workers), and three in construction and trades (welders, electricians and

plumbers).30 This illustrates the broad economic and societal importance of ensuring that

recognition procedures for professionals function efficiently across the European labour

market. This broad scope of regulation of professions is evidenced by information available

on the Regulated Professions Database (RegProf), which provides a comprehensive overview

of professions regulated by Member States and notified under Directive 2005/36/EC.31

Member States are required under Article 59 of the PQD to notify the Commission of the

professions they regulate and the activities covered by such regulation. These notifications are

made available through the RegProf database. However, the information submitted by

Member States is not always complete, consistent or sufficiently detailed, meaning that

the database does not currently provide the fullest overview of regulated professions across

the EU.

It should be noted in this regard that the number of regulated professions is only one indicator

of the extent of professional regulation in a Member State.32 Regulatory approaches differ

considerably. Some Member States regulate a broad professional field as a single profession,

while others regulate individual activities within that field as separate professions. Likewise, a

Member State may regulate relatively few professions but impose extensive requirements and

conditions for access and pursuit, whereas another may regulate a larger number of

professions subject to less stringent requirements. Consequently, the number of regulated

professions provides only a partial picture of the level of regulation.

30 Cf. Annex 8. 31 Regulated Profession Database 32 The extent of professional regulation varies considerably across Member States. While some regulate close to

100 professions, others regulate close to 400. Cf ECA Report 10/2024

8

Recognition procedures under the PQD seek to reconcile the legitimate objectives

pursued by professional regulation33 with the free movement of professionals. At the

same time, the responsibilities for processing recognition applications, designating competent

authorities, maintaining national lists of regulated professions, and providing information to

citizens lie with the MS. As a result, recognition of professional qualifications depends

largely on national regulatory regimes and administrative systems.

The recognition regimes included in the Directive are:

- Automatic recognition based on EU-level minimum training requirements is

applicable across all Member States and currently covers seven professions (including

medical doctors and general care nurses) as well as over 50 medical and dental

specialties. Under this system, the national competent authority must limit its scope to

verifying whether the diploma—and any accompanying certificates—corresponds exactly

to those listed in Annex V to the Directive. The authority may not check the contents of

the training, meaning it must refrain from requesting documentation specifying these

contents. It may, however, request other standard documents in line with Article 50 of the

Directive.

- Automatic recognition for professions in trade, industry or business based on

professional experience applies where the applicant’s professional activity is listed in

Annex IV to the Directive.. In these cases, the national authority proceeds directly to the

assessment of the professional experience documented by the applicant, which may

occasionally be accompanied by specific conditions related to training.

- Automatic recognition based on Common Training Principles includes Common

Training Tests (CTT) or Common Training Frameworks (CTF), which are based on an

EU-level test or EU-level minimum training requirements, respectively. This regime

applies exclusively within the Member States that actively participate in the specific CTT

or CTF.

- The general system of recognition, under which the competent authority of the host

Member State compares the applicant’s qualifications with the national training and

professional requirements established by that Member State for access to the profession,

and may require supporting documents to determine whether substantial differences exist

that could justify the imposition of compensatory measures, where the applicant’s

lifelong learning and professional experience do not compensate for those differences.

The Directive benefits not only professionals seeking long-term establishment in another

Member State, but also those wishing to exercise their profession temporarily and

occasionally across borders. It is thus closely linked to the Services Directive (2006/123/EC),

which lays down general provisions facilitating the free movement of services within the

Union. As the Services Directive itself acknowledges, its provisions give way to those of the

PQD where the two overlap. This reflects the central role of the PQD in governing the

mobility of professionals in regulated professions.

33 Member States remain free to regulate professions or amend existing professional regulation, provided that

such measures comply with the proportionality requirements laid down in Directive (EU) 2018/958 on a

proportionality test before adoption of new regulation of professions.

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2. PROBLEM DEFINITION

The decision to move and work in another Member State is influenced by a wide range of

factors, including employment opportunities, wages, working conditions, language, family

circumstances and broader economic conditions.34 Recognition of professional qualifications

is therefore only one of the determinants of mobility intentions. However, for regulated

professions, it occupies a unique position among these factors because it constitutes a legally

binding condition for access to the profession. Regardless of a professional's willingness to

move or the attractiveness of employment opportunities abroad, recognition requirements

determine whether they are legally permitted to practise their profession in the host Member

State. Efficient and predictable recognition procedures therefore do not create mobility

intentions in themselves, but they are essential for enabling existing mobility intentions to be

translated into actual cross-border professional mobility.35 This underlines the central role of

the PQD in enabling the free movement of professionals in regulated professions and

highlights the importance of improvements to recognition procedures assessed in this impact

assessment.

An average flow of 53 000 recognition decisions per year between 2020 and 2024 with a

positive recognition rate of 93% suggests that the different recognition systems offered by the

Directive effectively facilitate cross-border career transitions.36 However, the fact that, as

highlighted by ECA, only an estimated 6% of citizens aged 20 to 64 years moving to another

MS make use of the systems of recognition of professional qualification, while regulated

professions account for approximately 22% of the EU labour market, suggests that

professional mobility in regulated professions remains below its potential.37

34 The determinants of labour mobility extend beyond the scope of this initiative and are addressed through a

range of complementary EU policies, including the European Affordable Housing Plan, the forthcoming Quality

Jobs Act, the Union of Skills framework and the initiatives comprising the Fair Labour Mobility Package. The

proposed revision of Directive 2005/36/EC complements these initiatives by addressing the specific

administrative barriers arising from the recognition of professional qualifications. 35 Recent findings from Flash Eurobarometer 567 – Satisfaction with administrative services: citizens' views on

quality, accessibility and reliability illustrate the challenges citizens expect to face when interacting with public

administrations in another Member State. Nearly half of respondents (47%) identified the non-recognition of

documents or certificates from their home country as an expected difficulty, alongside language barriers (65%),

difficulties understanding how to access public services (57%), different requirements for non-nationals (52%),

confusing administrative processes (49%) and the need to provide the same information multiple times (47%). In

addition, 47% of respondents expected it to be difficult or very difficult to access public administration services

in another Member State. While the survey is not specific to the recognition of professional qualifications, it

provides useful evidence of the broader administrative barriers citizens anticipate in cross-border situations and

reinforces the need for simpler, more digital and interoperable recognition procedures. 36 The annual average is calculated by dividing by five the 264 000 decisions recorded in RegProf during the

period 2020–2024, for qualifications obtained in an EU MS and mobility to all EEA countries. Previously,

between 2008, when the transposition deadline for Directive 2005/36/EC expired, and 2015, before the

transposition deadline for the revisions of 2013 expired, Member States issued 475 226 recognition decisions.

Between 2016 and 2020, a period of only five years, compared with eight years for the previous reference

period— a further 375 106 decisions were taken. The consistently high number of recognition decisions

demonstrates the continued importance of the Directive as a framework for supporting the cross-border mobility

of professionals. 37 Cf. ECA (2024); ITEM (2025); MKW/Empirica (2009); Jeffrey/Morosi (2017).

10

The Commission's preparation of the Report on the implementation of the PQD covering the

period 2020–2024 and its accompanying SWD, adopted in February 2026, provided a

significant opportunity to assess the functioning and implementation of the PQD in practice.

Based on extensive evidence gathering and consultations with CAs, professional

organisations, citizens and other stakeholders, the exercise identified a number of persistent

shortcomings and implementation challenges.38

In addition to drawing on the evidence collected for the implementation report, the study

supporting this IA39 was informed by desk research, evidence from the Regulated Professions

Database (RegProf)40 and the Internal Market Information System (IMI),41 and stakeholder

consultations. Although these sources provided a sufficient evidence base for the assessment,

important data limitations remain, notably inconsistent reporting by MS, limited operational

metrics on the performance of recognition procedures and insufficient data on “potential

mobility”. These limitations are linked to the still limited digitalisation of recognition

systems, which results in fragmented data collection.

2.1. What is the problem?

Despite the existence of an EU legal and policy framework supporting the cross-border

recognition of professional qualifications, mobile professionals still face considerable

practical and administrative hurdles when trying to access regulated professions in another

MS. Applicants seeking to have their qualifications obtained in one MS recognised in another

MS to access a regulated profession often face long, complex and burdensome recognition

processes.42 Professionals are deterred from pursuing cross-border opportunities43. This

38 COM (2026) 86 and SWD (2026) 64. The Report found that recognition of professional qualifications across

MS can still be a complex and time-consuming process because of lengthy procedures, uneven digitalisation and

heavy documentation requirements. Previously, the 2011 Evaluation of the PQD (European Commission

(2011)). had already underlined concerns about access to information, the complexity and length of procedures

and limited cooperation between CA. The 2024 Special report by the European Court of Auditors (ECA 2024)

confirmed excessive documentation requirements, disproportionate checks and unjustified fees for handling

recognition applications as well as delays in the procedures exceeding the deadlines set out in the Directive. The

ECA report also underscored that in many MS the absence of fully developed electronic procedures continues to

limit efficiency and leads to significant variations in the experience of applicants. Where relevant, the findings of

the 2011 Evaluation, the 2024 ECA Report and the 2026 Implementation Report have been integrated in the

analysis of the problem drivers below. 39 Study supporting an impact assessment of Directive 2005/36/EC - Final Report on Targeted SPI-related

aspects, EY Advisory S.p.A – IRS, 2026. 40 RegProf (Regulated Professions Database) is the European Commission's database containing information on

regulated professions and professional qualifications recognition decisions reported by MS under the

Professional Qualifications Directive. 41 The IMI was developed by the Commission in close collaboration with the MS. Since its launch in 2008, more

than 485 000 information exchanges in total have taken place through it. IMI supports more than 100 cross-

border procedures, and connects over 12 500 public authorities with approximately 40 000 registered users. 42 In the public consultation conducted for the SPI, which gathered a total of 785 responses, 48 of the 66 EU

citizens who have undergone recognition process of their qualifications reported lengthy, complex and costly

procedures as major or very major problem. Additional evidence regarding the complexity of recognition

procedures, including their duration and costs, is presented in the sections below addressing each of the problem

drivers.

11

translates into limited recruitment options for companies, who find themselves unable to

easily tap into the full EU talent pool to fill critical vacancies.44 At macro-economic level,

barriers to recognition contribute to an inefficient allocation of skills across the EU, with

negative effects on labour mobility, productivity and potential economic growth,45 and

reinforce uneven mobility patterns contributing to brain drain from certain MS. When the

recognition of qualifications is stalled or denied, skilled professionals are forced into roles

that do not utilise their full expertise, contributing to “brain waste” and overqualification.46

This is evidenced by the considerably higher than average overqualification rates for mobile

workers in the EU: 31.3% for mobile EU citizens vs. 20.8 for domestic workers in 2023.47

The problems and their underlying drivers identified in the 2020–2024 report on the

implementation of the PQD, as discussed further below, reflect challenges that have persisted

over time,

The 2011 evaluation of the Directive48 had already observed that the general system of

recognition provided a pragmatic and effective solution, but that its application remained

burdensome for professionals and competent authorities. Regarding the automatic system, it

had found that it allowed overall for efficient treatment of requests for recognition. The

evaluation identified weaknesses in the consistency and accessibility of information, complex

procedures, limited administrative cooperation and limited availability of electronic

procedures. Although the PQD had strengthened and simplified administrative cooperation,

information exchanges were limited, and while the IMI system had significantly improved the

speed and efficiency of cooperation, its effectiveness was constrained by the fact that its use

was not mandatory for all professions and competent authorities.

43 21 out of 66 EU citizens participating in the public consultation on the SPI who had undergone a recognition

procedure reported that difficulties linked to the recognition of their professional qualifications discouraged them

from moving to, or applying for, a job opportunity in another country. 44 95% of SMEs report that finding employees with the right skills is a challenge for their business. Cf. European

Commission (2024). 45 Research suggests that increased cross-border mobility contributes to higher global long-run growth. Cross-

border migration can influence productivity growth, both in the receiving and sending countries through several

channels, such as skill and diversity spillovers, remittances, age structure, entrepreneurial skills (Brunow et al.,

2015; United Nations, 2011). Also, higher rates of migrants with management skills can positively influence

foreign direct investments in receiving country (Cuadros et al., 2019). 46 In the public consultation for the SPI, out of 66 respondents EU citizens who had undergone recognition

procedures, 17 indicated that they had accepted employment below their level of qualification, 13 reported that

the recognition process prompted them to undertake additional studies or training, 12 stated that they secured a

job opportunity corresponding to or exceeding their qualifications and 12 reported that they had missed such an

opportunity, 11 indicated that they moved into employment in a different field, 10 reported delays in starting a

new job, whereas 9 stated that the outcome discouraged them from applying for job opportunities in another MS. 47 While overqualification is a phenomenon that affects mobile workers across all sectors, its impact is

particularly concerning within regulated professions given that many of the acute shortage professions in critical

sectors—such as healthcare, engineering, and education—are regulated. According to the latest (2024) European

Employment Services (EURES) report on labour shortages and surpluses, nursing professionals, generalist and

specialist medical practitioners, pharmacists and dentists are ranked among the most widespread shortage

occupations by number of countries and prevalence of high severity. 48 2011 evaluation of the PQD.

12

In response to these findings, a number of reforms were introduced by Directive

2013/55/EU49 aimed at improving the efficiency, transparency and digitalisation of

recognition procedures. These included the creation of the European Professional Card (EPC),

an electronic procedure applying to professions for which the Commission would

subsequently adopt an implementing act,50 allowing professionals to submit applications for

the recognition of qualifications or declarations for the temporary and occasional provision of

services through an online platform. The EPC was intended to simplify administrative

procedures, reduce processing times and strengthen cooperation between competent

authorities through the IMI system. The revision also introduced an alert mechanism requiring

Member States to notify each other when professionals had been prohibited or restricted from

exercising their profession, strengthened rules on administrative cooperation and information

exchange, expanded the information to be made available online on recognition procedures,

required the possibility to complete procedures by electronic means, established assistance

centres to support professionals, and reinforced transparency obligations concerning regulated

professions. These reforms produced improvements. IMI provided competent authorities with

a common, secure and structured channel for identifying and communicating with their

counterparts. It improved authority-to-authority cooperation, trust and traceability. The EPC

demonstrated that a faster and more transparent electronic recognition procedure was possible

by establishing a structured online workflow, allocating responsibilities between the home

and host authorities and setting specific procedural deadlines.

In 2018, the Commission published an assessment of stakeholders' experience with the

EPC and the alert mechanism.51 The assessment concluded that the EPC and the alert

mechanism made a positive contribution to the objectives of the 2013 revision of the PQD,

providing added value compared to the 'traditional' processes and facilitating information

exchanges. The evaluation demonstrated a high interest of the users in the EPC and an

increasing use of the alert mechanism by Member States. The public authorities appreciated

both EPC and the alert mechanism as secure tools for information exchanges and as a useful

facilitation. At the same time, the assessment highlighted the need for continuous

improvements, including further refinement of IMI functionalities, enhanced guidance for

competent authorities, more transparency, and ongoing dialogue with users to ensure the

effective and consistent operation of these new digital tools.

The 2020 implementation report52 concluded that the revised PQD had been broadly

effective in facilitating the mobility of professionals across the EU. The digital tools

introduced by the 2013 revision were found to support administrative cooperation and the

recognition process effectively. At the same time, the report found that Member States

49 Directive - 2013/55 - EN - EUR-Lex amending Directive 2005/36/EC on the recognition of professional

qualifications and Regulation (EU) No 1024/2012 on administrative cooperation through the Internal Market

Information System (‘the IMI Regulation’) 50 In practice, from 2016 the EPC became available for five professions: general care nurses, physiotherapists,

pharmacists, real estate agents and mountain guides. 51 SWD(2018) 90 final, Assessment of stakeholders' experience with the European Professional Card and the

Alert Mechanism procedures 52 COM(2020) 191 final, Report on the implementation of certain new elements introduced by Directive

2013/55/EU of the European Parliament and of the Council of 20 November 2013

13

continued to impose burdensome procedural requirements, failed to provide comprehensive

online information and electronic procedures, and did not fully comply with transparency

obligations. The mutual evaluation exercise had not resulted in regulatory reforms, while

proportionality assessments of professional regulation were often insufficient. In addition,

several issues remained open, particularly concerning language checks, temporary service

provision and partial access. The report confirmed further the need to refine the IMI platform.

In 2024, the European Court of Auditors published a special report on

the recognition of professional qualifications in the EU53 concluding that, although the EU

system for the recognition of professional qualifications is essential for supporting labour

mobility, it is applied inconsistently and remains burdensome. It recommended that the

Commission strengthen the uniform implementation of the Directive through clearer

guidance, better monitoring and enforcement, and greater consistency in the application of

procedural requirements and deadlines. The report also called for stronger integration of the

alert mechanism into recognition procedures, faster and more efficient automatic recognition

for sectoral professions, including shorter decision deadlines, and more reliable, complete and

consistent information for professionals.

The findings of the 2026 implementation report54 largely confirmed the earlier diagnosis.

Recognition procedures may still be lengthy and complex, national digitalisation remains

uneven, documentary requirements can be burdensome, and information available through

national portals and EU-level sources is not always complete, consistent or up to date. The

persistence of these problems does not mean that the reforms adopted since 2011 were

ineffective. Rather, they improved specific parts of the system without comprehensively

redesigning the recognition process.

As regards the EPC, the predecessor of the broader IMI-based digital workflow introduced by

this proposal, the evidence collected for the 2026 Implementation Report indicated that,

despite its potential, its impact has remained constrained by a range of operational and

systemic challenges. Targeted consultation highlighted that the IT system underpinning the

EPC is often perceived as complex, rigid and cumbersome to operate. Document uploads are

considered time-consuming, navigation is not sufficiently intuitive, and the overall workflow

is regarded as more burdensome than national procedures or the standard recognition

procedures. Technical and interoperability issues, linked in particular to uneven levels of

digitalisation across Member States, have further hindered its effective functioning. In

addition, low awareness among both professionals and competent authorities has limited its

uptake. Since the EPC does not automate or simplify key administrative tasks, such as

verifying the authenticity of documents or classifying supporting evidence, these continue to

require significant manual effort by competent authorities. Overall, the evidence pointed to

the need for a more unified and scalable digital approach that strengthens the mutual trust

underpinning the PQD while improving efficiency, transparency and the user experience.

53 ECA special report 10/2024 54 COM(2026) 86 final, Report on the 2020-2024 implementation of the PQD

14

A comparison with the 2011 evaluation therefore shows continuity rather than the

emergence of entirely new problems. Previous reforms successfully improved

administrative cooperation and demonstrated the benefits of electronic recognition

procedures, but their scope and design prevented them from resolving the problems across the

Directive as a whole.55 The remaining challenge is to build on those reforms through a

scalable, interoperable and user-centred digital process covering the full recognition

workflow.

As explained in more detail below, the remaining inefficiencies stem from several

interrelated causes. Processing times and administrative burdens are influenced by a

combination of factors affecting both applicants and competent authorities. The provision of

information constitutes the first of these. While Member States and competent authorities

remain responsible for maintaining information on regulated professions, competent

authorities and national requirements, insufficient alignment between national and EU-level

information sources can lead to inconsistencies, reducing the reliability and clarity of the

information available. As a result, applicants are not always sufficiently informed about the

applicable requirements, leading to incomplete applications and additional exchanges with

competent authorities. Recognition procedures are fragmented across a large number of

competent authorities with differing workloads, resources, levels of expertise, administrative

capacities and exposure to cross-border mobility in regulated professions. The workload

associated with the recognition of professional qualifications is not limited to assessing

applications and determining whether qualifications are equivalent. Competent authorities

also devote considerable resources to supporting administrative activities, such as maintaining

information portals, responding to enquiries from applicants and other competent authorities,

issuing certificates for outgoing professionals, and managing information in the Regulated

Professions Database. These horizontal tasks are indispensable for the functioning of the

recognition system and represent a significant share of the overall administrative effort

required from competent authorities. Authorities operating under the general system

frequently have to assess qualifications obtained in different education and training systems,

making recognition procedures inherently more complex. Delays may also arise when

information must be obtained from competent authorities in other Member States. These

challenges are compounded by uneven levels of digital maturity. Existing digital tools do not

always communicate effectively with one another, requiring manual interventions and

duplicative work, while some authorities continue to rely on paper-based or only partially

digital processes. Recognition procedures also continue to depend heavily on documentary

evidence whose authenticity must be verified on a case-by-case basis. In the absence of

interoperable and widely verifiable digital qualifications, competent authorities often request

certified copies, translations or additional attestations, increasing both the administrative

burden and the duration of procedures. Although IMI provides a common channel for

administrative cooperation, the Directive does not sufficiently regulate intermediate

procedural steps or authority-to-authority exchanges, and certain procedural obligations lack

the precision needed to ensure consistent implementation. Consequently, delays often arise

55 Effectively, improving some aspects (such as communication between the Member State authorities through

IMI) made other issues more visible (recurring requests concerning authentication of evidence, contributing to

delays in procedures).

15

not from an unwillingness to cooperate but from divergent national workflows, differing

administrative practices and the absence of common operational processes.

These issues give rise to the problem drivers analysed in the following section.

2.2. What are the problem drivers?

The problem identified above can be broken down into three underlying problem drivers.

These drivers arise from a combination of divergent national regulatory frameworks, differing

administrative practices across MS, and, in some areas, provisions of the PQD that leave

scope for varying interpretations.

When analysing the drivers of the identified problems, it is useful to distinguish between

issues of design and issues of implementation. Design issues arise where the Directive does

not provide a common element that is instrumental for the effective functioning of the

recognition system, such as a common workflow or other shared procedural arrangements.56

Implementation issues arise where the Directive already contains the relevant elements, but

they are either not defined with sufficient specificity to support consistent application across

Member States or are not correctly applied in practice. As explained below, the analysis

identifies both types of issues.

Fragmented and inconsistent information available to applicants

In this area, the main challenge lies not so much in the design of the framework established by

the Directive as in its implementation. While the necessary elements are largely in place, they

are not implemented consistently or in a sufficiently aligned manner across Member States.

Individuals seeking to access or exercise a regulated profession in another MS must comply

with national rules governing access to that profession. As a first step, applicants therefore

need access to clear, comprehensive and up-to-date information on applicable national

requirements. The PQD requires MS to ensure centralised access to information through

Points of Single Contact (PSCs) and provides for the establishment of Assistance Centres

(ACs) to support applicants in navigating national procedures and legislation.57 In addition,

the Single Digital Gateway Regulation58 introduces additional digital access and online

service availability obligations. Despite this, however, professionals still encounter practical

difficulties in accessing reliable and user-friendly information: information is often

fragmented across multiple institutional sources.59 While some MS provide comprehensive

56 Alternatively, design issues may also concern existing measures which proved to be unnecessary or

ineffective. 57 The mandates, use and visibility of ACs vary significantly across MS. Cf. SWD (2026) 64, Section 8.2. 58 Regulation (EU) 2018/1724 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. 59 In the public consultation for the SPI, most of the EU citizens who had undergone or planned to undergo

recognition of their professional qualifications (n = 157) indicated multiple sources of information used to gather

insights into the recognition process. The most frequently used source was official national government websites

(43 out of 157), followed by EU websites (35 respondents), professional organisations and unions (19

respondents), informal networks (18 respondents), recognition authorities and contact points (18 respondents),

16

and centralised information,60 the availability, accessibility and quality of information vary

significantly across professions and MS.61 The fragmented and inconsistent information

contributes to incomplete or incorrect applications62 and generates repeated requests for

clarification addressed to CA.63 National business federations flag that companies find it

difficult to assess whether qualifications obtained in one country meet the requirements of

another country.64 Although the applicable legal framework requires alignment between

information available at EU and national level, inconsistencies persist, such as

discrepancies between the lists of regulated professions published in the RegProf database and

those available on national websites.65 Although the PQD requires MS to notify to the

Commission their lists of regulated professions, specifying the activities covered by each

profession, in practice only some MS provide continuous updates while others do so only

periodically.66 On the other hand, while MS are required by the PQD to provide information

at national level, the legal framework does not always specify in sufficient detail the content

of that information, resulting in variations in quality and completeness.

Process inefficiencies

In this area, the main challenge lies in the design of the recognition framework. The Directive

does not establish a common workflow or sufficiently harmonised procedural rules for how

recognition procedures should be conducted, resulting in divergent national processes and

associated inefficiencies.

Evidence gathered in the context of the 2020–2024 PQD implementation report highlights

concerns about heavy procedural requirements and the continued reliance on paper-based

submissions in some MS.67 Professionals face difficulties due to a lack of streamlined

processes.68 Recognition procedures under the PQD are resource-intensive.69 CA for

social media or online forums (16 respondents), and employers or recruiters (14 respondents). Only 35 out of the

157 respondents considered the information provided to be very clear. 60 During a consultation workshop with members of the GoC (participants from 22 MS), representatives reported

comprehensive national information websites in Estonia, Finland, Hungary, Romania and Sweden. 61 Cf. SWD section 8.2. and study supporting this IA (Annex 10). The fact that the search for comprehensive and

reliable information on where and how to apply for qualification recognition for a given profession can indeed

act a deterrent and/or causes delays in the process is also confirmed by various cases studies. Cf.

Jeffrey/Milio/Vale (2017). 62 In a consultation workshop with members of the GoC, only 4 of 24 respondents considered that applications

for recognition received by CAare complete and correct to a great extent. 63 Cf. Annex 10 of the study to support this IA. 64 Cf. SWD (2026) 64, section 10.2 The business perspective. 65 To illustrate, the ECA report found that the RegProf listed fewer regulated professions for Austria, Belgium,

and Czechia compared to the national lists maintained by each respective country. See ECA (2024), Box 6 and

SWD (2026) 64, section 8.2. 66 Cf. Annex 10 of the study to support this Impact Assessment, based on responses by National Coordinators

from 22 MS. 67 The 2011 PQD evaluation reporthad also flagged the complex and lengthy application procedures, as well as

the limited administrative capacity of CA. European Commission (2011). 68 On this, see SWD (2026) 64, section 10.1 Individuals’ views and section 10.2 The business perspective. 69 Data gathered through surveys of CA conducted by the Commission for the 2020–2024 implementation report

of PQD shows that CA rely on varying staffing models and divisions of labour. To illustrate, in some cases

relatively large teams are required to manage high volumes of applications—for example, 17 staff members

17

professions subject to the general system of recognition requiring an individual assessment of

qualifications find that staffing constraints and high workloads result in delays.70 Automatic

recognition, although it is based on harmonised minimum training requirements, in practice

remains far from fully automatic — checks of documents and exchanges with CA in the home

MS continue to rely on manual processing and require significant human resources.71 While

the PQD provides for legally binding procedural deadlines, they are not consistently

respected.72 Many MS still require physical submission of documents as fully digital

procedures are not always available.73 For applicants, this reliance on physical documentation

handling around 1 700 recognition decisions annually (Ireland), or 6 case officers managing approximately 500

applications per year (Germany/ Baden-Württemberg). In other cases, recognition procedures are managed with

very limited resources, such as a single staff member responsible for the entire process in certain professions

(Austria, Ireland, Malta, Poland, and Spain for secondary school teachers), or small teams of two reporting the

need for additional personnel (Portugal), or teams responsible for multiple professions (e.g. across all healthcare

professions in Denmark). In addition, the recognition process often involves, beyond administrative case

handlers, technical evaluators, decision-making bodies (such as boards or heads of CA), and external experts or

commissions supporting the assessment of qualifications. This points to a multi-layered and resource-intensive

process, suggesting that internal administrative capacity alone is often insufficient to cope with the complexity

and volume of cases. For example, in one MS, two staff members are supported by a technical commission of

four members (Portugal); in another, a single staff member conducts initial reviews with a six-member

commission responsible for hearings (Lithuania); in one MS (Malta), the board consists of eight members; in

another, nine members are involved (Romania); while elsewhere, one lawyer handles administrative tasks,

supported by a committee of four social workers and one expert in social worker training (Croatia). 70 Cf. SWD (2026) 64, Section 2 - Length of procedure, where it is evidenced that for professions falling under

the general system, the duration of recognition procedures varies considerably across MS. Processing times can

range from as little as a few weeks to several months, with most applications typically completed within one to

four months. However, in some cases—particularly where additional documentation is required or administrative

constraints arise—procedures may extend to seven or eight months. 71 Cf. Annex 10 of the study supporting this IA and SWD (2026) 64, section 4.2 Automatic recognition based on

minimum training requirements – Application procedure. 72 It should be underlined that the deadlines provided for in the PQD only kick-in once the application is

complete. Often, however, a lot of precious time is spent by the applicant gathering missing documents,

clarifying information, or correcting errors in the initial submission before thecompetent authority

acknowledges receipt of a complete file.Among the 284 individual respondents to the implementation report

consultation who provided information on the duration of recognition procedures, 80 reported that the procedure

lasted more than four months, while 25 indicated that it lasted more than one year. In the public consultation for

the SPI, among 66 EU citizens who applied for recognition and responded to a question about the duration of the

recognition process, including the time required to gather the documentation necessary for their application,

many reported durations of several months. 13 respondents indicated that the process lasted between 3 and 6

months, while another 13 reported a duration of 6 to 12 months. For 10 respondents the process lasted between 1

and 3 months, and for another 10 it took less than one month. However, there were also cases where the process

took substantially longer, with 2 respondents reporting a duration of 1 to 2 years, 4 respondents reporting 2 to 3

years, and 5 respondents indicating that the process lasted more than 3 years. 73 The data presented in ECA (2024), Figure 6, p. 21 highlight considerable divergence across MS in the share of

recognition procedures carried out electronically. Only a limited number of MS report levels close to or above

70%, while in most cases the proportion remains around or below 50%. In nine MS, the share falls below 40%,

underscoring the uneven uptake of digital procedures. This picture is corroborated by the findings in Annex 6 of

the study supporting this impact assessment, based on responses from national coordinators and CA in 22 MS.

These indicate that applicants are still frequently required to submit documents in paper format. While fully

electronic procedures exist for certain professions in several MS, their availability and use vary significantly, and

paper documentation remains necessary where digital solutions are not in place. As a result, the time needed to

collect supporting documentation directly affects the overall duration of recognition procedures.

18

increases costs74, administrative burden, and delays.75 Documentation requirements, although

defined and limited under the PQD, often exceed what is strictly necessary in practice,

including certified originals, notarised copies, apostilles, and sworn translations.76 This is

often linked to a lack of trust in qualifications issued in other MS.77 Certified translations and

copies generating additional costs and delays particularly where multiple documents must be

processed. Finally, as the PQD leaves to MS to define recognition fees, both the level and

structure of fees vary widely, creating uncertainty for applicants which may discourage them

from applying.78

Fragmented administrative cooperation among national authorities and between

national authorities and the Commission

This problem reflects both shortcomings in the design of the current framework and in its

implementation. The absence of a common workflow is compounded by inconsistent

74 Cf. Chapter 6 below. 75 CA also face inefficiencies due to paper-based processes. Manual handling of documents—including

verification, scanning, processing, and returning originals—is resource-intensive. Paper documents are not

inherently verifiable, requiring additional authenticity checks, which are increasingly complex in light of

evolving fraud risks, including AI-based falsification. The absence of digital records complicates tracking and

archiving, increases the risk of errors, and contributes to delays. 76 Cf. Annex 10 of the study to support this IA, based on responses by National Coordinators from 22 MS. Data

collected for the 2020-2024 implementation report of the also point to divergence across MS in the number of

documents requested from applicants under the general system. Although the categories used are relatively broad

(up to five, five to ten, and more than ten documents), all four professions examined show distributions across

more than one category, indicating significant variation in documentary requirements. This suggests a lack of

convergence, which is likely even more pronounced in practice, given that each category encompasses a wide

range of possible document counts (Cf. SWD (2026) 64, Section 2). 77 Procedural complexity is related to lack of trust in the professional qualifications obtained in another MS and

the training institutions and CAs of that MS. However, lack of trust is not mentioned in this IA as a problem

driver. There is, in practice, a degree of caution on the part of CA when assessing professional qualifications

obtained in another MS, which may manifest itself in different forms: limited information on the underlying

training and curricula, difficulties in comparing qualifications across national systems, doubts about the quality

assurance of training, or concerns about the authenticity of documents. However, this is expected to some extent

in the context of regulated professions. Unlike non-regulated professions, access is subject to legally defined

requirements, and MS are both entitled and obliged to verify that applicants meet these conditions. In that sense,

a certain degree of prudence should not, in itself, be considered problematic. The issue arises rather in how this

caution is operationalised, notably in the type and extent of requirements imposed, the nature of the requests

addressed to applicants, the proportionality of the evidence required, and the way applications are handled. This

is why “lack of trust” is not identified as a standalone problem driver in the analysis, even though it can be

understood as an underlying factor behind certain challenges observed in practice, such as lengthy processing

times, extensive information requests, and burdensome documentation requirements. 78 On differences in fees, see also SWD (2026) 64, Section 2 (General system of recognition – Fees), which

shows that, for the professions covered by the general system, recognition fees in the MS range from no fee, to

low fees (up to EUR 100), higher fees (up to EUR 1 000), and in some cases significantly higher amounts (above

EUR 1 000). This pattern is broadly reflected in the replies to the public consultation for the SPI. Out of the 66

EU citizens who had undergone recognition processes, 2 indicated that the procedure was free of charge, 5

reported costs below EUR 250, 6 reported costs between EUR 251 and EUR 500, and a further 6 reported costs

between EUR 501 and EUR 1 000, while 3 indicated costs between EUR 1 001 and EUR 2 500, and 7 reported

costs exceeding EUR 2 500. At the same time, 10 respondents considered the question not applicable to their

situation and more than 22 did not indicate the cost of the recognition procedure.

19

implementation of existing cooperation mechanisms, resulting in fragmented exchanges and

cooperation.

Cooperation among MS is primarily supported by IMI, which provides a secure

communication platform for CA to exchange information. Despite the support provided by

IMI, coordination challenges, stemming from differences in national administrative structures

and the level of engagement across MS complicate implementation.79 Inconsistent use of the

IMIundermines its potential to support administrative cooperation under the PQD.80 The EPC

remains underutilisedand its uptake varies significantly across MS and professions.81 More

broadly, recognition procedures across the EU are still unevenly digitalised.82 Although

many MS have introduced online portals and digital document upload functionalities,

professionals frequently encounter hybrid systems combining digital and paper-based

elements.83 Interoperability issues between national systems further exacerbate these

79 The evidence collected for the 2020–2024 implementation report for the PQD (cf. SWD (2026) 64, Section

8.2) points to significant differences across MS in how national contact points for professional qualifications

collect feedback and statistical data to support information exchanges. 80 Issues with the use of the IMI system were already noted in the 2011 evaluation of the PQD. Following the

2013/55/EU amendment, the Commission introduced the EPC and an Alert Mechanism, both powered by the

IMI to streamline recognition procedures and enhance safety. Since then, continuous improvements to the IMI’s

interface were implemented and guidance and training was provided to CA to optimise the system. Under the

general system, CA report slow responses via IMI to questions on training content covered by a professional

qualification. Under the automatic recognition system, delayed responses in IMI can impede compliance with

legally prescribed deadlines for recognition decisions. Cf. SWD (2026) 64, Sections 2 and 4 on the general and

the automatic systems of recognition. 81 The EPC has been available since January 2016 for five professions: general care nurses, pharmacists,

physiotherapists, mountain guides and real estate agents. It provides an electronic procedure for the recognition

of professional qualifications with shorter deadlines (e.g. one month for the CA of the home MS to acknowledge

receipt and issue the EPC) and tacit recognition in cases where it is for the CA of the host MS to take a decision

within a deadline and no such decision is taken. The application of fees for EPC procedures remains inconsistent,

reducing predictability for applicants. Cf. ECA (2024) and European Parliament (2019). Also, the EPC interface

is perceived as complex and time-consuming. Cf. SWD (2026) 64, Section 6 on the functioning and current use

of the EPC and its future implementation. 82 The level of digitalisation of public administrations varies significantly across MS. Data from the

Commission’s eGovernment Benchmark and the OECD Digital Government Index, point to persistent disparities

in the availability, quality and interoperability of digital public services. While some MS have developed highly

user-centric, fully digital and interoperable administrative systems, others continue to rely to a greater extent on

fragmented, paper-based or only partially digital procedures. As a result, professionals seeking recognition of

qualifications across borders face uneven levels of digitalisation, contributing to longer processing times, higher

administrative burden and reduced predictability of procedures. The cost survey of CAs carried out for the IA

points specifically to differences in the degree of digitalisation of recognition procedures across MS. Out of 81

respondents, 29 reported that they had fully digitalised their recognition processes over the last five to ten years,

while 38 reported having done so only partially. At the same time, 14 respondents indicated that they had not

digitalised their recognition processes during this period. These results suggest that recognition procedures are

currently carried out through a variety of digital and non-digital approaches, depending on the authority

concerned. The survey also showed differences in the parts of the process that have been digitalised. The data

presented in the 10/2024 report by ECA also highlight considerable divergence across MS in the digitalisation of

recognition procedures. Only a limited number of MS report digitalisation levels close to or above 70%, while in

most cases the proportion remains around or below 50%. In nine MS, the share falls below 40%, underscoring

the uneven uptake of digital procedures. 83 In some cases, applicants can download documents available online, but must return them by post or email. In

others, online platforms serve only as repositories for forms rather than enabling full electronic submission.

During transitional phases, some authorities continue to rely heavily on email exchanges, often supplemented by

20

challenges. Cooperation via the IMI system does not currently function as a tracking tool

for the entire recognition procedure. Significant data gaps persist, most notably concerning

the actual duration of recognition procedures from the moment of initial application to the

final decision. Resolving these gaps currently requires substantial administrative effort and

results in an incomplete evidence base.84 Ultimately, this lack of transparent, real-time data

limits the Commission's enforcement capabilities, making it difficult to identify systemic

delays or effectively hold MS accountable to legally prescribed deadlines.

***

The problem drivers described above are represented in the visual below, which sets out the

intervention logicof the initiative. In addition to illustrating the overall problem and its

underlying drivers, it captures the key issues identified and the objectives pursued in relation

to each problem driver.

secure electronic signatures. Cf. Annex 6 of the study to support this IA, based on surveys carried out for the

PQD implementation report 2020-2024 with 450 citizens and CA from 23 MS. 84 The difficulty of establishing a reliable evidence base is highlighted in the 2026 SWD underpinning the Report

on the implementation of the Directive, which relies on targeted, ad-hoc stakeholder surveys conducted between

Q2 2024 and Q1 2025 to capture data not systematically available in the IMI system.

21

As illustrated in Annex 10, the shortcomings identified above can have a compounded

negative impact across the entire user journey. When information gaps, procedural

hurdles, and administrative cooperation bottlenecks converge, they create a cumulative

'friction' that fundamentally compromises the applicant's experience. The initial difficulty in

finding reliable information often leads to incomplete or incorrect applications, which creates

delays at the very beginning of the process. These can be further exacerbated by burdensome,

paper-based processes and uneven cooperation between the CA, where administrative inertia

of a single authority can stall the entire process. Finally, a lack of precise real-time data on

processing times hampers the effective monitoring of compliance.

2.3. How likely is the problem to persist?

In the absence of additional EU action, some gradual and incremental improvements can be

expected as a result of improved technical infrastructure and the use of possibilities already

provided under the PQD.85 However, in the absence of more systemic reforms the portability

of qualifications across borders will continue to be hampered. As indicated above, the number

of regulated professions in the EU has remained constant at a high level between 2016 and

2023.86 Since the regulation of professions is within the competence of the MS, administrative

obstacles arising from differences in national regulatory requirements are not expected to

decrease. In response to technological change, digitalisation and the shift towards a net-zero

emissions economy, MS are revising existing regulated professions or even defining new ones

to ensure safety and quality in both emerging and established sectors.87 They are likely to

continue to do so in the coming period. In the absence of central coordination, this will create

additional regulatory divergence for a considerable share of professions. Technical

improvements within individual MS will not automatically yield system-wide benefits, as

the overall speed of recognition procedures remains critically dependent on the quality of

bilateral cooperation. The uneven uptake of digital tools across the Union creates

"bottlenecks" where the inefficiencies of one national authority hinder the cross-border

process. Digitalisation at individual MS level can even hamper rather than smoothen

85 This includes the delegated powers provided for under the Directive, for example those relating to the

establishment of Common Training Frameworks, which are considered part of the baseline (see Section 5.1 and

Annex 9). 86 Cf. fn 21. 87 The regulation of professions in EU MS is a dynamic and uneven process, shaped by technological change,

market demand and new regulatory priorities. New or newly formalised activities may become regulated

professions or regulated specialisations: for example, France regulates the titles and practice of genetic

counsellor and medical physicist, both linked to advances in genomic medicine, radiotherapy, and medical

imaging. MS create new specialties like the advanced practice nurse pathway, and tend to add new specialties in

engineering like biomedical and clinical engineering, reflecting the growing role of technology. Regulatory

change can also create new market-facing roles, as seen with sustainability assurance auditors, leading to the

development of dedicated training, and – prospectively – to the emergence of new regulated professions. Similar

market and public-policy needs are visible in the regulation of building energy assessors and renewable-energy

installers. At the same time, regulation is fragmented: some countries regulate an activity or title while others

rely on sectoral certification, professional registers or training schemes. As a result, professionals seeking

recognition of their qualifications in another MS may face significant differences between regulatory regimes: in

one country the activity may be treated as a new regulated profession, in another as a specialty of an existing

profession, and in a third as a certification or licensing requirement attached only to certain activities. This

makes recognition increasingly dependent on a detailed comparison between traditional professional categories

and newer, more specialised or technology-driven forms of regulation.

22

recognition, by making interoperability more difficult. Furthermore, the PQD in its current

form does not provide the operational metrics needed to monitor the end-to-end performance

of recognition systems, nor does it ensure the systematic collection and transmission of

relevant data between CA and to the Commission. In the absence of additional measures,

these data limitations will continue to hamper monitoring and enforcement.

3. WHY SHOULD THE EU ACT?

3.1. Legal basis

The legal basis for this policy action is Article 53(1) of the Treaty on the Functioning of

the European Union (TFEU), which empowers the Union to adopt directives for the mutual

recognition of diplomas, certificates and other evidence of formal qualifications, as well as for

the coordination of national provisions governing access to and pursuit of regulated

professions, including for self-employed persons88. This provision, in conjunction with

Articles 45, 49 and 56 TFEU on the free movement of workers, freedom of establishment

and freedom to provide services, underpins Directive 2005/36/EC on the recognition of

professional qualifications. The present initiative does not alter the substantive scope or

overall architecture of the Directive, nor does it harmonise national rules on the organisation

of professions or qualification requirements. The envisaged measures fall within the scope of

Article 53(1) TFEU, as they aim to facilitate the effective recognition of qualifications and

thereby enable access to regulated professions across MS.

3.2. Subsidiarity: Necessity and added value of EU action

The initiative concerns the functioning of the internal market, which is an area of shared

competence between the Union and the MS pursuant to Article 4(2)(a) TFEU. Accordingly,

the principle of subsidiarity applies. The existence of an EU legal framework in the form of

the PQD since 2005, and the decision to maintain this instrument as the reference framework

while amending and modernising it in 2013, illustrate the common understanding that EU-

level action in this area is both necessary and appropriate. The need for Union action thus

arises not only from the rationale for mutual recognition as such, which is already established,

but from persistent shortcomings in the practical functioning and enforcement of an existing

EU framework. The initiative aims to improve this pre-existing legal framework for

recognition at EU level. Changes to the EU framework can only be done by EU level action.

Recognition procedures inherently require interaction between CA in different MS, including

the exchange and verification of information, validation of qualifications, and clarification of

documentation. Unilateral efforts by MS to streamline their own procedures do not

resolve these cross-border frictions, as they neither ensure reciprocity nor establish common

operational rules for cooperation. These issues are structural and cross-border in nature and

cannot be adequately addressed through isolated national measures Without coordinated

action at Union level, the system remains dependent on heterogeneous practices and ad hoc

communication, limiting the potential for simplification and efficiency gains. Moreover, the

integration of digital tools to facilitate recognition procedures requires a common

88 Thus, the choice of legal instrument is determined both by the TFEU provisions and the nature of the action.

23

framework to be effective. If developed separately at national level89, such tools would risk

fragmentation, duplication and lack of interoperability.

Union action is also necessary to strengthen transparency and enforcement of the

existing rules. At present, the monitoring of recognition procedures relies largely on MS’

self-reported data and individual complaints, which does not provide a comprehensive or

reliable basis for assessing compliance and to enforce the rules in the event of systematic

incompliance. Action at EU level is needed to ensure consistent and comparable data to

support both national and EU-level corrective measures. Such transparency cannot be

achieved through uncoordinated national systems. In the absence of Union intervention, the

identified problems are likely to persist, resulting in continued delays, administrative burdens

and legal uncertainty for applicants and CA. Coordinated EU action is therefore necessary to

ensure that the existing framework operates as intended and that the rights conferred by the

Treaties can be effectively exercised in practice. A further coordinated EU framework

would lead to more consistent and reliable recognition decisions across MS. By

streamlining information requirements, deadlines and cooperation practices, the initiative

would reduce variability in how similar cases are handled and limit the risk of divergent or

conflicting assessments. This can also facilitate the availability of reliable and comparable

data, reduce administrative effort, lower reporting costs, and minimise risks of errors or

inconsistencies, while enabling more timely and accurate monitoring.

EU-level action also offers clear economies of scale and avoids duplication of efforts. A

common EU approach to streamlining key aspects of the recognition process is more cost-

effective than multiple parallel national solutions, which may be incompatible or require

complex interfaces. EU-level intervention ensures interoperability, thereby maximising the

benefits of digitalisation and preventing fragmentation. While Union action requires initial

adaptation efforts by national administrations, including changes to existing procedures and

systems, these costs are expected to be offset by long-term efficiency gains, reduced

administrative burden, and improved service delivery. Overall, EU action provides a more

efficient and coherent solution than uncoordinated national approaches, delivering benefits

that cannot be achieved at the same scale or consistency by MS acting alone.

4. OBJECTIVES: WHAT IS TO BE ACHIEVED?

The PQD has long provided a solid legal framework for the recognition of professional

qualifications across MS, consolidating several previous instruments in this area. This

initiative does not seek to overhaul the system established by the Directive, the effectiveness

of which is evidenced by a constant stream of positive recognition procedures.90 Rather, it

aims to identify and address specific pain points, including both underutilised opportunities

and persisting obstacles. Accordingly, the initiative is designed to remain proportionate and

targeted, addressing only those issues that require action. Its objective is not to create a new

89 The key elements need to be developed at the EU level and be further implemented at national level by

transposing them to (ensure compatibility with) national legal frameworks. 90 Cf. PQD Implementation Report 2020-2024 (COM(2026) 86), under 2: The Professional Qualifications

Directive provides crucial support to mobility in the Single Market.

24

system, but to introduce focused improvements to enhance the functioning of the existing

framework.91

4.1. General objective

The general objective of the action is to ensure the free movement of workers92 in

regulated professions across the EU. This contributes to the Union’s overarching policy

objective of deepening and strengthening the Single Market as a driver of competitiveness,

resilience and sustainable growth, as reflected in recent Commission priorities and strategic

reflections on Europe’s economic performance. In this context, the action supports the

objectives of the Union of Skills, notably by enhancing the portability and recognition of

skills and qualifications,facilitating cross-border recruitment, and improving the matching of

skills supply and labour market demand across MS. Furthermore, the initiative contributes to

addressing structural labour shortages and skills mismatches, thereby supporting productivity

growth and the efficient allocation of human capital, in line with the Union’s broader

competitiveness and innovation agenda. By promoting interoperable recognition systems

through the uptake of digital tools, the action also aligns with the EU’s digital transition

objectives and the development of a more integrated and future-proof Single Market.

4.2. Specific objectives

This intervention is structured around three specific objectives, each addressing one of the

identified problem drivers. For each objective, a corresponding reference is proposed. The

latter are intended as concrete benchmarks rather than exhaustive reflections of the specific

objectives they refer to. Acknowledging that quantitative indicators cannot fully capture the

multifaceted nature of the problem drivers, they provide the essential empirical standards

required to drive accountability and evaluate the intervention's impact.93

The first specific objective proposed (SO1) is to ensure that information on qualification

requirements and recognition procedures at national level is complete, clear and easily

accessible, in a manner that is consistent with the information made available at EU level

under the PQD. The proposed point of reference for achieving this objective is the

establishment of a single, reliable and up-to-date EU-level source of information, enabling

applicants, employers and competent authorities to access accurate and comparable

information across Member States. The second specific objective (SO2) is to make

recognition procedures faster, simpler and less burdensome. The proposed benchmark for

achieving this objective is a 25% reduction in the overall cost of recognition procedures

compared to the baseline.94 The third specific objective (SO3) is to improve cooperation and

communication among national competent authorities responsible for recognition

procedures, as well as between national authorities and the Commission. The proposed

91 A visual representation of the objectives is provided in Annex 11. 92 While the objective refers specifically to workers in regulated professions, it is relevant for all holders of EU

qualifications seeking access to regulated professions, including self-employed. 93 The specific objectives should be read in combination with the draft performance monitoring framework

(Annex 9). They together outline what the success of the initiative could look like. 94 In line with the 25% overall burden reduction target set out in the Competitiveness Compass. COM(2025) 30

final.

25

point of reference for achieving this objective is ensuring that requests for administrative

cooperation are answered within a maximum period of two weeks, as a general rule.

The three Specific Objectives are closely interrelated and mutually reinforcing, as they

address different but interdependent drivers of the same underlying problem. SO1 (clear and

complete information) functions as a precondition for the effective operation of the system.

When applicants have access to accurate, complete and consistent information on

qualification requirements and recognition procedures, they are better able to identify the

appropriate CAs and submit complete applications. This directly supports SO2, by reducing

errors, requests for clarification and resubmissions, and indirectly supports SO3, by limiting

avoidable information exchanges between authorities. SO2 (faster and less burdensome

procedures) addresses the operational efficiencyof recognition processes once applications

are submitted. Streamlined procedures, clearer deadlines applicable across all recognition

paths, and greater use of digital tools reduce processing times and administrative effort for

both applicants and CAs. SO3 (improved administrative cooperation) underpins both SO1 and

SO2 by strengthening trust, communication and consistency among CAs, and between them

and the Commission. More timely and structured cooperation contributes to the accuracy and

updating of information provided to applicants (SO1), and enables faster handling of cross-

border verifications and recognition decisions (SO2).

The benchmarks proposed above are reflected in the indicators included in the monitoring

framework presented in Chapter 9 and Annex 16. These indicators will be used to track

progress towards the specific objectives and assess whether the initiative is delivering the

expected results. The direct impacts of the initiative are expected to start materialising from

2029, once the implementation phase of the European Digital Recognition System (EDRS) in

2027 and 2028 has been completed. Wider impacts, including effects on professional

mobility, labour market functioning and the overall performance of recognition systems, are

expected to emerge progressively thereafter. Evaluating the initiative five years after the

expiry of the transposition deadline95 would allow sufficient time for both the direct impacts

and the broader effects of the initiative to become observable.

5. WHAT ARE THE AVAILABLE POLICY OPTIONS?

5.1. What is the baseline from which options are assessed?

If no new measures are introduced at EU level, the Commission would continue to implement

and enforce the current legal framework while MS would continue to make use of existing

instruments at differing speeds, depth and levels of effectiveness.

Digitalisation of recognition‑related processes would continue to advance, driven not only

by the gradual rollout of the European Digital Credentials and national e‑government reforms,

but also by the ongoing implementation of EU‑wide digital enablers, notably the Single

Digital Gateway Regulation, the Once‑Only Technical System96 and the deployment of the

95 This timeframe would be comparable to previous experience under thw PQD, which was evaluated in 2011,

four years after the expiry of the transposition deadline. 96 OOTSHUB Home - OOTSHUB

26

EU Digital Identity Wallet.97 While these initiatives are not specifically designed for the

recognition of professional qualifications, they provide concrete, Commission‑developed

tools that can be leveraged to streamline recognition procedures. Under the baseline, however,

without any initiative to at least encourage, if not actively monitor, integration of these tools,

results would remain partial and uneven across MS and professions, with significant

untapped potential.

Under the baseline, incremental improvements in certain aspects of recognition processes

can be expected by 2030. Continued progress in national referencing to the EQF and the

availability of EU‑level transparency tools (e.g. Europass, ESCO) are likely to enhance

formal comparability of qualifications and mutual understanding between authorities. The

gradual uptake of digital credentials and authentication tools may reduce fraud risks and

enable faster checks in those MS and professions where such tools are fully integrated into

administrative workflows. However, these improvements are unlikely to translate into

system‑wide efficiency gains. The voluntary and non‑binding nature of most EU instruments

means that procedural requirements, documentation standards, timelines, fees and appeal

mechanisms are expected to remain diverse across MS. Fragmented digital uptake, the

continued reliance on hybrid or paper‑based procedures in many jurisdictions, and limited

end‑to‑end interoperability between national systems are likely to constrain the practical

usability of digital solutions.

Another dimension of the baseline concerns the continued use and development of

Common Training Frameworks (CTFs).98 The Commission is already actively working on

this instrument and intends to continue advancing it in close cooperation with MS. As part of

the SPI, specific professions have been identified as prime candidates to pilot and expand this

collaborative framework. These include professions that are crucial for the EU’s overall

competitiveness and innovation potential, such as civil engineers and biomedical laboratory

technicians; professions that play a key role in the green transition, including electricians,

heating, ventilation and air-conditioning technicians, and landscape architects; as well as

several care professions, such as nursing and health care assistants, occupational therapists

and radiographers, and professions related to education, including kindergarten teachers and

child care workers. A streamlined approach to CTFs will yield tangible time and cost savings

for applicants while significantly freeing up administrative resources for CAs. However,

97 EU Digital Identity Wallet Home - EU Digital Identity Wallet 98 The baseline scenario includes not only the provisions of the PQD itself but also the mechanisms and

delegated powers already provided in it. In particular, Article 49a empowers the Commission to establish

Common Training Frameworks (CTFs) through delegated acts, thereby extending automatic recognition to

additional professions where the relevant conditions are met. The development of CTFs is therefore an existing

possibility under the current framework rather than a new policy measure to be considered in this impact

assessment. CTFs serve as a highly effective tool to facilitate existing mobility patterns for professions that

already exhibit a sufficient level of convergence in national regulations and training requirements. By

eliminating the need for the application of compensatory measures by host MS, a CTF enables the automatic

recognition of qualifications that meet its harmonized criteria. The indirect link between CTFs and the policy

options considered here is through improving administrative cooperation in the Group of Coordinators to

facilitate the future development and implementation of CTFs. However, such measure would pursue wider

objectives and would not be limited to that purpose. Consequently, any future extension of automatic recognition

through CTFs is considered part of the baseline scenario rather than an impact attributable to the policy options

assessed. Cf. Annex 9.

27

while CTFs deliver substantial, targeted benefits for the professions involved, the instrument

is subject to structural limitations. Because it relies on a high baseline of existing alignment

of national regulatory measures, a CTF can only be successfully deployed for a restricted

number of professions. Furthermore, its ultimate success and take-up remain highly

dependent on the political willingness of MS to implement it within their domestic legal

systems. In conclusion, while expanding the use of CTFs in the future will successfully

eliminate recognition frictions for specific mobile professionals, it is no substitute for a

broader systemic reform on national level to ensure that regulation remains proportionate and

is not expected to yield in itself across-the-board efficiency gains across the wider EU labour

market.

Although the available evidence does not establish that the existing shortcomings will

necessarily worsen over time, it is likely that consequences will become more pronounced

in the absence of further action. This reflects broader developments affecting the context in

which the Directive operates.

First, demographic change is reducing the size of the available workforce. The EU's working-

age population is projected to shrink significantly over the coming decades, exacerbating

labour and skills shortages across many sectors.99 As Member States increasingly rely on the

mobility of qualified professionals to address these shortages, recognition systems will need

to process a growing number of applications efficiently and without unnecessary

administrative burden.

Second, demographic ageing and increasing life expectancy are driving demand for healthcare

and long-term care services, many of which are delivered by regulated professionals. At the

same time, persistent labour and skills shortages will make it increasingly difficult for

Member States to meet this demand from the domestic workforce alone. As a result, cross-

border mobility of regulated professionals is expected to play an increasingly important role

in addressing workforce needs.

Then, the green and digital transitions are transforming labour markets by creating demand

for new skills and occupations and by changing the competences required in existing

professions. This is likely to lead to more updates to training curricula, greater diversity of

qualifications and, where appropriate, the regulation of new professions, increasing the

complexity of recognition decisions.100

Finally, rapid technological progress and the digitalisation of public administration continue

to raise the expectations of citizens and businesses for digital, user-friendly, interoperable and

99 The EU's population is projected to start decreasing before 2030 and to continue declining until 2100, while

the size of the labour supply is expected to decrease by about 16% by 2070 compared to 2019, corresponding to

a total loss of approximately 32 million potential workers in the EU. Cf. European Commission (2026b);

European Commission (2021). 100 Eurofound (2023), Measures to tackle labour shortages: Lessons for future policy, Publications Office of the

European Union; ESDE (2023).

28

efficient public services. Recognition procedures that remain fragmented, paper-based or

insufficiently digitalised risk becoming increasingly out of step with these expectations.

Against this background, administrative workloads are likely to increase faster than the

coordination capacity, digital maturity and institutional resources of competent authorities.

This may result in greater risks of delays, backlogs and inconsistent decision-making,

particularly in professions characterised by high mobility or persistent labour shortages.

Professionals may continue to experience delayed labour market entry or under-employment,

while employers, especially SMEs, may face continuing difficulties in recruiting qualified

professionals across borders despite persistent vacancies.

Overall, it cannot be concluded with certainty that recognition systems will perform worse

under the baseline scenario. However, as external pressures intensify, the existing

shortcomings of the framework are likely to become increasingly consequential. In this

context, addressing these shortcomings becomes progressively more important to ensure that

recognition systems remain efficient, responsive and capable of supporting the evolving needs

of the Single Market.

5.2. Description of the policy options

Three policy options are presented below. Each option comprises a set of measures designed

to contribute to all specific objectives and address all three problem drivers. Within each

option, the measures proposed are broadly consistent in their nature, ranging from non-

legislative measures to legislative measures combined with enforcement mechanisms. Moving

from one option to another, the degree of ambition to ensure integrated results progressively

increases. In a limited number of cases, a measure has been retained in a subsequent option

where it remained compatible with the overall logic of that option and was not rendered

unnecessary by other, more far-reaching measures. The analysis below is complemented by

Annex 11, which presents and describes the specific measures included under each option.101

5.2.1. Option 1 – Convergence of administrative practices through shared standards

This option relies on non-legislative measures to complement the existing EU legal

framework, such as Commission guidance, common templates and voluntary peer reviews,

to streamline administrative practices. It improves information quality by promoting

interoperable information architectures and aligning EU-level sources with national sources

101 A number of potential measures were examined during the preparation of this initiative but were ultimately

not retained. These are presented in a dedicated table in Annex 12, structured by problem driver and listing, for

each measure, the corresponding rationale for its dismissal. Most discarded measures raised concerns related to

proportionality, feasibility or coherence with the existing framework. In particular, a number of options were

considered either insufficiently effective to achieve the stated objectives, or disproportionate, notably where they

would entail excessive administrative burden or go beyond what is appropriate in areas where MS retain

significant competences.

29

and enhancing the clarity and consistency of national information. It promotes process

efficiency and transition from paper-based processes to digital procedures, and supports in

that context faster processing with fewer documentary requirements. To facilitate procedures,

it introduces voluntary tools and soft measures, including an EU-developed AI-assisted

workflow system, indicative shorter deadlines where applicants make use of EU digital

credentials, shared standards for digital interoperability, and updated Code of Conduct

provisions on proportionate documentation and reasonable fees. Cooperation among CA is

reinforced through nonbinding IMI response deadlines, expanded training on digital tools, and

encouragement to conduct recognition procedures fully online while allowing MS to choose

their own systems. This approach acknowledges the diversity of national contexts and

operational needs - for instance, differences in the number of CA, application volumes, or

available administrative capacity – and consists of improvements which can be implemented

without imposing uniform procedural requirements.

Policy measures proposed under PO1

Ensure complete and clear information on qualification requirements and recognition

processes at national level, in line with EU level information102

• Issue Commission guidance on information structure and quality for CA websites

• Carry out voluntary peer review of national portals

Make recognition processes faster, easier, and less burdensome

• Develop, for voluntary use by MS, an interoperable AI-assisted workflow management

system to support CA in the recognition process and supporting applicants in preparing

applications.

• Develop shared understanding between MS on which standards to use, how to improve

interoperability of digital systems for recognition (e.g. Community of practice via a GoC

Subgroup)

• Encourage processing of applications in shorter deadlines than provided in the PQD

when EU digital credentials are used (e.g. update of Code of conduct, pilot with like-

minded countries)

• Ensure that the document requirements are proportionate (e.g. update the Code of

Conduct, share best practices)

• Issue guidelines (e.g.: a formula) to calculate reasonable fees for recognition processes

(e.g. update the Code of Conduct, share best practices)

102 As a flanking measure supporting all policy options, aimed at ensuring that information on recognition

procedures and requirements is complete and clear, the Commission would launch a pilot on the use of chatbots

as tools to support the provision of information to applicants.

30

Improve cooperation and communication among CA and between them and the

Commission103

• Establish indicative response deadlines for administrative cooperation requests between

CA (e.g., 2 weeks) and report regularly on non-compliance per country via GoC

• Increase efforts to disseminate training on digital tools and processes (e.g.: IMI, EPC,

etc.) to CA (training at more frequent intervals, recorded training with voice over in all

EU languages, etc)

• Encourage recognition processes to be entirely conducted online by CA (whilst allowing

CA to choose their own system)

5.2.2. Option 2 – Targeted procedural reforms for improved interoperability

This option introduces specific legislative amendments to the Directive aimed primarily at

supporting the digitalisation and interoperability of recognition procedures across MS,

while preserving flexibility for national administrations in the organisation of their

workflows. It supports improved information through automated updates of the RegProf and

the possibility to deploy a chatbot to support applicants. It also improves the management of

digital workflows while maintaining national flexibility. Some process improvements rely

on voluntary uptake (e.g. an AI-assisted workflow tool would be made available by the

Commission for national systems to integrate it at their own discretion) whereas others would

be mandatory (e.g. verifiable, interoperable digital credentials would be mandated for the

professions under automatic recognition). The identification of specific deadlines for each

step of the recognition process, with a focus on the cooperation between CA, would help

structure it and support shorter processing times. Documentation, translation requirements and

fee practices would be further clarified by non-binding recommendations in the Code of

Conduct. Binding deadlines for responses to administrative assistance requests would be

introduced, while allowing MS to use their existing national digital workflows under a

“digital first” principle. This option effectively structures the recognition process and data

exchange without mandating a specific EU-wide digital workflow.

Policy measures proposed under PO2

Ensure complete and clear information on qualification requirements and recognition

processes at national level, in line with EU level information

• Issue Commission guidance on information structure and quality for CA websites

103 Another flanking measure, aimed at improving cooperation and communication among CAs, and between

CAs and the Commission, would be the strengthening of cooperation within the expert group on the recognition

of professional qualifications and its subgroups through the adoption of annual work programmes.

31

• Carry out voluntary peer review of national portals

• Amend the PQD to ensure real-time automated update through interoperability with the

RegProf database information on recognition decisions

Make recognition processes faster, easier, and less burdensome

• Develop, for voluntary use by MS, an interoperable AI-assisted workflow management

system to support CA in the recognition process and supporting applicants in preparing

applications, combined with a requirement for MS to ensure digital workflow for

recognition procedures.

• Amend the PQD to specify deadlines of individual steps of the recognition process with a

view to shortening the overall deadlines

• Amend the PQD to introduce legal obligation for MS issue Annex V qualifications as

interoperable digital credentials104

• Ensure that the document requirements are proportionate (e.g. update the Code of

Conduct, share best practices)

• Issue guidelines (e.g.: a formula) to calculate reasonable fees for recognition processes

Improve cooperation and communication among CA and between them and the

Commission

• Amend the PQD to establish binding response deadlines for administrative cooperation

requests between CA (e.g. 2 weeks)

• Increase efforts to disseminate training on digital tools and processes (e.g.: IMI, EPC,

etc.) to CA (training at more frequent intervals, recorded training with voice over in all

EU languages, etc)

• Require recognition procedures to be capable of being conducted online by CAs (whilst

allowing CA to choose their own system, compliant with the AI-assisted workflow)

5.2.3. Option 3 – Unified EU workflow and enhanced enforcement

This option constitutes a comprehensive procedural reform of the existing legal

framework through legislative amendments, mandating a single EU-wide digital

workflow across all MS. It ensures the completeness and clarity of information on

recognition requirements and procedures by further specifying the information to be provided

104 This policy measure links with Action 1 of the SPI.

32

at national level and by enabling the automated updating of RegProf. It introduces a

mandatory EU-wide digital workflow incorporating an AI-assisted management system to be

integrated into a harmonised digital procedure applicable across all MS.105 Legally binding

deadlines for every procedural step are reinforced by a financial compensation mechanism for

administrative delays. The option also introduces a significant reduction in documentation and

translation requirements, while fees would also be standardised. Through binding deadlines

with penalties for non-compliance, and mandatory training to CAs for all new tools and

processes, the option also strengthens administrative cooperation and coherence in the

recognition system and ensures consistent and simplified user experience throughout the

Union.

Policy measures proposed under PO3

Ensure complete and clear information on qualification requirements and recognition

processes at national level, in line with EU level information

• Amend the PQD to specify in more detail minimum content requirements for national

information (regulated professions, documentation, timelines, fees, appeal rights etc.)

• Amend the PQD to ensure real-time automated update through interoperability with the

RegProf database information on recognition decisions.

Make recognition processes faster, easier, and less burdensome

• Develop, for mandatory use by MS an AI-assisted workflow management system to

support CA in the recognition process and applicants in preparing applications

• Amend the PQD to specify deadlines of individual steps of the recognition process with a

view to shortening the overall deadlines, and foresee lump-sum compensation for non-

compliance.

• Amend the PQD to prevent MS from requesting additional information when receiving

digital credentials (for professions in Chapter III of the PQD)

• Amend the PQD to introduce a legal obligation for MS to issue Annex V qualifications

as interoperable digital credentials and accept digital credentials as valid evidence of

Annex V qualifications

• Amend the PQD to further reduce documents requirements allowed by law. Add

provision requiring MS to accept documents in all official EU languages.

• Amend the PQD to include common rules to establish fees (not exceeding the cost of the

105 The mandatory digital workflow would require adaptation by all MS, and public administrations currently

display varying levels of digital maturity. The implications of these differences, including implementation

challenges and associated costs, are discussed in the assessment of impacts below.

33

service provided) that CA can charge applicants for the recognition process.

Improve cooperation and communication among CA and between them and the

Commission

• Amend the PQD to establish binding response deadlines for administrative cooperations

requests between CA (e.g. 2 weeks) and foresee lump-sum compensation (i.e.: penalty

fee) for non-compliant CAs

• Increase efforts to disseminate training to CA (training at more frequent intervals,

recorded training with voice over in all EU languages, etc). Participation becomes

mandatory for all new tools or processes to guarantee coherent implementation across

MS.

• Mandate that recognition processes be entirely conducted online by CA with the AI-

assisted workflow provided by the Commission (Digital-Only Principle).

The European Digital Recognition Solution

Design and operation

The preferred option establishes a single European Digital Recognition Solution (EDRS)

supporting the complete workflow for the recognition of professional qualifications. The

system does not harmonise national recognition rules or affect Member States' competence to

regulate professions or decide on recognition requests. Competent authorities remain fully

responsible for assessing applications and taking recognition decisions in accordance with

national law and Directive 2005/36/EC. The initiative only harmonises the workflow.

The proposed digital solution covers the entire recognition procedure from end to end. It

provides applicants with a single entry point where they can identify whether a profession is

regulated in the Member State of destination, understand the applicable requirements, prepare

and submit their application, upload supporting documents and follow the progress of their

case. For competent authorities, the system provides integrated workflow management,

document management, communication with applicants and other competent authorities,

support for the assessment process, issuance of decisions and automatic statistical reporting. It

therefore replaces fragmented procedural arrangements with a single digital workflow

applicable across all professions and all competent authorities.

This represents a significant evolution compared with the current situation. Recognition

procedures remain predominantly national, with varying degrees of digitalisation. Some

competent authorities rely entirely on paper-based procedures, others operate partially digital

systems, while others have developed national online portals covering only specific parts of

34

the procedure.106 At EU level, digital cooperation is currently limited mainly to the IMI

system, which facilitates administrative cooperation between competent authorities, and to the

EPC, whose digital workflow applies only to a limited number of professions. The preferred

option builds on these existing instruments while extending digital processing to all

professions covered by the Directive.

In practice, the recognition procedure would operate through a single workflow. An applicant

wishing to establish in another Member State would first access the digital interface to obtain

information on the applicable recognition procedure and the documents required. Where

available, applicants could submit digital credentials issued under the EUDI framework or

evidence retrieved through the SDG and the OOTS. Where equivalent digital evidence is not

available, or where applicants have limited digital skills or access to digital tools, competent

authorities would continue to accept non-digital submissions and, where necessary, digitise

the application and manage it within the system on the applicant's behalf. This ensures that

digitalisation improves efficiency without excluding any applicant.

Once the application has been submitted, it is made accessible by the competent authority of

the host Member State. The authority performs the preliminary verification of completeness

within the deadlines established by the Directive, requests any missing information where

necessary and communicates with applicants directly through the system. Where cooperation

with authorities in another Member State is required, all exchanges also take place within the

same workflow. Throughout the procedure, applicants can monitor the progress of their

application, while competent authorities benefit from automated workflow management,

deadline monitoring and secure document handling.

The system would also include digital support functions designed to reduce administrative

burden while leaving all substantive decisions to competent authorities. Artificial intelligence

tools would support the automatic translation of documents submitted in any official Union

language, facilitate document classification, compare submitted evidence against the

procedural requirements applicable to each profession and assist in identifying potentially

fraudulent or inconsistent documents. These functionalities support administrative processing

but do not replace the assessment carried out by competent authorities, which remain solely

responsible for the recognition decision.

The preferred option also provides a clear allocation of responsibilities between the

Commission and Member States. The Commission would design, develop, operate and

maintain the common digital infrastructure extending the existing IMI platform. It would be

responsible for the technical operation, cybersecurity, maintenance, future upgrades and

interoperability with other Union digital infrastructures. Member States would continue to

designate competent authorities, process applications, communicate with applicants, assess

qualifications and adopt recognition decisions in accordance with their national legislation.

The Commission therefore provides the common procedural infrastructure, while

Member States retain full responsibility for the substantive recognition procedure.

106 A 2024 Commission study identified only around 40 digital solutions across more than 3 000 competent

authorities in the Union, most of which were limited to information provision or electronic submission of

applications. None supported the complete recognition workflow envisaged under this initiative.

35

Unlike the intermediate policy option, the preferred option does not require Member States to

develop or maintain separate national workflow systems. The common European workflow

constitutes the operational system used by all competent authorities. Consequently,

interoperability with national recognition systems is not required because recognition

procedures are managed directly within the common infrastructure. This considerably reduces

implementation risks associated with the development of 27 different national solutions and

ensures a uniform level of digital functionality across the Union. Interoperability is instead

only required with complementary Union digital infrastructures, notably IMI, the EUDI

framework, digital credentials, the SDG and the OOTS. These interfaces are developed

centrally by the Commission, ensuring consistent implementation and avoiding divergent

national technical solutions.

The proposed solution is therefore not conceived as a new standalone platform but as a

modular evolution of the existing digital infrastructure. It reuses established governance

arrangements, user management, security architecture and administrative cooperation

mechanisms while extending them to support the complete recognition workflow. It also

builds on the experience gained through the European Professional Card, replacing its

profession-specific digital procedure with a scalable solution covering all professions while

maintaining compatibility with future developments in digital credentials and evidence

exchange.

The initiative guarantees that digitalisation increases efficiency without creating new barriers

to access. The resulting system combines a single European digital workflow with

flexibility during implementation and coherence with the wider Union digital ecosystem.

Coherence with relevant tools and initiatives

The proposed digital solution has been designed to build on existing Union digital

infrastructures rather than duplicate them. It reuses existing systems where these already

provide the required functionality, adapts or extends them where necessary and creates

synergies with other initiatives under the Skills Portability Initiative and the wider EU digital

ecosystem.

The IMI system will continue to be the backbone for administrative cooperation. It already

provides the secure infrastructure for administrative cooperation between competent

authorities under Directive 2005/36/EC. Rather than establishing a parallel platform, the

initiative extends the communication workflow in IMI with a complete workflow

management system covering the entire recognition procedure. This approach allows the

initiative to benefit from existing governance arrangements, user management, security

architecture and operational experience while avoiding duplication of IT investments and

limiting implementation risks.

The initiative is closely linked to SPI Action 1, which promotes the digitalisation of

qualifications through the European Digital Identity (EUDI) framework for all professions.

Action 2 enables the use of these digital credentials as the means for submitting qualifications

in recognition procedures for regulated professions. Where available, applicants will also be

able to reuse evidence retrieved through the Single Digital Gateway (SDG) and the Once-

Only Technical System (OOTS), reducing the need to submit the same documents

repeatedly. For professions benefiting from automatic recognition, the proposal goes a step

36

further by requiring competent authorities both to issue and to accept digital qualifications

without requesting further evidence or additional verification. The Commission will ensure

the interoperability of the European Digital Recognition Solution with the EUDI framework,

digital credentials, the SDG and the OOTS through centrally developed interfaces,

guaranteeing consistent implementation across the Union while avoiding divergent national

technical solutions. The two initiatives are therefore mutually reinforcing: Action 1

establishes the framework for issuing trusted digital credentials and other digital evidence,

while Action 2 provides the operational recognition workflow through which these digital

assets can be effectively used in regulated professions and, in particular, ensures that digital

credentials achieve their full potential in the system of automatic recognition.

The initiative builds on the experience gained with the European Professional Card (EPC).

The EPC demonstrated the benefits of digital handling of recognition procedures but remains

limited to a small number of professions. The proposed solution replaces this profession-

specific approach with a single, scalable workflow applicable across all professions covered

by the Directive while reusing the operational experience, governance arrangements and

technical lessons developed through the EPC.

The initiative also complements the Regulated Professions Database (RegProf), which

remains the Union's authoritative source of information on regulated professions, competent

authorities and recognition requirements. Information contained in RegProf will be

restructured using the classifications of European Skills, Competences, Qualifications and

Occupations (ESCO), and directly feed the applicant interface of the European Digital

Recognition Solution, ensuring that applicants always access a single, reliable and up-to-date

source of information when preparing their application. At the same time, the operation of the

digital workflow will automatically generate and update information relevant to RegProf,

including changes relating to competent authorities, regulated professions and statistical data

on recognition procedures. The two systems will therefore be synchronised, improving the

completeness, quality and timeliness of information while reducing duplicate reporting and

manual updates by Member States.

Finally, the initiative creates important synergies with SPI Action 3 concerning the

recognition of qualifications held by third-country nationals. By establishing a single

European digital workflow linking applicants and competent authorities across all Member

States, Action 2 creates a common procedural infrastructure that can also support the handling

of recognition applications from third-country nationals. Rather than requiring separate digital

solutions for different categories of applicants, the same workflow, case management tools,

document handling and communication mechanisms can be used irrespective of whether the

applicant is an EU citizen or a third-country national, while applying the respective legal rules

governing each procedure. This reduces administrative fragmentation, avoids duplication of

IT developments and facilitates the future implementation of Action 3 by providing an

operational digital infrastructure on which it can build.

Taken together, these interactions ensure that the proposed digital solution complements

rather than duplicates existing Union initiatives. It creates a coherent digital ecosystem in

which existing infrastructures perform their respective functions while contributing to a

seamless recognition procedure for applicants and competent authorities.

37

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?

This chapter examines the economic and social impacts of the proposed policy options.

Section 6.1 analyses the direct cost impacts associated with each option. The direct impacts

associated with each option comprise both benefits and costs. On the benefits side, these

include administrative cost savings and monetised time savings for applicants, employers and

competent authorities. On the costs side, they include implementation costs as well as

additional administrative costs related to the expected increase in the volume of recognition

applications and cases generated by the policy options. Administrative cost savings (under

6.1.1) include reductions in regulatory burdens for mobile professionals and, where they are

involved in recognition procedures, their employers, as well as for competent authorities,

while monetised time savings capture the direct microeconomic benefit for mobile

professionals resulting from faster recognition procedures.107 The implementation costs

estimated in Section 6.1.2 consist primarily of the IT development costs associated with the

three policy options, while Section 6.1.3 estimates costs related to the expected volume

increases.108 Broader economic impacts are presented qualitatively in section 6.2.109 These

include the impacts on the competitiveness of firms which are related to increased recruitment

opportunities, mitigation of critical shortages, reduced attrition and turnover as well as

macroeconomic impact such as improved allocative efficiency and asymmetric shock

absorption. Section 6.3 analyses the social impacts, including employment opportunities,

upward career mobility, combatting undeclared work, equal treatment, access to essential

services. Together, these elements form the basis for the comparative assessment of the policy

options in Chapter 7.110

107 In this analysis, these time savings are quantified as individual gross value added (GVA) gains stemming

from faster occupational matching. 108 The expected volume increments used in the total burden calculation (+5%, +8–10% and +10–15%) are

calibrated policy-scenario assumptions rather than estimates derived from a statistical model. This approach is

appropriate because the relevant counterfactual—the number of professionals who would have initiated a

recognition procedure in the absence of existing procedural barriers—is not observable, and no Member State

systematically collects data on professionals who considered applying but ultimately did not do so. Moreover,

historical recognition volumes cannot be reliably extrapolated due to structural breaks caused by the withdrawal

of the United Kingdom and the mobility restrictions during the COVID-19 pandemic (2020–2022). The selected

increments are therefore anchored in the available evidence on the existence of induced demand. In particular,

524 of 785 respondents to the SPI public consultation identified lengthy, complex and costly recognition

procedures as an important problem, while the contractor's survey of citizens and professionals confirmed that

procedural barriers—including the time required to complete the process, its costs (e.g. fees, translations and

notarisation) and difficulties in accessing information or using partially digital procedures—discourage

applications. By analogy, the ex ante impact assessment accompanying the Single Digital Gateway Regulation

also identified an induced demand effect resulting from procedural simplification of comparable scope. The

increments are deliberately conservative, remaining small relative to the baseline of approximately 53 000

recognition procedures per year and increasing gradually with the expected intensity of intervention under each

policy option. They should therefore be understood as plausible volumes induced by the removal of procedural

barriers, used as calibrated assumptions for the comparative assessment of the policy options rather than as

forecasts of future recognition volumes. 109 Since these macro-level benefits depend on complex, long-term market dynamics, any attempt at precise

quantification would require overly extensive modelling assumptions. 110 Note on environmental impacts: An assessment of environmental factors has not been carried out, as this

initiative is not expected to have significant environmental impacts, including under the ‘do no significant harm’

(DNSH) principle and climate consistency requirements. The envisaged measures may nevertheless entail certain

38

6.1. Direct cost impacts

6.1.1. Administrative cost savings and monetised time savings

The three policy options are expected to generate cost-savings for stakeholders through their

effects on the compliance costs and administrative burden associated with recognition

procedures under the PQD. The main stakeholders in this context are professionals seeking

recognition and CAs111. For the purposes of cost estimation, recognition activity is treated as

constant over the medium term, with an annual baseline volume of approximately 53 000

procedures per year. 112 The total administrative cost113 is estimated by multiplying this

number of procedures by the unit cost per procedure, which is EUR 330 per procedure for

applicants and EUR 950 for CAs (combined unit cost of EUR 1 280 per procedure).114 This

gives a total annual cost of EUR 67.8 million. Given that the development phase is expected

to take place in 2027–2028, the estimation assumes that the associated benefits begin to

materialise from 2029 onwards.

Under PO1, non-binding measures are expected to generate modest reductions in

administrative costs for both applicants and CAs. The effect is concentrated on the most

information-sensitive cost components, where guidance-based simplification can have a direct

impact. The savings attributable to each cost component reflect the specific mechanisms

through which PO1 measures are expected to operate.115 Cost-savingsare estimated as

limited positive environmental effects, notably through the gradual replacement of paper-based procedures by

digital processes, thereby reducing paper consumption and the carbon footprint associated with administrative

procedures. In addition, the initiative is expected to benefit establishment more than the temporary and

occasional provision of services, in line with trends observed under the current system. Between 2020 and 2024,

around 185 000 decisions were taken by EU MS on the recognition of professional qualifications for the purpose

of establishment, compared to around 40 000 declarations submitted for the temporary and occasional provision

of services in another Member State over the same period. This suggests that the initiative is not expected to lead

to significant additional transport-related environmental impacts. 111 Employers also sometimes bear costs when seeking to recruit professionals in regulated professions;

According to survey data collected through the SME Panel Survey (n = 159), 19 respondents indicated that

recognition procedures are handled directly by the employer on behalf of the prospective employee, while 47

respondents indicated that the employer supports the procedure, with the employee retaining responsibility for it.

The cost savings for employers are discussed in more detail below and in Annex 4. 112 Cf. above Section 2. 113 For the purposes of this report, administrative costs and administrative cost savings are understood not only

as costs borne by, or savings realised by, public administrations, but more broadly as all expenses associated

with the completion of the administrative recognition procedure, whether borne by the applicant, the competent

authority or the employer. The breakdown of these cost components is provided in Annex 4. 114 The unit cost corresponds to the combined applicant and competent authority administrative costs incurred

per recognition procedure. To estimate this, three primary data sources have been used in addition to the RegProf

database: the CA survey (n=81), the citizens/professionals survey (n=48), and the SPI public consultation

(n=785), triangulated against the data collected for the PQD implementation report. Cf. Annex 4. 115 Fee reductions at the qualification-issuing institution and home CA level (gross saving 5–10%) are expected

to materialise through clearer pre-application guidance reducing the number of documents resubmitted, as

documented in ECA Special Report 2024-10 (document proliferation as primary cost driver) and confirmed by

the GoC Focus Group (4 March 2026), where 24 out of 28 CA identified information gaps as a primary

workload driver. Improved information on documentation requirements is expected to reduce by 10–15% the

number of documents being unnecessarily translated. Notarisation, postal and CA fee components are expected

to yield modest reductions (5–10%) through reduced document volumes and clearer fee information, consistent

39

percentage reductions in the baseline per-procedure burden and reduced by a realisation factor

(i.e.: a percentage) reflecting expected partial achievement of savings.116 For PO1, the

expected administrative cost savings for applicants and CAs are estimated at EUR 81.5 per

procedure.117 At the SCM baseline of 53 000 procedures per year,118 the aggregate annual

administrative savings for applicants and competent authorities under PO1 are estimated

at approximately EUR 4.3 million(recurrent, starting from 2029).

In addition to these administrative cost savings for applicants and CAs, the direct cost impacts

include monetised time savings for applicants: as recognition procedures become faster and

waiting times decrease, applicants can more quickly enter the regulated profession for which

they are qualified, translating into higher productivity and wages at the individual level.

Applying the calculation method explained in Annex 4,119 Option 1 is expected to yield for

the applicants additional monetised time savings of EUR 86.2 million per year(recurrent,

starting from 2029).

with evidence on fee opacity as a barrier (SWD (2026) 64). CA variable staff costs are expected to decline

(gross saving 5–10%) through a reduction in preliminary enquiries and incomplete submissions, which Q18 of

the CA survey identifies as a significant driver of processing time; the GoC Focus Group (4 March 2026)

confirms that pre-application guidance directly reduces this workload. CA other variable costs (gross saving 3–

7%) reflect modest efficiency gains from standardised document checklists and voluntary digital tools. 116 The realisation factors reflect expected effectiveness of the policy option, i.e. the extent to which the intended

specific objectives are achieved in practice. They are calibrated based on qualitative evidence, institutional

design, and comparable impact assessments. For further details on the realisation factors applied under each

policy option, cf. footnotes accompanying the respective policy option tables in Annex 13. 117 Cf. tables in Annex 13 (The first five cost elements shown in the tables for PO1, PO2 and PO3 relate to

applicants, while the last three relate to CAs. Accordingly, the administrative cost savings associated with the

first five elements are obtained by applicants, whereas those associated with the last three elements in those

tables are obtained by CAs). The sources used for the calculations are: citizens/professionals survey (Q17: In the

most recent recognition procedure you were involved in, what were the approximate out-of-pocket costs borne

by you (in EUR)?" - the total is constructed as the sum of six cost components: fee paid to the qualification-

issuing institution, fee paid to the home competent authority for the official documents required, certified

translation costs, notarisation or apostille costs, postal or courier charges, and the host competent authority

application fee); CA survey (Q9, Q11, Q18: Survey on costs targeted at CAs, Q9: “What is the average annual

salary (in EUR) of staff involved in managing the recognition process in your organisation?” Q11: “What are the

annual estimated costs – in terms of man-days – incurred by your organisation to conduct the following

activities?” Q18: “What is the estimated annual cost – in terms of man-days – for the following activities?”);

Scholz and Rohr (2026) “How can AI translations be used for equivalence assessments?”, in study supporting

this IA. Savings apply the 60% realisation factor to the minimum and maximum gross savings. The estimate

(EUR 81.5 per procedure) is the midpoint of the resulting range (EUR 55–108). 118 In limited number of cases, the total or part of the host CA calculation fees could be borne by a prospective

employer (see 6.1.5 below). 119 As explained in Annex 4, the baseline assumes approximately 53 000 recognition procedures per year. Of

these, around 24 380 fall under the automatic recognition system, where the average monthly salary is estimated

at between EUR 4 000 and 4 500, while for the remaining cases the average monthly salary is estimated at

between EUR 3 000 and 3 500. The calculation of saved wages is based on the expected reduction in processing

time, notably the reduction from three months to one month for the automatic system and from four to three

months for the general system. It also takes into account the share of respondents indicating that they remain

unemployed or employed in positions not corresponding to their qualifications while awaiting a recognition

decision, and the realisation factor applicable to the PO. Applying this methodology to both automatic

recognition and general system cases leads to an estimated total annual welfare gain for PO1 of between EUR

80.7 million and 91.8 million. The detailed calculation methodology is set out in Annex 4.

40

Beyond the costs incurred by applicants and competent authorities, recognition procedures

also generate administrative costs for employers seeking to recruit professionals qualified in

another Member State. These costs arise from the internal staff time devoted to supporting or

managing recognition procedures, the payment of recognition fees where employers submit

applications on behalf of prospective employees, and expenditure on external legal or

consultancy services to navigate cross-border recognition requirements. The estimates are

based on the SME Panel Survey conducted by the European Commission through the EU

Survey portal in 2026 (159 SMEs across 18 EU and third countries).120 Of the 159

respondents, 19 indicated that they directly manage recognition procedures on behalf of

prospective employees, including the payment of the associated fees. This corresponds to

approximately 12% of recognition procedures involving direct employer participation and

forms the basis for the calculations. Respondents also estimated that a common EU digital

recognition system could reduce employer-borne administrative costs by between 26% and

36%, depending on the cost category. 121 Applying the realisation factors used for each policy

option (60% under PO1, 75% under PO2 and 95% under PO3) to this expected saving, and

assuming approximately 6 360 employer-managed procedures annually with an average

administrative cost of EUR 814 per recruitment,122 results in expected aggregate annual

reduction in employer-borne administrative costs of approximately EUR 1.0 million under

PO1.123

Thus, Option 1 would result in annual (recurrent, starting from 2029):

120 SME Panel Survey on Cross-border Recruitment and Recognition of Qualifications, European Commission,

2026. Conducted via the EU Survey portal under the SME Panel consultation framework, as part of the impact

assessment of the Skills Portability Initiative. Respondent profile: 159 SMEs from 18 EU and third countries,

with the largest contributions from Spain (47 respondents), Greece (23), Poland (21), Italy (9), Germany (8),

France (8) and Romania (8). Distribution by business size: 47 micro-enterprises (1–9 employees), 50 small

enterprises (10–49 employees), 36 medium-sized enterprises (50–249 employees), 17 large enterprises (250

employees or more), and 9 self-employed respondents. Source: SME Panel Survey Summary Report, Tables 0–

2. 121 SME Panel Survey on Cross-border Recruitment and Recognition of Qualifications (2026), Summary Report,

Table 14 'Anticipated cost savings from a common EU digital recognition system, by cost category'. Mean

anticipated savings were reported by 35 SME respondents for fees charged by recognition bodies, 35 for

translation and certification costs, 35 for bridging or training costs, 34 for external consultancy or legal support,

35 for internal administrative time, 32 for recruitment-related costs, 32 for onboarding delays and reduced

productivity, 33 for compliance costs, and 32 for risk-related costs. The 26%–36% range cited in the text reflects

the lower bound (fees for recognition bodies) and the upper bound (internal administrative time) across the cost

categories most directly relevant to the administrative burden of the recognition procedure. 122 Among respondents who provided a quantitative estimate (n=7), the mean external cost per hire for the

recognition of non-national EU qualifications is in the order of EUR 814, with a median of EUR 250, a

maximum of EUR 3 500 and a minimum of EUR 50. Component-level figures reported separately in the

Survey's cost-category breakdown — fees for recognition bodies (mean EUR 407), internal administrative time

(mean EUR 354) and external consultancy or legal support (mean EUR 545) — are not additive to the per-hire

total, as they are derived from partially overlapping respondent groups and capture distinct dimensions of cost

rather than incremental components of a single estimate. SME Panel Survey, Summary Report, Table 12 'Cost

estimates by qualification origin', row 'Non-national / EU qualifications', column 'External cost per hire (EUR)':

mean 814, maximum 3 500, median 250, minimum 50, n=7 respondents providing a valid quantitative estimate.

The figure is reported in the Summary as a single aggregate variable (the total external cost per hire) and is not

decomposed at this level into incremental components. 123 Annex 4 explains in more detail the methodology used to estimate administrative costs borne by employers

and the measures taken to ensure that costs incurred by employers and applicants are not counted twice.

41

• administrative savings for applicants and competent authorities: EUR 4.3 million

• monetised time savings for applicants: EUR 86.2 million

• administrative savings for employers: 1.0 million

The cumulative present value of these direct cost savings over the period 2029–2040 is

estimated at EUR 858.5 million, discounted to 2026 using a 3% discount rate.124

PO2 consists of binding legislative measures complemented by voluntary digital tools, which

directly addresses the dominant cost drivers identified in the survey data and focus group

evidence: translation and documentation proliferation, excessive CA staff time on document

verification, and opaque fee. The binding character of the measures is expected to produce

materially larger cost-savings.125 For PO2, the expected administrative cost savings for

applicants and CAs are estimated at EUR 243 per procedure.126 At the baseline of 53 000

procedures per year, the aggregateannual saving under PO2 is estimated at approximately

EUR 12.9 million administrative cost savings for applicats and competent authorities

(recurrent, starting from 2029). Applying the calculation method explained in Annex 4,

Option 2 is expected to yield additional monetised time savings of EUR 107.8 million per

year to the applicants.127Similarly to Policy Option 1, there would also be administrative cost

savings for employers. Applying the methodology explained above, these savings are

estimated at EUR 1.2 million per year for PO2.

Thus, Option 2 would result in annual (recurrent, starting from 2029):

• administrative savings for applicants and competent authorities: EUR 12.9 million

• monetised time savings for applicants: EUR 107.8 million

• administrative savings for employers: 1.2 million

The cumulative present value of these direct cost savings over the period 2029–2040 is

estimated at EUR 1 143.7 million, discounted to 2026 using a 3% discount rate.

Under PO3, a more comprehensive legislative revision is expected to produce the most

comprehensive reduction in per-procedure costs. It substantially reduces, and in some cases

eliminates, the translation and documentation burden, which is a dominant cost component,

124 Cf. Annex 13. 125 The savings attributable to each cost component reflect the PO2 binding measures. Recommendations on

proportionate document requirements are expected to reduce (gross saving 30–50%) both the number of

documents submitted and the share requiring certified translation, consistent with evidence (Scholz and Rohr

(2026)) confirming significant translation cost reduction potential under standardised documentation regimes.

CA variable staff costs (gross saving 15–25%) reflect the combined effect of binding procedural deadlines —

which reduce the volume of follow-up interactions — and digital tools supporting document verification; the CA

survey (Survey on Costs targeted at CAs, Q18) identifies document verification and follow-up as the dominant

time cost. Fee components (gross saving 10–25%) through guidelines on canculation of reasonable fees

consistent with evidence data (SWD(2026) 64 final) on fee heterogeneity and GoC Workshop findings

(Consultation Workshop with GoC members on the problem definition) on the prevalence of unjustified fee

structures. Reductions in CA other variable costs (gross saving 10–20%) reflect efficiency gains from procedural

standardisation. 126 Cf. table in Annex 13. 127 Cf. Annex 4.

42

standardises CA processing workflows, and substantially reduces procedural discretion. The

realisation factor of 95% reflects the mandatory character of the provisions, with very limited

scope for national discretion following transposition. For PO3, the expected administrative

cost savings for applicants and CAs are estimated at EUR 512.5 per procedure.128 The savings

attributable to each cost component reflect the comprehensive scope of PO3 mandatory

measures.129 At the SCM baseline of 53 000 procedures per year, the aggregate annual saving

under PO3 is estimated at approximately EUR 27.2 million (recurrent, starting from 2029).

Applying the calculation method explained in Annex 4, Option 3 is expected to yield

additional monetised time savings of EUR 136.6 million per yearto the applicants. In

addition, there would also be administrative cost savings for employers. Applying the

methodology explained above, these savings are estimated at EUR 1.5 million per year for

PO3.

Thus, Option 3 would result in annual (recurrent, starting from 2029):

• administrative savings for applicants and competent authorities: EUR 27.2 million

• monetised time savings for applicants: EUR 136.6 million130

• administrative savings for employers: 1.5 million

The cumulative present value of these direct cost savings over the period 2029–2040 is

estimated at EUR 1 550.9 million, discounted to 2026 using a 3% discount rate.

The table below shows the discounted cumulative benefits by policy option for the period

2029–2040, broken down into administrative cost savings for applicants and competent

authorities, monetised time savings for applicants, and administrative cost savings for

employers. All values are expressed as discounted present values.

Table 1 - Savings (EUR million) 2029-2040

Cumulative present value

Policy

Option 1

Policy

Option 2

Policy

Option 3

Administrative cost savings (applicants and CAs) 40.3 121 255.2

128 Cf. table in Annex 13. 129 The certified translation component (gross saving 50–80%) is structurally transformed under PO3: mandatory

digital credentials are expected to substantially reduce, and in some cases eliminate, the need for certified

translation across a large share of procedures, consistent with early pilot findings (e.g. DC4EU) suggesting that

digital credential verification can substantially reduce manual processing times, and with evidence (Scholz and

Rohr (2026)) on the upper bound of translation cost reduction potential. CA variable staff costs (gross saving

25–40%) reflect the elimination of manual document verification through digital credential systems, the

enforcement of binding deadlines with sanctions, and the standardisation of assessment workflows; Q18 of the

CA survey identifies document verification as the dominant time cost, and the GoC Focus Group (4 March 2026)

confirms that mandatory streamlining would materially reduce processing time across all procedure types. Fee

components at issuing institution and host CA level (gross saving 20–40%) are expected to decline substantially

through mandatory harmonisation and caps, removing the fee heterogeneity documented in the ECA Special

Report and in SWD (2026) 64. CA other variable costs (gross saving 20–35%) reflect near-complete elimination

of discretionary administrative steps through mandatory standardisation. 130 Cf. Annex 4 for a sensitivity analysis of monetised time savings under the preferred option.

43

Table 1 - Savings (EUR million) 2029-2040

Cumulative present value

Policy

Option 1

Policy

Option 2

Policy

Option 3

Monetised time savings (applicants) 808.8 1 011.4 1281.7

Administrative cost savings (employers) 9.4 11.3 14.1

TOTAL 858.5 1 143.7 1 550.9

***

Above, under the specific objective of making recognition processes faster, easier and less

burdensome, a reference point was proposed consisting in apossible reduction of the overall

cost of recognition procedures by 25%. The 25% simplification target used in EU Better

Regulation discussions is treated here as an indicative reference point rather than as a binding

target, in line with the analytical purpose of the assessment.131 Considered against this

reference: PO1 would deliver a comparatively limited annual reduction in the total system

burden ofapproximately 7.8% (5.3/67.8 million EUR) relative to the annual baseline; PO2

would deliver an annual reduction in total system burden of approximately 20.8% (14.1/67.8

million EUR); and PO3 would deliver annual reduction in total system burden of

approximately 42.3% (28.7/67.8 million EUR) relative to the annual baseline.

6.1.2. Implementation costs

This section assesses the implementation costs132 associated with the different policy options

and identifies whether these costs would be borne by the Commission or by MS’ national

administrations, including CAs.133 Under all policy options, digital workflows would be

implemented, but their deployment would vary: PO1 would rely on the voluntary use of the

EU-level tool by MS; PO2 would introduce a mandatory workflow, with MS having the

choice to implement the workflow on national level or to voluntarily use the EU-level tool;

PO3 would require the use of a mandatory EU-level tool. In options 1 and 3, the Commission

would set up and operate the workflow management system, while Member States would use

it on a voluntary basis in option 1 and on a mandatory basis in option 3. As the procedure

would run within the common EU system, interoperability with national systems would not be

required. In option 2, by contrast, implementation would depend on both the Commission and

Member States: the Commission would enable cross-border communication and statistics,

while Member States would maintain national systems aligned with a common workflow.

This option therefore requires substantial interoperability and carries higher risks of

incomplete compliance, uneven implementation and delayed deployment.

131 Cf. Section 4.2 above. 132 The implementation of the policy options would also entail compliance and legal adjustment costs, beyond

IT-related investments. notably due to the need to adapt national laws, administrative procedures and

organisational practices. Nevertheless, given the central role of digitalisation and interoperability measures in the

initiative, the assessment below focuses primarily on estimating the main costs associated with the development,

adaptation, operation and maintenance of the relevant IT systems and digital infrastructures. 133 The description here is supported by a table in Annex 13, complemented by a detailed breakdown of the

different cost components in Annex 4.

44

In all three options, the Commission would cover the costs of developing and operating

the European Digital Recognition System (EDRS) at EU level. The EDRS would include:

a common digital workflow; state-of-the-art interfaces for applicants and competent

authorities; AI-supported tools to streamline the handling of recognition applications;

interoperability with key Commission systems, such as the SDG Once-Only Technical

System (SDG-OOTS) and the European Digital Identity Wallet (EUDI Wallet); analytics and

statistics dashboards; and integration with an enhanced Regulated Professions Database. One-

off development costs, covering security, release, training and communication activities), are

estimated at EUR 4.46 million and would be incurred equally in 2027 and 2028. Following

the system’s launch at the end of 2028, annual operational costs, covering hosting,

maintenance and user support, are estimated at EUR 1.09 million during a two-year

stabilisation period (2029–2030) and EUR 0.65 million thereafter (2031–2040).

The identical costs in all three policy options would thus be:

• One-off implementation costs (split over 2 yrs): EUR 4.46 million

• Operation costs (years 1 & 2): EUR 1.09 million per year

• Operation costs (year 3 onwards): EUR 0.65 million per year

The total implementation cost for the 2027-2040 period would be EUR 13.12 million, or EUR

11.14 million, expressed in present value terms and discounted to 2026 at a rate of 3%.

Under policy option 2, additional costs would need to be borne by MS opting for national

solutions (e.g., to improve interoperability with domestic systems). These are estimated to

face one-off costs of EUR 2.89 million per MS (split over two years). Such costs would cover

the adaptation and development of national systems, integration with EU shared services,

EUDI verification and issuing features, and SDG-OOTS verification integration. Annual

operational costs per national system are estimated to be EUR 0.29 million. Total costs for

MS for the period 2027-2040 would depend on the uptake of the EU-level solution: EUR 0 if

all MS use the EU-level solution; up to EUR 171.67 million if all develop national solutions;

EUR 69.94 million in a realistic scenario where 11 MS implement national solutions. Over

the period 2027–2040, the total cost is estimated at EUR 60.24 million in discounted

present value terms, expressed in 2026 prices and applying a discount rate of 3%.

The total implementation costs for the 2027-2040 period would thus be: PO1 and 3:

EUR 13.12 million (discounted at 3%: EUR 11.14 million); PO2 (realistic scenario):

EUR 83.06 million (discounted at 3%: EUR 71.38 million).

6.1.3. Costs related to expected volume increases

On top of the IT implementation costs, one should also consider the costs related to the

expected volume increases in recognition procedures (see footnote above).134 Under PO1, the

expected increase corresponds to approximately 2 650 additional procedures annually from

134 As explained in Annex 13, each recognition procedure entails an average cost of EUR 1 280 (in current

values), of which part is borne by the applicant and part by the CA. A higher number of recognition procedures

would result in higher aggregate procedure costs.

45

2029 onwards. This would entail additional costs of EUR 3.4 million annually from 2029

onwards and result in cumulative additional costs with a discounted (3%) present value of

approximately EUR 31.9 million over the period 2029-2040 under PO1. Under PO2, the

expected increase corresponds to approximately 4 770 additional procedures annually from

2029 onwards. This would entail additional costs of EUR 4.9 million annually from 2029

onwards and result in cumulative additional costs with a discounted present value of

approximately EUR 46 million over the period 2029-2040 for PO2. Under Policy Option

3, the expected increase corresponds to approximately 6 625 additional procedures annually

from 2029 onwards. This would entail additional costs of EUR 5.1 million annually from

2029 onwards and result in cumulative additional costs with a discounted present value of

approximately EUR 47.9 million over the period 2029- 2040 for PO3.135

Table 2 – Costs (EUR million) 2029-2040

(cumulative present value)

Policy

Option

1

Policy Option

2

Policy

Option 3

IT implementation costs 11.1 71.4 11.1

Costs related to expected volume increases 31.9 46 47.9

TOTAL 43.0 117.4 59.0

6.2. Broader economic impacts

In addition to the direct cost savings estimated in section 6.1., all three policy options are

poised to generate broader economic benefits to the extent that they facilitate cross-border

recognition of professional qualifications required to access regulated professions.

At firm-level, this results in increased recruitment opportunities relative to the baseline,

enhancing their competitiveness and growth potential. Businesses can tap into a wider,

geographically diverse pool of applicants whose qualifications are formally recognized by

competent authorities. Whereas this effect benefits large corporations, they are particularly

advantageous for SMEs, which often lack the administrative capacity to (help the applicant)

navigate complex recognition procedures and are disproportionately impacted by acute labour

shortages hampering growth.136 According to a Eurobarometer survey, while 95% of SMEs

report that finding employees with the right skills is a challenge for their business, only 14%

have attempted to address these shortages by recruiting talent from other EU MS. When asked

why they did not try to hire non-domestic talent, between 4% and 6% of companies

specifically refer to difficulties in getting the professional qualification recognised. Of those

135 Cf. Annex 13. 136 Fragmented and slow recognition processes directly constrain companies’ ability to recruit across borders

within the Single Market. This limits firms’ effective access to the EU-wide talent pool, reducing their capacity

to fill vacancies in sectors experiencing persistent labour and skills shortages. CESI. (2025). Union of Skills:

Improve training, recognition of qualifications & fair transitions.

46

that did try to hire workers from another MS, 6% to 7% pointed to such difficulties.137

Facilitating cross-border recognition of qualifications addresses this concern, thus helping to

reduce vacancy durations for critical roles and improve the structural match between the

skills required for a position and the actual profiles of applicants. In its turn, better matching

has a positive impact on employee productivity and retention.138

At macro-economic level, less costly and faster recognition procedures reduce “brain

waste” and overqualification. By enabling qualified professionals to more easily access

regulated occupations that match their specialized skills, they enhance the allocative

efficiency and aggregate productivity of the workforce.139 This increases potential GDP at

a constant labour supply. The size of these impacts depends on the share of workers currently

underemployed, the share employed in regulated professions, the degree of trust local

employers have in foreign qualifications. It is also contingent on the relative importance of

other legal and administrative barriers that hamper cross-border mobility. The potential

magnitude of addressing these collective bottlenecks is illustrated by the European Value-

Added Assessment on overcoming cross-border barriers. The study explicitly identifies the

lengthy procedures for recognizing qualifications as a prominent barrier among many.

According to its macroeconomic modelling, a realistic scenario achieving a 20% reduction

across all covered cross-border barriers would unlock an estimated EUR 123 billion per year

in gross value added (i.e. approximately 1% of total EU GVA) and help create over 1 million

jobs throughout the affected EU land border regions.140 In addition, swifter and less expensive

cross-border recognition contribute positively to overall labour market resilience. By

fostering greater geographic mobility, they help balance regional employment mismatches

and absorb localized economic shocks.

Finally, the policy options also advance the digital transformation of recognition systems to

varying degrees, improving efficiency, user-friendliness, and long-term digital capacity-

building.141 PO1 relies on voluntary digitalisation, promoting interoperability through

137 Cf. European Commission (2024). 39% of SMEs surveyed in 2023 through the Eurobarometer 529 (European

Year of Skills: Skills shortages, recruitment and retention strategies in small and medium-sized enterprises)

indicated that easier procedures for the recognition of foreign qualifications would at least moderately help their

company recruit staff with the required skills. This is also reflected in evidence on barriers faced by SMEs when

operating or scaling up across the EU, where recognition of professional qualifications is identified as one of the

regulatory frictions that can hinder cross-border activity alongside other administrative constraints. European

Commission. (2025a). Flash Eurobarometer 559: Startups, scaleups and entrepreneurship. According to the SME

Panel Survey 2026, SMEs anticipate faster recruitment (61%) and easier hiring from other EU MS (50%) among

the key expected benefits of an EU digital recognition system. 138 Coraggio L. et al. (2025) provides a summary overview of the relevant literature about the relationship

between job match quality and firm productivity. In addition, the study provides robust empirical evidence

suggesting that higher match quality directly translates into measurable increases in labour productivity and

overall firm profitability, particularly when supported by high-quality managerial oversight. 139 Brain waste particularly affects mobile EU professionals whose qualifications may remain unacknowledged

across borders. Over time, these mismatches weaken the EU’s ability to align labour supply with demand in

critical sectors such as healthcare and engineering, and reduce incentives for skilled professionals to move where

they are most needed. ESDE (2023). 140 European Parliament Research Service (2023). 141 According to the OECD Digital Government Policy Framework (2020), digital transformation can improve

the efficiency of public administrations and support the delivery of more user-driven, proactive and effective

public services in the digital environment.

47

guidance and best practices. While flexible, this approach risks uneven uptake, particularly in

Member States with lower digital maturity. PO2 introduces mandatory digital workflows and

interoperability standards, ensuring structured digitalisation across MS. However,

implementation may pose challenges for authorities with limited digital infrastructure. PO3

goes further by mandating a unified EU-level digital system, guaranteeing full interoperability

and standardisation. This reduces Member State implementation burdens but may limit

integration with existing national systems.

All three policy options contribute positively to these firm-level and macroeconomic

effects, though their impacts relative to the baseline vary. PO1 is expected to provide only

marginal benefits, as its reliance on non-legislative, soft-law measures—such as voluntary

peer reviews, common templates, and non-binding deadlines—leaves actual implementation

entirely to the discretion of individual MS. In contrast, PO2 delivers a more pronounced

impact; by establishing legally binding response deadlines and mandating interoperable

digital credentials for automatically recognized professions, it introduces greater structure and

predictability into cross-border data exchanges. Due to its stronger reliance on binding

measures and by introducing a unified workflow, PO3 delivers the most substantial reductions

in both applicant- and employer-borne costs while yielding the greatest time savings, even

when taking into account the expected increase in the volume of applications under each of

the policy options. It is therefore expected to also deliver the strongest positive impact on the

various dimensions outlined.

6.3. Social impacts

At the individual level, faster and less costly recognition procedures compared to the baseline

increase high-quality employment opportunities for mobile professionals.142 By

142 The initiative is expected to have positive impacts especially for young people across the EU. Young people

tend to be more mobile than other age groups and are more likely to seek employment opportunities in other MS.

At the same time, the costs associated with recognition procedures may represent a greater burden for individuals

at the beginning of their careers. Contributions received through the EU Youth Stakeholders Consultation with

15 civil society organisations, public authorities and business associations from 14 MS highlighted strong

expectations for faster, simpler and more predictable recognition procedures. Young stakeholders expect

measures aimed at improving digital recognition procedures and interoperability to facilitate mobility, improve

the portability of skills and support smoother transitions between education, training and employment, and stress

the importance of ensuring that digitalisation remains accessible to all. 24 of the 32 young respondents to the

public consultation on the SPI (32 responses from young people between the ages of 16-25, with an average age

of 23), indicated that they had previously applied, were currently applying, or intended to apply for a job or

pursue professional activities in an EU Member State other than the one in which they obtained their

professional qualifications, and 26 of 32 indicated that they consider lengthy, complex and costly recognition

procedures for access to a regulated profession in another country to be a moderate, significant or very

significant problem. A recent study concerning young EU movers and labour market identifies higher labour-

market mismatches among young EU movers than young people working in their home EU country, which

could be attributable to difficulties in the recognition of professional qualifications or validation of skills and

could be addressed by improved recognition procedures. European Commission (2026c): the report analyses

factors specific to young people, such as accepting a first job below one’s qualification level as a temporary

“stepping stone” to explain relatively high figures of educational mismatches (27% for EU movers and 21% for

young people working in their home EU country), and skills mismatches (25% and 18%, respectively).

Concerning the significant gap between the two groups, the report identifies language barriers, weaker local

networks and limited knowledge of the host-country labour market as possible contributing factors. However,

48

accelerating entry into formal, regulated occupations that match their true skill levels, they

boost upward career mobility and enhance long-term income security.143 The magnitude

of these effects depends on a variety of factors, including the degree of occupational

regulation in the host country, the transferability of country-specific human capital, the initial

level of occupational downgrading, and local language proficiency.

Facilitating cross-border recognition ensures that mobile citizens can practice their profession

based purely on merit, regardless of their Member State of origin. By removing these

administrative and regulatory barriers, it secures the fundamental freedoms of movement,144

establishment, and service provision within the internal market while upholding the core

principles of equal rights and non-discrimination.

Increased mobility of professionals holding qualifications giving access to regulated

professions may also strengthen the resilience and accessibility of essential public services,

such as healthcare and education.145 While nearly every Member State suffers from healthcare

workforce shortages, these challenges are not uniformly distributed within the EU or within

national borders,146 reflecting different demographic, health socio-economic characteristics of

populations, as well as diversity of health and long-term care policies in place at local and

national levels. EU-wide and national averages frequently mask acute cross-country and

regional disparities, with particularly urban centres attracting talent and rural, peripheral, and

border regions facing severe shortages. As emphasised in a 2021 study by the JRC, such

territorial imbalances confirm the need for a territorial approach in workforce planning

exercises.147 Facilitating cross-border mobility allows vulnerable regions to directly access

the pattern is also consistent with a recognition/validation problem: qualifications, professional titles, sectoral

certificates or other credential-backed skills acquired in one Member State may not be immediately legible,

trusted or formally usable in another. This is especially plausible for regulated professions. 143 According to responses to the public consultation on the SPI, 36 out of 146 EU citizens responding to the

question “How did recognition of your professional qualifications affect how well your job matched your

qualifications?” indicated that difficulties related to the recognition or acceptance of their qualifications resulted

in them being overqualified for the job they ultimately obtained. This is particularly relevant for younger

workers and professionals as they are particularly exposed to “scarring effects”, where early-career

unemployment or severe underemployment permanently suppresses long-term lifetime earnings and career

progression. Furthermore, younger generations exhibit the highest propensity for geographic mobility but

possess the lowest financial buffers. High entry costs and lengthy, opaque bureaucratic processes act as a

regressive barrier that effectively prices out young, low-wealth applicants. 144 21 out of 66 EU citizens participating in the public consultation on the SPI who had undergone a recognition

procedure reported that difficulties linked to the recognition of their professional qualifications discouraged them

from moving to, or applying for, a job opportunity in another country. 145 The European Labour Authority (2024) documents shortages of specialist medical practitioners in 75% of EU

countries, generalist practitioners in 64%, and nurses in 78%. Shortages of qualified professionals in healthcare

are increasingly recognised as a constraint on service provision, system resilience and the long-term

sustainability of health systems across several MS. OECD/European Commission (2024), Health at a Glance:

Europe 2024: State of Health in the EU Cycle, OECD Publishing, Paris. 146 According to Eurostat (2024), significant disparities continue to exist across MS in the number of newly

qualified healthcare professionals entering the labour market each year. These wide variations in training output

underline the importance of efficient recognition procedures to facilitate the mobility of healthcare professionals

and help address uneven workforce availability across the EU. 147 JRC (2021) New perspectives on territorial disparities - From lonely places to places of opportunities

49

and draw upon the wider Single Market talent pool, effectively stabilizing local social

infrastructure where it is needed most.148

All three policy options contribute positively to these micro- and macro-social effects,

albeit to varying degrees depending on the nature of the regulatory intervention. PO1 is

expected to yield only marginal social benefits as it operates through non-enforceable, soft-

law instruments. Policy Option 2 delivers an intermediate impact as it introduces greater

predictability into cross-border data exchanges and shortens timelines through binding

deadlines. As demonstrated above, PO3 delivers the most substantial reductions in both

applicant-borne barriers and integration timelines. It is therefore expected to deliver the

strongest positive impact across all social dimensions outlined, most effectively translating

administrative simplification into tangible social improvement.

The impacts of the initiative are expected to vary across MS and are unlikely to be

distributed evenly across the Single Market. Both implementation costs and the magnitude of

the expected economic and social benefits will depend on a number of structural and

administrative factors, including the extent and sectoral composition of professional

regulation, the volume of intra-EU mobility involving regulated professions, the organisation

and performance of recognition procedures, including fees and processing times, and the

degree of digital maturity of public administrations and recognition systems. These factors

influence both the scale of the effort required to implement the proposed measures and the

extent to which MS may benefit from simpler, faster and more digital recognition procedures.

The main drivers of these differentiated impacts are examined in more detail in Annex 8. The

diverging territorial impact reflects the diversity of national regulatory and administrative

systems that the PQD is designed to accommodate. Facilitating recognition across such

diverse systems lies at the heart of the mutual recognition framework established by the PQD.

The initiative seeks to strengthen common pathways, interoperability and administrative

cooperation within this diverse landscape, thereby supporting the functioning of the Single

Market.

6.4. Summary overview of impacts

The table below summarises the above impacts of the three policy options, including impacts

assessed quantitatively and impacts described qualitatively.

Table 3 PO1 PO2 PO3

Direct cost impacts (EUR million) 2029-2040 (present value)

Total savings

858.5 1 143.7 1 550.9

Total costs

43.0 117.4 59.0

148 European Commission (2021b)

50

Broader economic impacts

Firm-level

competitiveness

Marginal impact on

increased recruitment

opportunities, lower

vacancy durations for

critical roles,

improved intra-firm

matching, higher

labour productivity

Moderate impact on

increased recruitment

opportunities, lower

vacancy durations for

critical roles, improved

intra-firm matching,

higher labour

productivity

Strong impact on

increased

recruitment

opportunities, lower

vacancy durations

for critical roles,

improved intra-firm

matching, higher

labour productivity

Macro-economic

benefits

Marginal impact on

reduced

overqualification,

improved allocative

efficiency and

aggregate labour

productivity as well

as labour market

resilience.

Moderate impact on

reduced

overqualification,

improved allocative

efficiency and

aggregate labour

productivity as well as

labour market

resilience.

Strong impact on

reduced

overqualification,

improved allocative

efficiency and

aggregate labour

productivity as well

as labour market

resilience.

Digitalisation -

interoperability

Marginal positive

impact

Moderate positive

impact

Strong positive

impact

Social impacts

Individual

labour market

performance

and social well-

being

Marginal impact on

employment

opportunities, upward

career mobility and

enhanced income

security.

Moderate impact on

employment

opportunities, upward

career mobility and

enhanced income

security.

Strong impact on

employment

opportunities,

upward career

mobility and

enhanced income

security.

Exercise of

fundamental

rights, equal

rights and non-

discrimination

Marginal positive

impact

Moderate positive

impact

Strong positive

impact

Resilience,

accessibility of

essential public

services

Marginal positive

impact

Moderate positive

impact

Strong positive

impact

51

7. HOW DO THE OPTIONS COMPARE?

This section evaluates the relative performance of each policy option by assessing: (i) their

effectiveness in achieving the three specific objectives of the initiative; (ii) their efficiency in

terms of the balance between savings and costs and their capacity to reduce inefficiencies in

recognition procedures; and (iii) their coherence, namely the extent to which measures remain

consistent with broader EU policy objectives, and contribute to a more coherent recognition

system across the EU. The options are scored on a scale ranging from ‘-/+’ to ‘---/+++’

relative to the baseline. A single ‘-/+’ indicates a limited effect, while ‘--/++’ and ‘---/+++’

indicate a moderate and significant effect respectively.149

7.1. Effectiveness

The effectiveness of the policy options is assessed against the three specific objectives of the

initiative. For SO1, the comparison focuses on the extent to which the policy options improve

the clarity, accessibility and user-friendliness of information, ensure greater consistency

between national and EU-level information sources, and reduce incomplete applications and

unnecessary exchanges between applicants and CAs during the preparation and submission of

applications. For SO2, the assessment considers the extent to which the policy options

increase digitalisation, reduce administrative burden and simplify procedures. For SO3 the

comparison examines improvements in the timeliness and quality of administrative

cooperation, the use of interoperable digital tools, and the consistency of implementation

across MS.150

PO1 remains closest to the baseline, relying exclusively on non-legislative measures to

promote a more consistent interpretation and application of the existing provisions without

amending them (+). PO2 introduces targeted legislative amendments limited to those

necessary to support interoperability and the digitalisation of procedures across MS,

complemented by non-legislative measures (++). PO3 goes further by introducing a broader

set of legislative changes and supporting them with operational tools designed to promote

consistent implementation across MS (+++). As a result, the expected effectiveness increases

progressively from PO1 to PO3.151

Table 4 - Comparison of Policy Options – Effectiveness PO1 PO2 PO3

Ensure complete, clear and aligned information on qualification

requirements and recognition procedures+ ++ +++

Make recognition procedures faster, easier and less burdensome+ ++ +++

149 The analysis below is further supported by additional explanations in Annex 15. 150 Cf. Annex 16 on measures of success under each of the specific objectives. 151 At the same time, as the initiative would remain based on a Directive, MS would continue to retain a degree

of flexibility as regards the means used to achieve the envisaged objectives.

52

Table 4 - Comparison of Policy Options – Effectiveness PO1 PO2 PO3

Improve cooperation and communication among CAs + ++ +++

7.2. Efficiency

The assessment of efficiency examines two aspects. First, it considers the relationship

between the expected benefits and costs of each option, as presented in Section 6.1. Second, it

assesses improvements to the efficiency of recognition procedures as such.152

Compared to the baseline, PO1 generates the lowest benefits but also entails low costs (++).

PO2 delivers greater benefits, but also requires higher implementation costs (+). PO3 is

expected to generate the highest ratio benefits/costs compared to the baseline (+++). As

regards the efficiency of recognition procedures as such, PO1 remains closest to the baseline

and is therefore expected to deliver only limited improvements (+). PO2 introduces targeted

procedural changes that improve efficiency in specific areas. However, as MS would need to

adapt solutions individually, implementation may remain uneven, limiting efficiency gains

(++). PO3 goes furthest by combining more comprehensive legislative changes with

supporting tools that facilitate implementation and administrative cooperation. Although

achieving these efficiency gains would entail certain administrative burdens and obligations,

these are expected to be offset in both the short and longer term (+++).

Table 5 – Comparison of Policy Options - Efficiency PO1 PO2 PO3

Benefits-costs ratio153 ++ + +++

Less inefficiences in recognition procedures (faster, simpler) + ++ +++

7.3. Coherence

The assessment of coherence examines: first, the coherence of the policy options with other

relevant EU initiatives and broader Union objectives, including digitalisation, interoperability,

administrative simplification, labour mobility and the functioning of the Single Market, and,

second, the extent to which each policy option contributes to a more aligned, coordinated and

integrated recognition system across MS, including through greater consistency between

152 This covers the extent to which the options are expected to reduce reliance on paper-based procedures,

increase digitalisation and interoperability, shorten procedures, reduce unnecessary administrative steps and

exchanges, and improve the efficiency of communication between applicants and CAs, and among CAs across

MS. 153Calculated as the ratio of benefits to costs, obtained by dividing the estimated total benefits by the estimated

total costs. This is 20 for PO1, 9.7 for PO2, 26.3 for PO3.

53

national systems, stronger interoperability of tools and procedures, and more coherent

cooperation between CAs and the Commission.

Compared to the baseline, policy options differ in the extent to which they support broader

EU objectives, notably simplification, digitalisation and administrative cooperation. PO1 is

expected to make only a limited contribution through encouraging a more convergent

interpretation and application of the existing framework (+). PO2 contributes more directly to

these objectives through targeted measures supporting interoperability and information

exchange (++). PO3 provides the strongest support by promoting a comprehensive digital and

simplified approach to recognition procedures and administrative cooperation (+++).

As explained above under 5.2.3, the preferred option is coherent with the Union's broader

digital policy framework because it builds on existing EU instruments rather than creating a

parallel system. It is designed as a modular extension of the IMI system, reusing its

governance, user base and administrative cooperation processes while extending its

functionality to support the complete recognition workflow across all regulated professions. It

also builds on the experience gained through the EPC, replacing its profession-specific

approach with a single, scalable solution applicable across professions. At the same time, the

proposal creates synergies with the EUDI Wallet, digital credentials under the SPI, and the

SDG-OOTS. These tools are integrated where available, but their use is introduced

progressively and without creating dependencies that could delay implementation. Where

digital building blocks are not yet fully deployed, applicants will continue to be able to submit

evidence themselves, authorities will continue to exchange information through IMI, and

paper credentials will remain valid. This phased and interoperable approach ensures

coherence with the Union's digital agenda while remaining proportionate and operationally

realistic, avoiding duplication of existing systems and ensuring that implementation does not

depend on the simultaneous maturity of all related initiatives.

The options also differ in their ability to increase coherence across recognition systems in the

EU. PO1 is expected to bring only limited improvements compared to the baseline (+). PO2

would strengthen coherence by introducing common interoperability requirements and

improving exchanges between CAs (++). PO3 is expected to have the greatest impact, as the

European Digital Recognition System would support a more consistent implementation of

recognition procedures across MS and enhance coherence throughout the system (+++).

Table 6 – Comparison of Policy Options - Coherence PO1 PO2 PO3

Coherence with other EU initiatives and broader objectives + ++ +++

Aligned, coordinated and integrated recognition across MS + ++ +++

54

7.4. Comparative overview

The table below presents an overview of the comparison of the policy options on the basis of

the criteria of effectiveness, efficiency and coherence.154 As shown below, PO3 scores highest

overall across these criteria. The assessment of proportionality also confirms that all three

policy options would remain proportionate, each within the scope and level of intervention

envisaged.

Table 7 – Comparison of the three policy options PO1 PO2 PO3

Effectiveness + ++ +++

Efficiency ++ ++ +++

Coherence + ++ +++

8. PREFERRED OPTION

8.1. Option 3: Unified EU workflow and enhanced enforcement

From the ranking and comparison of POs, PO3 stands as more effective, efficient and

coherent than PO2 and PO1. PO3 comprises the most comprehensive set of binding

legislative measures, combined with enforcement tools, and is therefore expected to deliver

the objectives of the initiative in the most effective manner. As regards efficiency, PO3 is

expected to generate the highest cost savings while keeping implementation costs much

lower. It is designed as the most far-reaching simplification option and is estimated to

alleviate around 40% of the burden currently associated with recognition procedures. Overall,

it is expected to deliver cumulative cost savings of approximately EUR 1.6 billion by 2040.

By centralising European digital resources and solutions, the approach ensures that key

development costs are incurred only once at EU level, rather than separately by all 27 MS. In

this way, it helps keep the main implementation costs linked to the creation of the European

Digital Recognition System as low as possible. As regards coherence, this option ensures the

strongest mutual reinforcement between measures, while also providing the highest level of

alignment with broader EU initiatives and priorities on digitalisation, simplification,

portability of skills, and the deepening and more effective functioning of the Single Market.

In terms of EU added value, the preferred PO3 delivers the greatest benefits through the

establishment of the European Digital Recognition System as a common framework for

recognition procedures across the Union. A single EU framework avoids duplication of

154 Proportionality has also been a key consideration. It was applied as a knock-out criterion during the screening

of the initial long list of measures (cf. Annex 12), ensuring that measures appearing disproportionate to their

likely benefits were discarded at an early stage. Consequently, all measures retained and subsequently combined

into policy options were considered proportionate to the problems identified and the objectives pursued. Cf;

Annex 15.

55

investments, reduces fragmentation, promotes interoperability and generates economies of

scale, while ensuring a more consistent and efficient recognition process across Member

States. The preferred option complies with the principle of proportionality, as it does not go

beyond what is necessary to achieve the objectives pursued. While the proposal introduces

targeted amendments to Directive 2005/36/EC to address persistent shortcomings identified

through its implementation, these measures are limited to improving the procedural

functioning of the recognition framework, including the provision of information, the

organisation of recognition procedures, administrative cooperation and the use of

interoperable digital tools. The proposal does not harmonise the substantive rules governing

regulated professions or the conditions for the recognition of professional qualifications.

Member States remain fully responsible for regulating professions, determining qualification

requirements, assessing applications and taking recognition decisions. The preferred option

provides the most effective response to the identified problems while maintaining an

appropriate balance between the expected benefits and the implementation effort required.

Although it entails a greater degree of intervention than the alternative options, this is justified

by the scale and persistence of the identified shortcomings and remains confined to

procedural aspects of the framework, fully respecting Member States' competences over

substantive recognition decisions.

As regards practical implementation, challenges may arise, but these are expected to be

manageable, as the preferred option has been specifically designed to overcome the principal

shortcomings of the current framework. As explained above, the identified problem drivers

include both issues of design and issues of implementation, with special focus on the former.

Design issues arise where the current Directive misses common elements that are

instrumental for the effective functioning of the recognition system and where the existing

measures do not guarantee that the recognition procedures will fully benefit from

technological progress and digital developments. Accordingly, the preferred option addresses

design issues by completing the architecture of the PQD with common elements that are

currently missing. The cornerstone of this approach is the European Digital Recognition

Solution, which establishes a mandatory common digital workflow for recognition procedures

across the Union. By replacing fragmented national solutions with a single interoperable

system spanning the entire recognition procedure, from the preparation of applications to the

issuance of recognition decisions, the preferred option streamlines workflows, reduces

incomplete applications and repetitive exchanges, limits unnecessary procedural iterations and

duplication of work, creates economies of scale and provides a common operational

framework for competent authorities. The system will be developed and financed by the

Commission, thereby reducing implementation costs for Member States while supporting

authorities with AI-assisted functionalities (e.g. automated translation with confidence score)

throughout the recognition process.155 The preferred provides authorities with common tools

155 The feasibility of integrating AI-assisted functionalities is supported by the findings of a Commission study

on the analysis of digital solutions for recognition processes and the AI proof of concept. The study

demonstrated that AI can effectively support several stages of the recognition workflow, including the translation

of documents, document classification, the assessment of document authenticity and integrity, and the analysis of

the content of supporting evidence against the applicable legal and procedural requirements. These findings

indicate that AI can substantially reduce administrative workload and improve the speed and consistency of

56

and infrastructure rather than relying solely on national solutions. The European Digital

Recognition Solution reduces administrative burdens and manual processing, allowing scarce

administrative resources to be used more efficiently. The preferred option further strengthens

the design of the framework by integrating into the recognition process interoperable digital

credentials for qualifications under the automatic system. It establishes that these credentials

constitute trusted evidence of the qualifications they certify, thereby limiting the possibility

for competent authorities to request additional documentation and reinforcing trust within the

automatic recognition system.

On the other hand, the preferred option strengthens the implementation of the existing

legal framework by making its requirements clearer, more operational and easier to

apply consistently across Member States156. It specifies in greater detail the information

that Member States must provide on recognition procedures and ensures that this information

is kept up to date through interoperability with the Regulated Professions Database. It clarifies

which documents may be requested, establishes common principles governing recognition

fees and introduces binding deadlines for the individual stages of recognition procedures as

well as for administrative cooperation between competent authorities. By translating general

obligations into more operational rules, these measures reduce uncertainty and facilitate more

uniform implementation across the Union.

The preferred option further reinforces implementation through supporting measures.

Regular training for competent authorities and a more structured framework for cooperation

within the Group of Coordinators on Professional Qualifications will help competent

authorities apply the Directive more consistently and identify implementation challenges at an

earlier stage. The annual work programme of the Group of Coordinators157 and its subgroups

will provide a more systematic framework for monitoring implementation, exchanging good

practices and preparing future developments of the recognition system. Additional mitigation

measures could include transitional implementation periods, targeted capacity-building

support, EU financial support for digital transformation where appropriate, and the

progressive deployment of interoperable digital tools.

Taken together, the preferred option addresses both the structural and the practical causes of

the identified problems. By introducing common elements that are currently missing from the

Directive while making existing rules more precise and providing competent authorities with

better tools, clearer rules, more structured procedures and stronger support, it is expected to

improve the consistency, efficiency and reliability of the implementation of the Professional

Qualifications Directive.

recognition procedures, while leaving the final assessment and recognition decision entirely with the competent

authority. 156 The main advantage of the European Digital Recognition Solution is that it should be applied consistently

among Member States. In other words, it aims to ensure that all recognition procedures can benefit from and

integrate other common EU digital developments such as EU Digital Identity Wallet, thereby reducing the risk of

uneven implementation. 157 The Group of Coordinators is an expert group bringing together the national coordinators designated by MS

under the PQD for matters related to the recognition of professional qualifications. It serves as a forum for

cooperation, exchange of experience and discussion of implementation issues arising under the Directive.

57

The transition towards a more digital and, under PO3, largely “digital-only” recognition

environment may create risks of digital exclusion for certain categories of applicants,

including older professionals or applicants with limited digital skills or access to digital

infrastructure. While the initiative aims to simplify and accelerate procedures, the move

towards digital procedures would create obligations for CAs rather than applicants.

Applicants would remain free to submit supporting documents in paper form. However, those

choosing to submit documents digitally would benefit from faster processing and reduced

administrative. Where applicants are unable to create or submit a digital application

themselves, CA could provide assistance and, where necessary, create the digital application

on their behalf. Similarly, the introduction of binding deadlines would not create additional

obligations for applicants. These deadlines would apply to CAs and their cooperation with

each other, ensuring that procedures are completed more quickly and predictably for the

benefit of applicants. The Commission would support implementation through guidance and

training for CAs using the digital tools, while applicants would benefit from digital guidance

tools such as pilot AI chatbots. The gradual implementation timeline, including the

transposition period for MS and the time foreseen for the development of the European

Digital Recognition System by the Commission, would provide sufficient time for MS, CAs

and the Commission to prepare, coordinate and put the necessary support arrangements in

place.

Moreover, stakeholders may express concerns that a greater reliance on digital tools could

increase digital security and reliability risks. However, the initiative is expected to mitigate

rather than exacerbate these risks. The use of verifiable digital credentials would make

documents significantly more secure and more difficult to forge than paper-based documents,

thereby increasing the reliability of the information exchanged in recognition procedures and

strengthening trust among competent authorities. Furthermore, as artificial intelligence is

increasingly being used in administrative processes, embedding AI-assisted functionalities

within a common European framework would help ensure their transparent, coordinated and

consistent use across MS. This would reduce the risks associated with fragmented national

approaches, divergent outcomes and inconsistent quality standards, while promoting greater

legal certainty, reliability and mutual trust in recognition procedures.

The implementation of the preferred option will require efforts from Member States and

competent authorities, particularly to adapt existing procedures, working methods and digital

systems. Some challenges may be greater for authorities with more limited administrative

capacity or lower levels of digital maturity.158 Nevertheless, we expect that these challenges

will be manageable and that the authorities concerned will be broadly supportive of the

proposed measures. The preferred option was designed on the basis of stakeholder feedback

and is composed primarily of measures that national coordinators and competent authorities—

the actors responsible for implementing the Directive—identified as among the most effective

158 Cf. Annex 14.

58

responses to the problems encountered in practice.159 These results provide confidence that,

although implementation will require adaptation and sustained effort, the preferred option is

closely aligned with the practical needs and assessments of the authorities that will be

responsible for applying it. In addition, the use of a common EU-level solution will reduce the

need for Member States to develop and maintain separate national systems, thereby limiting

national implementation costs and technical burdens while ensuring interoperability and a

more consistent approach across the Union.

8.2. REFIT (simplification and improved efficiency)

The initiative is expected to contribute significantly to simplification and efficiency by

directly addressing procedural complexities and inefficiencies identified as part of the

problem definition. The measures proposed under the initiative are specifically designed to

reduce these inefficiencies. By definition, measures such as reducing paper-based procedures,

promoting interoperable digital credentials, reducing documentary requirements, accelerating

exchanges between CAs and strengthening digital workflows are expected to simplify

procedures, reduce waiting times and lower administrative and compliance costs. More

complete and standardised information is expected to reduce the number of incomplete or

incorrect applications and limit the need for clarification exchanges. This would reduce the

time and effort required for applicants to understand requirements and prepare applications,

while reducing rework associated with incomplete applications for CAs and improving

processing workflows. For professionals, simplified and standardised procedures, together

with the reduction and standardisation of documentation requirements and clearer and more

predictable procedures, are expected to reduce both the time and costs associated with

preparing and submitting applications, as well as broader compliance costs linked to

recognition procedures.160 The combination of harmonised procedures, mandatory digital

workflows and fully digital processes is also expected to significantly reduce administrative

effort per case and streamline case handling. More structured and predictable cooperation

mechanisms are expected to reduce repeated exchanges, incomplete requests and processing

159 For example, in a focus group with national coordinators on professional qualifications, 16 out of 17

respondents ranked support to Member States in providing information among the most effective measures for

reducing incomplete applications. Minimum content requirements for information provided at national level

were selected by 13 out of 17 respondents, while 11 out of 17 identified guidance and peer review of national

portals as particularly effective. These measures are reflected in the preferred option. Measures aimed at

reducing processing times also received strong support. Electronic-by-default recognition procedures were

ranked among the most effective measures by 17 out of 19 respondents, while 14 out of 19 selected an AI-

assisted workflow system and 9 out of 19 selected shortened deadlines combined with the use of digital

credentials. In relation to administrative cooperation, 11 out of 19 respondents ranked online recognition

procedures supported by an AI-assisted workflow system among the most effective measures for reducing

delays. All these measures form part of the preferred option. 160 Stakeholder evidence supports these expected benefits. Survey results with citizens indicate that fully

digitalising recognition procedures would primarily lead to shorter processing times (65%), followed by reduced

administrative burden (56%), greater efficiency (50%) and lower costs (48%). Cf. study supporting this impact

assessment.

59

delays.161 For employers, more efficient and predictable recognition procedures are expected

to facilitate faster recruitment processes, improve workforce planning and reduce delays

in accessing qualified professionals, particularly in sectors facing labour shortages. Unlike

more voluntary approaches, PO3 ensures uniform application and maximises efficiency gains

through mandatory and integrated measures across the Union. At the same time, these

expected simplification and efficiency gains are accompanied by significant upfront

implementation costs. The introduction of harmonised systems, digital workflows and fully

digital processes will require investment in IT systems and infrastructure, staff training and

organisational adjustments. As a result, PO3 may initially lead to increased administrative

costs during the transition phase. Over time, however, these costs are expected to be offset by

efficiency gains and reductions in administrative effort per case, leading to a more coherent,

predictable and efficient recognition system across the Union.

8.3. Application of the ‘one in, one out’ approach

This initiative falls within the scope of the One-In-One-Out (OIOO) approach as it constitutes

a revision of an existing EU instrument (Directive 2005/36/EC). PO3 contributes to the

administrative burden reduction target by delivering aggregate annual administrative cost

savings of approximately EUR 27.2 million, corresponding to a reduction of around 40% of

the EUR 67.8 million baseline annual administrative burden. The main instrument carrying

this reduction is the harmonisation and digitalisation of recognition procedures. The full

quantification is developed above under Section 6.1 and also summarised below in Table III

in Annex III.

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?

Monitoring would focus on indicators measuring the extent to which the initiative succeeds in

simplifying and making less costly and burdensome the preparation and processing of

recognition applications, including cooperation between CAs. The Commission would carry

out such monitoring in close cooperation with national coordinators and CAs in the MS.

Monitoring would rely on two sources. First, MS would provide information through national

reporting coordinated by the national coordinators designated under the PQD. Such reporting

would take place every two years and would cover indicators that cannot be automatically

generated through digital systems. Second, data would be retrieved annually from the

digital tools supporting the implementation of the initiative, including the European Digital

Recognition System and other relevant systems and databases.

For monitoring purposes, 2029 would constitute the baseline year, as this is the first year in

which the benefits of the initiative are expected to start materialising following the

deployment of the European Digital Recognition System during 2027 and 2028. To establish

a robust pre-implementation benchmark, a first collection of monitoring data would take place

in 2028. A second wave of data collection would then take place in 2029 for indicators to be

161 CAsimilarly identified shorter processing times (54%), lower costs and reduced administrative burden (both

49%) and significant staff efficiency gains (28%) as the main expected benefits of digitalisation, suggesting that

digitalisation primarily improves speed and procedural simplicity rather than reducing staffing needs.

60

collected annually and in 2030 for indicators subject to biennial reporting, allowing an initial

comparison between the situation before and after implementation. This approach would

ensure the availability of meaningful evidence on the effects of the initiative and support a

comprehensive evaluation approximately five years after the expiry of the transposition

deadline.

Progress towards Specific Objective 1 will be monitored through indicators measuring the

completeness and consistency of information provided on regulation of professions and

recognition of qualifications, the share of incomplete or incorrectly prepared applications

attributable to information gaps, and user satisfaction with the clarity and accessibility of

information. Progress towards Specific Objective 2 will be monitored through indicators

measuring the average processing time of recognition procedures, the average number of

documents, translations and certifications requested per application, the administrative effort

required to process an application, and the share of applications completed within the

prescribed deadlines. Progress towards Specific Objective 3 will be monitored through

indicators measuring the average response time to administrative cooperation requests, the

average number of information requests and confirmation exchanges per recognition case, and

the satisfaction of competent authorities with the quality and usefulness of the responses

received.

A more detailed presentation of the monitoring indicators, sources and collection methods is

provided in Annex 16.

61

ANNEX 1: PROCEDURAL INFORMATION

1. Lead DG, Decide Planning/CWP references

DG for Employment, Social Affairs and Inclusion (DG EMPL). PLAN/2025/2645: Fair

labour mobility package / Skills Portability 2: modernise and expand recognition processes

for regulated professions - Potential measures to facilitate, modernise and expand recognition

processes for EU citizens to access regulated professions, action under the Skills Portability

Initiative. Commission work programme 2026, Supporting people, strengthening our societies

and our social model - 25: Skills and fair labour mobility – Fair labour mobility package

2. Organisation and timing

The consultation and evidence-gathering activities build on earlier work carried out in the

context of the 2020–2024 implementation report on Directive 2005/36/EC and were further

developed through more recent exercises conducted under the Skills Portability Initiative.

These included the public consultation and call for evidence carried out between November

2025 and February 2026, complemented by desk research and data analysis undertaken by

DG EMPL and by the contractor responsible for preparing the study supporting the present

impact assessment.

The contract for the study supporting the impact assessment of Directive 2005/36/EC started

in October 2025 and had a duration of fifteen months. The contractor submitted the final

report supporting the impact assessment, focusing on the SPI-related aspects of the Directive,

in May 2026 for the purposes of the scrutiny process by the Regulatory Scrutiny Board.

An Inter-service Steering Group (ISG) was established by the Secretariat-General to support

the preparation of the initiative as part of the broader SPI package. Representatives from the

following Directorates-General and services participated in the ISG: EAC, ECFIN, ENV,

GROW, HOME, REGIO, RTD, SANTE, TRADE, the Secretariat-General and the Legal

Service.

3. Consultation of the RSB

The draft IA was submitted to the Regulatory Scrutiny Board (RSB) on 17 June and discussed

at a hearing on 15 July, following the submission of written replies to the RSB checklist and

technical comments received in advance of the hearing. The RSB subsequently issued a

positive opinion with reservations. The IA was subsequently revised to address the

recommendations set out in the RSB opinion, while also taking into account the technical

comments provided by the Board in the course of the scrutiny process. The table below

summarises the RSB’s main recommendations and the corresponding updates made to the IA

to address them.

Main recommendations for improvement Modifications in the IA report

Clarify what constitutes (a) a professional

qualification, (b) ‘automatic recognition’ and

how the process under the PQD applies to it

for cross-border purposes, and (c) ‘regulated

Chapter 1.3 on skills portability and regulated

professions has been essentially rewritten.

The socio-economic importance of regulated

professions, the rationale for regulating

62

professions covered by other recognition

systems’. Provide indicative examples of

respective professions and explain to what

extent the scope of the initiative covers

activities in the areas of craft, commerce and

industry, and professionals willing to provide

services in another Member State on a

temporary or occasional basis. Explain to

what extent it excludes professions covered

by other EU legislation and, if so, which

ones.

access to professions and its links to labour

and skills shortages, the role of the

Professional Qualifications Directive within

this framework, and its interaction with other

relevant legal instruments are now explained

more clearly.

The introduction to the problem definition

has been substantially revised, with the

recognition of professional qualifications now

positioned within the broader context of

labour mobility.

Explain to what extent the findings of the

2011 PQD evaluation differ from those of the

2020-2024 PQD implementation report.

Explain what measures were taken since 2011

to address those shortcomings. Discuss the

extent to which the PQD has been effective in

reaching its objectives. Analyse the root

causes of the identified problems. Provide a

more granular analysis of the regulated

professions, the barriers hampering their

mobility as well as assess the link related to

obstacles with qualifications and their

economic importance, using more recent data

as far as possible.

Part of the modifications described just above

are also relevant for this recommendation.

Additionally, Section 2.1 has been

substantially expanded by introducing a

chronological overview of the problems

identified since the 2011 evaluation of the

Directive. The assessments made at different

stages are now presented, followed by an

explanation of how the remaining

inefficiencies stem from several interrelated

causes.

In Section 2.2, a clearer distinction has been

introduced between issues relating to the

design of the existing framework and issues

arising from its implementation.

A more dynamic dimension has been added

to the description of the baseline in Section

5.1.

Describe better the measures. Explain the

proposed digital solution and what is going to

be part of the solution. Explain better to what

extent this initiative aims replacing the

respective national IT systems, how the

integration with national systems will be

ensured, and who will be responsible for

different parts of the digital solution. Clarify

who is responsible for the infrastructure and

operation of the solution. Explain what

interoperability is needed and how it will be

ensured.

In Section 5.2, the package of measures

considered under each policy option is now

presented more clearly.

In Section 5.2.3, the description of the

European Digital Recognition Solution has

been substantially elaborated, with its design,

operation and coherence with other relevant

tools and initiatives explained in greater

detail.

Better analyse the coherence with other Part of the modifications described just above

63

initiatives, further explain to what extent this

initiative uses the same IT elements as SPI

Action 1 and the possible synergies, risks or

unintended consequences that could arise

from its implementation. Analyse how Action

2 will interact with SPI Action 3 on third-

country nationals.

are also relevant for this recommendation.

In Section 7, the coherence of the initiative

with other relevant digital policy initiatives is

now explained more clearly.

The annex presenting the combined impacts

of the preferred options under Actions 1, 2

and 3 has been updated.

Explain in more detail how the practical

implementation of the preferred option would

take place. Explain how the preferred option

would be practically feasible.

In Section 2.2, a clearer distinction has been

introduced between issues relating to the

design of the existing framework and issues

arising from its implementation.

In Section 8 on the preferred option, the

explanation of its added value and

proportionality has been substantially

strengthened. In particular, it is now

explained more clearly how foreseeable

practical implementation challenges have

been anticipated and addressed through the

proposed package of measures, and why

broad stakeholder uptake of the proposed

approach can be expected.

Technical comments on estimation and

presentation of costs and savings

In the assessment of impacts, the

methodology used to estimate the expected

increase in the volume of recognition

procedures is explained more clearly. The

presentation of administrative cost savings

has been restructured, while the analysis of

employer savings has been substantially

rewritten to improve its clarity and the

underlying assumptions have been explained

more transparently.

As regards implementation costs, the

differences between the options have been

clarified and the overall presentation has been

improved.

In Annex 4 on analytical methods, a more

detailed explanation of the methodology used

to estimate costs for competent authorities

has been provided. The methodology for

monetising time savings has also been

clarified, and the analysis has been reinforced

through a sensitivity analysis, given that

64

monetised time savings represent the largest

component of the estimated benefits.

4. Evidence, sources and quality

The impact assessment draws on multiple sources of evidence and expertise, as detailed in

Annexes 2, 4 and 17 to the present report. These include, in particular, evidence collected by

the Commission services in the context of the 2020–2024 implementation report on Directive

2005/36/EC, as well as consultation and research activities carried out by the contractor

responsible for the supporting study. The Commission Expert Group on the Recognition of

Professional Qualifications was closely involved throughout the consultation process.

65

ANNEX 2: STAKEHOLDER CONSULTATION

The preparation of this initiative was supported by a broad evidence-gathering and

consultation process. This included data collected in the context of the implementation report

on Directive 2005/36/EC, targeted consultation activities carried out by DG EMPL, the public

consultation launched by the Commission, as well as additional stakeholder consultation

activities conducted by the external contractor supporting this IA.

1. Analysis of data collected for the report on the implementation of the PQD

The drafting of this IA has benefited extensively from data collected by DG EMPL, including

in cooperation with DG GROW, in the context of the preparation of the report on the

implementation of the PQD covering the years 2020–2024. The report and the accompanying

Staff Working Document were published in February 2026162 and have been extensively

referenced above. Those documents describe in detail how stakeholders’ views contributed to

identifying the main shortcomings in the implementation of the PQD and, subsequently, to

shaping the present initiative.

2. Targeted consultations carried out in the context of the SPI

In parallel to the work carried out with the contractor and the use of data and findings from

the implementation report to shape the problem analysis, DG EMPL also conducted targeted

stakeholder consultation activities as shown below. These proved particularly useful in

validating the different dimensions of the problem and gathering views and suggestions from

professionals and public authorities in the MS regarding possible solutions.

Date Title of meeting/event

19 May 2025 Portability of Skills in Cross-Border Regions (ISG consultation input)

3 July 2025 Meeting with Standing Committee of European Doctors (CPME)

2 October 2025 Meeting with EurHeCA (European Health Professionals’ Competent

Authorities)

6 November 2025 Targeted Consultation – EU Youth Stakeholders

14 November

2025 Regular Network Meeting – Adult Learning Coordinators

18 November

2025 Regular Network Meeting – VET Providers

18 November

2025 European Federation of Nurses

19 November

2025 General Assembly - Pharmaceutical Group of the EU (PGEU)

25 November

2025 Meeting – Validation and Recognition Working Group

162 EU facilitates skills portability for over 185 000 professionals - Employment, Social Affairs and Inclusion

66

Date Title of meeting/event

27 November

2025 Meeting – Geodesks

3 December 2025 Meeting – Eurochambres Skills Committee

4 December 2025 Group of Coordinators for Professional Recognition

5 December 2025 Youth Guarantee Coordinators

11 December 2025 Annual NARIC Meeting

16 December 2025 EQF AG

13 January 2026 Dedicated Meeting – National Europass Centres

14 January 2026 Dedicated Meeting – ESCO and National Classifications Experts

16 January 2026 Dedicated Meeting – REGIO / EURES Cross-Border Regions

Stakeholders

20 January 2026 Targeted Consultation – Public Employment Services (PES Network)

23 January 2026 Targeted Consultation – Social Partners (Hearing)

27 January 2026 Targeted Consultation – Cross-Border EURES Projects

28 January 2026 Consultation – ENIC-NARIC Network

28 January 2026 Dedicated Meeting – EURES National Coordination Offices

29 January 2026 Targeted Consultation – VET Stakeholders (ACVT / DGVT)

6 March 2026 European network of competent authorities for architects (ENACA) -

conference

12 March 2026 Group of Coordinators for Professional Recognition

3. SPI public consultation (questionnaire and call for evidence)

The public consultation on the SPI, conducted between December 2025 and February 2026,

gathered views from a wide range of stakeholders on the portability of skills and

qualifications within the EU. The consultation aimed to identify the main challenges faced by

individuals and employers when using qualifications across borders, collect evidence on

experiences with recognition procedures and skills validation (including their effectiveness

and usability), and explore key obstacles to labour mobility linked to recognition issues. It

also sought to identify opportunities to improve mobility through more effective recognition,

validation and use of skills.

A total of responses were received from diverse stakeholder groups, including EU citizens

(336 – of whom 66 had undergone recognition of their professional qualifications in another

Member State), non-EU citizens (143), public authorities (81), academic and research

institutions (44), NGOs (43), business associations (41), companies (29), trade unions (11)

and other stakeholders (56). The input collected through this consultation has informed the

problem definition, supported the development of policy options, and contributed to the

assessment of impacts, in particular with regard to targeted aspects of the Professional

Qualifications Directive. The key points emerging from the public consultation are

67

summarised below. They broadly confirm the findings identified through the other

stakeholder consultation activities:

• Persistent barriers to skills portability. Respondents consistently identify lengthy,

complex and costly recognition procedures as one of the most significant obstacle to

skills portability in the EU (524 out of 785 total respondents).

• Fragmented and unclear information environment to guide recognition processes.

Information on recognition requirements is dispersed across multiple national and EU

sources, with no single authoritative entry point. EU citizens report unclear, incomplete

or missing information on procedures, CA, documentation requirements and expected

outcomes (36 out of 157 respondents to the relevant question), increasing the likelihood

of delays and failed applications.

• Insufficient access to guidance and support during recognition procedures. Only half

of applicants report having had access to support during recognition procedures (33 our

of 66 respondents – EU citizens having applied for recognition of professional

qualifications), while support is often considered limited or ineffective. The absence of

coordinated guidance and case management exacerbates administrative burden,

particularly for individual applicants, SMEs and early-career professionals.

• Excessive timeframes and high, uneven costs. Recognition procedures frequently last

months and, in some cases, years, thus often exceeding statutory deadlines (cf. Chapter 2

above). Applicants face significant and unpredictable costs related to fees, translations

and certifications, creating strong deterrents to mobility and reinforcing inequalities in

access to recognition (cf. Chapter 2 above).

• Need for better integration and interoperability. Stakeholders overwhelmingly

identify the creation of an EU-wide interoperable system for qualifications and skills as

the main solution to improve skills portability (404 out of 642 respondents). The priority

is not to multiply tools, but to ensure interoperability, reuse and trust across existing EU

and national systems.

• Digital credentials as a priority. Verifiable digital credentials are widely seen as a key

enabler of skills portability, provided they are trusted, legally meaningful and integrated

into established recognition frameworks, notably the PQD (they are considered very

important by 264 and important by 121 out of 449 respondents). Digitalisation is

expected to support faster verification, reduced duplication and greater transparency, but

not to replace substantive assessment by CA, especially in regulated professions.

• Simplification and digitalisation of recognition procedures. Respondents (n=642)

prioritise practical digital solutions that streamline administrative procedures, including

single online portals for the submission and tracking of applications (469 respondents),

automated document verification (372 respondents), certified and automated translations

(372 respondents), and digital pre-screening to determine whether recognition is required

(212 respondents). These solutions aim to reduce duplication, delays and uncertainty for

both applicants and employers.

68

• The recognition process can have significant consequences for the professional

opportunities and mobility of applicants. Among the 66 EU citizens who had

undergone a recognition procedure, 17 respondents reported accepting a job below their

qualification level, indicating a skills mismatch. Thirteen respondents stated that the

process encouraged them to resume studies or training in order to meet recognition

requirements. 12 respondents obtained a job opportunity matching or exceeding their

qualification level, while another 12 respondents reported having missed a job

opportunity as a result of the recognition process. 11 respondents indicated that they had

started working in a different field, and 10 respondents reported delays in starting a new

job. In addition, 9 respondents stated that the outcome discouraged them from moving to

or applying for a job opportunity in another country, while 2 respondents indicated that

the process ultimately led them to leave the EU and migrate elsewhere. Stakeholders

consistently associate delayed, partial or failed recognition with significant skills waste,

as professionals are compelled to accept underqualified roles or work outside their field

while procedures are pending, even in sectors experiencing acute labour shortages.

The call for evidence feeding into the public consultation confirms that qualification

recognition systems in the EU remain fragmented, lengthy and unpredictable, generating

significant barriers to labour mobility and skills portability. Stakeholders consistently report

that limited trust in foreign qualifications, divergent scopes of practice across MS, and

assessment practices centred on diplomas constrain both employer recruitment

decisions and individual career progression. These challenges translate into delayed labour

market entry, skills waste, downgraded employment outcomes and missed job opportunities,

with disproportionate effects on SMEs, early-career professionals and sectors characterised by

high regulatory or safety requirements. Employers, in particular, underline legal and

operational risks linked to uncertainty over professional status, good standing and timelines,

which discourages cross-border hiring even in contexts of labour shortages.

Evidence also highlights persistent structural weaknesses in recognition procedures

themselves, which frequently exceed PQD deadlines and impose high direct and indirect

costs related to fees, translations, compensatory measures and income loss during

prolonged procedures. Fragmented information landscapes and the lack of a single

authoritative entry point further exacerbate uncertainty for applicants and employers, leading

to inappropriate applications, procedural duplication and administrative fatigue. These

shortcomings undermine confidence in the practical enforceability of free movement rights

and generate spill-over effects for employers through delayed onboarding, disrupted

workforce planning and increased reliance on interim labour solutions.

Finally, contributors show strong support for EU-level action to address these challenges,

provided it builds on existing legal and administrative frameworks rather than creating

parallel mechanisms. Stakeholders broadly endorse better integration, interoperability and

operational use of EU transparency tools such as the EQF, Europass, ESCO and the

SDG, alongside clearer, more intelligible qualification information. While digital and

verifiable credentials are viewed positively in principle, their uptake is conditional on clear

legal value, robust governance, and full embedding into established recognition procedures.

Across stakeholder groups, there is a consistent call for proportionate, profession-specific

solutions that improve predictability and trust while safeguarding professional standards,

liability frameworks and public interest objectives.

69

4. Stakeholder consultations carried out for the supporting study

As part of the evidence-gathering for this impact assessment, a range of targeted consultation

activities was carried out by the contractor to collect additional input from key stakeholders.

These activities aimed to refine the problem definition, inform the design of policy measures,

and assess their potential impacts. They comprised strategic interviews, a consultation

workshop, focus groups, and surveys, as outlined below.

Strategic interviews were conducted to refine the scope of the analysis and gather additional

evidence on the SPI, the PQD, key issues affecting recognition procedures, and possible

adjustments suggested by stakeholders. In total, 8 interviews were carried out with 10

Commission staff members from DG EMPL, DG GROW and DG SANTE. A consultation

workshop was organised to discuss and further develop the problem definition. The

workshop took place in February 2026 and brought together 39 participants, including

members of the GoC and National ACs. Two focus groups were organised to collect

stakeholder feedback on the expected impacts of the preliminary policy measures designed to

address the identified problems in recognition processes. The first focus group took place in

February 2026 with EU-level representative organisations of the seven sectoral professions

benefiting from automatic recognition based on minimum training requirements. The second

focus group was held in March 2026 with members of the GoC and covered the same set of

topics. Finally, two surveys were conducted to collect evidence on (i) the costs incurred

during recognition procedures and (ii) the potential benefits of digitalisation. One survey

targeted national CA responsible for recognition processes in the seven sectoral professions

under automatic recognition and was disseminated through the GoC and direct outreach. The

second survey targeted EU citizens holding professional qualifications who are currently

seeking, or have previously sought, recognition for one of these professions; it was circulated

through professional representative organisations participating in the consultation process.

70

Tool/Method Objectives

Stakeholders

(number and

type)

Start –

end date IA elements/steps

Scoping

interviews

Refine the scope of

the study

Collect additional

qualitative evidence

on the PQD and

views on the SPI

Identify key issues

affecting recognition

procedures

Gather stakeholders’

views on potential

adjustments or

improvements to the

existing recognition

framework

DG SANTE (1)

DG EMPL (4)

DG GROW (5)

20.01.26-

06.02.26

Problem definition

Development of

policy options

Consultation

workshop

Discuss and refine the

problem definition

Members of the

Group of

Coordinators (39,

covering 22 MS)

10.02.26 Problem definition

Focus groups

Gather participants’

feedback on the

expected impacts of

the preliminary policy

measures.

Assess whether the

proposed measures

adequately address

the problems

identified in

recognition processes.

Identify perceived

strengths,

weaknesses, and

potential unintended

effects of the

proposed measures.

EU‑level

representative

organisations of

the seven sectoral

professions

benefiting from

automatic

recognition based

on minimum

training

requirements (21)

Members of the

Group of

Coordinators

covering (28,

covering 16 MS)

23.02.26

04.03.26

Development of

policy options

71

Tool/Method Objectives

Stakeholders