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EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 990 final

2026/0275 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on the recognition of qualifications of third-country nationals

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

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

competitiveness.

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

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

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

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

overqualification and the underutilisation of skills being significantly more pronounced

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

further learning are outside the scope of this proposal.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

obtained in third countries.

• Consistency with existing policy provisions in the policy area

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

Professional Qualifications Directive provides a robust framework for the recognition of

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

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

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

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

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

Member States to simplify or coordinate such procedures. Commission Recommendation

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

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

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

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

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

Action 2 modernises recognition procedures under the Professional Qualifications Directive

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

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

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

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

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

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

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

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

extensive prior review of the learning programmes concerned benefitting from automatic

recognition.

• Consistency with other Union policies

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

infrastructure) and SDG 10 (Reduced inequalities).

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

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

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

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

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

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

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

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

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

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

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

facilitating access to employment corresponding to their qualifications and reducing the

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

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

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

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

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

whether employed or self-employed.

• Subsidiarity (for non-exclusive competence)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

education and training systems, or migration and admission decisions.

• Proportionality

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

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

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

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

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

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

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

procedural requirements without harmonising substantive assessment standards; and PO3,

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

requirements under the Professional Qualifications Directive, preserves Member States'

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

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

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

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

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

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

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

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

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

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

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

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

general system simplifies procedures without harmonising substantive assessment standards.

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

preserves Member State competence over qualification standards and admission decisions;

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

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

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

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

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

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

• Choice of the instrument

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

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

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

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

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

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

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

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

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

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

and the common rules would not regulate the matter exhaustively.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

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

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

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

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

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

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

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

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

country nationals.

• Stakeholder consultations

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

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

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

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

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

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

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

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

society and professional-organisation respondents were broadly supportive of binding

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

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

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

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

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

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

• Collection and use of expertise

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

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

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

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

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

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

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

the external study and other bilateral meetings.

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• Impact assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

• Regulatory fitness and simplification

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

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

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

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

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

coordination between recognition and migration authorities eliminates duplicate qualification

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

on existing EU digital tools and platforms.

• Fundamental rights

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

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

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

procedural guarantees — binding timelines, defined documentation requirements and appeal

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

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

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

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

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

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

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

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

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

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

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

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

meeting the applicable minimum training requirements, compensation measures and language

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

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

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

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

4. BUDGETARY IMPLICATIONS

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

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

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

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

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

third-country nationals (Article 33).

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

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

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

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

complement the overall needs.

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

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

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

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

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

staffing allocations as of 2028 are indicative.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

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

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

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

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

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

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

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

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

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

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

without additional national reporting obligations. Member States will submit implementation

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

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

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

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

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

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

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

• Detailed explanation of the specific provisions of the proposal

Title I — General provisions (Articles 1–3)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

insurance funds.

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

residence permit (Articles 21 to 26)

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

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

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

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

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

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

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

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

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

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

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

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

effort.

Title IV — Common provisions (Articles 27 to 32)

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

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

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

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

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

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

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

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

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

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

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

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

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

applicants.

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

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

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

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

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

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

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

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

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

force and addressees.

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2026/0275 (COD)

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on the recognition of qualifications of third-country nationals

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

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

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

Having regard to the proposal from the European Commission,

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

Acting in accordance with the ordinary legislative procedure,

Whereas:

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

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

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

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

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

long-stay visa or a residence permit.

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

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

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

resulting in uncertainty, delays, and inconsistent outcomes across Member

States. Member States have taken commitments under the Lisbon Recognition

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

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

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

complexity create unnecessary barriers to labour market integration, contribute to

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

address persistent skills shortages.

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

establishing a framework for portability of skills and qualifications and amending

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

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

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

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

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

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

qualifications-concerning-higher-education.

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

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

accordingly, in order to avoid parallel procedures.

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

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

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

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

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

Union.

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

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

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

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

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

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

approaches persist, and the structural misalignment between migration systems and

qualification recognition frameworks remains unaddressed. Faster and more effective

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

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

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

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

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

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

competent authorities that the qualifications presented correspond to recognised levels

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

EN 12 EN

contributes to strengthening the labour market participation of disadvantaged groups

within the Union.

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

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

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

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

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

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

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

do so, such as through the EU Talent Pool.

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

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

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

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

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

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

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

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

nationals face significant disparities in recognition procedures across Member States.

Differences in required documentation, compensation measures and assessment

methods risk encouraging applicants to target jurisdictions with more lenient

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

competitive disadvantage in attracting global talent.

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

recognition of professional qualifications should enable third-country nationals to

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

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

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

profession should remain subject to applicable requirements relating to residence,

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

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

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

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

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

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

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

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

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

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

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

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

general interest.

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

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

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

formal qualifications or professional experience acquired in a Member State that

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

EN 13 EN

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

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

mutandis to them.

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

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

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

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

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

recognition of selected qualifications that meet Union minimum training and quality

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

obtained outside the Union.

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

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

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

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

difficulties of assessing qualifications and professional experience acquired outside the

Union.

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

methods of verification where the necessary documentation cannot reasonably be

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

circumstances outside the applicant's control.

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

disproportionate barrier to recognition, under the general system, compensation

measures should remain limited to cases of substantial differences between the

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

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

third-country qualifications, including variable training standards and legitimate

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

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

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

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

invoked arbitrarily or without justification, Member States should notify the

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

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

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

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

applicants' procedural rights and supports their effective integration into the

profession.

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

need for individual assessments, reducing administrative burdens and ensuring greater

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

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

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

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

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

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

EN 14 EN

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

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

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

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

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

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

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

adaptable over time.

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

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

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

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

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

public to ensure full transparency.

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

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

including alignment with the minimum training conditions set out in Directive

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

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

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

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

meeting Union standards are eligible for automatic recognition.

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

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

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

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

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

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

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

subsequent changes to applicable minimum training requirements are properly

reflected.

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

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

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

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

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

established, which have to be resolved promptly and fairly.

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

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

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

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

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

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

should be limited to specified professions.

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

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

EN 15 EN

oversight and administrative cooperation, the review requirement should be

adjusted for the institutions established in those third countries.

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

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

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

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

concerned.

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

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

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

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

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

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

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

without adding procedural burdens or conflicting with more favourable provisions.

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

assessment of their qualifications where such recognition constitutes a prerequisite or

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

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

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

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

oblige that Member State to introduce an additional procedure.

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

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

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

employers and competent authorities to understand and compare qualifications and

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

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

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

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

that purpose.

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

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

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

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

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

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

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

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

establish new or standalone recognition procedures where the necessary assessment

can be carried out within existing migration procedures.

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

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

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

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

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

Decision No 2241/2004/EC.

EN 16 EN

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

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

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

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

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

existing comparisons between third-country frameworks and the European

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

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

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

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

unnecessarily completing compensation measures before a final decision on entry or

residence, qualifications assessed under a learning outcomes approach should be

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

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

residence has been granted.

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

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

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

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

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

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

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

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

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

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

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

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

regulated profession in its territory, Member States should limit documentary

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

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

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

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

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

qualifications, skills or other evidentiary elements.

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

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

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

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

inherent security and verification mechanisms, digital credentials should be presumed

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

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

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

ensure that recognition procedures are not delayed or obstructed by circumstances

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

alternative methods of attestation.

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

recognition procedures. Verifying third-country qualifications often proves complex

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

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

EN 17 EN

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

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

credentials and diploma mills, which undermine trust in qualification recognition

procedures. While Member States have introduced stringent verification measures –

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

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

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

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

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

and through cooperation with third countries and relevant educational and professional

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

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

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

rather than binding conclusions.

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

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

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

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

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

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

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

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

Regulation, to be carried out through a delegated act.

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

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

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

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

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

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

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

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

prolonged by document collection, translation, legalisation and compensation

measures, hampering individuals' professional integration and disrupting employers'

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

limits for the acknowledgement of applications and the completion of recognition

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

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

fully accessible to beneficiaries of international protection unable to provide

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

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

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

2005/36/EC.

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

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

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

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

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

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

EN 18 EN

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

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

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

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

timely processing of such applications.

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

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

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

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

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

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

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

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

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

demonstrated intention to do so to complete the process remotely.

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

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

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

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

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

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

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

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

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

arise.

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

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

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

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

transparent, justified and proportionate.

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

country nationals seeking recognition of their qualifications, yet current information

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

EN 19 EN

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

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

facing critical health workforce shortages.

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

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

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

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

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

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

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

under Union or national law.

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

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

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

Commission carry out appropriate consultations during its preparatory work, including

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

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

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

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

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

expert groups dealing with the preparation of delegated acts.

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

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

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

Parliament and of the Council.15

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

to support its continuous improvement, Member States should provide the

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

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

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

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

Council.

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

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

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

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

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

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

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

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

this Directive.]

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

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

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

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

EN 20 EN

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

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

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

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

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

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

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

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

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

what is necessary to achieve those objectives.

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

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

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

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

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

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

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

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

HAVE ADOPTED THIS DIRECTIVE:

Title I

General provisions

Article 1

Subject matter

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

held by third-country nationals.

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

more favourable to third-country nationals, including provisions regarding

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

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

international instruments, including future or existing mutual recognition agreements

for qualifications with third countries.

Article 2

Scope

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

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

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

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

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

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

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

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

EN 21 EN

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

nationals:

(a) legally residing in a Member State;

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

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

Title III;

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

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

conditions:

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

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

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

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

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

for the role.

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

further learning.

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

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

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

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

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

stay visa or a residence permit for work purposes.

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

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

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

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

government.

Article 3

Definitions

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

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

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

permits;

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

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

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

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

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

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

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

the territory of the host Member State;

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

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

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

country and certifying successful completion of professional training;

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

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

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

the following:

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

(ii) a specific examination without prior training;

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

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

previous 10 years;

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

general knowledge;

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

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

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

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

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

based immigration system;

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

meaning of Article 20(1) TFEU;

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

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

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

Directive;

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

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

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

of Directive 2005/36/EC;

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

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

(m) ‘test of professional competence’ means a standardised test, designed for a specific

profession in order to evaluate an applicant’s knowledge and skills that are essential

to pursue that profession in the host Member State;

(n) ‘bridging course’ means a targeted course designed for a defined target group of

already qualified professionals to address specific typical gaps in professional

knowledge, skills and competences and enable them to practise the regulated

profession in the host Member State;

(o) ‘quality assurance agency’ means an independent body carrying out external quality

assurance in higher education or in vocational education and training (VET);

(p) ‘European Quality Assurance Register for Higher Education (EQAR)’ means the

register of quality assurance agencies that have demonstrated substantial compliance

EN 23 EN

with the Standards and Guidelines for Quality Assurance in the European Higher

Education Area, in the applicable version at the relevant time;

(q) ‘digital credential’ means a credential issued in electronic form which provides

information on qualifications, qualification levels, skills or learning outcomes, and

which can be used to demonstrate that information in a reliable and verifiable

manner.

Title II

Recognition to access a regulated profession

Chapter 1

General provisions

Article 4

Effects of recognition

1. The recognition of professional qualifications by the host Member State shall allow

beneficiaries to gain access in that Member State to the same profession as the one

for which they are qualified in the third country or in the other Member State where

they obtained their qualifications under the same conditions as the nationals of the

host Member State, provided the beneficiaries meet all necessary legal requirements

for employment and residency.

2. For the purposes of this Directive, the profession which the applicant wishes to

pursue in the host Member State shall be considered the same as the one for which

they are qualified in a third country or in another Member State if the activities

covered are comparable.

3. By way of derogation from paragraph 1 of this Article, partial access to a profession

in the host Member State shall be granted under the conditions laid down in Article

5.

Article 5

Partial access

1. The competent authority of the host Member State shall grant partial access, on a

case-by-case basis, to a professional activity in its territory only when all the

following conditions are fulfilled:

(a) the professional is fully qualified to exercise in a third country or another

Member State the professional activity for which partial access is sought in the

host Member State;

(b) differences between the professional activity legally exercised in the third

country or in the other Member State and the regulated profession in the host

Member State as such are so large that the application of compensation

measures would amount to requiring the applicant to complete the full

programme of education and training required in the host Member State to

have access to the full regulated profession in the host Member State;

(c) the professional activity can objectively be separated from other activities

falling under the regulated profession in the host Member State.

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For the purpose of the first subparagraph, point (c), the competent authority of the

host Member State shall take into account whether the professional activity can be

pursued autonomously in the third country or in the other Member State.

2. Partial access may be rejected if such rejection is justified by overriding reasons of

general interest, suitable for securing the attainment of the objective pursued, and

does not go beyond what is necessary to attain that objective.

3. Applications for the purposes of establishment in a Member State shall be examined

in accordance with Chapter 2 of this Title and with Title IV.

4. By way of derogation from Article 19, the professional activity shall be exercised

under the professional title of the third country or of the other Member State once

partial access has been granted. The host Member State may require use of that

professional title in the languages of the host Member State. Professionals benefiting

from partial access shall clearly indicate to the service recipients the scope of their

professional activities.

5. This Article shall not apply to professionals benefiting from automatic recognition of

their professional qualifications under Chapter 3 of this Title, and in cases where

Chapter II, III or IIIa of Title III of Directive 2005/36/EC have been applied to third-

country nationals in accordance with Article 6 of this Directive.

Article 6

Evidence of professional qualifications obtained in the Union

Where third-country nationals hold an attestation of competence, evidence of formal

qualifications, or professional experience obtained in the Union, and such qualifications or

experience would allow a Union citizen to access or pursue a regulated profession in the host

Member State pursuant to Title III of Directive 2005/36/EC, the provisions of that Directive

shall apply to those third-country nationals accordingly when they seek recognition to access

and pursue that profession in the host Member State.

Chapter 2

General system for the recognition of evidence of training issued

in third countries

Article 7

Scope

This Chapter applies to situations which are not covered by Article 6, or by Chapter 3 of this

Title or where the applicant does not satisfy the conditions laid down in Chapter 3 of this

Title.

Article 8

Conditions for recognition

1. If access to or pursuit of a regulated profession in a host Member State is contingent

upon possession of specific professional qualifications, the competent authority of

that Member State shall permit applicants to access and pursue that profession, under

the same conditions as apply to its nationals, if they possess an attestation of

competence or evidence of formal qualifications, issued by a competent authority in

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a third country, and required by a third country in order to gain access to and pursue

that profession on that country’s territory.

2. Access to, and pursuit of, a profession as referred to in paragraph 1 shall also be

granted to applicants who have pursued the profession concerned on a full-time basis

for one year or for an equivalent overall duration on a part-time basis during the

previous 10 years in a third country which does not regulate that profession, and who

possess one or more attestations of competence or evidence of formal qualifications

issued by that third country which does not regulate the profession.

Attestations of competence and evidence of formal qualifications shall satisfy both of

the following conditions:

(a) they are issued by a competent authority in a third country;

(b) they attest that the holder has been prepared for the pursuit of the profession

concerned.

3. By way of derogation from paragraphs 1 and 2 of this Article, the competent

authority of the host Member State may refuse access to, and pursuit of, the regulated

profession to applicants who only possess an attestation of competence, where access

to or pursuit of that regulated profession in the host Member State requires a diploma

certifying successful completion of a post-secondary course of at least four years, or

for an equivalent duration on a part-time basis, which may in addition be expressed

with an equivalent number of ECTS credits, at a university or establishment of

higher education or another establishment of equivalent level.

4. When the applicant duly documents that, despite reasonable efforts, they were unable

to obtain the attestation of competence referred to in paragraphs 1, 2 and 3, the host

Member State shall assess the feasibility of, and where appropriate, employ

alternative methods to assess qualifications, skills or other evidentiary elements.

Those methods may include affidavits, third-party assessments, professional

interviews or reputable evaluation frameworks like qualifications passports, designed

for refugees and vulnerable migrants. The host Member State shall ensure that

applicants are not unduly disadvantaged due to those circumstances and shall base its

decisions on available and reasonable evidence.

Article 9

Compensation measures

1. Article 8 shall not preclude the host Member State from imposing on the applicant a

compensation measure among those listed in paragraph 2 of this Article in one of the

following cases:

(a) the training that the applicant has received covers substantially different

matters from those covered by the evidence of formal qualifications required in

the host Member State;

(b) the regulated profession in the host Member State comprises one or more

regulated professional activities which do not exist in the corresponding

profession in the third country where the applicant obtained the attestation of

competence or evidence of formal qualifications, and the training required in

the host Member State covers substantially different matters from those

covered by the applicant’s attestation of competence or evidence of formal

qualifications;

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(c) the Member State has justified doubts as to the quality of the education,

training or qualification system under which the evidence of formal

qualifications has been awarded.

For the purpose of this Article, ‘substantially different matters’ means matters in

respect of which knowledge and skills acquired are essential for pursuing the

profession and with regard to which the training received by the applicant shows

significant differences in terms of content from the training required by the host

Member State.

In case a Member State decides to impose compensation measures on the basis of

justified doubts according to point (c), it shall notify the Commission of the country

and profession concerned and the nature of the doubts.

2. If the host Member State makes use of the option provided for in paragraph 1, it shall

indicate to the applicant which of the following compensation measures they are

required to complete:

(a) an adaptation period, not exceeding three years, where the applicant undergoes

supervised practice and, if necessary, additional training;

(b) an aptitude test;

(c) a test of professional competence;

(d) a bridging course, with a duration of up to one year.

3. Paragraphs 1 and 2 shall be applied with due regard to the principle of

proportionality. In particular, if the host Member State intends to require the

applicant to complete a compensation measure, it shall first ascertain whether the

knowledge, skills and competences acquired by the applicant in the course of the

applicant’s professional experience or through lifelong learning, and formally

validated to that end by a relevant body, in any Member State or in a third country, is

of such nature as to cover, in full or in part, the substantially different matters.

4. The decision imposing a compensation measure shall be duly justified. In particular,

the applicant shall be provided with the reasons for the compensation measure,

information on the substantial differences, and, where relevant, why those

differences cannot be compensated by knowledge, skills and competences acquired

in the course of prior experience or other qualifications through lifelong learning

formally validated to that end by a relevant body.

5. Member States shall ensure that an applicant who fails the aptitude test or test of

professional competence referred to in paragraph 2, points (b) and (c), or one or more

tests forming part of a bridging course or adaptation period, referred to in paragraph

2, points (a) and (d), is given the opportunity to retake the respective tests. Member

States shall ensure that feedback detailing assessment results and areas for

improvement is provided to applicants, and ensure that applicants are entitled to at

least two further attempts to pass each test that they have failed.

6. Member States shall ensure that an applicant has the possibility of taking the aptitude

test or the test of professional competence referred to in paragraph 2, points (b) and

(c), not later than six months after the initial decision imposing an aptitude test or test

of professional competence on the applicant. Member States shall also ensure that an

applicant has the possibility to start a bridging course referred to in paragraph 2,

point (d), no later than six months after the initial decision imposing the completion

of a bridging course on the applicant.

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Article 10

Minimum training requirements for certain professions

Where Articles 24, 25, 28, 31, 34, 35, 38, 40 and 44 of Directive 2005/36/EC set out

minimum conditions on the training for certain professions, under this Chapter any

recognition of evidence of formal qualifications in one of those professions shall be

contingent upon fulfilment of those minimum conditions.

Chapter 3

Recognition on the basis of reviewed training programmes in

accordance with minimum training conditions

Article 11

Principle of automatic recognition based on reviewed training programmes in third

countries

1. Each Member State shall recognise evidence of formal qualifications giving access to

the professional activities of doctor with basic training or specialised doctor, as nurse

responsible for general care, as dental practitioner, as specialised dental practitioner,

as midwife, as veterinary surgeon, as pharmacist, and as architect, obtained in a third

country, and shall for the purposes of access to and pursuit of those professional

activities, give such evidence the same effect on its territory as the evidence of

formal qualifications which it itself issues, provided that all of the following

conditions are met:

(a) the evidence of formal qualifications has been obtained following successful

completion of a training programme which has been reviewed in accordance

with Articles 13 and 14 by a trusted review body within the meaning of Article

12;

(b) the trusted review body has publicly disclosed the result of the review process

and a review report;

(c) the evidence of formal qualifications is issued as a digital credential.

2. Each Member State shall, for the purpose of access to and pursuit of a regulated

profession that is covered by a common training framework pursuant to Article 49a

of Directive 2005/36/EC, and where that Member State is not exempted from the

obligation of introducing a common training framework in accordance with Article

49a(5) of Directive 2005/36/EC, give evidence of formal qualifications acquired in

third countries the same effect in its territory as the evidence of formal qualifications

which it itself issues, provided that all of the following conditions are met:

(a) the evidence of formal qualifications has been obtained following successful

completion of a training programme which has been reviewed in accordance

with Articles 13 and 14 by a trusted review body as referred to in Article 12;

(b) the trusted review body has publicly disclosed the result of the review process

and a review report;

(c) the evidence of formal qualifications is issued as a digital credential.

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Article 12

Trusted review bodies

1. A quality assurance agency established in the Union may apply to the Commission to

be listed as a trusted review body for higher education programmes if it fulfils all of

the following criteria:

(a) it is registered in the European Quality Assurance Register for Higher

Education (EQAR) without interruption for a period of at least 10 years;

(b) it has documented prior experience in conducting external quality assurance

reviews, as a quality assurance agency, in at least three different third

countries.

2. A quality assurance agency established in the Union may apply to the Commission to

be listed as a trusted review body for vocational education and training (VET)

programmes if it fulfils all of the following criteria:

(a) it is competent, under national law, in the Member State in which it is

established, for the quality assurance of VET programmes;

(b) it has documented prior experience in conducting external quality assurance

reviews, as a quality assurance agency, in at least three different third

countries.

3. The Commission is empowered to adopt a delegated act supplementing this Directive

by listing the trusted review bodies in accordance with Article 36. It shall list all

quality assurance agencies that applied to be listed in accordance with paragraphs 1

and 2, and that comply with the requirements set out in those paragraphs.

4. Only trusted review bodies listed in the delegated act referred to in paragraph 3 shall

be considered trusted review bodies for the purposes of this Directive, and only in

relation to the professions indicated therein.

Article 13

Reviewed training programmes

For the purposes of Article 11, only training programmes that have been reviewed in

accordance with Article 14 and found to fulfil the following criteria shall be considered as

reviewed training programmes:

(a) The training programme is compliant with the Standards and Guidelines for Quality

Assurance in the European Higher Education Area (ESG), in the version applicable

at the relevant time, in case the training programme is delivered through a higher

education institution;

(b) Quality assurance measures comprising independent assessment, a competence-

based assessment methodology, transparent outcomes, periodic external review, and

an appeal or complaint mechanism have been implemented for the delivery of the

programme, in case the training programme is delivered through vocational training;

(c) The institution delivering the programme is lawfully established in the third country

concerned and authorised under the law of that country to award the qualification in

question;

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(d) For the professions listed in Article 11(1), the training programme is compliant with

the minimum conditions on the training applicable to the relevant profession as set

out in Articles 24, 25, 28, 31, 34, 35, 38, 40, 44, and 46 of Directive 2005/36/EC;

(e) In the cases of Article 11(2), the training programme is compliant with the applicable

common training framework.

Article 14

Review of training programmes in third countries

For the purposes of Article 11, Member States shall ensure that the review of training

programmes is carried out as follows:

(a) Upon request by a training institution in higher education or in vocational training

outside the Union, a trusted review body pursuant to Article 12 assesses compliance

with the criteria set out in Article 13.

(b) To this end, the trusted review body forms a review team which carries out the

assessment of the training programme. For that purpose, the review team shall

consist of:

(i) between five and nine reviewers selected by the trusted review body. Those

reviewers shall include subject matter experts of the relevant discipline or

disciplines, and specialists in quality assurance and evaluation methodologies;

and

(ii) up to three reviewers that Member States appoint for the review following an

invitation to all Member States by the trusted review body. For that purpose,

each Member State shall appoint only one reviewer. Where more than three

Member States intend to appoint a reviewer, a randomised process shall apply

for the selection of the three reviewers.

Each of the reviewers selected pursuant to points (i) and (ii) shall declare, prior to

participating in the review, the absence of any conflict of interest in relation to the

institution under review, including any consultancy, advisory or other remunerated

relationship with that institution within the preceding three years. A reviewer unable

to make that declaration shall not participate in the review of the institution

concerned.

(c) The trusted review body organises at least one on-site visit of the review team as an

integral part of the assessment of the training programme.

(d) The trusted review body communicates its decision on the outcome of the assessment

to the institution organising the reviewed training programme and to the

Commission.

(e) Following a positive assessment of a training programme, the trusted review body

grants the status of ‘reviewed’ on the basis that the applicable requirements laid

down in Article 13 are satisfied. The status of ‘reviewed’ shall be valid for a period

of five years or until the transposition deadline of any Commission delegated act,

adopted pursuant to Article 21(6), second subparagraph of Directive 2005/36/EC,

which updates the knowledge and skills referred to in Articles 24(3), 31(6), 34(3),

38(3), 40(3), 44(3), or 46(4) of Directive 2005/36/EC.

(f) After each assessment the trusted review body makes the result of the review process

publicly available in a dedicated, clearly identifiable and easily accessible section of

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its website or other publicly accessible online interface, no matter if the outcome of

the review was positive or negative.

(g) If requested by the training institution with a reviewed programme, the trusted

review body carries out a new review following the submission of a renewal

application at least six months before the expiration of the current status of

‘reviewed’. The training institution shall present detailed reports demonstrating

continuous compliance with the training standards since the last review, alongside

documentation outlining enhancements in training methodologies, assessment

processes, and quality assurance practices. The trusted review body shall review the

renewal application and communicate its decision to the institution organising the

reviewed training programme and to the Commission within three months of

application submission. The review team under point (b)(i) shall not be the same as

the review team for the institution's immediately preceding review.

(h) Any fee or charge levied by the trusted review body for the review shall be

transparent and proportionate to the costs of the service provided, and shall be

commensurate with the complexity, scope and duration of the review carried out by

the trusted review body. This shall not preclude the trusted review body from

including in its fees a reasonable margin over its costs, provided that such margin

does not render the fee disproportionate to the service provided.

Article 15

Right to appeal or contest review decisions

1. Training institutions whose training programmes received a negative result

following the review in accordance with Article 14 shall be allowed to appeal that

result under the national law of the Member State where the trusted review body is

established. Member States shall establish procedures ensuring that such appeals are

resolved fairly and promptly.

2. If a Member State has justified doubts on the review carried out pursuant to Article

14, that Member State may communicate its concerns in writing to the Commission.

Within 15 working days after receipt of that communication, the Commission shall

provide its views and invite the other Member States to express their views. In case

at least 5 Member States express support for this concern to the Commission within

two months following that invitation, the Commission shall inform all Member

States in writing that they shall only consider the given training programme as

reviewed once a second review has been carried out pursuant to Article 14.

3. If following the second review pursuant to paragraph 2 the training programme is

granted the status of ‘reviewed’, the validity period referred to in Article 14, point (e)

shall start from the date of that result.

4. If the result of the second review is negative, the programme shall not be considered

as a reviewed training programme in the meaning of Article 13 and cannot benefit

from recognition pursuant to Article 11.

Article 16

Listed third countries

1. For qualifications obtained in a third country listed in the delegated acts referred to in

paragraph 2 of this Article, Member States shall ensure that trusted review bodies

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automatically consider the criteria laid down in Article 13, points (a) and (b) as being

fulfilled.

2. The Commission is empowered to adopt delegated acts in accordance with Article 36

to supplement this Directive by establishing and amending a list of third countries for

which the learning quality assurance systems provide guarantees as regards all of the

following elements:

(a) public oversight or equivalent supervision of qualifications;

(b) quality assurance or accreditation of the relevant institutions or training

programmes;

(c) authenticity, reliability and verifiability of the qualifications issued;

(d) comparability and consistency of the intended learning outcomes or

qualification standards relevant to the application of this Directive;

(e) administrative cooperation with the competent authorities of the Member

States and the Commission.

3. The Commission shall monitor whether the third countries listed in the delegated acts

referred to in paragraph 2 continue to fulfil the conditions laid down in paragraph 2,

points (a) to (e). Where the Commission has well-founded concerns that the

conditions for the inclusion of a third country in the list are no longer fulfilled, it may

adopt a decision suspending the application of paragraph 1 in respect of that third

country. The Commission shall inform the third country concerned and the Member

States of the suspension and the reasons without delay.

4. The suspension referred to in paragraph 3 of this Article shall apply until the

Commission, following its assessment, either lifts it or adopts a delegated act in

accordance with Article 36 removing the third country concerned.

Chapter 4

Rules for pursuing the profession

Article 17

Knowledge of languages

1. Professionals benefiting from the recognition of professional qualifications shall

have a knowledge of languages necessary for practising the profession in the host

Member State.

2. A Member State shall ensure that any controls carried out by, or under the

supervision of, the competent authority for controlling compliance with the

obligation under paragraph 1 shall be limited to the knowledge of one official

language of the host Member State, or one administrative language of the host

Member State provided that it is also an official language of the Union.

3. Controls carried out in accordance with paragraph 2 may be imposed if the

profession to be practised has patient safety implications. Controls may be imposed

in respect of other professions in cases where there is a serious and concrete doubt

about the sufficiency of the professional’s language knowledge in respect of the

professional activities that that professional intends to pursue.

Controls may be carried out only after the recognition of a professional qualification.

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4. Any language controls shall be proportionate to the activity to be pursued. The

professional concerned shall be allowed to appeal such controls under national law.

Article 18

Use of academic titles

Without prejudice to Article 19, the host Member State shall ensure that the right shall be

conferred on the persons concerned to use academic titles awarded to them in another

Member State or in a third country, and possibly an abbreviated form thereof, in the language

of that other Member State or that third country. The host Member State may require that title

to be followed by the name and address of the establishment or examining board which

awarded it. Where an academic title of another Member State or of a third country is liable to

be confused in the host Member State with a title which, in the latter Member State, requires

supplementary training not acquired by the beneficiary, the host Member State may require

the beneficiary to use the academic title of the Member State or third country where it has

been issued in an appropriate form, to be laid down by the host Member State.

Article 19

Use of professional titles

1. If, in a host Member State, the use of a professional title relating to one of the

activities of the profession in question is regulated, third-country nationals who are

authorised to practise a regulated profession on the basis of this title shall use the

professional title of the host Member State, which corresponds to that profession in

that Member State, and make use of any associated initials.

2. Where a profession is regulated in the host Member State by an association or

organisation within the meaning of Article 3(2) of Directive 2005/36/EC, third-

country nationals shall not be authorised to use the professional title issued by that

organisation or association, or its abbreviated form, unless they furnish proof that

they are members of that association or organisation.

If the association or organisation makes membership contingent upon certain

qualifications, it may do so only under the conditions laid down in this Directive, in

respect of third-country nationals who possess professional qualifications.

Article 20

Approval by health insurance funds

Member States which require persons who acquired their professional qualifications in their

territory to complete a preparatory period of in-service training and/or a period of professional

experience in order to be approved by a health insurance fund, shall waive this obligation for

the holders of evidence of professional qualifications of doctor and dental practitioner

acquired in other Member States or in other third countries.

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Title III

Recognition in the context of a procedure to obtain a long-stay

visa or a residence permit

Article 21

Scope

This Title applies where the recognition by the host Member State of a qualification or skills

obtained in another Member State or in a third country, and held by a third-country national,

constitutes a factor determining the outcome of a procedure to obtain a long-stay visa or a

residence permit for work purposes, including within a points-based immigration system.

Article 22

Right to assessment of qualifications and skills in the context of a procedure to obtain a

long-stay visa or a residence permit

1. Member States shall ensure that, where the recognition or assessment of

qualifications or skills constitutes a factor determining the outcome of a procedure to

obtain a long-stay visa or a residence permit for work purposes, applicants have the

right to have assessed and taken into account the following for the purposes of that

procedure:

(a) their formal qualifications obtained in another Member State or in a third

country;

(b) their skills acquired through professional or other experience.

2. Where relevant to that procedure, that assessment may take into account information

provided by a current or prospective employer of the applicant, in particular

concerning the tasks, responsibilities and skills required for the position offered.

3. Member States shall ensure that qualifications and skills referred to in paragraph 1

are not refused solely on the ground that they were obtained in another Member State

or in a third country.

4. Member States shall ensure that the recognition and assessment procedure is fair,

does not impose unnecessary burdens on applicants, and is designed to facilitate the

efficient processing of applications for a long-stay visa or a residence permit.

5. Member States shall ensure that the recognition or assessment results are presented

to the applicant in a reasoned decision. That decision shall determine whether the

qualifications or skills of the third-country national are:

(a) recognised and thus treated as equivalent to the qualification level or other

qualification requirements applicable in the context of the procedure to obtain a

long-stay visa or a residence permit;

(b) recognised provisionally, contingent upon the applicant completing

compensation measures in accordance with Article 25(3);

(c) not recognised.

Article 23

Procedural requirements

EN 34 EN

1. Member States shall ensure that any recognition or assessment referred to in Article

22 is carried out within the procedure to obtain a long-stay visa or a residence permit

and in accordance with the principles of necessity, proportionality and simplification.

2. Where the procedure to obtain a long-stay visa or a residence permit does not require

recognition or assessment of qualifications that would give access to a regulated

profession in its territory, the host Member State shall assess qualifications or skills

within the procedure to obtain a long-stay visa or a residence permit and shall not

require a separate recognition or assessment procedure outside that procedure. In

particular, that Member State shall:

(a) not duplicate previous assessments or the requirement to submit evidence that

is already available to, or capable of being obtained by, the competent

authorities of that Member State;

(b) integrate any request for information or supporting evidence to carry out the

recognition or assessment in the application to obtain a long-stay visa or a

residence permit, and not require a separate application for recognition of

qualifications;

(c) limit documentary requirements to those that are necessary for the assessment

and reasonably available to the applicant or, with the applicant’s consent, to a

current or prospective employer submitting evidence on the applicant’s behalf;

(d) not charge any separate or additional fees for the assessment or recognition of

qualifications or skills, other than fees that may be charged for the procedure to

obtain a long-stay visa or a residence permit;

(e) ensure that the assessment or recognition of qualifications or skills is carried

out within the time limits of the procedure to obtain a long-stay visa or a

residence permit and does not cause delay in the processing of the relevant

long-stay visa or residence permit application.

Article 24

Recognition of qualification levels

1. Where, for the purposes of recognition in the context of a procedure to obtain a long-

stay visa or a residence permit, Member States establish the level of a qualification,

they shall apply the levels and descriptors of the European Qualifications Framework

(EQF) as set out in [Annex III of Regulation xxxx/xx/EU establishing a framework

for portability of skills and qualifications and amending Regulation (EU) 2018/1724

('Skills Portability Act')].

For that purpose, Member States shall take into account any relevant existing

comparison of qualification levels or frameworks of third countries to the EQF.

2. The level of the qualification shall not constitute the only element of the assessment

but shall be considered together with the qualification’s intended learning outcomes,

duration, content, workload, practical training, professional experience and, where

relevant, the scope of professional activities to which it gives access in another

Member State or the third country in which it was awarded.

Article 25

Recognition of qualifications without access to regulated professions

EN 35 EN

1. Where Member States evaluate qualifications for the purpose of recognition in the

context of a procedure to obtain a long-stay visa or a residence permit, and where

that evaluation goes beyond a comparison of qualification levels as provided for in

Article 24 and a general classification of the field of study, they shall ensure that a

learning outcomes approach is applied, focusing primarily on comparing the

applicant’s acquired skills to the relevant reference qualification. Where possible, the

assessment shall also consider experiences gained through non-formal learning and

skills acquired through professional or other experience. Where provided, and with

the applicant’s consent, information from a current or prospective employer relevant

to the skills required for the position offered may also be taken into account.

2. Member States shall recognise a qualification in the context of a procedure to obtain

a long-stay visa or a residence permit if all of the following conditions are met:

(a) there are no substantial differences in qualification level;

(b) there are no substantial differences in the intended learning outcomes;

(c) there are no justified doubts on the quality of the education, training or

qualification system under which the evidence of formal qualifications has

been awarded in a third country.

3. If substantial differences in intended learning outcomes or levels of qualification are

established, or if the Member State has justified doubts on the quality of the

education, training or qualification system under which the evidence of formal

qualifications has been awarded in a third country, provisional recognition shall be

granted, contingent upon the applicant completing suitable compensation measures

within a clearly defined timeframe laid down by the host Member State. For the

purpose of the procedure to obtain a long-stay visa or a residence permit, the

provisionally recognised qualification shall be treated as finally recognised. The host

Member State shall, at the time provisional recognition is granted, inform the

applicant in writing of the compensation measures required, the timeframe within

which they shall be completed, and the consequences of failing to complete them

within that timeframe. The successful completion of the compensation measures

shall only be required if the applicant is subsequently granted a long-stay visa or a

residence permit.

4. The compensation measures shall be designed to address identified gaps and shall be

selected from one of the following:

(a) an aptitude test;

(b) a test of professional competence;

(c) a bridging course, with a duration of up to one year.

5. By way of derogation from paragraph 3, if substantial differences in the learning

outcomes or the level of qualification cannot be adequately remedied through

compensation measures, Member States may refuse recognition of qualifications for

the purpose of the procedure to obtain a long-stay visa or a residence permit. A

decision to refuse recognition of qualifications shall not automatically result in the

rejection of the application for a long-stay visa or a residence permit.

6. For the purposes of paragraphs 2, 3 and 4:

(a) 'substantial difference in intended learning outcomes' means instances where

the essential knowledge and skills, necessary for practising a given profession,

EN 36 EN

are not among the intended learning outcomes of the third-country

national’s training, resulting in significant differences in terms of the essential

knowledge and skills obtained compared with those required by the host

Member State;

(b) ‘substantial difference in qualification levels’ means instances where the

qualification level of a third-country national is assessed to be two or more

levels below the level of the training required by the host Member State, as

determined by the descriptors of the EQF.

Article 26

Integrated procedure with the recognition of professional qualifications

1. Member States shall offer applicants seeking recognition of qualifications in the

context of a procedure to obtain a long-stay visa or a residence permit, who also wish

to access a regulated profession, the possibility of choosing an integrated recognition

procedure. That procedure shall satisfy the requirements laid down in this Title and

in Title II. Upon successful completion of the integrated recognition procedure, the

applicant shall receive a recognition of qualifications for the purposes of the

procedure to obtain a long-stay visa or a residence permit as referred to in Article

22(5), point (a), and for the access to the regulated profession, as provided for in

Article 4.

2. For applicants not opting for an integrated recognition procedure, Member States

shall ensure that recognition procedures in the context of the procedure to obtain a

long-stay visa or a residence permit, and recognition procedures for access to

regulated professions are coherent. Authorities shall take into account all prior

assessments and verifications of the provided evidence that have already been carried

out in previous procedures and shall not require applicants to resubmit documents

that have already been provided in those procedures.

3. Member States shall ensure that information on both integrated and separate

recognition procedures is readily available to applicants to support informed

decision-making.

4. With the applicant’s consent, Member States may inform a current or prospective

employer of the outcome of the recognition or assessment referred to in paragraph 1,

in particular where that outcome is relevant to a procedure for employment-based

admission.

Title IV

Common provisions

Article 27

Documentation and formalities

1. Where the competent authorities of the host Member State decide on the recognition

of a qualification by virtue of Title II or Article 26, those authorities may require

solely the types of documents and certificates listed in Annex VII of Directive

2005/36/EC. Where the competent authorities of the host Member State decide on

the recognition of a qualification by virtue of Articles 24 and 25 as part of a

procedure to obtain a long-stay visa or a residence permit, for the purpose of the

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recognition of the qualification those authorities may demand solely the types of

documents listed in Annex VII of Directive 2005/36/EC, point 1(b). This limitation

on the documents that can be required for the purpose of recognising a qualification

is without prejudice to any other document requirements applicable under Union or

national law for the part of the examination of the application for a long-stay visa or

a residence permit that is unrelated to the recognition of the qualification.

2. For the purposes of this Directive, where the documents requested are to be provided

by another Member State or a third country, the references to “home Member State”

or “the Member State from which the foreign national comes” in Annex VII of

Directive 2005/36/EC shall be understood as referring to the other Member State or

the third country, as applicable.

3. Where the host Member State imposes requirements as to the date of issue of the

documents referred to in Annex VII of Directive 2005/36/EC, point 1(d), (e) and (f),

it shall accept documents issued within the three months preceding the date on which

they are submitted.

The Member States, bodies and other legal persons involved in the process shall

guarantee the confidentiality of the information which they receive.

4. In cases of justified doubts, the host Member State may, after obtaining agreement

from the applicant, require from the competent authorities of a Member State or a

third country confirmation of the authenticity of the attestations and evidence of

formal qualifications awarded in that other Member State or the third country.

5. Where a digital credential is issued under a trusted framework provided in

Regulation (EC) No 910/2014 it shall be presumed authentic unless the competent

authority has concrete and specific indications that the credential is not authentic.

6. In cases of justified doubt, where evidence of formal qualifications, as defined in

Article 3(e), has been issued by a competent authority in a Member State and

includes training received in whole or in part in an establishment legally established

in the territory of another Member State, the host Member State shall be entitled to

verify with the competent body in the Member State of origin of the award all of the

following:

(a) whether the training course at the establishment which gave the training has

been formally certified by the educational establishment based in the Member

State of origin of the award;

(b) whether the evidence of formal qualifications issued is the same as that which

would have been awarded if the course had been followed entirely in the

Member State of origin of the award;

(c) whether the evidence of formal qualifications confers the same professional

rights in the territory of the Member State of origin of the award.

7. In cases of justified doubts, the host Member State may require from the competent

authorities of a third country or of a Member State confirmation of the fact that the

applicant is not suspended or prohibited from the pursuit of the profession as a result

of serious professional misconduct or conviction of criminal offences relating to the

pursuit of any of their professional activities.

8. Where the applicant duly documents that, despite reasonable efforts, he was unable

to obtain the documents referred to in paragraph 1, or the host Member State cannot

obtain the confirmations referred to in paragraph 4 or paragraph 7 of this Article,

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from the third country, the host Member State shall assess the feasibility of, and

where appropriate, employ alternative methods to assess qualifications, skills or

other evidentiary elements. Those methods may include affidavits, third-party

assessments, professional interviews, or reputable evaluation frameworks, like

qualifications passports designed for refugees and vulnerable migrants. The host

Member State shall ensure that applicants are not unduly disadvantaged due to those

circumstances and shall base its decisions on available and reasonable evidence.

9. Where a host Member State requires its nationals to swear a solemn oath or make a

sworn statement in order to gain access to a regulated profession, and where the

wording of that oath or statement cannot be used by a third-country national, the host

Member State shall ensure that the person concerned can use an appropriate

equivalent wording.

10. Member States shall accept the documents referred to in paragraph 1 in any of the

official languages of the Union.

Article 28

Support Services for the Assessment of Authenticity

1. The Commission shall provide support services for the assessment of authenticity.

2. In providing these services, the Commission shall support Member States in the

recognition of qualifications obtained in a third country by offering assessments on

the authenticity of submitted evidence of formal qualifications.

3. At the request of a competent authority of a Member State, the Commission shall

assess the authenticity of qualifications, diplomas, certificates or other evidence of

formal qualifications issued in a third country and submitted in the context of an

application falling within the scope of this Directive, in particular by utilising digital

tools, international databases and through cooperation with third countries and

educational and professional bodies. Requests shall be submitted electronically and

be accompanied by the documents necessary for the assessment and proof of

payment of any applicable fee referred to in paragraphs 7 and 8.

4. The Commission shall provide the requesting Member State with a substantiated

assessment of authenticity, including detailed explanations of the evaluation process

and findings. That assessment shall be advisory in nature and shall not be binding on

competent authorities of the Member States who shall remain solely responsible for

the recognition decision.

5. For the purposes of paragraph 3, the Commission is empowered to conclude

administrative arrangements, aimed at facilitating the exchange of information

necessary for the assessment of authenticity, with the competent authorities of third

countries and with international or professional bodies responsible for the issuance or

accreditation of qualifications. The Commission shall cooperate, where relevant,

with Union delegations to third countries and EU agencies. Such arrangements shall

not create binding obligations under international law on the Union.

6. The Commission shall respond to a request submitted pursuant to paragraph 3 within

three weeks of receipt of the complete documentation referred to in that paragraph.

Where the Commission is unable to provide an assessment within that period, in

particular due to the need to obtain information from a third-country authority or

body referred to in paragraph 3, it shall inform the requesting competent authority

EN 39 EN

without delay, indicating the reasons for the delay and the anticipated timeframe for

completion.

7. The Commission may charge a cost-recovery fee to the requesting competent

authority for the provision of the assessment referred to in paragraph 3.

8. The Commission shall, by means of implementing acts, adopt uniform rules

regarding:

(a) the calculation methodology for determining cost recovery;

(b) the applicable fee amounts and payment modalities;

(c) specific cases where fee exemptions or reductions apply, in particular for

beneficiaries of international protection or applicants in demonstrably

vulnerable situations.

Those implementing acts shall be adopted in accordance with the examination

procedure referred to in Article 38.

9. In relation to personal data processed for the provision of support services for the

assessment of authenticity, the Commission shall act as controller within the

meaning of Article 3(8) of Regulation (EU) 2018/1725 and shall ensure, in

accordance with Article 33 of that Regulation, the security of the processing by

implementing appropriate technical and organisational measures, taking into account

the nature of the personal data processed, including where submitted documents may

incidentally contain special categories of personal data, referred to in paragraph 10.

10. For the purpose of carrying out the tasks referred to in paragraph 3, the Commission

may process the following categories of personal data, to the extent strictly necessary

for a given assessment:

(a) the applicant's identification data as contained in the evidence of formal

qualifications submitted;

(b) data relating to the submitted qualifications, diplomas, certificates or other

evidence of formal qualifications issued in a third country, including the

awarding institution, date of issue, field and level of study, and any identifiers

or security features of the document.

The Commission shall not process special categories of personal data within the

meaning of Article 10 of Regulation (EU) 2018/1725. Where documentation

submitted by a competent authority incidentally contains such data, the Commission

shall ensure that those data are not retained and are deleted without delay.

11. Personal data processed for the purpose of assessing authenticity shall be retained

only for as long as necessary for that purpose and, in any event, for no longer than

12 months from the date on which the assessment is provided to the requesting

competent authority, unless a longer period is necessary for the purposes of an

ongoing appeal, audit or investigation, in which case the data shall be erased without

delay thereafter.

12. The Commission shall periodically report on the support services for the assessment

of authenticity to ensure transparency and continued improvement. Member States

are encouraged to provide feedback to facilitate enhancements in service delivery.

13. The Commission is empowered to adopt delegated acts in accordance with Article 36

laying down the organisational and technical measures necessary for the provision of

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the support services, and for the security of processing of personal data, including as

regards the systems used for the exchange of requests and supporting documents

between the Commission and the competent authorities of the Member States, access

to such systems, the interfaces made available to competent authorities of the

Member States, the data sources to be consulted and arrangements for keeping them

up to date, and the administrative and operational management of these services.

Article 29

Recognition procedure

1. For procedures under Title II and under Article 26, the host Member State shall

ensure that:

(a) the competent authority acknowledges receipt of the application for recognition

of professional qualifications within one month of receipt and informs the

applicant of any missing document;

(b) the procedure for examining an application for the recognition of professional

qualifications is completed as quickly as possible and leads to a duly

substantiated decision by the competent authority in the host Member State

within three months after the date on which the applicant submitted the

complete application with the required evidence.

The deadline provided for in the first subparagraph, point (b), may be extended by

one month except in cases falling under Title II, Chapter 3.

2. For procedures under Title III, except those covered by Article 26, recognition shall

not extend, suspend or otherwise affect, any time limits or procedural deadlines

applicable under Union or national law to the examination of and decision on the

application for a long-stay visa or a residence permit. Member States shall ensure

that the organisation of the recognition procedure does not undermine the effective

processing of the application for a long-stay visa or a residence permit within the

applicable time limits.

3. The decision on the application for recognition of professional qualifications, or

failure to reach a decision, within the deadline, shall be subject to appeal under

national law.

4. Applicants shall receive regular updates regarding the progress and current status of

their application, including information on the specific stage within the procedural

process.

5. The host Member State shall offer applicants the choice to receive communications,

such as acknowledgments of receipt, decisions and any other information related to

the procedure, in an official language of that Member State, or in at least one other

language commonly spoken by incoming third-country nationals or third-country

nationals already legally residing in that Member State.

Article 30

Access to recognition procedures

1. The host Member State shall ensure that recognition procedures can be completed

remotely and by electronic means, and that third-country nationals who are not

residing in that Member State can access and complete recognition under Titles II

EN 41 EN

and III remotely from their country of residence. Such a possibility shall not prevent

the competent authorities of the host Member State from requesting certified copies

at a later stage in the event of justified doubts and where strictly necessary.

2. The host Member State shall grant or extend the validity of residence permits to

third-country nationals who fulfil all of the following conditions:

(a) they are legally residing in the host Member State;

(b) they can demonstrate an ongoing effort to secure employment in the profession

concerned, such as registration with a public employment service, submission

of job applications, or a conditional offer of employment;

(c) they have applied for recognition of their professional qualifications under

Title II or Article 26 at least four months before their long-stay visa or

residence permit expires.

Member States shall ensure that the residence permit remains valid during the

recognition procedure, including where procedural delays occur that are not

attributable to the applicant.

3. Member States shall grant or extend the validity of residence permits for the period

needed for completing compensation measures required pursuant to Article 9 to

third-country nationals legally residing in the Member State, unless it can be

established at the time of the application for recognition of their professional

qualifications that the third-country national does not satisfy the other conditions for

the issuance of such a permit.

Article 31

Fees and charges

1. A host Member State shall either waive fees for recognition procedures and

compensation measures or, except for the cases referred to in Article 23(2), point (d),

ensure that any fees charged do not exceed the actual cost incurred in providing the

service to applicants.

2. By way of derogation from paragraph 1, Member States may impose flat-rate charges

if they can be justified by the average cost of providing the service to applicants.

3. Member States shall ensure that detailed information on the structure of the fee and

justification for any charges imposed as part of the recognition process is publicly

available and easily accessible and shall actively inform applicants of this

information before the recognition process begins.

Article 32

Information provision

1. Member States shall ensure that third-country nationals, irrespective of whether they

reside within or outside their territory, have access to timely, comprehensive and

user-friendly information and support concerning procedures for the recognition of

qualifications under this Directive.

2. The information referred to in paragraph 1 shall cover the following aspects:

(a) applicable legal and administrative requirements;

EN 42 EN

(b) procedural steps, expected timelines and applicable costs;

(c) the rights and obligations of applicants;

(d) available remedies, appeal mechanisms and complaint procedures.

3. Member States shall ensure that the information they provide in accordance with

paragraph 2 clearly distinguishes and explains the different procedures laid down

in Titles II and III.

4. Where applicable, Member States shall provide comprehensive information on

compensation measures, including adaptation periods, aptitude tests, tests of

professional competence and bridging courses, as referred to in Articles 9 and 25,

covering their organisation, conditions, obligations for applicants, and other relevant

practical arrangements.

5. Where applicable, Member States shall provide comprehensive information on any

complementary measures available to third-country nationals, including language

courses and integration support, reskilling or upskilling pathways, and links to

employment services.

6. Member States shall ensure that refugees, beneficiaries of subsidiary protection in

accordance with Regulation (EU) 2024/1347 have access to tailored information,

assistance and support services, considering their specific legal status, needs and

vulnerabilities.

7. To facilitate a coherent and user-friendly experience, Member States shall, where

appropriate, organise information provision through coordinated or streamlined

arrangements, including digital platforms, and activities of the national assistance

centres as laid down in Article 34.

8. Member States shall ensure that the information referred to in this Article is also

made available on existing Union tools and platforms.

9. Member States shall ensure that the information provided pursuant to this Article is

regularly reviewed and kept up to date. They shall put in place mechanisms to collect

and analyse feedback from third-country nationals, with a view to improving the

quality, clarity, accessibility and coherence of the information and of the support

services.

10. Member States and the competent authorities involved shall ensure the

confidentiality of personal and sensitive information obtained in the context of

information provision and assistance, in accordance with applicable Union and

national law.

Title V

Reporting and final provisions

Article 33

Group on the recognition of qualifications of third-country nationals

1. Member States shall assist one another in the implementation of this Directive.

2. A group on the recognition of qualifications of third-country nationals (‘the Group’)

is established as an advisory group to the Commission.

3. The Group's tasks shall be the following:

EN 43 EN

(a) promoting uniform application of this Directive;

(b) contributing to the effective cooperation between Member States’ authorities

and the Commission with regards to matters covered by this Directive;

(c) advising the Commission, as appropriate, in the early preparations of draft

implementing acts to be adopted pursuant to this Directive;

(d) contributing to the smooth cooperation with other relevant expert groups;

(e) facilitating the exchange of experience and best practices for an efficient and

effective organisation of recognition of qualifications of third-country

nationals, including through outreach to professionals, their representative

organisations and social partners, quality assurance agencies and qualifications

recognition networks.

4. Each Member State shall appoint one representative and one alternate representative

to the Group.

5. The Group shall be chaired by the Commission. The Commission shall provide the

Group’s Secretariat.

On a proposal by the Commission, the Group shall adopt its rules of procedure.

6. The Group shall meet at regular intervals that allow the Group to effectively perform

its tasks provided for in this Directive.

Article 34

Assistance centres

The assistance centres designated by Member States pursuant to Article 57b of Directive

2005/36/EC shall provide assistance on the recognition of qualifications relating to third-

country nationals provided for in this Directive, for the benefit of third-country nationals

including through cooperation, where appropriate, with employers, other contact points, and

authorities in other Member States and third countries.

The assistance centres shall operate without prejudice to the responsibilities of other

competent authorities under Union or national law.

Article 35

Alert mechanism

Where a third-country national is restricted or prohibited, including on a temporary basis, by a

national authority or court from pursuing, in whole or in part, on the territory of a Member

State, any of the professional activities referred to in Article 56a(1) of Directive 2005/36/EC,

the competent authority of that Member State shall inform the competent authorities of all

other Member States. For this purpose Article 56a of Directive 2005/36/EC shall apply

mutatis mutandis.

Article 36

Exercise of the delegation

EN 44 EN

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts referred to in Article 12(3) and Article 16(2) shall

be conferred on the Commission for a period of five years from the entry into force

of this Directive. The Commission shall draw up a report in respect of the delegation

of power not later than nine months before the end of the five-year period. The

delegation of power shall be tacitly extended for periods of an identical duration,

unless the European Parliament or the Council opposes such an extension not later

than three months before the end of each period.

3. The delegation of power referred to in Article 12(3) and Article 16(2) may be

revoked at any time by the European Parliament or by the Council. A decision to

revoke shall put an end to the delegation of the power specified in that decision. It

shall take effect on the day following the publication of the decision in the Official

Journal of the European Union or at a later date specified therein. It shall not affect

the validity of any delegated acts already in force.

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. A delegated act adopted pursuant to Article 12(3) and Article 16(2) shall enter into

force only if no objection has been expressed either by the European Parliament or

the Council within a period of two months of notification of that act to the European

Parliament and the Council or if, before the expiry of that period, the European

Parliament and the Council have both informed the Commission that they will not

object. That period shall be extended by two months at the initiative of the European

Parliament or the Council.

Article 37

Statistics

1. By [31 May of the year following the third year of entry into force], and annually

thereafter, Member States shall report to the Commission statistics on the

implementation of this Directive. Those statistics shall cover the previous calendar

year and include the following information:

(a) the number of applications received and handled, and decisions taken,

disaggregated by:

(i) citizenship;

(ii) occupation;

(iii) status (i.e. the residence or migration status under which the third-

country national is present or seeking to be present in the Union);

(iv) type of procedure (procedures under Article 6; Title II, Chapter 2; Title

II, Chapter 3; Article 24, Article 25 and Article 26);

(v) outcome of the decision (positive, positive with partial access; positive

with compensation measure, broken down by type of compensation

measure; negative);

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(b) the proportion of applications that are complete at first submission;

(c) the average duration of processing applications;

(d) the average number of information exchanges per case;

(e) the number of authenticity checks requested.

2. The Commission shall make a summary of the information provided in accordance

with paragraph 1 publicly available.

Article 38

Committee procedure

1. The Commission shall be assisted by the Committee on the Recognition of

Professional Qualifications established by Article 58(1) of Directive 2005/36/EC.

That committee shall be a committee within the meaning of Regulation (EU) No

182/2011.

2. Where reference is made to this paragraph, Article 5 of Regulation (EU) No

182/2011 shall apply.

Article 39

Reports

1. By 31 May [of the year following the third year of entry into force], and every

five years thereafter, Member States shall submit a report to the Commission on the

application of this Directive. The report shall contain the following information

regarding the recognition of qualifications in the context of procedures for access to

regulated professions and for obtaining a long-stay visa or residence permit:

(a) processing times of applications;

(b) outcomes;

(c) user experience;

(d) results of the review of the procedures, including constraints and areas

requiring improvement identified.

As part of preparing the report, Member States shall collect feedback from

employers, professional bodies, third-country nationals, and other stakeholders.

2. No sooner than seven years after the date of transposition of this Directive,

the Commission shall carry out an evaluation of this Directive and present a report

on the main findings to the European Parliament and the Council. Member States

shall provide the Commission with the information necessary for the preparation of

that report.

Article 40

Transposition

1. Member States shall bring into force the laws, regulations and administrative

provisions necessary to comply with this Directive by [2 years after entry into force]

at the latest. They shall forthwith communicate to the Commission the text of those

provisions.

EN 46 EN

When Member States adopt those provisions, they shall contain a reference to this

Directive or be accompanied by such a reference on the occasion of their official

publication. Member States shall determine how such reference is to be made.

2. Member States shall communicate to the Commission the text of the main provisions

of national law which they adopt in the field covered by this Directive.

Article 41

Entry into force

This Directive shall enter into force on the twentieth day following that of its publication in

the Official Journal of the European Union.

Article 42

Addressees

This Directive is addressed to the Member States in accordance with the Treaties.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

[...] [...]

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LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Directive of the European Parliament and of the Council on the

recognition of qualifications of third-country nationals

1.2. Policy area(s) concerned

Employment, social affairs and inclusion. The initiative is also relevant to the

internal market policy area (recognition of professional qualifications) and to the

migration and home affairs policy area (legal migration and integration of third-

country nationals), given its interaction with Directive 2005/36/EC and with the

Union's legal migration acquis.

1.3. Objective(s)

1.3.1. General objective(s)

To facilitate the recognition of qualifications held by third-country nationals so as to

help address labour and skills shortages in the Union.

1.3.2. Specific objective(s)

Specific objective No

1. Streamlined recognition systems within and between Member States: Improved

alignment and consistency between national recognition systems across the EU, and

coherence within Member States, between recognition procedures for access to

regulated professions and those embedded in migration regimes.

2. Reduced legal and administrative complexity for recognition of qualifications of

third-country nationals: Clearer and less burdensome requirements, documentation

and procedural steps for third-country national applicants, employers and authorities,

including, reduced administrative steps and enhanced user-friendliness.

3. Increased trust and understanding of qualifications obtained in third countries:

Improved transparency, comparability and trust of third-country qualifications within

the EU, through enhanced information availability and mechanisms that support the

assessment of foreign qualifications and skills.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the

beneficiaries/groups targeted.

For third-country national applicants: shorter and more predictable recognition

procedures, clearer information on requirements, and a genuine prospect of

recognition for qualifications obtained outside the Union, with an associated increase

in the probability of employment matched to their qualification level and a reduction

in the incidence of overqualification. For employers, including SMEs: faster access

to recognised professionals, reduced administrative costs linked to hiring, and

improved ability to fill vacancies in sectors facing structural shortages, including

healthcare. For competent authorities and Member States: reduced administrative

burden and duplication of effort, more consistent decision-making, and stronger

evidence and cooperation channels through which to identify and act on fraudulent

documentation. For the Union as a whole: a measurable contribution to addressing

EN 48 EN

labour and skills shortages and to the coherence of the Union's approach to legal

migration.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

General objective

(a) Share of third-country nationals in qualification-matched employment within 12

months of arrival

(b) Number of recognition procedures initiated and completed per year by third-

country nationals

Specific objective 1

(a) Share of cases requiring parallel submissions (duplicate qualification checks

across recognition and migration procedures)

(b) Number of cases requiring re-submission or additional information, as a share of

total applications

(c) Share of recognition applications submitted digitally

Specific objective 2

(a) Average end-to-end processing time per recognition procedure, by Member States

and procedure type

(b) Average number of documents requested per application, including certified

translations

(c) Estimated applicant-side cost per recognition procedure Share of complete

applications at first submission

Specific objective 3

(a) Number of authenticity checks processed via the EU-level service per year

(b) Share of CA reporting sufficient information on third-country qualification

systems to make timely decisions without requesting additional documentation or

compensation measures

(c)Processing time for sectoral professions under automatic recognition channel

1.4. The proposal/initiative relates to:

☑ a new action

☐ a new action following a pilot project/preparatory action (1)

☐ the extension of an existing action

☐ a merger or redirection of one or more actions towards another/a new

action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

(1) As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 49 EN

In the short term, Member States will need to transpose the Directive's common

procedural rules (timeframes, information requirements, single points of contact)

within the transposition deadline of 2 years. The Commission will need to establish

the authentication service and make it operational and adopt any implementing

measures needed to specify the professions eligible for automatic recognition. In the

longer term, full-scale operation of the automatic recognition channel and of the

authentication service will require ongoing coordination with Member States,

competent authorities and third countries, periodic review of the list of professions

covered, and monitoring of implementation.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante) Recognition of third-country qualifications

is currently handled through divergent national procedures, with no common Union

framework equivalent to Directive 2005/36/EC for intra-EU mobility. This

fragmentation generates duplicated authenticity checks across Member States,

inconsistent outcomes for applicants with comparable qualifications, and an absence

of the trust infrastructure needed to support automatic recognition for professions

facing acute shortages. Individual Member States acting alone cannot replicate the

economies of scale of a shared authenticity-verification service, nor secure the cross-

border consistency needed to build mutual trust between competent authorities.

Expected generated EU added value (ex-post) A common Union framework is

expected to reduce duplication and verification costs across Member States, increase

the consistency and speed of recognition decisions, and strengthen the Union's

collective ability to address labour and skills shortages, in a manner that no

individual Member State could achieve acting alone.

1.5.3. Lessons learned from similar experiences in the past

The experience of Directive 2005/36/EC demonstrates that a common Union

framework for recognition, combined with structured administrative cooperation

(competent authority networks, the Internal Market Information system), can

substantially reduce recognition timeframes and improve consistency, while showing

that purely voluntary cooperation (as tested under Policy Option 1 in the impact

assessment) is insufficient to achieve comparable results at Union level. The

Directive's existing minimum training requirements for a number of professions offer

a further lesson, showing that agreement on common substantive standards, and not

only procedural rules, can itself be a basis for building trust and cooperation between

competent authorities, a precedent relevant to the design of the automatic recognition

channel under this initiative. The Council Recommendation of 22 December 2020 on

a comprehensive approach to the recognition of qualifications of third-country

nationals offers a related lesson, in that its non-binding, voluntary approach has not

resulted in the level of convergence or consistency needed across Member States,

reinforcing the case for the more binding measures proposed under this initiative.

The German Federal Recognition Act experience shows that formalised recognition

procedures for foreign qualifications are associated with a measurable increase in the

probability of qualification-matched employment.

EN 50 EN

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

This proposal is compatible with the Commission’s proposal for the Multiannual

Financial Framework 2028-2034. It generates synergies with Action 1 of the Skills

Portability Initiative, with Directive 2005/36/EC as amended under Action 2, and

with instruments under the Fair Labour Mobility Package and the EU Talent Pool.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The preferred financing option is direct financing from the Union budget, as the

initiative requires the development, deployment and operation of a common

European authentication system that will be used across all Member States. A

centrally financed solution ensures economies of scale, avoids duplication of costs,

and guarantees interoperability and consistent implementation across the Union.

Alternative approaches based on separate national developments or decentralised

financing would require multiple parallel investments, increase integration costs and

create risks of fragmentation and inconsistent implementation. Financing through

existing Union programmes and budgetary resources allows the initiative to build on

existing digital infrastructure and expertise while ensuring efficient use of Union

funds. Where appropriate, existing resources will be redeployed to support the

implementation of the initiative.

The current proposal entails additional staff costs under Heading 4 of the proposal

for the 2028-2034 multiannual financial framework, as it is a new action. For

operational costs, it builds on the Commission proposal for National and Regional

Partnership Plans and its EU Facility under Heading 1 of the 2028-2034 multiannual

financial framework, subject to its adoption, and the EU annual budgetary procedure.

1.6. Duration of the proposal/initiative and of its financial impact

☐ limited duration

☐ in effect from [DD.MM]YYYY to [DD.MM]YYYY

☐ financial impact from YYYY to YYYY for commitment appropriations

and from YYYY to YYYY for payment appropriations.

☑ unlimited duration

Implementation with a start-up period from YYYY to YYYY,

followed by full-scale operation.

1.7. Method(s) of budget implementation planned(2)

☐ Direct management by the Commission

☑ by its departments, including by its staff in the Union delegations;

☐ by the executive agencies

☐ Shared management with the Member States

(2) Details of budget implementation methods and references to the Financial Regulation may be found on

the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 51 EN

☐ Indirect management by entrusting budget implementation tasks to:

☐ third countries or the bodies they have designated;

☐ international organisations and their agencies (to be specified);

☐ the European Investment Bank and the European Investment Fund;

☐ bodies referred to in Articles 70 and 71 of the Financial Regulation;

☐ public law bodies;

☐ bodies governed by private law with a public service mission to the

extent that they are provided with adequate financial guarantees;

☐ bodies governed by the private law of a Member State that are entrusted

with the implementation of a public-private partnership and that are

provided with adequate financial guarantees;

☐ bodies or persons entrusted with the implementation of specific actions in

the common foreign and security policy pursuant to Title V of the Treaty

on European Union, and identified in the relevant basic act

☐ bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance

with sector-specific rules, with the implementation of Union funds or

budgetary guarantees, to the extent that such bodies are controlled by

public law bodies or by bodies governed by private law with a public

service mission, and are provided with adequate financial guarantees in

the form of joint and several liability by the controlling bodies or

equivalent financial guarantees and which may be, for each action,

limited to the maximum amount of the Union support.

Comments

[...]

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

The Commission will monitor implementation on a continuous basis through the

indicators set out in section 1.3.4, drawing on administrative data reported by

Member States' competent authorities, authentication service caseload and

processing-time data, and periodic surveys of competent authorities. Member States

will report on transposition and on the functioning of national recognition procedures

in accordance with the reporting obligations set out in the Directive. The

Commission will carry out an evaluation in accordance with the Better Regulation

Guidelines within 7 years of the deadline for transposition, assessing effectiveness,

efficiency, coherence, relevance and EU added value against the general and specific

objectives.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

Direct management, as per article 62.1(a) of the Financial Regulation, is the

preferred mode of implementation, as the actions will be carried out by the European

EN 52 EN

Commission, specifically Directorate-General for Employment, Social Affairs and

Inclusion (DG EMPL), which will ensure the coordination with Member States and

the various stakeholders.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The controls are part of the internal control system of DG EMPL. The new activities

will be subject to the same risk identification and mitigation approach.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The controls are integrated into the internal control system of DG EMPL. The new

activities will generate negligeable additional control costs at DG level.

2.3. Measures to prevent fraud and irregularities

The Commission shall ensure that, when actions financed are implemented, the

financial interests of the Union are protected by the application of preventive

measures against fraud, corruption and any other illegal activities, by effective

checks and by the recovery of the amounts unduly paid and, if irregularities are

detected, by effective, proportional and dissuasive penalties. The Commission is

authorised to carry out checks and verifications in situ under this Decision, in

compliance Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996

concerning on-the-spot checks and inspections carried out by the Commission in

order to protect the European Communities financial interests against fraud and other

irregularities. If need be, investigations shall be carried out by the European Anti-

Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the

European Parliament and of the Council of 25 May 1999 concerning investigations

conducted by the European Anti-Fraud Office.

EN 53 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s) affected

Existing budget lines

In order of multiannual financial framework headings and budget lines.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and

does not pre-judge the next Multiannual Financial Framework. The source of financing and scope of Union financial

commitment in the post-2027 period remain subject to the outcome of interinstitutional negotiations on the MFF

2028-2034 and thereafter shall be determined through the annual budgetary procedure. All appropriations and staffing

allocations as of 2028 are indicative.

Heading of multiannual

financial framework

Budget line

Type of

expendit

ure

Contribution

Number Diff./No

n-diff. (3)

from

EFTA

countries (4)

from

candidat

e

countries

and

potential

candidat

es (5)

from

other

third

countrie

s

other assigned

revenue

1

To be determined after the

adoption of the MFF and

in the context of the

annual budgetary

Diff./No

n-diff. YES/NO YES/NO YES/NO NO

(3) Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. (4) EFTA: European Free Trade Association. (5) Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 54 EN

procedure for the EU

Facility – Successor of 07

02 04 00 – ESF+ EaSI

strand

New budget lines requested

In order of multiannual financial framework headings and budget lines.

Heading

of

multiannu

al

financial

framework

Budget

line

Type of

expenditur

e

Contribution

Number Diff./non-

diff.

from

EFTA

countries

from

candidate

countries

and

potential

candidates

from other

third

countries

other

assigned

revenue

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

☐ The proposal/initiative does not require the use of operational appropriations

EN 55 EN

☑ The proposal/initiative requires the use of operational appropriations, as explained below:

3.2.1.1. Appropriations from voted budget

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the

next Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the

annual budgetary procedure. All appropriations and staffing allocations as of 2028 are indicative

EUR million (to three decimal places)

Heading of multiannual financial framework Number 1 - Economic, social and territorial cohesion,

agriculture, rural and maritime prosperity and security

DG: EMPL Year

2028

Year

2029

Year

2030

Year

2031

Yea

r 2

032

Year 2

033

2034

and

subsequ

ent

years

TOTAL MFF

2028-2034

Operational appropriations

Budget line – successor 07

02 04

Commit

ments (1a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s (2a) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Appropriations of an administrative nature financed from the envelope of specific programmes (6)

Budget line (3) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

(6) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 56 EN

TOTAL appropriations

for DG EMPL

Commit

ments

=1a+1

b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s

=2a+2

b+3 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Heading 1 Year

2028

Year

2029

Year

2030

Year

2031

Yea

r 203

2

Year

2033

2034

and

subsequ

ent

years

TOTAL MFF

2028-2034

TOTAL operational

appropriations

Commit

ments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(6) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING 1

of the multiannual financial

framework

Commit

ments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Heading of multiannual financial

framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

EN 57 EN

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes (7)

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

(7) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 58 EN

Appropriations of an administrative nature financed from the envelope of specific programmes (8)

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Heading 1 Year

2028

Year

2029

Year

2030

Year

2031

Yea

r 2

032

Year 2

033

2034

and

subsequ

ent

years

TOTAL MFF

2021-2027

TOTAL operational

appropriations

Commit

ments (4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(6) 0 0 0 0 0 0 0 0

TOTAL appropriations

under HEADING 1

of the multiannual financial

framework

Commit

ments =4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payment

s =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

(8) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 59 EN

Year

2028

Year

2029

Year

203

0

Year

2031

Year

2032

Year

2033

2034

and

subsequ

ent

years

TOTAL MFF

2021-2027

TOTAL operational

appropriations (all

operational headings)

Com

mitme

nts

(4) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Paym

ents (5) p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations of an

administrative nature financed from

the envelope for specific

programmes (all operational

headings)

(6) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

TOTAL appropriations

Under Heading 1 to 3

of the multiannual financial

framework

(Reference amount)

Com

mitme

nts

=4+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Paym

ents =5+6 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Heading of multiannual financial framework 4 ‘Administrative expenditure’ (9)

DG: EMPL Year

2028

Year

2029 Year

203

Year

2031

Year

2032

Year

2033 2034

and

TOTAL MFF

2021-2027

(9) The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 60 EN

0 subsequ

ent

years

Human resources 0.582 0.582 0.58

2 0.582 0.582 0.582 0.582 4.074

Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG EMPL Appropriations 0.582 0.582 0.58

2 0.582 0.582 0.582 0.582 4.074

TOTAL appropriations under HEADING

4 of the multiannual financial framework

(Total

commitme

nts = Total

payments)

0.582 0.582 0.582 0.582 4.074

EUR million (to three decimal places)

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

2034

and

subs

eque

nt

year

s

TOTAL MFF

2021-2027

TOTAL appropriations under

HEADINGS 1 to 4

of the multiannual financial

framework

Commitments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Payments p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

EN 61 EN

The staff needed to implement this proposal has been assessed at 3 full time equivalent (FTE), of which 1 are redeployed from existing

staff in the DG and 2 are to be covered by the redeployment pool of the Commission.

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indi

cate

obje

ctive

s

and

outp

uts

⇓

Year

2028

Year

2029

Year

2030

Year

2031

Enter as many years as necessary to show

the duration of the impact (see Section 1.6) TOTAL

OUTPUTS

Type (10)

Aver

age

cost

No Cost No Cost No Cost No Cost No Cost No Cost No Cost Total

No

Total

Cost

SPECIFIC

OBJECTIVE No 1 (11): [...]

Outp

ut p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Outp

ut

Outp

ut

(10) Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.). (11) As described in point 1.4.2. 'Specific objective(s)...'

EN 62 EN

Subtotal for specific

objective No 1 p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

SPECIFIC

OBJECTIVE No 2

...

Outp

ut

Subtotal for specific

objective No 2

SPECIFIC

OBJECTIVE No. 3

Outp

ut p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

Subtotal for specific

objective No. 3

TOTALS p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.2.3. Summary of estimated impact on administrative appropriations

☐ The proposal/initiative does not require the use of appropriations of an administrative nature

☑ The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033 2034 and

subsequent

TOTAL MFF

2021-2027

EN 63 EN

years

HEADING 4

Human resources 0.582 0.582 0.582 0.582 0.5

82

0.5

82

0.5

82 4.074

Other administrative expenditure 0.000 0.000 0.000 0.000 0.0

00

0.0

00

0.0

00 0.000

Subtotal HEADING 4 0.582 0.582 0.582 0.582 0.5

82

0.5

82

0.5

82 4.074

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0

00

0.0

00

0.0

00 0.000

Other expenditure of an administrative

nature 0.000 0.000 0.000 0.000

0.0

00

0.0

00

0.0

00 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.0

00

0.0

00

0.0

00 0.000

TOTAL 0.582 0.582 0.582 0.582

0.582

0.5

82

0.5

82 4.074

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure

and the steering mechanism. All appropriations and staffing allocations as of 2028 are indicative.

EN 64 EN

3.2.3.3. Total appropriations

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative

purposes only and does not pre-judge the next Multiannual Financial Framework. The source of

financing and scope of Union financial commitment in the post-2027 period remain subject to the

outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined

through the annual budgetary procedure and the steering mechanism. All appropriations and staffing

allocations as of 2028 are indicative.

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from

the DG that are already assigned to management of the action and/or have been redeployed within the DG, together, if necessary, with

any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary

constraints.

3.2.4. Estimated requirements of human resources

☐ The proposal/initiative does not require the use of human resources

☑ The proposal/initiative requires the use of human resources, as explained below

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs) (12)

VOTED APPROPRIATIONS Year

2028

Year

2029

Year

2030

Year

2031

Year

203

2

Year 2033 2034 and

subsequent years

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's

Representation Offices) 3 3 3 3 3 3 3

(12) Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed within

your DG and what are your net needs.

EN 65 EN

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

External staff (in FTEs)

20 02 01 (AC, END from the 'global envelope') 0 0 0 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU

Delegations) 0 0 0 0 0 0 0

Admin.

support line

[XX.01.YY.Y

Y]

at Headquarters 0 0 0 0 0 0 0

in EU Delegations 0 0 0 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0 0 0 0

TOTAL 3 3 3 3 3 3 3

This proposal is a new action and no current staff is assigned to this new task. The three FTE mentioned above are additional staff needed to

implement the proposal, to be covered by the redeployment pool of the Commission.

3.2.4.2. Financed from external assigned revenues

EN 66 EN

3.2.4.3. Total requirements of human resources

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading

7 or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts 3 0 N/A N/A

External staff

(CA, SNEs,

INT)

0 0 N/A N/A

The staff needed to implement this proposal has been assessed at 3 full time equivalent (FTE), of which 1 are redeployed from existing

staff in the DG and 2 are to be covered by the redeployment pool of the Commission.

Description of tasks to be carried out by:

Officials and temporary staff

Outsource the authentication services to an external entity by public

procurement, writing the specifications for the tendering procedure;

monitor the work of the selected entity; ensure the functioning of the

authentication services.

External staff

3.2.5. Overview of estimated impact on digital technology-related investments

EN 67 EN

Compulsory: the best estimate of the digital technology-related investments entailed by the proposal/initiative should be included in the

table below.

Exceptionally, when required for the implementation of the proposal/initiative, the appropriations under Heading 7 should be presented

in the designated line.

The appropriations under Headings 1-6 should be reflected as "Policy IT expenditure on operational programmes". This expenditure

refers to the operational budget to be used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation of the

initiative and their associated investments (e.g. licences, studies, data storage etc). The information provided in this table should be

consistent with details presented under Section 4 "Digital dimensions".

TOTAL Digital and IT

appropriations

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL

MFF

2021-2027

HEADING 4

IT expenditure (corporate) 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 4 0.000 0.000 0.000 0.000 0.000

Outside HEADING 4

Policy IT expenditure on

operational programmes 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING

4 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

EN 68 EN

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

☑ can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF).

☐ requires use of the unallocated margin under the relevant heading of the MFF

and/or use of the special instruments as defined in the MFF Regulation.

☐ requires a revision of the MFF.

EN 69 EN

3.2.7. Third-party contributions

The proposal/initiative:

☑ does not provide for co-financing by third parties

☐ provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034 Total

Specify the co-financing

body (EFTA, (potential)

candidate countries, third

countries)

p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

TOTAL appropriations co-

financed p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m.

3.3. Estimated impact on revenue

☑ The proposal/initiative has no financial impact on revenue.

☐ The proposal/initiative has the following financial impact:

☐ on own resources

☐ on other revenue

☐ please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

EN 70 EN

Budget revenue line:

Appropriations

available for the

current financial year

Impact of the proposal/initiative (13)

Year

2024

Year

2025

Year

2026

Year

2027

Article ..........

For assigned revenue, specify the budget expenditure line(s) affected.

[...]

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

[...]

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

If the policy initiative is assessed as having no requirement of digital relevance:

Justification of why digital means cannot be used to enhance policy implementation and why the ‘digital by default’ principle is not

applicable

[...]

Otherwise:

High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital

solutions and/or digital public services)

Reference to the

requirement

Requirement

description

Actors affected or

concerned by the

requirement

High-level Processes Categories

(13) As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20% for

collection costs.

EN 71 EN

Article 11

Paragraph 1c: Member

States shall recognise

evidence of formal

qualifications for

doctors (with basic and

specialised training),

nurses responsible for

general care, dental

practitioners, specialised

dental practitioners,

midwives, veterinary

surgeons, pharmacists,

and architects obtained

in a third country,

provided the following

conditions are met: (c)

The evidence of formal

qualifications is issued

as a digital credential,

ensuring authenticity,

security, and ease of

verification.

Member States Third

countries’ institutions

Issuance of

qualifications Data/ Digital solutions

Article 28 (1-3)

The Commission shall

provide support services

for the assessment of

authenticity.

1. In providing

these services, the

Commission shall shall

support Member States

in the recognition of

European Commission

provides the system for

Member States upload

evidence provided by

the applicant in the

system

Processing, assessment

and recognition of

evidence authenticity

Data/Digital

Solutions/Digitalisation-

automation of

activities/Digital Public

Services

EN 72 EN

qualifications obtained

in a third country by

offering assessments on

the authenticity of

submitted evidence of

formal qualifications.

2. At the request of

a competent authority of

a Member State, the

Commission shall assess

the authenticity of

qualifications, diplomas,

certificates or other

evidence of formal

qualifications issued in a

third country and

submitted in the context

of an application falling

within the scope of this

Directive, in particular

by utilising digital tools,

international databases

and through cooperation

with third countries and

educational and

professional bodies.

Requests shall be

submitted electronically

and be accompanied by

the documents necessary

for the assessment and

proof of payment of any

EN 73 EN

applicable fee referred

to in paragraph 8.

3. The Commission

shall provide the

requesting Member

State with a

substantiated assessment

of authenticity,

including detailed

explanations of the

evaluation process and

findings. That

assessment shall be

advisory in nature and

shall not be binding on

competent authorities of

the Member States who

shall remain solely

responsible for the

recognition decision.

Article 28 (8-11)

The processing of

personal data by the

Commission for the

purposes of the support

services for assessment

of authenticity shall

comply with Regulation

(EU) 2018/1725 and be

limited to what is

necessary and

proportionate for the

European Commission Processing of personal

data Data/ Digital solutions

EN 74 EN

performance of a task

carried out in the public

interest as laid down in

Article 5(1)(a) of

Regulation (EU)

2018/1725. The

Commission shall

ensure that personal data

is processed lawfully,

securely, and with the

necessary safeguards to

protect individuals’

privacy rights, including

data minimisation,

transparency, and access

rights for data subjects.

The Commission shall

periodically report on

the activities and

effectiveness of support

services to ensure

transparency and

continual improvement.

Member States are

encouraged to provide

feedback to facilitate

enhancements in service

delivery.

Article 30

Access to recognition

procedures Member

States shall ensure that

all requirements,

Member States

Applicants professionals

(users)

Recognition procedure Data/Digital public

services/Digital

Solutions/Digitalisation-

EN 75 EN

procedures and

formalities in

recognition procedures

may be easily

completed, remotely and

by electronic means.

This shall not prevent

competent authorities of

Member States from

requesting certified

copies at a later stage in

the event of justified

doubts and where

strictly necessary.

automation of activities

Article 36

Statistics Member States

shall communicate to

the Commission

statistics on the

implementation of this

Directive. Those

statistics shall cover the

previous calendar year

and include information

on the number of

applications received

and handled and

decisions taken, and

shall be disaggregated

by citizenship, by

occupation, status

(beneficiaries of

international protection,

European Commission

Member States

Statistics on the

recognition processes

Data/Digital

Solutions/Digitalisation-

automation of activities

EN 76 EN

beneficiaries of the right

to free movement, etc),

type of procedure

(Article 6; Title II,

Chapter 2; Title II,

Chapter 3; Article 23;

Article 24 or Article 25),

and outcome of the

decision (positive,

positive with partial

access; positive with

compensation measure,

broken down by type of

compensation measure;

negative). They shall

also include the share of

complete applications at

first submission, average

processing times,

average information

exchanges per case, and

number of authenticity

checks requested.

Article 38

Reports Member States

shall send a report to the

European Commission

on the application of this

Directive. To this end,

Member States shall

collect data on

processing times,

outcomes, and user

European Commission

Member States

Reporting on the

recognition processes

Data/Digital public

services/Digital

Solutions

EN 77 EN

experience across both

procedures for access to

regulated professions

and for migration

purposes, and include

this information in the

report. They shall also

review the procedures to

report on identified

bottlenecks and

opportunities for

improvement. Member

States shall collect

feedback from

employers, professional

bodies, third-country

nationals, and other

stakeholders as part of

this exercise.

4.2. Data

High-level description of the data in scope

Type of data Reference to the requirement(s) Standard and/or specification (if

applicable)

Digital qualification attestations

Article 11 – Formal qualifications issued

as digital credentials by Third country

institutions/Article 28 – Support services

for assessment of authenticity, provided by

the Commission

N/A

Non-digital evidence of formal Article 28 – Support Services for Documents listed in Annex VII of

EN 78 EN

qualification and other supporting

evidence

Assessment of Authenticity Directive 2005/36/EC; accepted in any

official language of the Union

Personal information used for the support

services for assessment of authenticity,

provided by the Commission

Article 28 – Processing of personal data

by the Commission to provide support

services for assessment of authenticity

EUDPR (Reg. (EU) 2018/1725); data

minimisation, transparency and data-

subject access rights (Art. 28)

Annual statistical summary of recognition

procedures (includes number of

applications received and decisions,

breakdowns, outcomes, processing times

and delays)

Article 36

Report on the application of the Directive.

Member States shall send a report to the

European Commission with data regarding

the processing times, outcomes,

procedures on the recognition processes.

Moreover, this report should also include

the identification of bottlenecks and

opportunities for improvement. The

European Commission shall submit a

report to the European Parliament and the

Council on the application of the

Directive.

Article 38

Alignment with the European Data Strategy

Explanation of how the requirement(s) are aligned with the European Data Strategy

[...]

Alignment with the once-only principle

Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored

EN 79 EN

[...]

Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

[...]

Data flows

High-level description of the data flows

Type of data Reference(s) to the

requirement(s)

Actors who

provide the data

Actors who receive

the data

Trigger for the

data exchange

Frequency (if

applicable)

Type of data #1

Type of data # 2

4.3. Digital solutions

High-level description of digital solutions

Digital solution

Reference(s) to

the

requirement(s)

Main mandated

functionalities

Responsible

body

How is

accessibility

catered for?

How is

reusability

considered?

Use of AI

technologies (if

applicable)

Digital solution

#1

Digital solution

#2

EN 80 EN

For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments

Digital solution #1

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI Act

EU Cybersecurity framework

eIDAS

Single Digital Gateway and IMI

Others

Digital solution #2

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI Act

EU Cybersecurity framework

EN 81 EN

eIDAS

Single Digital Gateway and IMI

Others

4.4. Interoperability assessment

High-level description of the digital public service(s) affected by the requirements

Digital public service

or category of digital

public services

Description Reference(s) to the

requirement(s)

Interoperable Europe

Solution(s)(NOT

APPLICABLE)

Other interoperability

solution(s)

Support services for

assessment of

authenticity

The support services

will be tasked with

supporting Member

States in the recognition

of qualifications

obtained outside the

Union by offering

assessments on the

authenticity of

submitted evidence of

formal qualifications.

Requests to the service

shall be submitted

electronically. The

service might use digital

tools and international

databases to perform its

tasks.

Article 28 (1-3)

EN 82 EN

As mentioned in Article

28(12), delegated acts

will be prepared by the

Commission to set out

the organisational and

technical measures

required for the

operation of the service.

The interoperability

assessment of the

service will be carried

out in the context of

these delegated acts.

Impact of the requirement(s) as per digital public service on cross-border interoperability

Digital public service #1

Assessment Measure(s) Potential remaining barriers (if

applicable)

Alignment with existing digital and

sectorial policies. Please list the

applicable digital and sectorial policies

identified

Digital or sectorial policy #1 Digital or

sectorial policy #2 Digital or sectorial

policy #3

Barrier #1 Barrier #2 Barrier #3

Organisational measures for a smooth

cross-border digital public services

delivery. Please list the governance

measures foreseen

Governance measure #1 Governance

measure #2 Governance measure #3 Barrier #1 Barrier #2 Barrier #3

EN 83 EN

Measures taken to ensure a shared

understanding of the data. Please list

such measures

Measure #1 Measure #2 Measure #3 Barrier #1 Barrier #2 Barrier #3

Use of commonly agreed open technical

specifications and standards. Please list

such measures

Measure #1 Measure #2 Measure #3 Barrier #1 Barrier #2 Barrier #3

4.5. Measures to support digital implementation

High-level description of measures supporting digital implementation

Description of the

measure

Reference(s) to the

requirement(s) of

digital relevance that it

supports

Commission role (if

applicable)

Actors to be involved

(if applicable)

Expected timeline (if

applicable)

Measure #1

Measure #2

Measure #3

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 989 final

COMMISSION STAFF WORKING DOCUMENT

Subsidiarity Grid

Accompanying the document

Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

on the recognition of qualifications of third-country nationals

{COM(2026) 990 final} - {SEC(2026) 990 final} - {SWD(2026) 990 final} -

{SWD(2026) 991 final}

1

Subsidiarity Grid

1. Can the Union act? What is the legal basis and competence of the Unions’ intended action?

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative?

The proposal is based on Article 79(2)(a) and (b) of the Treaty on the Functioning of the European Union (TFEU). Article 79(2)(a) TFEU empowers the European Parliament and the Council, acting in accordance with the ordinary legislative procedure, to adopt measures on the conditions of entry and residence of third-country nationals, including standards on the issue of long-term visas and residence permits. Article 79(2)(b) TFEU provides the legal basis for measures defining the rights of third-country nationals legally residing in a Member State, including the conditions governing freedom of movement and of residence in other Member States. Recognition of qualifications is directly linked to the conditions of entry and residence within the meaning of Article 79(2)(a) TFEU, since access to employment, and therefore to residence for work purposes, often depends on whether qualifications acquired in a third country can be recognised. The action also supports the effective exercise of rights of third-country nationals legally residing in the Union under Article 79(2)(b) TFEU, by facilitating access to employment corresponding to their qualifications and skills. The envisaged Union action therefore falls within the scope of both Article 79(2)(a) and (b) TFEU.

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in nature?

The Union's competence is shared.

Article 79 TFEU falls within Title V TFEU (the Area of Freedom, Security and Justice), which Article 4(2)(j) TFEU identifies as an area of shared competence between the Union and the Member States. The Union and Member States therefore share competence in this area, with Union action and Member State action being complementary. The proposal does not seek to replace Member States' responsibility for defining which professions are regulated, organising national education and training systems, or taking migration and admission decisions, all of which remain primarily under national competence. Instead, it aims to establish common procedural rules to facilitate the recognition of qualifications of third-country nationals across the Union.

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?

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN 2 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN 3 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML 4 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN

2

- The proposal has been subject to extensive consultation activities. A Call for Evidence covering the Skills Portability Initiative (SPI), its three actions and envisaged policy options was published on 5 December 2025 and remained open until 27 February 2026. A Public Consultation was conducted in parallel, running from October 2025 to April 2026, in which 95.3% of respondents considered EU-level action very or somewhat necessary.

- In addition, targeted consultations were conducted between October 2025 and April 2026 with competent authorities, healthcare professional organisations, employers, civil society organisations and third-country nationals applicants (including a dedicated survey), together with bilateral meetings with Member States and written contributions from national governments. A full overview of the consultation activities and their results is summarised in Annex 2 (Stakeholder consultation synopsis report) of the Impact Assessment.

- The Impact Assessment contains a detailed problem definition, supported by qualitative and quantitative indicators, including an estimated average cost of EUR 1,500 and an average duration of 14.2 months per recognition procedure, with 70.4% of third-country nationals surveyed considering the length of the process a 'big' or 'very big' problem. The quantitative baseline, sensitivity analysis and cost estimates underpinning the appraisal of EU-level action are set out in Annex 4 (Analytical Methods).

2.2 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the conformity with the principle of subsidiarity?

The explanatory memorandum and Impact Assessment explain that the subsidiarity principle applies since the proposal does not fall under the exclusive competence of the EU. The objectives of the proposal cannot be sufficiently achieved by the Member States at national, regional or local level and can be better achieved at Union level for the following reasons:

• Divergent national recognition systems, combined with the absence — unlike for EU nationals under Directive 2005/36/EC (PQD) — of any comparable EU framework for third- country nationals, generate uncertainty and burden that individual Member State action cannot resolve;

• Recognition procedures for third-country nationals interact structurally with EU migration instruments adopted under Article 79 TFEU (such as the EU Blue Card, the EU Talent Pool and Talent Partnerships), whose effectiveness depends on recognition systems functioning adequately; Member States cannot individually address this structural misalignment between migration and recognition frameworks;

• The lack of trust in, and understanding of, third-country skills and qualifications is best addressed through EU-level tools (such as a shared authenticity-verification service and mutual learning on third-country qualification systems) that generate economies of scale which would be inefficient to replicate separately across 27 national systems.

Moreover, the identified gap stems from the personal scope of the Single Market legal basis underpinning the PQD, which is necessarily limited to EU nationals and cannot be extended by Member States acting alone to cover third-country nationals. Further EU action is therefore required to establish a framework equipping Member States with common tools to recognise third-country nationals qualifications more effectively.

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)?

No. The objectives of improving streamlined, simple and trusted recognition procedures for third- country nationals cannot be sufficiently achieved by Member States acting alone. A coordinated EU-level approach is necessary to address divergence between national systems, establish

3

common procedural rules and deliver more predictable outcomes across the Union. The Public Consultation confirmed this, with 95.3% of respondents considering EU-level action very or somewhat necessary. While Member States remain fully responsible for defining which professions are regulated, organising their national education and training systems, and taking individual recognition and admission decisions, no single Member State can establish a coherent, EU-wide approach to procedural consistency, information exchange on third-country qualifications, or coordination between recognition and migration authorities. These limitations stem from the design of the existing EU legal frameworks themselves (see Annex 8) and cannot be remedied by national action alone.

(a) Are there significant/appreciable transnational/cross-border aspects to the problems being tackled? Have these been quantified?

Yes. Recognition of qualifications of third-country nationals is inherently a cross-border phenomenon at EU level. The share of the EU working-age population born in a third country rose from approximately 8% in 2014 to 12.6% in 2024. The scale of the burden this generates has been quantified: an average cost of EUR 1,500 and an average duration of 14.2 months per recognition procedure, rising to years in some cases, with a further EUR 300 in administrative costs for migration-related recognition procedures outside regulated professions. These figures, along with the 95.3% Public Consultation result confirming the perceived necessity of EU-level action, are set out in the problem definition and Annex 4 of the Impact Assessment.

(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?

Yes. Persistent fragmentation in recognition procedures undermines the functioning of the Single Market and the EU's collective competitiveness in the global competition for talent, weakening the effectiveness of EU instruments such as the EU Blue Card, the EU Talent Pool, Talent Partnerships and the European Legal Gateway Office pilot, whose value depends on recognition systems functioning adequately. It also creates inconsistent treatment of third-country nationals and unpredictable outcomes for employers, including SMEs, operating across different Member States.

(c) To what extent do Member States have the ability or possibility to enact appropriate measures?

Member States remain responsible for defining regulated professions, organising national education and training systems, and taking migration and admission decisions. However, the Single Market legal basis underpinning the PQD is limited in personal scope to EU nationals and cannot be extended by Member States acting alone to cover third-country nationals. Member States acting individually therefore cannot establish a coherent, cross-cutting recognition framework applicable across the Union.

(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?

The scale of the problem varies with Member States' exposure to inbound migration of third- country nationals and the concentration of shortage sectors such as healthcare, ICT, construction and engineering, as well as with the existing degree of coordination between national migration and recognition authorities (see Annex 11, Diverging territorial impact of policy options). However, the underlying structural misalignment between migration and recognition frameworks is common

5 https://europa.eu/european-union/about-eu/eu-in-brief_en

4

across Member States and stems from the design of the relevant EU legal frameworks themselves (Annex 8), and therefore requires coordination beyond the national level.

(e) Is the problem widespread across the EU or limited to a few Member States?

The problem is Union-wide, even though its intensity varies. Third-country nationals represent a growing and substantial share of the EU workforce (12.6% of the working-age population in 2024), with nurse shortages recorded in 78% of Member States and specialist medical shortages in 75%. The challenges addressed by the proposal therefore affect Member States to different degrees but are Union-wide in nature, relating to the functioning of the internal market and the implementation of common EU migration rules.

(f) Are Member States overstretched in achieving the objectives of the planned measure?

This is less a question of national administrative capacity than of structural limits. Because the Single Market legal basis underpinning the PQD cannot be extended by Member States acting alone to cover third-country nationals, and because Article 79 TFEU migration instruments are not designed around qualification recognition, Member States cannot individually create the missing framework, regardless of their administrative capacity.

(g) How do the views/preferred courses of action of national, regional and local authorities differ across the EU?

Member States' positions diverge. Some explicitly support common rules modelled on the PQD's general system, adapted to reflect the diversity of third-country quality assurance standards. Others, offer conditional supporting views tied to avoiding new administrative burden and ensuring alignment with existing recognition frameworks. Several Member States more broadly stress the importance of preserving national flexibility over substantive recognition standards. These positions are reflected in the written contributions summarised in Annex 2 (Stakeholder consultation synopsis report) and in the wider consultation record described in the Impact Assessment.

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?

Yes. EU-level action supports the effectiveness of the EU's talent-attraction ecosystem (the EU Blue Card, the EU Talent Pool, Talent Partnerships and the European Legal Gateway Office) and improves predictability for third-country nationals and employers alike. This could not be achieved without action at EU level.

(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?

Yes. The preferred policy option (PO3) is estimated to generate aggregate administrative savings of approximately EUR 22.3 million per year, monetised time savings for applicants of approximately EUR 300 million per year, and a reduction in employer-borne administrative costs of approximately EUR 20 million per year. These benefits are achieved through shared EU tools — including an EU authenticity-verification service and a public register of third-country learning

5

programmes eligible for automatic recognition — that are inherently more effective when developed once centrally than replicated separately across 27 Member States.

(c) What are the benefits in replacing different national policies and rules with a more homogenous policy approach?

The proposal does not replace national recognition decisions or create a 'once-only' EU-wide validity of recognition granted in one Member State. It establishes common procedural rules on documentation, timelines and safeguards and, for a limited set of professions, automatic recognition grounded in prior verification of third-country learning programmes. This reduces fragmentation and increases legal certainty for third-country nationals, employers and administrations without imposing a single substantive assessment standard.

(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)?

Yes. The proposal does not impact Member States' competence over the definition of regulated professions, national education and training systems, or migration and admission decisions. Given the limited degree of competence affected, the economies of scale, legal certainty and competitiveness benefits described above outweigh the marginal reduction in national discretion over procedural detail.

(e) Will there be improved legal clarity for those having to implement the legislation?

Yes. Common procedural rules on documentation, timelines, coordination between recognition and migration authorities, and use of the shared authenticity-verification service would provide considerably greater legal clarity for competent authorities, employers and third-country nationals than the current fragmented landscape.

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. Each of the policy options assessed in the Impact Assessment is shown to respect the principles of subsidiarity and proportionality. Policy Option 1 imposes no new obligations on Member States and is fully compatible as a non-binding option. Policy Option 2 addresses procedural requirements without harmonising substantive assessment standards or affecting Member State competence over recognition or admission decisions. The preferred option, Policy Option 3, introduces automatic recognition for a defined set of professions grounded in the existing framework of minimum training requirements under the PQD; it is a proportionate response that preserves Member States' competence over qualification standards and admission decisions, and participation by third-country institutions in the automatic recognition register is voluntary.

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?

6

Yes. The preferred option's measures are directly linked to the scale and persistence of the problems they address — an average recognition duration of 14.2 months, an average cost of EUR 1,500 per application, and persistent information asymmetry regarding third-country qualifications — and are targeted at the specific objectives of streamlined recognition systems (SO1), reduced legal and administrative complexity (SO2) and increased trust in third-country qualifications (SO3), while preserving Member States' responsibilities.

(a) Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on their own, and where the Union can do better?

Yes. The initiative is confined to procedural aspects of recognition — common rules on documentation, timelines and safeguards, and automatic recognition for a defined set of professions grounded in verified third-country learning programmes — rather than to admission policy, migration volumes or the definition of regulated professions, all of which remain with Member States.

(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.)?

The action is intended to take the form of a Directive establishing common procedural rules on the recognition of qualifications of third-country nationals. This is consistent with the choice of a Directive as the instrument for the parallel amendment of the PQD under Action 2 of the SPI, and reflects the need to leave Member States discretion over how competent authorities apply the common rules within their own administrative structures. The analysis also considered a non- binding instrument, such as a Commission Recommendation, drawing on prior experience with this approach in the field of qualifications recognition. This experience indicated that non-binding instruments have not delivered consistent implementation across Member States, and that a binding instrument is necessary to achieve the objectives of common procedural rules, enforceable deadlines and reliable outcomes for third-country nationals.

(c) Does the Union action leave as much scope for national decision as possible while achieving satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum standards or use a less stringent policy instrument or approach?)

Yes. The proposal does not harmonise the definition of regulated professions, national education and training systems, or Member State competence over migration and admission policy. It leaves Member States discretion over how they organise the competent authorities responsible for applying the common procedural rules, and participation by third-country institutions in the automatic recognition register remains voluntary.

(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?

Yes, and the costs identified are modest relative to the benefits. Implementation costs under the preferred option are estimated at EUR 28.7–50.7 million one-off and EUR 3.7–6.0 million per year, borne mainly at EU level (with limited adaptation costs for Member States linked to database interoperability), against estimated aggregate annual benefits of over EUR 340 million (administrative savings, monetised time savings for applicants and reduced employer-borne administrative costs). No new administrative costs are expected for citizens or businesses, consistent with the 'one in, one out' approach.

7

(e) While respecting the Union law, have special circumstances applying in individual Member States been taken into account?

Yes. The Impact Assessment recognises that implementation costs and benefits will not be distributed equally across Member States, and identifies five determinants of this territorial variation: the volume of inbound migration applications involving qualification recognition; the scale, density and fragmentation of the national professional-regulation landscape; the existing degree of coordination between national migration and recognition authorities; and the procedural distance between current national practice and the proposed common EU rules (Annex 11, Diverging territorial impact of policy options). The proposal's common framework is designed to accommodate this diversity while respecting Member States' different national contexts and responsibilities.

EUROPEAN COMMISSION

17.07.2026

SEC(2026) 990

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 990}

{SWD(2026) 989-991}

Impact assessment / Recognition of qualifications and skills of third country nationals

________________________________

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 / Recognition of qualifications and skills of third country nationals

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context The initiative is part of the broader Skills Portability Initiative (SPI), which comprises three complementary actions: facilitating worker mobility across the EU through skills transparency and digitalisation (action 1); modernising and expanding the recognition of qualifications for access to regulated professions (action 2); improving the recognition of qualifications and skills for third-country nationals (action 3). Action 3 aims to address EU labour and skills shortages by facilitating the recognition of qualifications for third country nationals. The initiative focuses on making the Single Market a more attractive destination for third-country nationals by enabling them to have their qualifications recognised and their skills validated more easily. The Skills Portability Initiative is part of the Fair Labour Mobility Package and is to contribute to the Union of Skills.

(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 magnitude of the problem is not sufficiently described. The problem

definition does not sufficiently draw on evidence from evaluations. (2) It is not sufficiently explained how the uniform application of common rules will

be ensured and consistently implemented across Member States. (3) The report does not sufficiently assess effectiveness and efficiency, including

costs and benefits. (4) The coherence is not sufficiently analysed, in particular coherence with the

Talent pool platform and digital solutions developed under other parts of SPI.

2

(C) What to improve (1) The report should clarify to what extent the magnitude of the problem stemming from the obstacles related to skills portability can be established and analytically isolated from other factors affecting Third Country Nationals’ (TCN) choice of the EU as a destination. The main report should better use evidence from the existing evaluations of relevant instruments, as detailed in Annex 8, to substantiate the problem definition and the problem drivers. (2) The report should further elaborate the basis of the common approach, and on how a uniform approach by Member States will be ensured given the flexibility foreseen by the legal instrument. The report needs to consider enforcement in more detail, in particular regarding how rules - in particular regarding fixed deadlines, exhaustive lists of documents and transparency of fees - will be enforced. Under policy option 3, the report should better explain the role of the envisaged EU quality assurance agencies, including how these bodies would be selected and how they would relate to the existing landscape of quality assurance for professional qualifications. The report should clarify how the EU wide quality assurance channel provided for by this Action, relates to national approaches. (3) The analysis of effectiveness and efficiency must be improved. The report needs to analyse to what extent the competent authorities have the capacity and incentives to deliver on qualification recognitions, including complying with shorter deadlines, without increasing processing costs. It also needs to demonstrate what productivity or efficiency gains drive this enhanced capacity, and if and how these gains are achieved through the intervention. The specificities of automatic qualification recognition process should be explained in more detail, for example its role in accelerating the processing of qualification recognition and authentication requests. The report also needs to analyse the different types of competent authorities that deal with the recognition of professional qualifications, including these organisations’ governance and incentive structures, and how this might impact on their delivery of the envisaged improved outputs, and compliance with deadlines and other requirements. The risk of possibly limited enforcement of these requirements needs to be factored in in the analysis of effectiveness. (4) The report should provide evidence of the expected level of interest from third country institutions, that provide professional qualifications, to have their qualifications recognised in the envisaged automatic recognition system and their willingness to bear the related expected costs. The report should present a more balanced approach to the expected benefits and their monetisation, considering the uncertainties in the evidence base, the assumptions made, and the flexibility foreseen at Member States level. The main report should more clearly specify which assumptions form the basis for its analysis and findings regarding productivity gains through IT and governance improvements; and describe to what extent the findings may change if the underlying assumptions are changed. (5) The report should strengthen the coherence analysis in relation to the ‘ecosystem of initiatives’ to address EU labour market needs, including the EU Talent Pool Regulation, as well as the other initiatives of the SPI. In particular, the report should analyse the possible synergies with the digital solution to be developed under Action 2, including to be used based on voluntary basis. The report should specify what type of legal act would be proposed under this initiative. Some more technical comments have been sent directly to the author Service.

3

(D) Conclusion The lead Service may proceed with the initiative. 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 Fair labour mobility package - Skills Portability 3: recognition

of qualifications and skills of third country nationals

Reference number PLAN/2026/2650

Submitted to RSB on 17 June 2026

Date of RSB meeting 15 July 2026

Electronically signed on 17/07/2026 12:58 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 990 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

Proposal for a

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on the recognition of qualifications of third-country nationals

{COM(2026) 990 final} - {SEC(2026) 990 final} - {SWD(2026) 989 final} - {SWD(2026) 991 final}

i

TABLE OF CONTENTS

1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 1

2. PROBLEM DEFINITION ..................................................................................................................... 6

3. WHY SHOULD THE EU ACT? ......................................................................................................... 25

4. OBJECTIVES: WHAT IS TO BE ACHIEVED?................................................................................ 27

5. WHAT ARE THE AVAILABLE POLICY OPTIONS? ..................................................................... 27

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 38

7. HOW DO THE OPTIONS COMPARE? ............................................................................................ 50

8. PREFERRED OPTION ....................................................................................................................... 54

9. HOW WILL THE ACTUAL IMPACTS BE MONITORED AND EVALUATED? ......................... 56

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 58

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................ 61

ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................... 80

ANNEX 4: ANALYTICAL METHODS ...................................................................................................... 87

ANNEX 5: COMPETITIVENESS CHECK ............................................................................................... 110

ANNEX 6: SME CHECK ........................................................................................................................... 114

ANNEX 7: DISCARDED OPTIONS ......................................................................................................... 122

ANNEX 8: LEGAL AND POLICY CONTEXT ........................................................................................ 125

ANNEX 9: MAPPING OF RECOGNITION PROCEDURES TO ACCESS REGULATED

PROFESSIONS AND AS PART OF MIGRATION PROCEDURES IN EU MS ........................... 138

ANNEX 10: VALIDATION OF SKILLS .................................................................................................. 186

ANNEX 11: DIVERGING TERRITORIAL IMPACT OF POLICY OPTIONS ....................................... 194

ANNEX 12: POLICY OPTIONS: DESCRIPTION OF MEASURES ....................................................... 199

ANNEX 13: COMBINED COSTS AND BENEFITS OF SPI PREFERRED OPTIONS UNDER

ACTION 1, 2, AND 3 ....................................................................................................................... 209

ANNEX 14: MONITORING ...................................................................................................................... 213

ANNEX 15: RESOURCES......................................................................................................................... 215

ii

Glossary

Term or acronym Meaning or definition

CA Competent Authorities

CSO Civil society organisations

EQF European Qualifications Framework

ETF European Training Foundation

HR Human Resources

IA Impact Assessment

ICT Information and communication technology

IO International organisation

IOM International Organisation for Migration

MRA Mutual Recognition Agreement

MS Member State(s)

OECD Organisation for Economic Cooperation and

Development

PC Public Consultation

PO Policy Option

PQD Professional Qualifications Directive

QA Quality Assurance

SMEs Small and medium-sized enterprises

iii

TCN Third-country nationals

TCQ Third-country qualifications

Note on terminology

In this impact assessment (IA), the expression “recognition of qualifications” refers to two

distinct but related sets of procedures.

In relation to regulated professions1,e.g. doctor, nurse, electrician, (“recognition of

professional qualifications”), it refers to the process by which a person’s qualifications are

assessed and verified by a competent authority (CA) to determine whether they meet the legal

requirements to grant that individual the right to practice the profession in that Member State

(MS).

In the context of migration policy, “recognition of qualifications” refers to the process by

which a person’s qualifications are assessed as part of a procedure to grant residence in that

MS.

While recognition of professional qualifications by a CA grants the legal right to practice a

specific regulated occupation, migration-related recognition functions as an entry filter to

verify that an applicant’s qualifications meet the thresholds required for admission into the

domestic labour market.

Professional and migration-related recognition procedures can intersect when the legal

migration pathway itself is legally contingent upon the applicant already holding the right to

practise a regulated profession within the host Member State.

The problem analysis distinguishes between “recognition systems” and “recognition

procedures”. The former refers to the recognition governance and operational structures in

MS (which authorities are involved, which assessment methods are applied and for what

purpose is recognition required?). The latter refers to the various steps in the administrative

handing of recognition requests (what documents are required, which deadlines apply, etc.?)

within these “recognition systems”. 

1 The expression “regulated profession” refers to a professional activity or group of professional activities the

access to and/or the pursuit of is subject to the possession of specific professional qualifications by virtue of

regulatory or administrative provisions

1

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,2 its strong performance masks a structural

challenge: widespread skilled labour shortages that threaten business growth and the EU’s

global competitiveness.3

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.4 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 channels5. Labour and skills gaps also threaten the delivery of essential

public services like healthcare, education and long-term care.6

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)7.

Uncertainty about whether qualifications and skills will be fully understood, valued, and

formally recognised (in the case of regulated professions8) in another MS, may discourage

2 The employment rate for people aged 20-64 equalled 76.3% in the Q1 of 2026. 3 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. 4 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. 5 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. 6 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). 7 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. 8 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.

2

professionals from seeking employment opportunities outside their MS.9 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

relocation10. Improving skills portability across borders thus also contributes to the ‘right to

stay’.

The Letta report on the Single Market to theEuropean Councilhighlightedthat: “Free

movement of people has been and remains the least developed of the four freedoms.” It also

stressed that fragmented national labour markets hinder European growth and competitiveness

and that “extending the system of automatic recognition of professional qualifications and

reviewing the need for and extent of professional regulation would facilitate mobility and help

to respond to persistent labour shortages.” 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.” 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.”13 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.14

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,

9 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). 10 ITEM study on challenges and solutions for recognising professional qualifications in cross-border regions. 11 Letta (2024). 12 Von der Leyen (2024). 13 European Council meeting (19 March 2026) – Conclusions 14 One Europe, One Market Roadmap of the European Parliament, the Council of the European Union and the

European Commission

3

addressing barriers to its implementation.15 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.16

As part of the Fair Labour Mobility package17,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 qualifications and skills they acquired abroad because

labour market actors find it relatively more difficult to interpret and verify non-national

credentials. This putsqualifications and skills acquired in a non-national context at a

disadvantage. The Skills Portability Initiative aims to address these barriers through a set of

three distinct but interrelated actions:

Action 1: Improving availability of reliable, comparable and verifiable digitalised

information on qualifications and skills in the EU

This action aims to bring simplification for employers and workers by making qualifications

instantly understandable and verifiable for labour market actors across the Single Market, and

facilitating comparison of the level and content of qualifications issued in the EU. It aims to do

so by building on existing tools such as the European Qualifications Framework, Europass and

the European Digital Identity Wallet, and through setting common standards for digital

attestations of qualifications to be interoperable, secure, and machine-readable. This will reduce

the ‘interpretative burden’ on hiring managers, and prevent further fragmentation between MS

resulting from uncoordinated investments in digitalisation.

This action is relevant for all workers using qualifications obtained in other EU MS in any

labour market context, including for access to regulated professions. In the context of

unregulated professions, which constitute 78% of EU labour force, the improved availability of

digitalised and comparable information on qualifications and skills will contribute to decreasing

the uncertainty about how to treat qualifications obtained in another MS, which at the moment

15 SOC/837-EESC-2025 16 CDR-1105-2025 17 For more context, see CWP 2026 Commission work programme 2026 - European Commission.

4

leads employers to request costly and time-consuming comparisons with national qualifications

even though these are not legally required. In regulated professions, the digital attestations set

up thanks to Action 1 are a key element of the simplification of the recognition procedures

under Action 2. The various problem drivers, Policy Options and impacts are discussed in this

IA.

Action 2: Targeted Intervention for Regulated Professions

The second action focuses specifically on improving cross-border recognition procedures for

access to regulated professions.18 There are currently over 5,700 professions regulated across

the EU19 covering an estimated 22% of the labour force20, 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 proportionality21. Consequently, there is a high variety of approaches to regulating the

access to professions between MS which creates barriers to professional mobility within the

EU. To address those barriers, the EU has established the Professional Qualifications

Directive22 (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

18 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.”. 19 According to the ECA, the combined data on professions that are regulated in the MS show that the total

increased from around 5 400 in 2016 to around 5 700 in 2023 (average per MS: 212 regulated professions). Annex

8 of the IA accompanying Action 2 of the Skills Portability Initiative provides more background on regulated

professions in the MS, for illustrative purposes. The European Commission’s RegProf allows to verify which

professions are regulated at national level in the EU, by MS. 20 See COM (2016) 820 final. 21 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. 22 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.

5

minimum training requirements (such as doctors and nurses). For specific economic activities

in trade and commerce there is automatic recognition based on professional experience. The

action aims to extend automatic recognition to professions which are not currently covered

using Common Training Frameworks. It is covered as part of the baseline in the dedicated IA

for action 2.23 The second work strand on Modernisation and Digitalisation of Procedures

aims to simplify and speed up recognition of professional qualifications for regulated

professions, by streamlining the existing recognition procedures under the Directive, leveraging

the potential of digital tools. Action 2 is based on articles 46, 49, 53 and 62 TFEU. The various

problem drivers and Policy Options in this second work strand are discussed in a dedicated IA.

Action 3: Attracting and Empowering Global Talent

Acknowledging that intra-EU mobility alone cannot solve all labour market needs, Action 3

focuses on making the Single Market a more attractive destination for TCN by enabling them

to have their qualifications recognised and their skills validated more easily. This will both

benefit the TCN already residing and working in the EU and those who intend to migrate to 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 this IA.

Actions 1, 2 and 3 are closely interlinked and coherent.

The interoperable, secure and verifiable digital attestations developed under Action 1 are a

foundation, on which actions to simplify and speed up recognition procedures in the context of

regulated professions under the PQD (Action 2) build,by reducing administrative burdens on

Competent Authorities enabling smoother, faster assessments of qualifications.

Action 3 addresses a critical gap: the PQD’s recognition procedures do not cover third-

country nationals (TCNs). TCNs and EU citizens holding non-EU qualifications do not

always benefit to the same extent from the existing EU transparency tools. This puts them at a

disadvantage compared to EU citizens holding EU qualifications, undermining the

attractiveness of the Single Market as a destination for global talent. To address these issues,

specific action to facilitate recognition of qualifications of TCN is warranted. This is the

purpose of Action 3. Just like Action 1, Action 3 uses the European Qualifications Framework

as a key tool to enable comparability and portability of qualifications across borders,

implemented in particular through comparisons between the EQF and qualifications

frameworks of third countries, such as in the context of Talent Partnerships, or other EU

partnerships.

Together the three actions form a coherent package, each addressing distinct but interlinked

dimensions of skills portability: 1) the framework for availability of digitalised information

about qualifications and skills which forms the foundation for the other actions, 2) the

recognition of qualifications for intra-EU mobility in regulated professions, and 3) the

recognition of qualifications of TCN. As such, the three actions are mutually reinforcing and

23 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

contribute to the broader objectives of supporting labour mobility, reducing skills mismatches,

and improving the functioning of the Single Market.

2. PROBLEM DEFINITION

The primary scope of this action is TCN seeking employment in the EU.24 The focus on

TCN (rather than TCQ) is due to Treaty legal basis, as well as existing EU acquis, that require

any EU intervention in this area to be framed around the personal scope, i.e. focused on TCN

and their rights (discussed in Annex 8).

The action addresses recognition procedures, not migration flows. It does not alter Member

States' competence to determine admission conditions, set migration volumes or decide which

professions they regulate. Legal migration is a necessary component of the EU's long-term

response to demographic decline25, a context within which this action operates exclusively

through procedural improvement. Where relevant, the IA has regard to ethical and geopolitical

dimensions of talent mobility, including the potential impact on origin countries facing

documented workforce pressures.

The recognition landscape facing TCN involves two distinct types of procedures which

are organised differently across 27 national systems.

The first is formal recognition for access to a regulated profession. Where a TCN seeks to

practise a regulated profession, such as medical doctor, nurse, electrician, recognition is a

mandatory legal precondition for access to professional practice26. No TCN may practise a

regulated profession in a Member State without first obtaining a formal recognition decision

from the relevant authority. This decision involves a substantive assessment of the applicant's

qualifications against the national requirements for the profession concerned, may require the

submission of extensive documentation and may result in the imposition of compensation

measures27 before recognition is granted.

24 The IA also considers two further scenarios arising from the legal analysis for the action: TCNs who hold

qualifications obtained in another Member State, and EU nationals who hold third-country qualifications. These

scenarios are described in more detail in the Annex 8 description of the legal context. The scenarios do not alter

the central analysis, and they do not change the principal focus of this action, which is the absence of any EU

framework governing recognition procedures for TCNs. 25 The Commission's 2025 Strategic Foresight Report 26 The qualification requirement can also be linked a particular mode of pursuit, e.g. using a professional title or

working in a self-employed capacity. See the definition of “regulated profession” in Art. 3(1)(a) of Directive

2005/36/EC on the recognition of professional qualifications. 27 Under the PQD (which applies to EU citizens), if a host EU country finds substantial differences between an

applicant's professional qualifications and their national requirements, they may impose compensation measures.

Applicants are generally given the choice between two options: an adaptation period or an aptitude test. No

equivalent framework governs compensation measures for TCNs. In the absence of EU legislation, MS and CAs

determine independently whether compensation measures apply, in what form, and on what terms, resulting in

significant variation in both the nature and extent of the requirements imposed on TCN applicants for the same

profession across different national and regulatory contexts.

7

Unlike EU nationals moving between MS, who benefit from established mutual recognition

mechanisms under PQD (including automatic recognition for seven sectoral professions28)

TCN have no comparable framework for accessing regulated professions. This gap is

particularly acute in healthcare precisely where TCN migration flows are most concentrated29.

Nearly half of TCN who initiated recognition procedures in the EU were seeking access to a

regulated profession in healthcare30.

The second type of procedure is a qualification or skills check conducted as part of a

migration procedure. Several admission pathways, including the Blue Card, researcher visa

and national highly skilled worker schemes, require applicants to demonstrate that their

qualifications meet defined thresholds as a condition of entry or residence, irrespective of

whether the profession they intend to practise is regulated or unregulated31. These checks are

conducted by MS authorities under the legal framework applicable to the admission pathway,

and are distinct in purpose, institutional setting and legal basis from the procedure conducted

by CA. Their function is to establish eligibility for admission rather than to authorise access to

a specific profession.

TCN already make a substantial and growing contribution to EU labour markets. Over the past

decade, the share of the working-age population in the EU born in a third-country has

consistently increased, reaching 12.6% in 2024, compared to approximately 8% in 2014. By

contrast, the share of working-age people born in one MS but living in another rose only

modestly, from 4% in 2014 to 4.4% over the same period32. Employed TCN have particularly

strong presence in sectors facing acute labour shortages, including health and long-term care,

ICT, construction and engineering. Yet, despite available opportunities, OECD analysis shows

that Sweden is the only MS among the top five preferred destinations for highly skilled

workers33, that TCN tend to favour destinations such as the United States, Canada, Australia

and New Zealand.

Several MS have adopted dedicated talent attraction strategies, encompassing fast-track

admission pathways, and targeted visa schemes34, sometimes incorporating solutions for

recognition barriers.35 The issue underpinning talent attraction is not one of a need to increase

migration flows but to deepen the pool of candidates who consider the EU a viable destination.

A larger interested pool, even with unchanged admission volumes, improves the quality of

selection available to MS and employers.

28 The PQD has introduced minimum training requirements for a total of 7 professions: doctors, nurses responsible

for general care, dental practitioners, veterinary surgeons, midwives, pharmacists and architects. 29 OECD (2019) 30 46.8% of TCN survey respondents declared a regulated healthcare profession, and administrative data record

23,500 medical doctor recognition applications from TCNs across 11 Member States in 2023 alone. 31 See Annex 9 Mapping of recognition procedures - Qualifications and Skills Checks with migration pathways 32 European Commission (2025c). 33 OECD (2023). 34 EMN–OECD, Inform on innovative strategies to attract foreign talent in the EU Member Countries, February

2025. Since 2021, 15 EMN Member Countries have introduced new or innovative approaches, including dedicated

national talent strategies (Denmark, Estonia, Finland, Netherlands), sector-specific fast-track pathways (Germany,

Portugal) and active international recruitment programmes 35 See Annex 9 (a) (i) Cooperation — within Member States, between Member States, and with third countries

8

The EU has developed an ecosystem of instruments designed to attract, match and recruit talent

beyond its borders including the EU Talent Pool connecting third-country jobseekers with EU

employers, Talent Partnerships with priority non-EU countries building structured labour

mobility pathways, the European Legal Gateway Office pilot in India, and EU legal migration

directives36. These instruments reflect a strategic goal, articulated in the Union of Skills37, to

make the EU a competitive destination of choice for skilled workers in the global race for talent,

in which other major economies offer faster, more predictable and better-understood pathways.

This ambition is reinforced by a Visa Strategy aimed at streamlining procedures for top

students, researchers and trained workers38, a Commission Recommendation on attracting

talent for innovation39 advocating simpler and faster procedures for long-stay visas and

residence permits, and the Action Plan on Integration and Inclusion40, which specifically

identifies recognition of qualifications as a lever for improving labour market participation for

people with a migrant background

Across this ecosystem, the ability of TCN to have their qualifications recognised in a way that

is simple, trusted and effective remains structurally underdeveloped at both EU and national

level. Therefore, this action focuses on recognition as a distinctive procedural requirement.

Recognition has direct consequences for employers and workers, and impacts the effectiveness

of instruments to attract, match and recruit talent. Challenges associated with recognition,

described in the next section, operate at both EU and national level and addressing these is

therefore both an EU and national priority.

Finally, the decision of a TCN to seek employment in the EU is shaped by a broad set of factors,

including employment opportunities, working conditions, career prospects, cultural and

linguistic affinities, language barriers, access to integration support, housing and social

infrastructure, and general quality of life.41 Available survey evidence typically captures these

motivations at a high level of aggregation, under headings such as work or family, within which

procedural factors such as recognition are embedded rather than separately identified, and it is

inherently difficult to estimate the share of potential migrants for whom the EU is a candidate

destination. The magnitude of the recognition problem cannot therefore be analytically isolated

from the other determinants of destination choice with statistical precision. What the evidence

does establish is that recognition acts as a critical enabling factor shaping the indicators

highlighted in the OECD Indicators of Talent Attractiveness, such as the quality of

opportunities, income and future prospects, and that it is the determinant most amenable to EU-

level regulatory action. Whereas language, integration and social infrastructure require long-

term national investment and are addressed through complementary EU instruments, including

the EU Talent Pool, Talent Partnerships and the Action Plan on Integration and Inclusion, the

fragmentation of recognition procedures is a regulatory problem that EU legislation can target

36 See Annex 8 for an overview of existing EU instruments to attract, match and recruit talent. 37 Union of Skills, COM (2025).

38 Commission adopts a first-ever EU Visa Strategy 39 Commission Recommendation (EU) 2026/311 of 29 January 2026 40 Action plan on integration and inclusion 2021 - 2027 41 The OECD Indicators of Talent Attractiveness include 7 dimensions which impact capacity of a country to

attract and retain different types of talented migrants: (1) quality of opportunities, (2) income and tax, (3) future

prospects, (4) family environment, (5) skills environment, (6) inclusiveness, and (7) quality of life and (8) health

system performance.

9

directly. The focus on recognition is therefore the specific contribution of this action within the

EU's broader talent attraction strategy, not a claim that recognition is the sole or principal driver

of mobility. Moreover, the magnitude of the problem does not rest on the migration decision

alone, since improved procedures would directly benefit the substantial population of TCN

already present in EU labour markets and working below their qualification level, for whom

the barriers documented in this chapter apply in full.

2.1. What is the problem?

The procedures for the recognition of qualifications and validation of skills for TCN

wanting to work in the EU are complex, burdensome, and untransparent, leading to

uncertain and even inconsistent outcomes.

Whether already residing in a MS or seeking to migrate, TCN face a landscape for recognition

of qualifications impacted by three interconnected problems: divergent national systems;

complex and burdensome procedures; and lack of trust and understanding in third-country skills

and qualifications.

Divergent national systems: The TCN applicant navigates a recognition procedure that may

take years, in a country where their continued legal presence depends on its outcome. Where a

TCN seeks to practise a regulated profession through a migration pathway that carries

qualification criteria, both types of procedure may apply: a qualification check by the migration

authority as a condition of admission, followed by a separate formal recognition procedure

before the CA as a condition of access to professional practice. These two procedures operate

under different legal frameworks, involve different authorities and run on different timelines

which compounds the burden on individuals and generates a level of uncertainty that cannot be

addressed by individual Member State action alone.42

Complex and burdensome procedures: Beyond system level complexity, TCN face recognition

procedures that are in practice costly, time-consuming and administratively demanding

regardless of the pathway or profession concerned. The average total cost is estimated at EUR

1,500 per application and the average actual duration at 14.2 months, with 70.4% of TCN43

surveyed considering the length of the process either a ‘big’ or a ‘very big’ problem. A further

EUR 300 in administrative costs applies to migration-related recognition procedures that do not

involve a regulated profession, affecting a comparable annual volume of applications.

Lack of trust and understanding in third-country skills and qualifications: Recognition

outcomes also depend on whether the authority conducting the assessment has sufficient

knowledge and confidence to evaluate what a third-country qualification represents. National

authorities and employers frequently lack familiarity with third-country curricula, quality

assurance frameworks and documentation practices, generating caution, additional verification

42 Focus Group with individual TCNs (FG6, n=12); Public Consultation TCN responses (Annex 2). Quantitative

corroboration: TCN survey and PC data show that 22.6% of individuals who completed recognition procedures

reported total durations of between six months and three years; business organisations and CSOs reported timelines

ranging from under one month to two to three years 43 TCN Survey, Q8 (n=253)

10

burdens and inconsistent outcomes. Addressing this information asymmetry is therefore a

necessary condition for removing the barriers TCN face.

2.2. The scale of the problem

The IA draws on an extensive body of desk research, primary fieldwork, statistical data as

well as secondary literature to build a comprehensive evidence base and to triangulate

findings across sources. This includes a mapping of recognition procedures across all 27 MS,

covering both procedures for access to regulated professions and qualification checks

conducted as part of migration procedures, which describes the authorities involved, the

documents required, the typical timelines, the fees charged and the degree of coordination

between recognition and migration systems (see Annex 9). Nevertheless, important data

limitations remain. No regular EU-wide data collection exists on qualification recognition

procedures and the full extent of barriers for TCN. This gap is itself a product of the divergence

of national systems. Accordingly, surveys and focus groups were used to capture the volume of

procedures and the lived experience of TCN as systematically as possible. Taken together, these

sources provide a sufficient evidence base for the assessment and enabled the identification of

a set of key indicators, introduced below, which form the analytical thread running through the

issues assessed in this IA.

As indicated above, the share of the working-age population born in a third country has

consistently increased over the past years. The same applies to both the absolute number of

TCN employed in the EU and their share of the total employed workforce. In 2025,

approximately 12.8 million TCN were employed in the Union, up from 8.7 million in 2020 and

representing 6.4% of the total employed workforce. In 2024 alone, approximately 1.1 million

TCN obtained a first residence permit in the EU for employment reasons. These numbers have

been relatively stable in recent years and provide a conservative estimate of the actual

application workload as they represent issued permits, not counting visa applications that are

rejected during the vetting process.

Within this total pool, the EU Blue Card, the researchers visa and the national highly skilled

migration pathways require proof of a verified education degree or equivalent upper-level

vocational training. Consequently, in this impact assessment, the rounded sum of these three

specific categories—amounting to approximately 125,000 annual first permit issuances—is

utilised as the baseline estimate of the total number of annual applications which involve an

element of qualification assessment and fall within the scope of the proposed action.

To isolate the share of applications concerning regulated professions within this pool and

because migration databases do not record the regulatory status of the job the first residence

permit applies to, this IA relies on several other sources yielding a convergence interval of

between 40,000 to 85,000 applications for regulated professions per year, with a central

estimate of 62,500 applications annually.

The problem identified above has distinct implications for different stakeholders.

11

For TCN applicants who are already residing in the EU, the bottlenecks are well

documented. Successive studies44 highlight that TCN identified recognition procedures as the

main obstacle to securing employment that matches their skills. Within the area of regulated

professions, 73 out of 182 TCN professionals who had considered seeking recognition reported

that they had not done so due to the complexity, cost or duration of the process — with a further

16 out of 152 of those who initiated a procedure subsequently withdrawing for the same

reasons.45 Overqualification among TCN remains significantly higher than among nationals: in

2023, 39.8%46 of TCN in the EU were overqualified, compared with 20.8% of nationals. While

overqualification does not in itself measure unsuccessful recognition procedures, it is a strong

indicator that skills are not being effectively translated into labour market outcomes.

Recognition of qualifications is associated with better labour market outcomes: TCN with

recognised qualifications have lower unemployment rates compared to those without (16% vs

22%), and a similar pattern can be observed in labour market participation.47 Among tertiary-

educated TCN, participation reaches 81% for those with recognised qualifications compared

with 74% for those without, pointing to a significant gap in labour market integration.

Differences are less pronounced at medium education levels, but still present (79% vs 77%).

The effect of improving recognition systems on these outcomes is empirically well-

documented. Germany's Federal Recognition Act, which introduced a legal basis and

standardised procedures for equivalency assessment, increased employment probability in

regulated occupations for non-EU immigrants by 18.6%, rising to 25.1% in professions with

large application pools such as nursing and medicine.48 OECD data confirms that host-country

qualification recognition reduces the overqualification gap with native-born workers by 75%

on average across the EU49.

For young TCN50 in the EU labour market, qualifications serve as the primary signal of

competence available to employers and authorities yet they suffer particularly from over-

qualification51. High procedural costs and lengthy, opaque procedures act as a regressive barrier

that disproportionately affects young, low-wealth applicants who lack the financial buffers

needed to sustain extended recognition processes or fund compensatory measures.

Taken together, this suggests that barriers to recognition and validation contribute to weaker

labour market integration and to less efficient allocation of skills. These effects are particularly

problematic for sectors facing acute labour shortages, such as healthcare, where the

underutilisation of available skills directly affects public service provision and economic

44 European Parliament (2019); EPRS (2023) 45 TCN Survey and Public Consultation TCN sub-sample (pooled n=182); TCN Survey (n=152 reporting a

procedural outcome). 46 European Commission (2024) 47 Eurostat [lfsa_eoqgan]; EU Talent Pool IA background data. 48 Anger, S., Bassetto, J. and Sandner, M., Making Integration Work? Facilitating Access to Occupational

Recognition and Immigrants' Labor Market Performance, IAB Discussion Paper, 2022 49 OECD/European Commission, Indicators of Immigrant Integration 2023 50 In 2023, young non-EU citizens accounted for 11.9% of the EU population aged 15 to 29, a share that has

followed an upward trend since 2014, Eurostat. 51 In Czechia and Malta, overqualification rates for non-EU citizens aged 20–34 exceeded 50%, compared with

under 15% for nationals. Among non-EU-born individuals aged 20–34, notably high overqualification rates were

also recorded in Greece, Latvia and Czechia in 2024, Eurostat.

12

growth52. TCN facing prolonged barriers to employment are also at risk of taking up undeclared

or informal employment53, a point highlighted in the Social Partners Hearing for the SPI54. So

too, employers in shortage sectors may recruit informally rather than navigate compliance

requirements. Construction, accommodation, food services, care and manufacturing are the

sectors most exposed to illegal employment of TCN.55 The care sector is particularly

significant, with an estimated 6.8 million undeclared workers across the EU, with qualified

nurses and care professionals from third countries being disproportionately represented.56

Beyond the economic consequences, the persistence of overqualification and prolonged

inactivity during recognition procedures weakens economic independence of TCN57, increases

reliance on social support, and creates distance between TCN and the communities in which

they reside58.

For prospective migrants, these procedures create structural obstacles for attempting to

access the EU labour market from abroad. Complicated or absent pre-departure recognition

frameworks can act as a deterrent, discouraging highly skilled professionals from applying to

EU migration pathways in the first place. The pre-departure deterrence factor is inherently

difficult to quantify as individuals who are deterred never enter the national permit or

application statistics, but it is no less real or impactful in undermining the EU’s global talent

attraction. The economic consequence of this deterrence is not a reduction in the number of

TCNs admitted, as admission volumes remain a Member State decision - but in the smaller pool

of qualified/skilled migrant workers available to strengthen the EU economy.

For employers, and SMEs in particular: Employers face uncertainty when assessing

qualifications and skills acquired in third countries and often lack the resources needed to

navigate fragmented procedures, verify documentation or absorb the delays linked to

recognition processes. This reduces incentives to recruit from outside the EU, even where

shortages are severe. EU-level evidence indicates that only 1 in 7 SMEs have attempted to

recruit a non-EU worker within the EU in the previous 2 years59 and that recognising foreign

qualifications remains a significant obstacle. During stakeholder consultations, employers

reported that recognition procedures are often time-consuming and difficult to navigate, and

that the absence of predictable timelines significantly complicates workforce planning, leading

43 ELA (2024); EMN (2024). In healthcare, nurse shortages are reported across 78% of EU countries and specialist

medical shortages across 75%; 46.8% of TCN recognition applicants hold qualifications in this sector. 44 EMN Study on Illegal Employment of Third-Country Nationals (2025); Eurofound (2025), Undeclared work in

the EU. The EMN Study identifies SMEs in construction, accommodation, food services, care and manufacturing

as the sectors most prevalent in illegal employment of TCNs and notes that administrative obstacles are among the

key challenges in preventive measures. Eurofound estimates approximately 6.8 million undeclared workers across

the EU, predominantly women and often migrants. 54 See Annex 2 Stakeholder Consultation 55 EMN Study on Illegal Employment of Third-Country Nationals, 2025 56 Eurofound, Undeclared Work in the European Union, 2025. 57 OECD (2025). 58 Van Enk & Bilgili (2022) 59 Flash Eurobarometer 571 (December 2025) found that nearly half of all EU SMEs (46%) reported difficulty

finding or recruiting staff with the right skills over the preceding 24 months, rising to 70% among SMEs actively

hiring. Despite this, only one in seven EU SMEs (14%) had attempted to recruit TCN.7 Qualification recognition

challenges were cited by 13% of recruiters as a specific barrier, and by 8% of non-recruiting firms as a reason for

not attempting international recruitment.

13

to withdrawal of job offers, abandonment of international recruitment, hiring TCN applicants

at assistant or lower-skilled levels instead of at qualification level.60

The consequences of recognition barriers affect the EU economy and the delivery of public

services at scale. The aggregate effect of skills underutilisation across the TCN workforce

represents a structural drag on EU productivity. Where qualified professionals work in roles

below their skill level, or remain inactive during lengthy recognition procedures, the productive

value of their qualifications is lost to the economy for the duration of that period. The

opportunity costs for applicants working below their qualification level or not at all while their

recognition applications are processed is estimated at approximately EUR 300 million/year61.

Beyond the direct productivity effect, the persistence of recognition barriers contributes to

structural labour and skills shortages in sectors of critical public importance. In healthcare,

where TCNs account for a disproportionately large share of recognition applicants and where

nurse shortages are recorded across 78% of EU countries, recognition barriers translate directly

into reduced capacity to staff hospitals and long-term care facilities. Similar dynamics are

present in construction, where 31% of employers report that shortages are already constraining

output, and in ICT and education, where sustained skills gaps undermine the EU's capacity to

deliver on the green and digital transitions.62

Recognition barriers also carry social costs that compound over time. Where TCNs face

prolonged administrative uncertainty, the social distance between migrant communities and

host societies widens. Prolonged inactivity reduces economic independence, increases reliance

on social support and limits participation in civic and community life.63 These effects weaken

integration outcomes for a population that is both growing in size and increasingly central to

the EU's capacity to sustain public services and economic growth in the context of demographic

decline. Beyond the productivity effects set out above, this represents a waste of individual

human capital and a constraint on social cohesion64.

Validation of skills — a distinct challenge

Validation of skills of TCN presents a distinct set of challenges that cannot be analysed in the

same terms as qualification recognition.

Unlike recognition, which follows structured, requirements-based procedures leading to a

formal decision, validation is by nature flexible, local and context-dependent. There is no single

methodology, no uniform process, and no comparable decision at the end. Validation may take

the form of a structured assessment following the steps of the Council Recommendation on

60 IOM Webinar with private sector stakeholders (See Annex 2) 61 Calculated on the basis of the share of applicants either not working or working below their qualification level

during the procedure and the wage differential between qualification-matched and mismatched employment. See,

Annex 4.5 (Level 3 — welfare-side estimation); TCN survey Q15 (n=152): 49.3% of respondents working below

their qualification level during the procedure; wage proxy from Eurostat Structure of Earnings Survey. Reported

as an order of magnitude consistent with its scenario-based and modelled nature. 62 ELA (2024), Labour shortages and surpluses in Europe; ESDE 2023 63 The Commission's Action Plan on Integration and Inclusion 2021–2027 frames labour market inclusion of

legally-residing TCN as key to social cohesion and emphasises that inclusion means ensuring qualifications are

recognised so TCN can find jobs matching their aspirations, not merely any job. 64 The OECD Indicators of Immigrant Integration (2023) confirm that overqualification represents a waste of

human capital that generates lower motivation and undermines social integration.

14

validation65, or be undertaken through an employer-led skills check, a portfolio review or a

documented competence statement, depending on the setting.

Validation is not systematically available, for EU citizens or for TCN, and its use for TCN in

employment remains highly fragmented and largely informal across MS. Where migration

authorities conduct skills checks as part of admission procedures, these typically aim to verify

the plausibility of qualifications or experience rather than to formally validate skills. Validation

to access to regulated professions does not go beyond requiring MS to also take into account

evidence of different forms of learning.66

The analysis below focuses on recognition systems and procedures. Issues related to the

validation of skills of TCN, which present a distinct set of challenges, are examined in Annex

10.

The problem definition and its magnitude are corroborated by the evaluative evidence

available on the instruments governing legal migration to the EU, mapped instrument by

instrument in Annex 8. The Fitness Check on EU Legislation on Legal Migration concluded

that the acquis remained fragmented and had had a limited impact on the EU's ability to attract

the skills and talent its economy needs.67 The implementation report on the Single Permit

Directive identified the recognition of qualifications obtained outside the EU as one of the

practical problems affecting permit holders' access to the labour market.68 The impact

assessment underpinning the recast of the Blue Card Directive found that difficulties in

obtaining recognition limited the attractiveness of the EU's flagship scheme for highly qualified

workers.69 These findings informed the New Pact on Migration and Asylum and the

Commission Communication on attracting skills and talents, both of which committed the

Commission to addressing the shortcomings identified, including the recognition of

qualifications of TCN. This action is the legislative follow-through on that commitment and

applies the ‘evaluate first’ principle by building on the evaluative record of the existing acquis.

The experience of the PQD provides a further, comparative reference point. Its implementation

record demonstrates that binding common procedural rules, applied across a wide range of

competent authorities, can deliver predictable recognition outcomes at scale, and it is precisely

the absence of any equivalent framework for TCN that the problem drivers set out below

describe.

2.3. What are the problem drivers?

The underlying drivers relate to the divergence of national recognition systems, the complexity

and burden of procedures for TCN, and the difficulties faced by authorities and employers in

understanding and trusting qualifications and skills obtained in third countries.

65 Council Recommendation of 20 December 2012 on the validation of non-formal and informal learning, OJ C

398, 22.12.2012 66 Evidence of professional experience, training courses not forming part of a certificate or diploma, non-formal

and informal learning, or lifelong learning 67 Fitness Check on EU Legislation on Legal Migration, SWD(2019) 1055 final, 29 March 2019. 68 Report on the implementation of Directive 2011/98/EU (Single Permit Directive), COM(2019) 160 final 69 Impact assessment accompanying the proposal for the recast Blue Card Directive, SWD(2016) 193 final

15

The three drivers are mutually reinforcing. Because of diverging national systems (Driver 1),

the same TCN faces different requirements, authorities and levels of scrutiny depending on

which MS they apply in. Within each recognition system, complex and burdensome

administrative procedures (Driver 2) add cost and delay. Adding to that is a persistent lack of

trust and knowledge regarding third-country systems (Driver 3), which increases scrutiny

requirements, amplifies documentation burdens and makes outcomes less predictable. Systemic

divergence (Driver 1) reduces the ability to develop shared knowledge (Driver 3); the resulting

knowledge gaps drive burdensome case-by-case procedures (Driver 2); and the burden of those

procedures is amplified further by the absence of common standards (Driver 1).

SPI Action 3 Problem Tree

2.3.1. Driver 1: Diverging recognition systems within and between MS

Recognition systems for TCN are almost entirely governed by national legislation.70 As a result,

the same TCN may face very different requirements, procedures and outcomes depending on

the MS concerned, the profession at issue and the authority responsible.

Sub-driver 1.1: Different recognition systems applied to the same qualifications across MS

Recognition systems differ substantially at structural level across MS in terms of the purpose

of recognition, the legal framework and the authorities involved whether for regulated

professions or where checks are done as part of migration procedures, or both. These systemic

differences mean that the same TCN, with the same qualification, will encounter a

fundamentally different recognition system depending on where in the EU they seek

employment. This is particularly acute in regulated professions, where access to professional

practice depends on formal recognition procedures and where the scope of regulation itself

differs across MS. Even for the seven sectoral professions which are consistently regulated

70 See Annex 8: Legal and policy context.

16

across all Member States, procedures vary. For example, for TCN medical doctors, the

documents required71, the compensation measures applied72 and the assessment methods used

vary substantially across MS. Such variation occurs not only across Member States but also

within Member States where recognition is decentralised. 73 This is in clear contrast to the

situation for EU citizens who can in the case of regulated professions benefit from clear

procedural rules, under the PQD, including the system for automatic recognition for the sectoral

professions, which obliges MS to treat approved qualifications from other MS in a consistent

manner.

During consultation, MS public authorities raised the risk of TCN seeking first recognition in

more flexible MS before moving elsewhere which can only be mitigated against by having

minimum standards applied uniformly across the EU74. This inconsistency contributes to

uneven decision-making and legal uncertainty for applicants facing different outcomes for the

same qualification depending on where they apply. This is an inherent structural weakness at a

time when the EU is competing with other destination countries that offer faster, more

predictable pathways to employment.

Sub-driver 1.2: Duplication and inconsistencies between recognition systems within MS

Within MS, competence for recognition are often scattered across different levels and bodies

of government, including sector-specific boards for regulated professions, lacking a unified

coordinating framework75. Qualification checks that are conducted within recognition

procedures and as part of migration pathways may run in parallel rather than sequentially or

coherently76. Across almost all MS, preliminary qualification checks for residence permits or

visas are conducted by migration authorities, while formal recognition for access to a regulated

profession is handled by a separate CA under different legal and administrative frameworks.

This can lead to overlapping checks, repeated requests for the same documents, inconsistent

guidance and multiple administrative steps for the same person.77 These arrangements are

particularly pronounced in decentralised governance systems.78 In many MS, recognition

bodies do not take into account prior qualification assessments conducted during migration

71 See Annex 9, Figure 7 - Overview of documents required for doctors across MS. 72 Under the PQD, if a host EU country finds substantial differences between an applicant's professional

qualifications and their national requirements, they may impose compensation measures. Applicants are generally

given the choice between two options: an adaptation period or an aptitude test. No equivalent framework governs

compensation measures for TCNs. In the absence of EU legislation, Member States and competent authorities

determine independently whether compensation measures apply, in what form, and on what terms, resulting in

significant variation in both the nature and extent of the requirements imposed on TCN applicants for the same

profession across different national and regulatory contexts. CA survey, Q28 (n=190) 73 Regulation is decentralised in AT, BE, DE and IT. See Annex 9. 74 In a targeted consultation with the Group of Co-ordinators for recognition of professional qualifications on SPI

Action 3, RO supported by EE, IT, PT, CY, SK, HR, HU flagged the risk of TCNs seeking first recognition in

more flexible MS before moving elsewhere. Minimum standards applying uniformly across MS are the primary

design safeguard against this risk (See Annex 2). 75 Bilateral MS meetings 76 DG HOME/Kantar (2023) 77 Focus Group with ENIC-NARIC centres, PES and CSOs (FG3, n=28); Public Consultation TCN responses

(Annex 2) 63 AT, BE, DE, IT

17

processes meaning TCN may undergo parallel and duplicative procedures under different

institutional frameworks, each with its own timeline79.

The dependence of migration status on recognition outcomes is a distinctive and compounding

source of vulnerability for TCN that does not arise for EU nationals exercising free movement

rights. Where recognition is a precondition for the issuance or renewal of a work permit, a

delayed or unsuccessful recognition procedure translates directly into an inability to work, loss

of income and, in the most serious cases, the prospect of forced return. In several MS, formal

recognition is a legal precondition for the issuance of a residence permit, meaning that an

unsuccessful or delayed recognition procedure directly determines whether the applicant's right

to reside and work is granted or maintained80. The IOM has noted in the public consultation

(PC) that shortcomings in recognition procedures for TCN are magnified by their direct

interaction with migration, visa and residence frameworks81.

Sub-driver 1.3: Lack of clear and accessible information for TCN and employers

Even though almost all Member States have some form of information mechanism in place for

TCN on recognition procedures,82 these rarely provide comprehensive or detailed guidance on

requirements, costs, timelines or expected outcomes.83 Only a small number of Member States

(AT, DE, FI, IT, NL, PT, SE) operate dedicated information portals specifically designed for

TCN applicants. Several others provide general information through national websites, but

these are rarely profession-specific, rarely updated when procedures change, and rarely

available in languages other than the official language of the Member State.84

TCN face particular difficulties in identifying whether a profession is regulated in the receiving

Member State, and in determining which competent authority is responsible for recognition The

majority of TCN (154 out of 253) rely on official government websites as their primary source

of information on recognition procedures.85 Yet despite this reliance, 134 out of 253

respondents (53%) characterise the information those websites provide as only "somewhat

clear", and a further 54 out of 253 (21.3%) describe it as "not clear at all". Taken together, 188

out of 253 TCN surveyed — nearly three quarters — report that the information available to

them about recognition requirements is inadequate.86

79 Survey of CAs, Q33 (n=190). MS taking prior assessment into account: AT, BE, ES, FI, FR, IE, IT, LT, LV,

NL, PL, PT, SE, SI. 80 (CZ, NL, SK for the Blue Card pathway; BE, CZ, FR, HU, LT, PL, PT, SK, SE for sequentially structured

migration routes more broadly) 81 IOM PC response 82 CA survey, Q10 (n=134); Annex 9, Section 8.6 (Availability of information for TCN and support for applicants).

Almost all MS reported having at least one information mechanism, ranging from dedicated TCN portals to general

national websites covering recognition alongside other immigration-related information. 83 Focus Group on information and support to TCN (FG3, n=37, including ENIC-NARIC centres and PES from

18 MS and 2 EEA Members); PC TCN responses (Annex 2). 84 The difficulty of identifying the responsible CA is particularly acute in decentralised governance systems (AT,

BE, DE, IT) where recognition responsibilities are shared across regional bodies and sectoral regulators, and where

the responsible CA for the same profession may vary across regions of the same MS. 85 TCN survey, Q10 (n=253). 86 TCN survey, Q11 (n=253).

18

Information on recognition procedures is frequently split between ENIC-NARIC centres, which

hold expertise on academic qualification systems, CAs, and MA, who each operate under

different legal mandates and often with limited coordination between them.87 Focus group

participants consistently described information on recognition procedures as fragmented,

highly technical and dispersed across multiple institutional channels, with difficulties

particularly pronounced in decentralised systems where responsibilities vary across regions.88

See Annex 9 (a) (viii) for a full mapping of information availability and support mechanisms

across Member States.

Employers, and in particular SMEs, encounter significant difficulties understanding and

navigating recognition procedures.89 In targeted consultations, employer bodies and HR

departments consistently described recognition information as among the least transparent

aspects of international recruitment, a finding corroborated by the public consultation where

199 out of 486 respondents across all stakeholder types reported difficulties in understanding

and verifying foreign qualifications.

Driver 1 - EU instruments: No existing EU instrument imposes common rules on the design

or systems of TCN recognition systems. Commission Recommendation EU 2023/2611

encourages simplification and greater consistency but, as a non-binding instrument, cannot

establish procedural frameworks, meaning divergent systems remain in place. The PQD has

established rules explicitly for EU citizens mobile in the EU. Where information is available at

EU level, it is itself divergent in source and scope (e.g. Europass, EU Immigration Portal) which

do not offer TCN a coherent picture of the recognition procedures in MS. The ENIC-NARIC

network supplies comparability information that divergent systems need but cannot itself

resolve that divergence. Further analysis of EU instruments is provided in Annex 8,

Recognition-specific instruments.

2.3.2. Driver 2: Complex and burdensome administrative procedures for

recognition

This driver explains why the procedural experience of applying for recognition is onerous for

TCN, even where the appropriate route is known.

Sub-driver 2.1: Lengthy and untransparent procedures

The duration of recognition procedures is impacted by a number of factors. Recognition

procedures take considerably longer than reported by CAs and the lack of transparency

compounds burden for both TCNS and employers. For regulated professions, CAs report

timelines that cover only the period from receipt of a complete application to decision, but pre-

application requirements, document gathering, translation and legalisation mean the true

experience of recognition for TCN is considerably longer. In addition, the duplication of

87 Focus Group on information and support to TCN (FG3, n=37, ENIC-NARIC centres, PES and CSOs from 18

MS) 88 Focus Group on information and support to TCN (FG3, n=37, ENIC-NARIC centres, PES and CSOs from 18

MS); Focus Group on labour migration with MAs and IOs (FG4, n=28); targeted interviews (2 CSOs, 2 IOs, 1

HR, 1 professional body, 5 TC authorities) 89 PC, Q24 and Q25 (n=486); targeted interviews (2 EU employer bodies, 3 HR departments, 1 professional body);

Focus Group on attracting talent (FG5, n=27).

19

procedures, due to the misalignment between recognition and migration procedures, described

above in 1.2, intensifies delays as TCN may undergo parallel and duplicative procedures under

different institutional frameworks and separate timelines90.

In regulated professions, CAs report that only a small share of recognition procedures result in

a formal decision within one month. In most cases, decisions are delivered between one and

three months (65 of 190 CAs) or three and six months (58 of 190 CAs), with even longer

timelines in fewer cases) (18 CAs reported duration of 6-12 months; 6 reported 1-2 years and 3

reported 2-3 years).91 In several MS92, access to recognition procedures is conditional on first

obtaining a recognition statement from ENIC-NARIC centres, adding one to three additional

months93. Data from the TCN survey reveals a much lengthier reality: while 18.8% of

respondents received a decision within one to three months, 36.3% indicated that the process

dragged on for over a year.94 Accounting for pre-procedure requirements and administrative

delays, the estimated actual average duration of the full recognition process is approximately

14.2 months.95

The available evidence does not allow for a precise baseline on the expected duration of

qualification and skills checks within migration procedures.96 An indicative timeline of 6-

12 weeks can nonetheless be established for the majority of standard employment-related

applications, drawing on MA survey data.97

The lack of predictability is itself a barrier. Applicants cannot anticipate procedure duration,

and employers cannot plan recruitment around it. Where recognition determines whether a work

permit can be issued or renewed, delays translate into loss of income, administrative limbo, and

in some cases forced return98. TCN described procedures lasting several years and prolonged

periods of administrative silence. 21 (11.5%) of surveyed TCN withdrew their application due

to the excessive length and cost of the procedure99. Some testimonies linked long procedures to

forced professional inactivity (39 of 253), delayed careers (34 of 253), and prolonged

dependency on precarious employment (39 of 253). Hospitals and other employers report

situations where qualified professionals are legally present but unable to work, or unable to

work at their skill level, while awaiting recognition decisions100. This not only adds complexity,

but unpredictability may prevent the fulfilment of requirements for the recognition process,

including the ability to complete adaptation measures required by CA in some MS (DK, HR,

90 CA survey, Q33 (n=190). 83.7% declared they do not consider prior assessment. 91 Survey of CAs, Q16 (n=190); in addition 29 of 190 CAs reported they did not know the duration of procedures

for TCN. 92 Survey of CAs, Q10 (n=190). MS requiring the listed documents: AT, BE, DE, EE, ES, FR, HR, LT, MT, NL,

PT, RO, SI. 93 NARIC survey, Q10 (n=18) 94 TCN survey, Q13 (n=160) 95 See Annex 4: analytical methods (Level 3 – Social cost and opportunity cost) 96 MA survey (n=48). 50% could not quantify additional time. 50% indicated that the additional time attributable

to such checks is unknown (AT, CZ, FR, IE, IT, LT, MT, PL, PT, SK, SE). 97 MA survey (n=48). 50% report checks before conclusion; 14.6% in parallel; 14.6% varies by route. EMN

(2024b); MPF (2024). See Annex 9. 98 Focus Group with TCNs (FG6, n=12); PC, Q26 (n=98); TCN survey, Q12 (n=183) 99 CN Survey, Q12 (n=183)

100 Contribution to the call for evidence (DKG; CCBC); MS bilateral meetings

20

IE, PL), or result in the rejection of talent-visa applications for reasons related to visa

requirements (SE).101

Sub-driver 2.2: Burdensome documentation and translation requirements

Recognition procedures typically require extensive supporting documentation, including

diplomas, transcripts, proof of professional experience and other formal evidence. All surveyed

CA for regulated professions require on average over six different documentsto be submitted

in original paper form.102 These requirements generate particular complexity for TCN who

cannot access their original documents (including refugees, asylum seekers and those who fled

conflict103) for whom obtaining documents from institutions in the country of origin may be

impossible or prohibitively costly. In addition, the large majority of surveyed CA, across all

Member States, require certified translations adding to the complexity, length and cost of the

process.104

The documentation burden is one of the most distinctive aspects of the TCN experience. EU

nationals exercising intra-EU mobility under PQD face document requirements within a

framework that limits what can be demanded and provides legal recourse. No equivalent

framework exists for TCN. The requests for original curricula or legacy documents, are

amplified where TCN are required to go through repeated or overlapping processes in MS.

CA may also request additional documents that applicants do not directly hold, requiring

contact with national administrations or training institutions in their country of origin. This is

typically time-consuming and, in conflict-affected contexts, sometimes not achievable105. The

requirement for in-person verification or physical document submission is particularly

burdensome for TCN residing abroad who have no legal pathway for entry to a MS for

recognition purposes alone106. Moreover, only some MS have fully107 or mostly108 digitalised

procedures, thus pointing to an overall burdensome and lengthy recognition procedure for

TCNs.109 Where digital procedures exist, they may require a national eID110 or in-person

identity verification that TCN do not yet possess.111

For employers, documentation requirements generate their own burdens. Verifying the

authenticity of foreign documents may require engaging intermediaries, allocating internal

101 Bilateral MS meetings; Focus Group on labour migration with MAs and IOs (n=28) 102 Survey of CAs, Q10 and Q11 (n=190) 103 European Commission (2011); targeted interviews (3 IOs, 2 CSOs, 1 CA, 1 HR dept); call for evidence (IOM;

ENSIE) 88

151 out of 190 surveyed CA require certified translations, 111 requiring them systematically for all documents

submitted, and a further 54 in specific circumstances 105 Focus Group with individual TCNs (FG6, n=12); targeted interviews synthesis; NARIC survey: 66.7% of

centres identified missing or incomplete documentation as a cooperation challenge (n=18). 106 Survey of CAs, Q12 (n=190); European Commission (2011) 107 AT, BE, EE, ES, FI, FR, IE, IT, MT, PT, SE 108 LT, LU, LV, NL 109 Survey of CAs, Q18 (n=190). See Annex 8. 110 eID is a set of services provided by the European Commission to enable the mutual recognition of national

electronic identification schemes (eID) across borders: https://ec.europa.eu/digital-building-

blocks/sites/spaces/DIGITAL/pages/467109253/eID 111 Survey of CAs, Q18 (n=190)

21

administrative resources and understanding documents from unfamiliar systems. For SMEs,

which lack specialised HR capacity, such burdens can be disproportionate and may discourage

recruitment from third countries even where labour demand is clear.112

Sub-driver 2.3: High and unclear costs

Recognition procedures generate significant direct and indirect costs. Direct costs include

administrative fees, translations, legalisations, apostilles, examinations and mandatory training

or bridging courses. Indirect costs include income lost while preparing for and undergoing the

procedure, as well as employer opportunity costs from delayed recruitment and prolonged

vacancies.

Fee structures vary substantially across MS and are often difficult to anticipate in advance. The

level of application fees shows extreme variation across MS and professions, ranging from no

fees at all to charges exceeding EUR 2000, with an average lying at around EUR 150. 113 Health

professions, and in particular medical doctors and dentists, are consistently associated with the

highest financial burden, with fees above EUR 1,000 reported in several Member States (HR,

FI, NL, SE). Moreover, during the application process, in 16 MS 114 additional costs may arise,

such as authentication or legalisation of documents115, as well as expenses associated with

additional training, examinations, or tests required as part of compensation measures. For

medical qualifications, costs range from zero (BG, FR, LU, PL) to EUR 1,700 for the BI-

Test.116

The quantified cost baseline is presented in full in Section 6.1 (Table 6.1) and in Annex 4.5.

The average total cost per recognition procedure is estimated at EUR 1,500, comprising an

average application fee of approximately EUR 150 (ranging from zero to over EUR 2,000

across MS and professions), certified translations averaging EUR 200, legalisation averaging

EUR 150, and compensation measures where applicable.117

Financial uncertainty aggravates the burden. Whether for recognition procedures (for

visa/residence decisions, access to regulated professions or other purposes) applicants are rarely

informed in advance of the full scope and total costs involved118; initially unforeseen

obligations (e.g. translation requirements or in-person procedures) can emerge mid-process,

increasing both the financial and psychological burden and discouraging qualified persons from

pursuing recognition119. For TCN, this financial unpredictability is particularly acute. Unlike

EU nationals who can remain legally in the host MS while pursuing recognition for access to a

regulated profession, TCN often face these costs under conditions of precarious or conditional

112 European Commission (2023), Flash Eurobarometer 529 – SMEs, skills shortages and public

support; Eurofound (2021), Tackling labour shortages in EU Member States; Eurofound (2023), Measures to

tackle labour shortages: Lessons for future policy. 113 CA survey, Q17 (n=190) For further details, see Annex 9(b)(vi) Costs and fees (migration procedures). 114 AT, DE, EE, ES, FI, HR, HU, IE, IT, LV, MT, NL, PL, PT, RO, SI 115 Survey of CAs, Q17 (n=190). See Error! Reference source not found. 116 Survey of CAs, Q17 (n=190); EMN (2024a). The Netherlands BIG-register (Beroepen in de Individuele

Gezondheidszorg) requires non-EU doctors to pass a competence assessment called the BI-test. 117 Full cost methodology and breakdown in Annex 4.5. Summary in Section 6.1118 PC, Q36 (n=84); targeted interviews (2 CSOs, 2 IOs); Focus Group with individual TCNs (n=12); Focus Group

on information support (n=28) 119 Bilateral MS meetings; DG HOME/Kantar (2023)

22

residence, meaning that the decision to invest in recognition is taken under heightened financial

and legal uncertainty.

Driver 2 – EU Instruments: Procedural burdens cannot be resolved by the existing EU policy

ecosystem. Commission Recommendation EU 2023/2611 addresses procedural complexity but

creates no enforceable rights. The EU's attract and match instruments (The Talent Pool, Talent

Partnerships) help prospective applicants find vacancies, entry routes and information on

recognition procedures before arrival, but have no bearing on the nature of the recognition

procedures themselves in a MS. The EU legal migration directives grant certain categories of

TCN a right to equal treatment with nationals in accessing recognition procedures but say

nothing about how those procedures are designed. Further analysis of EU instruments is

provided in Annex 8, The EU talent ecosystem.

2.3.3. Driver 3: Lack of trust in and understanding of qualifications and skills

obtained in third countries

Assessing foreign qualifications or credentials requires not only verifying the authenticity of

documents, but also understanding how third-country education, training and professional

experience correspond to national requirements. Where such understanding is limited,

authorities apply more cautious and resource-intensive procedures, while employers hesitate to

recruit otherwise suitable candidates

Sub-driver 3.1: Concerns about authenticity and reliability of documentation

Concerns over the authenticity of documents issued in third countries constitute a significant

challenge for national CAs. Verifying the authenticity of third-country qualification documents

is among the main challenges reported by CAs: 18 of the 21 MS represented in the CA survey

identified this as a primary difficulty120 (AT, DE, EE, ES, FI, FR, HU, IE, IT, LV, LT, LU, MT,

NL, PL, PT, RO, SK), a finding corroborated by almost 90% of ENIC-NARIC centres consulted

across 15 countries.121

Particular difficulty was reported for qualifications from countries with weak administrative

systems or conflict zones, including Syria, several African countries, Ukraine, and for countries

where building trust is structurally difficult, such as India, Brazil, Mexico and the

Philippines.122 Several MS (BE, DE, EE, ES, IE, LV, SK) also reported evidence of fraudulent

documents and diploma mills. Concerns were confirmed by NARIC centres and recognition

bodies in third countries themselves.123 The PC highlighted that approximately 25% of public

authority respondents frame trust issues primarily in relation to verification and authenticity

concerns.

Sub-driver 3.2: Insufficient knowledge of third-country educational systems, curricula and

standards

120 Survey of CAs, Q28 (n=190) 121 NARIC survey, Q26 (n=18) 122 Bilateral MS meetings; Focus Group on access to regulated professions with CA of electricians and crane

operators ( n=20); Focus Group on information support to TCNs with ENIC NARIC centres and PES (n=37) 123 Targeted interviews with 15 TC authorities

23

National authorities often struggle to interpret and compare TCQs as well as the type of

professional activities performed by TCN in third countries, due to limited knowledge of third-

country education and training systems.124 The delays associated with such information

barriers make the recognition and, as a consequence, the recruitment

procedure lengthier and more burdensome and cause distrust of employers for the

qualifications possessed by TCN.125 Indeed, several MS (AT, DE, FR, ES, PL, SK) reported a

high degree of discrepancy between the EU and third-country education and training standards

which hinder the assessment.126

Employers, in particular SMEs, also experience challenges when assessing qualifications

obtained in third countries, due to lack of knowledge of third country qualifications.127 The

assessment of skills possessed by candidates often happens directly during the recruitment

procedure (e.g. through in-house, specific methods) in order to evaluate whether the candidate’s

skills align with the organisation’s needs and job requirements. Consulted stakeholders pointed

out that the lack of knowledge leads to the exclusion of TCN candidates.128

Sub-driver 3.3: Doubts about the efficacy of quality assurance within third-country systems

Even where formal quality assurance (QA) arrangements or qualifications frameworks exist in

third countries, recognition bodies frequently remain uncertain about their reliability.129 CA and

sectoral stakeholders in the PC underlined that third-country QA arrangements are often

insufficiently known, unevenly documented or difficult to verify from an EU perspective.130

As a consequence, authorities tend to adopt a precautionary approach, relying on intensive

individual scrutiny rather than systemic recognition. The trust deficit is widespread rather than

exceptional: 60.5% of CA reported trusting evidence and documents related to TCQ only to a

moderate (51.1%) or low (8.8%) extent.131 This directly affects how recognition applications

are assessed, often leading to more cautious, resource-intensive or fragmented outcomes.

This trust deficit is primarily driven by persistent information barriers. CA and employers

frequently lack access to standardised, verifiable and operational information on curricula,

learning outcomes and accreditation arrangements, leading to reliance on case-by-case

document scrutiny rather than systemic confidence.132 Without cumulative institutional

knowledge or shared reference points, QA arrangements in third countries are assessed in

isolation, without benefiting from learning effects across cases. This contributes to repeated

reassessment of similar qualifications and limits the development of stable recognition practices

over time.

124 Focus Group on information and support to TCNs with ENIC NARIC centres, PES and CSOs (n=37); Focus

Group on access to regulated professions with CA of electricians and crane operators ( n=20); Focus Group with

CA in the healthcare sector (n=31) 125 DG HOME/Kantar (2023) 126 Bilateral MS meetings 127 Bilateral MS meetings; DG EMPL/ECORYS (2017); DG HOME/Kantar (2023); targeted interviews (3 HR

depts, 1 IO) 128 Targeted interviews with three HR departments and one IO 129 ETF (2025); ETF (2024); targeted interviews (2 IOs) 130 ETF (2025); ETF (2024) 131 Survey of CAs, Q15 (n=190) 132 Call for evidence (Taflan GmbH; ZDH; ONCD); PC, Q25 (n=486)

24

Driver 3 – EU Instruments: The trust deficit is addressed only partially and indirectly by

existing EU instruments. The EQF offers a meta-framework for comparing qualifications across

systems, and Talent Partnerships support pre-departure skills development in partner countries,

but neither builds the institutional trust in specific third-country qualifications that MS

authorities need to simplify or accelerate individual recognition decisions. ENIC-NARIC

centres provide valuable expertise, but their assessments remain national and serve the

divergent needs of each system rather than a common trust framework. No existing instrument

provides a systematic mechanism for establishing trust in TCQ across all relevant authorities.

Further analysis of EU tools is provided in Annex 8, Recognition-specific instruments.

2.4. How is the problem likely to persist?

Without further action, the problem is likely to persist and may intensify over time.

First, the identified drivers are structural. Recognition systems and procedures differ

substantially across and within MS and mutual learning and cooperation among MS remains

fragmented. The administrative burdens associated with recognition are therefore unlikely to

diminish on their own. Even where MS take action to simplify procedures, these may only be

implemented for particular professions, sectors or migration pathways and results are siloed.

This pattern of national action addressing specific use cases rather than the underlying system

is consistent with the broader dynamic identified in the Commission's 2025 Strategic Foresight

Report133. Structural challenges that evolve in fragmented governance environments tend to

compound rather than resolve, as incremental national responses generate further divergence

and complexity rather than systemic improvement. In the absence of greater simplification the

scale of uncertainty, delays and costs may in fact worsen as structural issues of demographic

ageing and skills shortages intensify.

Second, labour market pressures are expected to remain high. Long-term demographic

projections indicate that the EU labour supply will continue to contract. The share of the

working-age population is projected to decline steadily after 2030, while the old-age

dependency ratio is expected to rise from 33% in 2022 to over 50% by 2050134. These trends

point to a structurally tighter labour market, with fewer entrants replacing retiring workers and

increasing reliance on migrant labour, particularly in sectors already experiencing shortages.

The EU population is projected to peak at around 453 million in 2029 before entering a gradual

decline; the share of the working-age population (aged 20–64) is projected to shrink from

approximately 58% in 2022 to around 50% by 2100135. The resulting strain on labour markets

and public finances are among the central structural challenges facing the EU through to

2040136.

Third, future skills demand is expected to remain strong even without rapid net

employment growth. Forecasts to 2035 indicate that around nine out of ten job openings in the

EU will arise from replacement demand, notably in health and long-term care, construction,

133 European Commission, Strategic Foresight Report 2025 — Resilience 2.0, September 2025, pp.4–5. 134 Cedefop (2023); Cedefop (2021); Cedefop (2020). 135 EUROPOP2023 population projections, March 2023 (dataset proj_23np) 136 European Commission, Strategic Foresight Report 2025 — Resilience 2.0, September 2025, pp.13–14

25

manufacturing, transport and technical professions137. Many of these sectors include regulated

occupations or depend on a high degree of confidence in qualifications and skills. This means

that barriers to recognition are likely to remain a binding constraint on labour market matching.

The Commission's 2025 Strategic Foresight Report reinforces this outlook, identifying labour

market reconfigurations driven by demographic and technological megatrends as a priority area

of action, and framing the ability to deploy skills effectively — including from abroad — as a

condition for sustaining EU competitiveness and economic resilience through to 2040.

Recognition barriers that prevent the effective deployment of available qualified workers are

therefore not only a procedural inefficiency but a constraint on a strategic EU priority.

Fourth, sector-specific shortages reinforce this outlook. In health and long-term care, for

example, the EU is expected to face a shortfall of around 2 million additional workers by

2030138. The Commission's 2025 Strategic Foresight Report confirms that healthcare and

elderly care systems face structural long-term pressures from labour and skills shortages that

compound the effects of demographic change that are among the central challenges to European

societal resilience through to 2040. Simulations project healthcare workforce growth of only

16% for doctors and 8% for nurses by 2071 against requirements of 30% and 33% respectively

to meet the demands of an ageing population, with the period to 2036 identified as the window

of greatest urgency as large cohorts approach retirement while replacement flows remain

insufficient.139 Foreign-trained professionals already play a significant role in European

healthcare systems, and several MS have reinforced their workforces through international

recruitment — underscoring that the gap between domestic supply and demand cannot be

closed without continued inflows of qualified professionals from third countries.140 The

consequences of this shortfall are not uniform: rural, peripheral and border regions face a

disproportionate burden, as systemic weaknesses prevent them from attracting or retaining the

qualified workforce that more dynamic urban centres can offer. The recognition of

qualifications constitutes a key access barrier within this complexity. Without improvements in

recognition systems, projected labour shortages are therefore likely to coexist with the

continued underutilisation of available third-country skills.

3. WHY SHOULD THE EU ACT?

3.1. Legal basis

The legal basis for this Union action is Article 79(2)(a) and (b) TFEU, which empower the

European Parliament and the Council, acting in accordance with the ordinary legislative

procedure, to adopt measures concerning the conditions of entry and residence of TCN, and the

definition of their rights, including access to employment.

137 Eurostat: Population projections in the EU, https://ec.europa.eu/eurostat/statistics-

explained/index.php?title=Population_projections_in_the_EU:. EU’s population projected to drop by 11.7% by

2100

: https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20260416-1 138 European Commission (2021). 139 Bernini, A., Icardi, R., Natale, F. and Nedee, A., Healthcare workforce demand and supply in the EU27, JRC,

2024 (JRC139503). 140 OECD, Recent Trends in International Migration of Doctors, Nurses and Medical Students, 2019; Bernini et

al., JRC139503, op. cit.

26

The action aims to facilitate the recognition of qualifications of TCN, to improve their access

to the EU labour market and the effective use of their skills. Recognition of qualifications is

directly linked to the conditions of entry and residence within the meaning of Article 79(2)(a)

TFEU. Access to employment and therefore to residence for work purposes often depends on

whether qualifications acquired in third countries can be recognised. The action contributes to

making the procedures linked to meeting the conditions for admission for employment purposes

simpler, more efficient and more transparent, and their outcomes more predictable for both

applicants and employers.

At the same time, the action supports the effective exercise of rights of TCN legally residing in

the Union under Article 79(2)(b) TFEU. By simplifying recognition procedures, the action

facilitates access to employment corresponding to their qualifications and skills, thereby

reducing underutilisation of talent and supporting equal treatment in working conditions. The

envisaged Union action therefore falls within the scope of both Article 79(2)(a) and (b) TFEU.

3.2. Subsidiarity: Necessity and added value of EU action

The objectives of improving streamlined, simple and trusted recognition procedures for TCN

cannot be sufficiently achieved by MS acting alone: a coordinated EU-level approach is

necessary to address divergence, establish common procedural rules and deliver more

predictable outcomes across the Union. The PC confirmed this with 95.3% of respondents

considering EU-level action very or somewhat necessary.

The added value of common rules for the recognition of qualifications in the EU lies in

simplifying a divergent set of national procedures into a more consistent approach that enables

the functioning of the Single Market. TCN will be able to better understand requirements,

prepare applications, and anticipate outcomes. Similarly, for employers, particularly SMEs that

currently lack the resources to navigate divergent national systems, more reliable and usable

recognition procedures would lower the administrative burden of recruitment and facilitate

workforce planning, directly addressing a barrier within the Single Market that limits

employers' ability to draw on the full pool of available talent.

More broadly, a coherent and accessible recognition framework would strengthen the EU's

position in the global competition for talent. The EU presents itself as a single destination, a

single trading partner, and a single labour market through instruments such as the EU Blue

Card, the EU Talent Pool, the European Legal Gateway Office pilot in India, and EU Talent

Partnerships. These each depend on recognition systems functioning adequately to deliver their

intended results. If recognition remains cumbersome and unpredictable, the value added of

those instruments will be reduced for employers and jobseekers. The action would send a clear

signal that the Union offers fair and navigable routes for skilled workers to use their

qualifications complementing these EU instruments and reinforcing competitiveness. Acting at

EU level would also generate economies of scale in addressing the issues of trust and

understanding of qualifications, by maximising mutual learning about qualifications issued in

third-countries. Shared tools are inherently more effective when developed collectively than

when replicated separately across 27 MS.

Critically, this action would complement rather than replace national systems. MS would

remain fully responsible for defining which professions are regulated, the organisation of

training systems, taking individual recognition decisions, and managing migration policy and

27

admission decisions. Importantly, although the action will aim to minimise duplication of

processes, it does not create a “once only process” by which recognition in one MS would be

valid for the whole of the EU.141 Hence, common rules on procedures, documentation, timelines

and safeguards, would support existing frameworks, while preserving flexibility in

implementation and respecting national competence.

4. OBJECTIVES: WHAT IS TO BE ACHIEVED?

4.1. General objectives

The general policy objective of SPI Action 3 is: Facilitating the recognition of qualifications

for TCN to address EU labour and skills shortages.

This general objective addresses persistent barriers faced by TCN in accessing EU labour

markets. By reducing divergence, administrative barriers, and legal uncertainty the action aims

to contribute to the EU economy and competitiveness by addressing labour and skills shortages

and support the Commission’s simplification agenda.

4.2. Specific objectives

The specific policy objectives are:

SO1: Streamlined recognition

systems within and between

MS

Improved alignment and consistency between national

recognition systems across the EU, and coherence within

MS, between recognition procedures for access to

regulated professions and those embedded in migration

regimes.

SO2: Reduced legal and

administrative complexity for

recognition of qualifications

of TCN

Clearer and less burdensome requirements, documentation

and procedural steps for TCN applicants, employers and

authorities, including, reduced administrative steps and

enhanced user-friendliness.

SO3: Increased trust and

understanding of

qualifications obtained in

third countries

Improved transparency, comparability and trust of TCQ

within the EU, through enhanced information availability

and mechanisms that support the assessment of foreign

qualifications and skills.

5. WHAT ARE THE AVAILABLE POLICY OPTIONS?

5.1. What is the baseline from which options are assessed?

Under the baseline, recognition of qualifications for TCN will continue to be governed by

divergent national systems without EU-level coordination. Improvements undertaken by

141 This approach is in line with the system in place for mobile EU citizens under the PQD. This system is built on

mutual recognition of professional qualifications but does not provide for mutual recognition of recognition

decisions.

28

individual MS are likely to address specific use cases (particular professions, sectors or

migration pathways) rather than the underlying structural fragmentation identified in Chapter

3. The result is a trajectory of incremental national change that is likely to generate further

divergence rather than convergence, as each MS develops its own responses in isolation.

At EU level, Commission Recommendation (EU) 2023/2611142 will continue to provide the

main horizontal framework, encouraging MS to simplify procedures and exchange good

practices. As set out in Annex 8, however, its non-binding character means it cannot create

enforceable procedural rights, impose deadlines or mandate coordination between recognition

and migration systems; its capacity to address the structural drivers identified in Chapter 3 will

therefore remain limited. Talent attraction instruments143 will continue to develop and will

improve information provision and upstream preparation but will not alter the nature of national

recognition procedures. EU legal migration directives144 will continue to provide harmonised

admission conditions for certain categories of TCN, but their impact on recognition procedures

through equal treatment provisions will remain limited. None of these instruments will

structurally address the organisation, design or functioning of recognition systems.

Under the baseline, TCN will therefore continue to face the procedural barriers described in

Chapter 3: divergent national systems producing uncertain and inconsistent outcomes,

burdensome documentation and cost requirements, and recognition authorities with limited

capacity to assess third-country qualifications with confidence. For prospective migrants, the

absence of predictable recognition pathways will continue to operate as a deterrent that shapes

destination choices in favour of countries offering faster and more predictable routes to

employment. The EU's structural disadvantage relative to competitor destinations in

recognition predictability will persist.145

These conditions will be particularly acute for access to regulated professions, where TCN will

continue to operate without the procedural guarantees available to EU citizens under the PQD.

Labour shortages in regulated sectors, documented in Chapter 3, will persist and are projected

to intensify in particular in healthcare, where demographic pressures will compound the effects

of current recognition barriers. The conditions conducive to undeclared work identified in

Chapter 3 will remain fully in place in the absence of binding procedural reform.

Mutual Recognition Agreements (MRAs), whether standalone or embedded in free trade

agreements, remain relatively rare in practice and their overall impact on addressing large-scale

labour market needs will remain limited. EU transparency tools, including the EQF, would

continue to contribute to improving the comparability and understanding of qualification from

third countries, in a context of comparisons between the EQF and qualifications frameworks

from third countries, but use of qualifications frameworks and meta frameworks will not resolve

underlying issues of divergence and duplication in recognition systems for third-country

nationals.

142 Commission Recommendation (EU) 2023/2611, recitals 4–6; Annex 8 (Legal and Policy Context). 143 The EU Talent Pool, Talent Partnerships and the European Legal Gateway Offices (Annex 8 (Legal and Policy

Context).) 144 Overview of EU legal migration instrument and links with recognition in Annex 8 (Legal and Policy Context). 145 OECD (2023)

29

Separately, implementation of validation of skills for TCN will continue to vary significantly

across MS and its use for TCN remains uneven (See Annex 10).

5.2. Description of the policy options

All three policy options identified aim at improving the recognition of qualifications of TCN in

the EU (including qualifications obtained in a third country and in another MS146. They each

address the divergence, procedural complexity and lack of trust that currently characterise

national systems. The options address procedural and systemic barriers to recognition of

qualifications but do not impact MS competence to define which professions are regulated, the

organisation of training systems, to take individual recognition decisions, and to manage

migration policy and admission decisions. A set of non-legislative supporting measures can

accompany each of the options to support their implementation and effectiveness. These include

promotion and awareness raising of the EU Talent Pool; facilitating pre-departure support under

Talent Partnerships; supporting cooperation and exchange of good practices among MSs and

stakeholders on recognition and validation147; and, awareness raising of the changes introduced

under this action focusing on the practical benefits of well-managed recognition for addressing

skills and labour shortages, and the benefits for TCN, EU citizens and employers within the

Single Market.

5.2.1. PO 1 – Soft measures to enhance procedures for the recognition of

qualifications of TCN (voluntary)

PO1 addresses the objectives through a coherent set of practical tools developed collaboratively

by the Commission, MS, and relevant stakeholders. This option creates the conditions for

greater commonality and more user-friendly processes. The voluntary character ensures that

progress is anchored in shared commitment and incremental trust, while its practical and

granular tools are designed to deliver tangible improvements to procedural barriers. The

measures comprising PO1 (B1–B10) are described in detail in Annex 12.

To drive convergence of systems, common EU guidelines and best practices would be

developed covering recognition systems and methodologies for consistent qualification

assessments, complemented by comparative studies to support evidence-based alignment.

These tools directly target the systemic fragmentation and duplication that currently impede

mobility and consistent outcomes within and between MS.

To support simplification of administrative procedures, common templates, checklists, and

guidance on procedural steps, fees and documentation requirements would be co-developed,

alongside improved EU-level information provision for TCN and employers. The aim is to

make processes more accessible, predictable and coherent in practice, addressing the

complexity and lack of transparency that often discourage or delay applications.

146 While the scope of this action is facilitating recognition for TCN, it will be complemented by targeted

amendments to the PQD to guarantee equal treatment for EU citizens holding TCQ. See Annex 8 Legal and Policy

context. 147 As set out in Annex 7 (discarded options), EU action on procedural rules for validation is not considered within

this IA. Accompanying measures are considered the most appropriate way to support exchange and cooperation

on validation, in alignment with the ongoing implementation of the Council Recommendation on validation

30

To build trust in TCQ, AI-assisted solutions for authenticity verification would strengthen

confidence among CA and employers, complemented by comparative work on how third-

country qualification frameworks relate to the EQF and analytical work to improve the

transparency and comparability of quality assurance arrangements in third-country systems.

Together, these tools support more consistent and well-informed decision-making, addressing

the uncertainty that can lead to inconsistent or overly cautious outcomes.

5.2.2. PO 2 – Common rules to streamline procedures (binding)

PO2 introduces a binding legal framework establishing EU level common procedural rules for

the recognition of qualifications. It will apply to recognition procedures to access regulated

professions and any qualifications recognition procedures that form part of migration

procedures. The measures comprising PO2 (A1–A10) are described in detail in Annex 12.

The rules are modelled on the procedural framework of the PQD. This ensures that TCN are

not treated more favourably than EU citizens exercising free movement rights and anchors the

rules in a framework already tested across MS148. The framework is designed to accommodate

the different contexts in which qualification checks take place. The standard of scrutiny applied

to a qualification check within a migration procedure need not replicate the depth of assessment

required for access to professional practice. The check should be proportionate to its purpose

and conducted within a predictable and transparent procedural framework without creating

undue burden for the MS. The aim throughout is to ensure that recognition supports rather than

delays or blocks decisions on migration and employment. Within these parameters, the common

rules would include:

Rules modelled on the PQD: (1) fixed deadlines (e.g.1 month to acknowledge receipt and

inform of missing documents, 3-4 months for taking a decision), (2) a right to a duly

substantiated decision; (3) a right to appeal; (4) an exhaustive list of documents that may be

required from applicants; (5) an obligation to provide full transparency on fees.

Rules addressing circumstances specific to TCN149 : (1) a right to receive communications and

submit documents in at least one language other than an official language of the Member State

that is frequently used by migrants; (2) a framework for imposing compensation measures150

on TCN, seeking access to regulated professions, with greater flexibility for MS than under the

148 Targeted amendments to the PQD will ensure that EU citizens with TCQ are not treated less favourably (see

Annex 8 (1) on Treaty legal basis). 149 Third-country nationals face procedural circumstances without equivalent in the PQD framework, including

the need to navigate migration procedures as a precondition to labour market access and the absence of the

information and support networks available to EU mobile workers. The rules in this section address those specific

circumstances. 150 Under the PQD, if a host EU country finds substantial differences between an applicant's professional

qualifications and their national requirements, they may impose compensation measures. EU citizens may choose

the form of compensation measure they wish to complete: an adaptation period or an aptitude test. No equivalent

framework governs compensation measures for TCNs. In the absence of EU legislation, Member States and

competent authorities determine independently whether compensation measures apply, in what form, and on what

terms, resulting in significant variation in both the nature and extent of the requirements imposed on TCN

applicants for the same profession across different national and regulatory contexts. In addition, to factor in the

potentially large volumes of applications as well as existing practices in MS, CA would be able to choose from

two additional types of compensation measures.

31

existing system for EU citizens under the PQD; (3) the possibility for TCN to choose a single

integrated recognition procedure, or to re-use verifications across procedures, where

recognition requirements arise under both migration procedures and for access to regulated

professions; (4) an obligation for MS to provide access to comprehensive, up-to-date and user-

friendly information regarding procedures for TCN, including tailored information for refugees.

In addition, PO2 would require MS to develop interoperable national databases on the

comparability of TCQ to facilitate the sharing of information and expertise between MS.

Furthermore, PO2 would establish an EU-level service to carry out authenticity checks on TCQs

to support MS authorities in their assessment procedures.151

MS would be required to adapt their recognition systems and procedures to comply with these

minimum rules, thereby establishing the basic conditions that any procedure must meet. This

includes aligning documentation requirements, introducing procedural guarantees (such as

deadlines and right of appeal), and ensuring coordination between recognition and migration

authorities to reduce duplicated procedures as part of clearer and more integrated pathways.

The legal instrument envisaged for this option would be a Directive, based on Article 79(2),

points (a) and (b), TFEU, consistent with the form taken by the existing legal migration acquis

and mirroring the approach of the PQD establishing common rules for the cross-border

recognition of qualifications of EU citizens. A Directive is the proportionate instrument because

it lays down a harmonised minimum set of procedural rules rather than exhaustively regulating

the field. Member States would retain competence over the regulation of professions, over

admission and migration policy more broadly, and over the institutional organisation of

recognition and migration authorities. The elements that determine applicants' legal certainty -

including the rules pertaining to deadlines, the categories of documents that may be requested,

the procedural guarantees, the right of appeal and the transparency of fees - would be

harmonised through binding minimum standards. These would be drafted with sufficient

precision to ensure uniform application and effective enforcement. While binding on the MS, a

Directive affords them the flexibility to integrate the procedural rules regarding recognition into

their unique domestic procedures and regulatory landscape. The framework therefore

establishes a predictable baseline of treatment throughout the Union, reinforced by strict

information obligations requiring the relevant information to be made publicly available

through existing EU tools and platforms. This would limit the divergence observed under the

current patchwork of national recognition systems while leaving MS discretion over how these

common standards are embedded into their national systems.

To ensure harmonised implementation, the Commission would closely monitor compliance

both in law and in practice through a transposition review, rigorous enforcement and regular

exchanges of good practices:

- Following the transposition deadline, and drawing on experience with the Professional

Qualifications Directive (PQD), a comprehensive conformity check would be deployed

151 Both these activities would be developed as an extension of existing Commission activities in the area of

transparency of qualifications and skills, building on established instruments including the European

Qualifications Framework, digital infrastructure, databases of qualification information, and the facilitation of

cooperation between Member States in this area.

32

to detect and address inconsistencies in national legal frameworks early on, particularly

in decentralised systems involving a wide range of different competent authorities. This

review would also verify that MS have established the necessary institutional

arrangements for practical compliance, including structured cooperation between

migration and recognition authorities where required.

- Following the initial transposition check, the Commission would follow up to ensure

that MS comply also in practice with their obligations under the Directive. The more

detailed annual statistics to be provided by MS - including data on outcomes, average

processing times, average information exchanges per case and the number of

authenticity checks requested - will provide a concrete basis for identifying possible

patterns of non-compliance, complemented by complaints received from TCN and other

stakeholders. Where evidence points to a broader administrative practice incompatible

with the Directive, the Commission may take enforcement action. At the same time, in

line with the Union’s decentralised enforcement system, individual cases remain

primarily a matter for national remedies and judicial review.

- Continuous uniform implementation would be reinforced through regular exchanges of

good practice within the relevant expert group, fostering convergence in administrative

interpretation and resolving operational bottlenecks collectively.

5.2.3. PO 3 – Common rules and Automatic recognition for selected

professions (binding)

PO3 includes the common procedural rules described under Option 2 and introduces an EU

system of automatic recognition for TCQ for specific regulated professions. The measures

comprising PO3 (A1–A13, building on the PO2 measures A1–A10) are described in detail in

Annex 12. The legal instrument for this Option would also be a Directive, integrating the

common procedural rules described under Option 2 and including additional provisions

specifically on automatic recognition. Harmonised implementation would be ensured in the

same way as explained above.

Regarding the additional elements pertaining to automatic recognition, recognised third-

country education and training institutions could apply to have specific programmes reviewed

for compliance with EU quality assurance standards152 and the relevant minimum training

requirements established under the PQD for the seven sectoral professions. Even well-run

procedures operating with common procedural rules still require individual case-by-case

scrutiny that cannot scale to meet the volume and pace of skilled migration the EU needs, and

still produce variable outcomes for the same qualification assessed in different MS. With

structural labour shortages deepening, particularly in the sectoral professions where EU-level

minimum training standards already exist, procedural improvements alone cannot deliver the

consistency and predictability that applicants and employers require. PO3 addresses this by

152 The Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG) and the

European Quality Assurance Reference Framework (EQAVET) provide complementary frameworks for internal

and external quality assurance across European education and training systems, supporting trust and mobility

across systems irrespective of the delivery mode. While the ESG underpin quality assurance in higher education

within the Bologna Process, EQAVET offers an equivalent European-wide reference framework for vocational

education and training (VET).

33

moving from procedural alignment to systemic trust, replacing repeated individual case-by-case

assessments with verification of programmes against agreed standards

For the system to operate, first, the applying institutions would undergo a quality assurance

review, building on established international cooperation in quality assurance. Reviews would

be conducted by trusted review bodies satisfying functional criteria defined at EU level, which

would apply to the Commission for inclusion on a dedicated list. For higher education

qualifications, the potential population of trusted review bodies comprises the quality assurance

agencies registered on the European Quality Assurance Register for Higher Education (EQAR).

Registration on EQAR requires demonstrated compliance with the Standards and Guidelines

for Quality Assurance in the European Higher Education Area (ESG), so that the framework

provides a defined quality standard, an independent mechanism for verifying that review bodies

meet it and, through the Database of External Quality Assurance Results (DEQAR), a public

record of review outcomes on which the system can rely. For the vocational strand, bodies

would be identified against the same functional criteria, adapted to the characteristics of VET.

The reviews would be performed by multidisciplinary expert teams and include on-site visits,

with both positive and negative outcomes published to ensure transparency.153 The second stage

would be a check of compliance with the minimum training requirements established under the

PQD for the relevant profession. The minimum training requirements define a fixed threshold,

and a programme either meets them or does not. It is upon this basis that automatic recognition

can be extended with confidence.

Approval would be granted for a defined validity period, indicatively five years, with renewal

subject to a further review confirming continued compliance, ensuring that recognised

programmes remain aligned with evolving EU standards. Between reviews, institutions would

be required to notify substantive changes to an approved programme, MS participating in

review teams could trigger an early re-assessment where justified concerns arise, and approval

could be suspended or withdrawn where the conditions are no longer met. The costs of

verification would be borne by the applying institutions, not by MS or individual applicants,

making the system financially self-sustaining. Fees would be set according to a defined scale

of factors, including profession type, the complexity of the assessment required, and whether

on-site visits are necessary.154 Recognition costs for individual TCN under this channel would

also fall, since the role of the competent authority is confined to verifying the applicant's

identity, the authenticity of the credential and its correspondence to a programme listed on the

EU register, with authenticity verification supported at EU level, so that individual procedures

are shorter and less costly than case-by-case assessment. Qualifications would need to be issued

as verifiable digital credentials by the third country institution to guarantee authenticity and

ease of verification by authorities and employers. Qualifications issued on the basis of

successfully reviewed programmes would be listed in a publicly accessible EU register.

153 Reviews would be adjusted to the nature of the third-country quality assurance system whereby more intensive

assessments may be applied where there are different or under developed QA systems or less intensive reviews of

QA where a robust national framework is in place. 154 For institutions in lower-income countries, cost may nonetheless constitute a significant barrier, and capacity-

building support under existing EU external action instruments, such as Talent Partnerships and the Global

Gateway, could serve as a flanking measure.

34

The plausibility of institutional demand is supported by the pattern of engagement observed

under existing skills mobility projects between individual MS and partner institutions in third

countries. Origin-country institutions have consistently demonstrated the willingness and the

capacity to align their training with EU requirements, submit to joint certification and bear the

associated adjustment costs, because doing so raises the value and portability of the

qualifications they confer.155 This pattern is corroborated by established international quality

assurance systems operating on the same logic: ABET, the leading accreditor for engineering

and technology programmes, now accredits close to 4,900 programmes across 42 countries

outside the United States, almost entirely through voluntary international uptake. In medical

education156, WFME's Recognition Programme grew from its first recognised accrediting

agency in 2012 to 33 recognised agencies and a further 16 in application by 2022, together

covering over three-quarters of the world's medical schools, once a clear link to US residency

eligibility created a concrete incentive to engage.157 The fees such bodies charge for

programme-level review have not deterred international take-up in these cases. Employers

place a high value on training matched to a recognisable standard and correspondingly little on

generic provision designed with no destination in mind, and origin institutions respond readily

wherever a concrete partnership gives them a standard to align to. An EU system of automatic

recognition would supply precisely such a standard at scale, giving these institutions a strong

and durable incentive to engage that builds on a demonstrated pattern of commitment rather

than presupposing an untested one. The EU-wide channel would operate alongside, and as a

complement to, the arrangements individual MS have developed with third countries; it would

not replace them and no transition period is required.

The automatic recognition mechanism would apply exclusively to professions for which

harmonised minimum training requirements have already been defined under the PQD158.

These professions already have agreed EU-level standards against which third-country

programmes can meaningfully be assessed, making prior verification both proportionate and

legally coherent. By anchoring the system in existing harmonised standards rather than creating

new ones, the option does not harmonise national education systems, does not extend beyond

the existing logic of automatic recognition under EU law, and fully respects MS competences

to define which professions are regulated, the organisation of training systems, to take

individual recognition decisions, and to manage migration policy and admission decisions.

155 Examples span sectors and regions, including German nursing curricula embedded into partner training

programmes in the Philippines, Indonesia and India; vehicle mechanic training co-designed and equipped by

Porsche at the Don Bosco Institute in Manila; and the France–Tunisia plastics partnership, comprising forty-two

training tracks built jointly with Tunisian vocational institutions. See CGD (2021); Business Advisory Group on

Migration (2024); EMN and OECD (2022); OECD (2018). 156 ABET, At a Glance, 2026, www.abet.org/about-abet/at-a-glance/

157 Tackett S. et al., "Examining the WFME Recognition Programme at 10 years", Medical

Teacher, 2023 (drawing on data to end-2022)

158 Doctors, nurses, dentists, pharmacists, midwives, veterinary surgeons and architects

35

Additional professions could become eligible for inclusion within this system over time through

the establishment of Common Training Frameworks (CTFs).159

Holders of approved qualifications would benefit from automatic recognition for access to the

relevant regulated profession across all MS, without individual assessment or compensation

measures, under the same conditions as qualifications issued within the EU under the PQD. MS

administrations would integrate this mechanism into their national procedures, replacing their

own assessments for covered professions. MS would nonetheless remain involved through

participation in review teams and the ability to trigger a second assessment in cases of justified

concern preserving national oversight within the system.

The system must be designed with awareness of political and geopolitical considerations,

including engagement with countries subject to EU sanctions or whose participation would be

incompatible with EU foreign policy commitments. Further, it must be emphasised that PO3

does not create new migration flows beyond those that MSs themselves decide to accept within

their territories. However, as third-country health professionals are already moving to EU MS

in substantial and growing numbers, this option will improve the speed, predictability and

consistency with which those professionals already can use their skills to the benefit of the EU

labour market. In maintaining the system, the Commission will nonetheless have regard to the

broader impacts on origin countries' public services, including by reference to the WHO Health

Workforce Support and Safeguards List160, where engagement with specific countries or

professions would risk exacerbating documented workforce pressures.

5.3. Stakeholder views

Full stakeholder feedback is set out in Annex 2. PO1 is widely accepted as a necessary starting

point. The PC showed that 75.7% of respondents considered EU-level action very necessary,

and MS, employers and CAs broadly welcome the tools proposed. The recurring reservation is

that voluntary measures cannot address structural gaps, particularly the absence of a shared EU

mechanism for verifying third-country qualification documents. PO2 attracts the widest support

across stakeholder groups. TCN, employers, civil society and professional organisations

strongly endorse binding minimum procedural rules. Views from MS authorities and

stakeholders are more varied, ranging from explicit support to conditional acceptance (RO) and

scepticism (DE) on mandatory binding rules for health professions. PO3 generates strong

interest from TCN, employers and some MS who identify it as potentially the most effective

option for shortage professions. The central concern, raised consistently by healthcare

professional organisations (CPME, EFN, UEMO), as well as CAs, is that any acceleration of

recognition timelines must be underpinned by genuinely rigorous prior verification of training

programmes.

159 Common Training Frameworks (CTFs) are established under Article 49a of Directive 2005/36/EC. They define

a common set of knowledge, skills and competences that professionals must possess upon completion of their

training, agreed at EU level in cooperation with Member States and relevant professional organisations. Where a

CTF exists for a given profession, it serves as the basis for automatic recognition of professional qualifications

across Member States, without the need for individual assessment of the qualification concerned. Efforts are

already underway to establish a CTF for physiotherapists, and the Commission is working to identify further

professions for which such frameworks could be developed, as described in the IA for SPI Action 2. 160 WHO Health Workforce Support and Safeguards List

36

5.4. Options discarded at an early stage

A number of potential measures were examined during the preparation of this action but were

not retained for detailed assessment. These are presented with their rationale in Annex 7. Across

the problem areas examined, these measures were discarded due to issues of proportionality,

legal feasibility and coherence with the existing framework. Among the discarded approaches

was a dedicated EU-level digital solution, examined in two variants, namely a new EU-wide

platform for recognition and validation procedures and the extension to TCN of the fully unified

workflow envisaged under Action 2 of the SPI. Both were discarded on feasibility and

proportionality grounds, since digitalisation without prior simplification of the underlying

procedures would not address the drivers of the problem, while a modular reuse of Action 2

digital building blocks is retained under all options. The full analysis is presented in Annex 7

and synergies with Action 2 are assessed in Section 7.3.

37

Intervention Logic

Problem drivers Sub-drivers Specific objective Option 1

Support & coordination

Option 2

Common rules

Option 3: Common rules + auto-

recognition

Option 2, complemented by:

Diverging

recognition

systems within and

between MS

Different recognition systems

applied to the same

qualifications across MS

Streamline recognition

systems within between

MS

• Common guidelines on

recognition systems

• Comparative studies on

recognition practices

• Common EU procedural rules for

recognition of qualifications of

TCN

• Clarification of legal effects of

recognition, ensuring access to

regulated professions

• Common EU legal framework for

automatic recognition of

approved TCQ

• EU-level register of reviewed TC

qualifications

• Same legal effect as national

qualifications for professions

under the PQD

Duplication & inconsistencies of

recognition procedures within

MS

Lack of clear & accessible

information for TCN and

employers

Complex and

burdensome

administrative

procedures for

recognition

Lengthy & untransparent

administrative procedures Reduce legal &

administrative complexity

for recognition of

qualifications

of TCN

• Guidelines, templates and

checklists to streamline

procedures

• Exchanges among MS to promote

convergence of administrative

best practices

• Simplification of documentation

requirements

• Clear procedural guarantees:

deadlines, rights of appeal

• Access to. compensation

measures

• Limitation of fees to cost-based

levels

• Automatic recognition

for approved qualifications

• Review costs borne by applying

education and training

institutions

Burdensome documentation &

translation requirements

High & unclear costs

Lack of trust &

understanding of

qualifications &

skills obtained in

third countries

Concerns over authenticity of

documents issued in third

countries

Increase trust &

understanding of

qualifications and skills

obtained in third countries

• Fraud and authenticity checklists,

digital/AI-powered verification

solutions

• EU-level service for authenticity

checks

• Compensation measures where

substantial differences in quality

• Interoperable national databases

on comparability of TCQ

• Verification of learning

programmes against EU quality

assurance standards

• Verifiable digital credentials

required from third-country

providers

• Review process with

multidisciplinary expert teams,

on-site visits, and renewal

mechanisms

Insufficient knowledge about

third-country educational

systems, curricula & standards

Doubts about efficacy of quality

assurance within third-country

systems

38

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?

The cost-saving analysis uses a baseline of 125,000 procedures, split between professional

recognition procedures in the context of regulated professions (62,500 procedures) and migration-

related recognition procedures (62,500 procedures). The source data and methodology

underpinning these baseline estimates are explained in detail in Annex 4.

Because they refer to two distinct types of procedures, these two types of recognition are kept

separate throughout the analysis. The 62,500 recognition applications in the context of regulated

professions are the most time- and resource-intensive, since they rely on a case-by-case assessment

of the professional qualifications of the applicant against the applicable legal requirements to

exercise a specific profession. The remaining share of migration-related recognition procedures

are less costly and time-intensive as, in this context, the assessment takes the form of a verification

of diplomas or the application of a standardised point system instead of

a comprehensive evaluation of the professional qualifications.

An assessment of environmental factors has not 161been carried out as this action is not expected

to have significant environmental impacts, including under the 'do no significant harm' (DNSH)

principle and climate consistency requirements. 162

6.1. Direct cost impacts

The direct cost savings estimated pertain to administrative cost savings (6.1.1.), monetised time

savings for the applicant (6.1.2.) and cost savings for the employers (6.1.3.). Implementation costs

for public authorities (IT development and maintenance, legal and compliance staff time,

recognition-related training, management overhead and cooperation with third countries) are

discussed in section 6.1.4.

6.1.1. Direct administrative cost savings

Direct administrative costs for applicants include the application fee paid to the host CA, a fee to

ENIC-NARIC where applicable, certified translations of documents, legalisation or apostille fees,

notarisation costs, postal or courier charges and additional documentation costs. Per procedure

administrative costs for CAs include administrative processing time, expert review time and the

costs associated with contacting external issuing bodies to verify information.163 These various

162 The initiative does not assume or project increases in migration to the EU and therefore does not generate additional

international travel as a direct consequence. The simplification of recognition procedures does not affect admission

flows. Furthermore, this initiative concerns TCNs who typically hold a residence permit tied to a single Member State

and do not enjoy the right to move freely between Member States to work. The initiative does not therefore trigger

additional cross-border or international movement 163 Beyond these variable per procedure costs, competent authorities for the recognition of professional qualifications

of TCN incur fixed and semi-fixed annual costs (IT systems maintenance, legal and compliance staff time, recognition-

related training, management overhead). These cost components do not enter per-procedure SCM calculations since

they do not scale directly with procedure volumes, but are expected to be partially reduced under POs 2 and 3 through

economies of scale and shared infrastructure (e.g. the EU comparability database and harmonised documentation

requirements reducing per-case verification effort, common procedural rules, binding deadlines and fee structure rules

reducing the case-by-case legal review effort, and the shared comparability database reducing the per-case verification

39

costs are estimated using survey sources involving CA, ENIC-NARIC centres, and TCN,

supplemented by national mappings and focus group dataforms. The source data and the

component-level value estimates are detailed in Annex 4.

For recognition procedures in the context of regulated professions, the average per procedure cost

is estimated at EUR 1,500 (EUR 1,100 borne by the applicant and EUR 400 by the CA). For

migration-related recognition procedures not pertaining to regulated professions, the cost borne by

the applicant is estimated at EUR 300.

The administrative cost savings of the different POs reflect partial reductions in document

preparation effort, payable fees and other legal and operational costs linked to the drivers listed in

Section 2. The size of these reductions is expressed as percentages of the per procedure cost,

estimated based on the expected effects of the policy measures on the different cost drivers. These

estimates are triangulated across survey evidence, focus group polls, stakeholder consultations and

documented administrative bottlenecks. To account for partial implementation effectiveness of the

different POs, the administrative cost savings are adjusted by a realisation factor. The analysis faces

certain degree of uncertainty, so results are presented in ranges and should be interpreted as

indicative. The full methodology, the source data underpinning the calculations and a sensitivity

analysis to test the assumptions are presented in Annex 4.

For PO1, administrative costs savings are estimated at 4–8% per procedure pertaining to regulated

professions. This reflects the reduction in document preparation effort enabled by improved

information availability, and the reduction in CA-side verification effort enabled by capacity

building on third-country qualification systems. The realisation factor of 60% per cent reflects the

soft-law character of the measures. Per-procedure savings under Policy Option 1 are therefore

approximately EUR 36–EUR 72 (≈EUR 54)164, corresponding to an aggregate annual

administrative saving of approximately EUR 3.4 million per year on the baseline of 62,500

procedures per year. For PO2, a cost savings estimate of 15-22% of the baseline is applied,

reflecting the structural reduction in document preparation effort enabled by harmonised

documentation requirements, the structural reduction in CA-side verification effort enabled by the

EU comparability database and authenticity check service, and the structural reduction in the

application fee component enabled by the proportionate fee structure, the multilingual document

acceptance reducing translation needs and the minimum mandatory information requirements. Per-

procedure savings under Policy Option 2 are therefore approximately EUR 169–EUR 247 (≈ EUR

208), corresponding to an aggregate annual administrative saving of approximately EUR 13 million

per year on the baseline of 62,500 procedures per year. The realisation factor of 75% reflects the

binding but transposition-discretionary character of the measures.

For PO3, a cost savings estimate of 33-47% is applied on the concerned subgroup of applications

for automatic recognition. This reflects the structural reduction in document preparation effort, CA-

side verification effort, application fee, certified translation effort and authenticity verification

effort enabled by the combination of binding common rules, automatic recognition for sectoral

procedures and digital credentials infrastructure. Per-procedure savings for the share of

automatically recognised applications under Policy Option 3 are approximately EUR 420–EUR

effort. These savings are reflected in the multi-criteria decision analysis as additional cost avoidance items under Policy

Options 2 and 3. 164 The figure between brackets is used for the assessment of total impacts. It represents the average reduction in costs,

based on the middle realisation factor (i.e. central scenario).

40

599 (≈ EUR 510). A realisation factor of 85% is applied to this share of applications specifically,

reflecting the fact that this type of recognition procedure leaves less transposition discretion that

the general-system rules. As the implementation of this option will happen only gradually (once a

larger number of training institutions have been accredited and TCNs fully trained according to the

MTR of the PQD become eligible for automatic recognition), aggregated cost savings will take

time to materialise. Under a steady state scenario whereby 40% of the 62,500 baseline would be

eligible for automatic recognition, they would equal approximately EUR 20.5 million per year on

the baseline of 62,500 procedures per year.

For migration-related recognition procedures, cost savings arise from the reduction of documents

required and their standardisation. Lower cost savings estimates were used than for regulated

professions, reflecting the fact that these checks concern non-regulated professions, which are less

complex and offer narrower scope for streamlining. They are estimated at EUR 0.5 million for PO1

and at EUR 1.8 million for both PO2 and PO3.

6.1.2. Monetised time savings for the applicants

In addition to the direct administrative costs linked to procedural requirements, a significant share

of the applicants also bear the opportunity cost of not being able to exercise the profession for

which they are qualified while the procedure is running. For the purpose of this analysis, the

baseline duration of a recognition procedure in the context of regulated professions is estimated at

14.2 months. The full methodology and the source data underpinning these estimates are detailed

in Annex 4.

The different policy options would reduce these opportunity costs by compressing the waiting time

to a different extent:

• PO1 introduces no binding deadline but raises the visibility and predictability of timelines

through the soft-law measures, with an indicative time gain of approximately 10% of the

actual baseline (≈1.4 months).

• PO2 introduces binding deadlines, reducing the median processing time from 14.2 months

to approximately 5 months on the central scenario, with a time gain of approximately 9

months.

• PO3 introduces the automatic recognition channel for the seven sectoral professions,

reducing the processing time for sectoral procedures from 14.2 months to approximately 4

months (range 3–5 months), with a time gain of approximately 10.2 months for the sectoral

subgroup, while the general system procedures retain the 5-month deadline introduced

under Policy Option 2.

To estimate the monthly opportunity cost for the applicants, occupational wage proxies were used.

Looking at various typical occupational profiles (nurses, medical doctors, engineers), the central

monthly gross wages proxy was set at approximately EUR 4,300, representing an opportunity cost

of approximately EUR 800/month for the share of applicants who work below their qualification

41

level during the processing time and of EUR 4,300/month for those who do not work at all.165 The

monetised time savings associated with each policy option were estimated by combining the

volume of procedures in each subgroup, the corresponding reduction in processing timelines, the

monthly opportunity cost proxy, the share of applicants either not working or working below their

qualification level during the procedure, a calibration factor to account for the fact that they do not

all find suitable employment at their qualification level following recognition, and the realisation

factors reported above, reflecting the expected degree of effective implementation under each

policy option. Taking these various factors into account, the aggregate annual monetised time

savings realised under each option are estimated at approximately EUR 33,5 million for PO1, EUR

273,5 million for PO2 and EUR 300 million for PO3. The full methodology is explained in Annex

4. A sensitivity analysis is also provided to test the impact of changes to the main assumptions

underpinning the model.

For the 62,500 applications pertaining to unregulated professions, no time savings were calculated

since the average duration of these migration-only related recognition procedures would not be

affected by the policy options.

6.1.3. Cost savings for employers

In addition to the costs borne by recognition applicants and public administrations, EU employers

also incur administrative and organisational costs related to the recruitment of third-country

nationals whose qualifications require recognition. These costs include the verification of the

recognition outcome, the coordination with the migration authorities for the work permit procedure

and the indirect cost of the recruitment cycle prolongation due to the recognition processing time.

These costs are estimated at approximately EUR 800–1,200 per recruitment of a TCN professional

applying for a regulated profession.

The reductions are driven primarily by shorter recognition processing times, which reduce the

employer's loss of productive capacity during the prolonged recruitment cycle, together with the

documentation and coordination improvements specific to each option. The different policy

options would reduce these costs to a different extent depending on the measures included:

• Under PO1, the employer-borne cost is reduced by approximately 5–10% through

improved employer-side information availability on the recognition timeline and outcome

and on the coordination with migration procedures.

• Under PO2, the reduction reaches approximately 20–30%, driven by the binding timelines

and the binding coordination requirements between recognition and migration authorities

and the harmonised documentation requirements.

• Under PO3, the reduction reaches approximately 35–50% for recruitments involving the

seven sectoral professions, driven by the automatic recognition channel and the digital

credentials infrastructure which enable near-immediate verification by the employer.

165 These shares are estimated at 49.3% and 16.4% on the basis of from the responses Q15 of the TCN survey, n =

152). For the sake of this simulation, it is assumed that 75% of those already working prior to their qualification

recognition will find a job at their qualification level. This share is adjusted to 50% for those not yet in employment

prior to the qualification recognition.

42

Based on these assumptions, the aggregate reduction in employer-borne costs amount to EUR 4.7

million/year under PO1, EUR 15.6 million/year under PO2 and EUR 20 million/year under PO3.

6.1.4. Implementation costs

Implementation costs vary substantially across the three policy options, reflecting differences

in the scope of digital infrastructure required at national and EU level. They are specified in further

detail in annex 4.

Under PO1, costs are relatively limited, as implementation mainly builds on existing structures

and focuses on mutual learning, exchange of best practices and voluntary convergence. The main

cost drivers one-off costs at EU level of EUR 1–3 million, mainly for guidance, peer learning and

analytical support, with only marginal and non-quantified costs for Member States.

Under PO2, costs increase significantly because the option requires both stronger cross-border

interoperability and the development of additional EU-level support, notably a centralized service

for authentication and verification of third country qualifications. This implies higher initial IT

development and integration costs, as well as recurring costs for maintenance, operation of the

infrastructure and the EU-centralised service and support. The overall cost burden remains uneven

across Member States, depending in particular on the maturity of their existing digital infrastructure

and the extent of system upgrades needed. One-off costs would be in the margin of EUR 27.3 –

47.9 million; yearly costs for operation around EUR 3.7 – 6.0 million. For the period until 2040,

this would sum up to EUR 72 – 120 million, out of which around EUR 46 – 80 million would be

borne by Member States and EUR 26 – 40 million by the EU level.

PO3 entails the highest implementation costs, as it combines the infrastructure needs of PO2 with

the establishment of a public register supporting automatic recognition. In addition to the costs

linked to database interoperability and EU-level authentication services, this option requires further

investment in developing, operating and updating the register, as well as ensuring data quality,

accessibility and governance arrangements. One-off costs would be in the margin of EUR 28.7 –

50.7 million; yearly costs for operation around EUR 3.9 – 6.5 million. For the period until 2040,

this would sum up to EUR 76 – 128 million, out of which around EUR 46 – 80 million would be

borne by Member States and EUR 30 – 48 million by the EU level.

Overall, while all options involve some adaptation costs, the scale and complexity of

implementation increase markedly from PO1 to PO3.

Table 6.1: Total implementation cost for the 2027-2040 period, discounted to 2026 present values (3% discount rate).

Baseline PO1 PO2 PO3

Total costs borne by EU

(discounted)

0.0 M€ 1.0 - 2.9 M€ 21.7 – 33.1 M€ 24.8 – 40.2 M€

Total costs borne by MS

(discounted)

0.0 M€ 0.0 M€ 39.4 – 69.0 M€ 39.4 – 69.0 M€

Total (discounted) 0.0 M€ 1.0 - 2.9 M€ 61.1 – 102.0 M€ 64.2 – 109.2 M€

6.1.5. Methodological uncertainty and sensitivity analysis

43

The estimated savings depend on the capacity and the incentives of the authorities concerned to

deliver improved outputs within the common rules. The proposed framework relies on an

established and tested institutional landscape, since the authorities that would apply the new

instrument are those currently managing recognition procedures under the PQD and the legal

migration acquis. These comprise several types of body with distinct governance and incentive

structures, including ministries and migration authorities, independent professional regulators,

chambers and professional associations exercising delegated public functions, and ENIC-NARIC

centres166. The evidence gathered for this IA indicates that the problem observed in practice is

inconsistency, opacity and delay in the handling of third-country cases, precisely because no

common procedural framework currently constrains the authorities' discretion in the way the PQD

does for intra-EU cases. The common rules address this directly, and while MS retain the

competence to designate the bodies involved167, including bodies close to the professions whose

position may raise a risk of self-interested gatekeeping (not evidenced in this IA), MS remain

legally accountable under the Treaties for uniform application, subject to Commission enforcement

and national judicial review (Chapter 9).

On capacity, the proposed deadlines are aligned with procedural approaches already familiar to the

authorities concerned. Migration authorities already operate under deadlines set by the EU legal

migration acquis which are in many cases at least as demanding as the proposed rules, for example

the 90-day deadline for a decision on an EU Blue Card application compared with the proposed

3+1 months for the recognition component taken in isolation, and MS retain the principal lever for

managing capacity pressures through their competence over admission volumes. Where migration

authorities assess qualifications within migration procedures, these checks are in any event more

limited and less time-consuming than full recognition procedures. Competent authorities for

regulated professions, and the ENIC-NARIC centres on which some of them rely, are already used

to complying with the same or similar deadlines for qualifications falling within the PQD or the

Lisbon Recognition Convention. Additional capacity is expected from two sources, namely the

digitalisation of intra-EU procedures under Action 2, which should free resources within the same

authorities, and the automatic recognition channel under PO3, which replaces repeated case-by-

case assessment with prior programme verification in the shortage professions where caseloads are

heaviest. The efficiency gains underpinning the analysis derive from identified elements of the

action, namely the EU authenticity assessment service, which absorbs a particularly time-

consuming and technically demanding step of the process; the interoperable national databases,

which reduce duplication of comparability assessments and allow authorities to rely more

systematically on existing ones; structured cooperation through the dedicated expert group,

supporting quicker access to information and more consistent decision-making; and the mandatory

166 Cedefop (2026). Recognition and validation of foreign VET qualifications in Europe: Comparative

insights for skills portability. Cedefop Insights No. 04. Luxembourg: Publications Office of the European Union. DOI:

10.2801/2307117

167 A comparative mapping of national recognition and validation arrangements for foreign VET qualifications and skills found

that CAs and recognition bodies are almost all public. Of the 73 named bodies across the 30 systems, about 93% are government

departments, statutory agencies or public-law corporations. The remaining 7% are private-law foundations or associations that

still carry out public tasks. See: Cedefop (2026b). Annex: Comparative Mapping of National Recognition and Validation

Arrangements for Foreign VET Qualifications and Skills [Dataset].

44

coordination between recognition and migration authorities, which eliminates duplicate checks and

rework.

On incentives, acute labour and skills shortages align the interests of professions experiencing

shortages, employers and public authorities in integrating qualified talent rapidly into the

workforce, while a simpler and more unified legal framework, the procedural support measures

that reduce workload and the greater transparency of applicants' rights reinforce timely handling.

Even under the baseline, demographic change and persistent shortages are increasing pressure on

MS to devote more resources to the recognition of qualifications of TCN; the action provides the

more coherent framework within which those resources can be used efficiently. The risk that the

requirements are imperfectly implemented or enforced is factored into the quantified analysis

through the realisation factors applied to each option, which discount the estimated savings to

reflect that a partial-harmonisation directive may not be fully effective in practice, consistent with

the Better Regulation guidance.

To reflect the inherent uncertainties surrounding baseline estimates, procedural volumes, and

implementation effectiveness across 27 national systems, the quantitative impacts presented above

are underpinned by the sensitivity analysis detailed in Annex 4.5.

Key parameters tested in the sensitivity framework include, among others:

- Realisation Factors: Realisation factors (60% for Policy Option 1, 75% for Policy Option

2, and 85% for the automatic recognition cases under Policy Option 3) reflect varying

degrees of national transposition efficiency and administrative uptake. Under conservative

scenarios (reducing the realisation factors by another 10 percentage points), annual

aggregate administrative cost savings would amount to EUR 2.8 million, EUR 11.3 million

and EUR 18 million for PO1, PO2 and PO3 respectively.

- Baseline caseload: As explained in more detail in Annex 4.2, the volume baselines are

intentionally conservative considering the available evidence. Since application flows

depend on various factors – such as geopolitical shifts and evolving migration policies –

the sensitivity analysis includes a low-case scenario of 40,000 annual procedures (instead

of 62,500). Under this assumption, the annual administrative costs savings for recognition

procedures in regulated professions would be reduced to EUR 2.2 million, EUR 8.3 million

and EUR 8.8 million respectively

6.2.Opportunity costs: Monthly opportunity costs were approximated using occupational wage

proxies from the Eurostat Structure of Earnings Survey 2022, EU-27 aggregate168), mean

annual gross earnings, enterprises with 10 or more employees. If, in a conservative scenario,

the opportunity cost proxies are reduced by 20% to EUR 640/month for those TCN that are

working but overqualified and to EUR 3,440/month for those that remain unemployed during

the recognition process, the monetised time savings amount to EUR 26.8 million/year, EUR

218.8 million/year and EUR 240 million/year for PO1, PO2 and PO3 respectively. Wider

Economic Impacts

168 The Eurostat statistic is published at EU-27 level and is used here as a proxy; the study perimeter is EU-26, Denmark

being outside the study.

45

All three policy options are expected to generate wider economic benefits compared to the baseline

to the extent that they facilitate recognition of professional qualifications of TCN.

At firm-level, this results in increased high-quality recruitment opportunities relative to the

baseline, enhancing businesses' competitiveness and growth potential. As per procedure costs

and waiting times are reduced, employers can tap into a wider, geographically diverse pool of

qualified TCNs, able to exercise the profession for which they have been trained.

The sizeable overqualification gap between EU citizens employed in their national labour market

(20.2% in 2023) and TCN (38.9% in that same year)169 suggests that there is a considerable pool

of untapped talent already present within the EU labour market. Empirical evidence suggests

that reforming recognition frameworks is a highly effective mechanism for unlocking this

underutilised potential. Germany’s “Federal Recognition Act” led to a 15% increase in the

probability that non-EU migrants already residing in the country would apply for recognition.

Faster and less cumbersome recognition processes improved labour market outcomes, resulting in

an almost 20% increase in the employment of TCNs within regulated, high-skill occupations (such

as healthcare and education), alongside measurable wage growth.170

Facilitating recognition of qualifications as part of migrant procedures and for access to regulated

professions would also make the Union a more attractive destination for qualified TCN. The

evidence presented in Chapter 2 suggests that barriers to recognition of qualifications can act as a

deterrent and that their removal would have a positive impact on the available pool of talent

considering the Single Market as a destination. Even if total legal labour migration flows, as

determined by MS migration policies, are kept constant, faster, less onerous and more predictable

recognition procedures would improve the quality of matches between the supply of talent and

skills demands in the EU. In this sense, the action contributes to the effectiveness of EU

migration instruments such as the Talent Pool and the Talent Partnerships, and to the overall

competitive position of the EUin the global race for talent.

The possibility to recruit from a broader pool of qualified TCN with skills that match their needs

benefits all businesses. It is particularly relevant for SMEs, however, as they report the most

difficulties in widening the recruitment pool beyond the borders of their national economy171.

169 Migrant integration statistics - over-qualification - Statistics Explained - Eurostat: overqualification gap between

EU citizens employed in their national labour market (20.2% in 2023) TCN (39.6% in that same year) 170 S. Anger, J. Bassetto, M. Sandner, Making Integration Work? Facilitating Access to Occupational Recognition and

Immigrants’ Labor Market Performance, IAB Discussion Paper, 2022. For a correct understanding of the reported

results, it is important to note that the study focused on the labour market integration effects of the reform, not on its

impact on migration flows. The analysis therefore concentrates on immigrants who lived in Germany before the reform.

Crucially, the study also notes that these gains were achieved without compromising professional quality standards or

depressing wages, providing clear evidence that streamlined recognition effectively bridges the overqualification gap

by aligning TCN talent with actual market needs.

171 Flash Eurobarometer 571 (December 2025) found that nearly half of all EU SMEs (46%) reported difficulty

finding or recruiting staff with the right skills over the preceding 24 months, rising to 70% among SMEs actively

hiring. Despite this, only one in seven EU SMEs (14%) had attempted to recruit TCN.7 Qualification recognition

challenges were cited by 13% of recruiters as a specific barrier, and by 8% of non-recruiting firms as a reason for not

attempting international recruitment.

46

At macro-economic level, effective recognition procedures reduce “brain waste” and

overqualification.172 By enabling residing qualified TCN to more easily access regulated

occupations that match their training, they enhance the allocative efficiency and aggregate

productivity of the existing workforce. They also ensure that newly arrived migrants are matched

more quickly with positions aligned with their qualifications. This improves both the total volume

and the quality of the available labour supply and helps to address shortages in critical sectors,

thussupporting GDP growth. The size of these impacts depends on the share of TCNs who move

into higher added-value jobs following recognition, on employer confidence in TCQs, and on the

relative importance of other factors that influence the choice of the destination of TCN. The

available evidence suggests that the effect of improved recognition on these both TCN labour

market outcomes173 and choice of destination is considerable.174

All three policy options contribute positively to these firm-level and macroeconomic effects,

though their impacts relative to the baseline vary.

Compared to the baseline, PO 1 would reduce deterrence among TCN already navigating the

system and improve the attractiveness of the Single Market as a destination for global talent by

providing guidance to prospective TCNs as well as their (potential) employers on how to navigate

applicable recognition procedures. Common EU tools would foster simplification of administrative

procedures and increased alignment towards more efficient models. However, no binding rights

are created, deadlines remain indicative and costs are only incrementally reduced. The effect on

recruitment opportunities, improved allocative efficiency of the TCN workforce and on the total

volume and the quality of the available labour migration pool is therefore expected to be limited,

particularly for SMEs, for whom voluntary measures cannot eliminate the open-ended timelines

and unclear fees that most directly undermine workforce planning.

Compared to the baseline, PO 2 introduces a binding legal framework with common, more

integrated and streamlined procedural rules that are expected to increase the incentives of TCNs

already residing in the EU to apply for recognition and to make the EU more attractive to TCN.

Procedural clarity and a more predictable framework with enforceable deadlines would also

incentivise SMEs to engage more in international recruitment.175 National databases on the

comparability of TCQ would facilitate the sharing of information and expertise between MS and

an EU-level authentication service would support MS authorities in their assessment

procedures. These measures help foster a deeper understanding of and trust in qualifications

obtained outside of the EU, thereby enhancing the effect of recognition on labour market outcomes.

172 The joint OECD and European Commission Indicators of Immigrant Integration report confirms that while

immigrants are more likely to be overqualified almost everywhere, host-country degree recognition reduces this

overqualification gap with native-born workers by 75% EU-wide, underscoring the central role of recognition systems

in closing the gap. 173 Cf. the study by Anger et allii quoted above which points at the improved labour market outcomes of TCNs residing

in Germany following the recognition of their qualifications. The results of this analysis show a robust positive effect

of degree recognition in increasing the number of high-skilled migrants by 30 to 60 percent. 174 Czaika M., & Parsons C., The Gravity of High-Skilled Migration Policies, KNOMAD Working Paper 13 (March

2016). Utilizing a panel dataset tracking bilateral migration labour flows across 10 OECD destinations from 2000 to

2012 the paper shows a robust positive effect of degree recognition in increasing the number of high-skilled migrants

by 30 to 60%. 175 Approximately 39% of SMEs indicated in the consultation that simpler recognition procedures could at least

moderately support their recruitment, underscoring the practical firm-level relevance of procedural simplification.

47

The impact on recruitment opportunities for and allocative efficiency of the TCN workforce is

expected to be significantly positive at both firm and macro level.

Under PO3, compared to the baseline and in addition to the measures included under PO2, the

automatic recognition system would further reduce the processing times of the concerned

applications and contribute positively to the predictability of their outcomes. The impact relative

to the baseline in terms of increased recruitment possibilities and the macro-level effects described

above on over-qualification, the volume and the quality of the available labour supply is expected

to also increase compared to PO 2. As the professions in scope are concentrated in the health care

sector, PO 3 most directly address the issue of critical shortages in this sector, aligning the EU's

offer more with the predictable, fast-track routes competitor destinations have established.

6.3.Social Impacts

Social impacts relate primarily to the situation of TCN navigating recognition procedures in the

EU for employment purposes, covering employment opportunities and career mobility, undeclared

work, access to essential public services, and fundamental rights. Impacts are also assessed against

the European Pillar of Social Rights (EPSR), SDG 8 (decent work and economic growth, targets

8.5 and 8.8) and SDG 10 (reduced inequalities, targets 10.2 and 10.7). All three policy options are

expected to have an overall positive social impact compared to the baseline, with binding options

delivering greater and more consistent benefits.

Recognition barriers directly suppress employment opportunities and upward career mobility

for TCN, but procedural improvements can translate into measurable labour market gains176. PO1

would help TCN navigate procedural complexity through guidance and voluntary simplification,

though outcomes remain modest and uneven across MS in the absence of binding rights or

deadlines. PO2 reduces the complexity that discourages or delays applications through binding

rules, sets documentation requirements and enforceable timelines, allowing employment

opportunities to materialise more quickly and at lower cost. PO3 combines PO2's procedural

guarantees with an automatic recognition channel that substantially reduces practical barriers for

TCN holding qualifications from verified programmes, significantly improving career prospects in

the Single Market. PO1 would improve transparency and access to information on recognition

procedures, including through non-binding guidance on the use of EU tools such as the EQF177.

For young people, the non-binding nature of PO1 measures limits their likely impact to address

their particular needs. PO2 would go further, introducing common procedural rules that would

reduce the unpredictability of recognition procedures and timelines. Binding measures on limits to

document requests, and to provide documents in languages spoken by migrants, respond directly

to calls for reduced administration and language barriers178. PO3 would bring the strongest effect

for young people. By establishing equivalence of qualification levels for the professions and

qualification types in scope, it eliminates the need for individual assessments entirely, removing

176 As set out in Chapter 2

177 The EU Youth Stakeholders Consultation for the SPI specifically highlighted the need for better implementation

and awareness of EU tools, including the EQF.

178 Input received during the EU Youth Stakeholders Consultation. Overview of Stakeholder Consultation in Annex 2.

48

the procedural burden at source and reducing the risk of underemployment at the start of a career

for those whose qualifications fall within scope.

As to combatting undeclared work, prolonged and uncertain recognition procedures create

structural incentives for informal work179, both for TCN waiting out procedures and for employers

in shortage sectors. PO1 does not materially shorten the period of uncertainty during which

informal work is most likely, as the absence of binding deadlines leaves the exposure window

structurally unchanged. PO2 substantially reduces that window through binding deadlines, set

documentation requirements and streamlined coordination between recognition and migration

authorities. PO3 goes furthest for the seven sectoral professions, compressing processing times

from 14.2 months to approximately 3 months in the care and health sectors where, undeclared

employment of migrant professionals is most prevalent.

On access to essential services, healthcare workforce shortages are acute, structural and

worsening, and cannot be addressed without continued inflows of qualified TCN professionals.

The recognition procedure is a direct bottleneck on that inflow: at 14.2 months average duration, it

delays or deters qualified professionals precisely where and when they are most needed. PO1

leaves that bottleneck structurally unchanged, delivering only marginal improvements in service

availability, with the most vulnerable regions continuing to bear a disproportionate share of unmet

need. PO2 accelerates integration through binding deadlines, with moderate positive effects on

service availability in shortage sectors. PO3 eliminates the bottleneck for the sectoral subgroup,

compressing processing times to approximately 3 months and freeing CA capacity in the

professions where shortages are most acute. Unlike intra-EU mobility measures, Action 3 brings

new professionals into EU labour markets, providing net additionality for regions that cannot be

served from within the existing EU workforce.

Regarding fundamental rights, all three options reduce procedural barriers to recognition,

enhancing access to occupations and employment rights (Articles 15 and 20, EPSR Principle 4).

PO1 relies on voluntary uptake and compliance with tools but PO2 and PO3 introduce enforceable

procedural guarantees (binding timelines, defined documentation requirements and appeal rights)

giving TCN an effective remedy against procedural failures (Article 47) and supporting the right

to good administration (Article 41). By enabling access to regulated professions commensurate

with TCN qualifications, they improve fair and just working conditions and wages (Article 31,

EPSR Principles 5 and 6). A common procedural baseline, applied regardless of nationality or

country of qualification, strengthens non-discrimination protections and promotes equal

opportunities (Articles 21 and 23, EPSR Principles 2 and 3). Under PO3, the automatic recognition

channel for the seven sectoral professions addresses the undeclared work risk disproportionately

borne by women in care and nursing, with a direct gender equality dimension (Article 23). PO3

also advances equal treatment between TCN and EU citizens for the covered professions (Article

20), and tailored information and support for refugees under the measure strengthens protection for

the most vulnerable applicants.

Digital measures under PO2 and PO3 must comply with GDPR and the EUDPR; no significant

risks to personal data are anticipated, with the database and authentication service designed to apply

the highest data protection standards in line with EPSR Principle 10.

179 As set out in Chapter 2

49

6.4. Impact on digitalisation

PO2 and PO3 offer distinct contributions to the EU’s broader digitalisation objectives by furthering

digital integration of what are currently fragmented national systems, often operating in a hybrid,

semi-digital manner. PO2 supports digitalisation by mandating the development of interoperable

national databases for sharing comparability expertise, establishing a centralised EU-level service

for digital authenticity checks, and allowing applicants to re-use digital verifications to eliminate

administrative duplication. PO3 builds on this and adds a centralised, publicly accessible EU

register of pre-verified training programmes and requiring qualifications to be issued by reviewed

third country institutions as verifiable digital credentials. This shift replaces repeated, manual, case-

by-case national assessments with a scalable, automated framework tailored to meet the volume

and pace of skilled migration. Although it is not possible to estimate the exact size, even assuming

the smallest reasonable impact, the option would still make a significant positive difference relative

to the baseline.

6.5. Unintended consequences

The design of the action is informed by an awareness of potential unintended consequences,

drawing on consultation findings, the experiences of MS active in international recruitment with

the clear scope of the action on recognition procedures and not on admission criteria or migration

volumes, which are Member State competence. Four categories of risk were identified and

considered throughout the analysis.

Procedural quality and fraud prevention: Streamlining procedures does not entail a reduction

in the substantive quality of recognition decisions. Member States will retain the capacity to make

confident, well-informed assessments; the action supports this through mutual learning, shared

comparability tools and an EU-level authenticity check service. This issue of fraud was raised

repeatedly throughout consultation. The action recognises that this is an existing problem under

current divergent systems, and addresses it directly in each policy option: tools for authentication

(PO1); EU authentication service (PO2); issuance of digital credentials by reviewed third country

institutions (PO3) to each enable systematic verification mechanisms.

Labour market integration outcomes: Faster recognition is a necessary but not sufficient

condition for full labour market integration. Some TCN may continue to face employer

discrimination, language barriers or conditions linked to migration status that fall outside the scope

of this action. Similarly, overqualification may persist where structural labour market factors

predominate. The action is coherently focused on the procedural barrier it can address; the

sensitivity analysis of cost savings reflects this by applying conservative assumptions on the share

of applicants who convert recognition into employment at qualification level.

Brain drain and ethical dimensions: The action does not stimulate migration or create new

admission pathways; it improves the treatment of qualifications for those already entering through

existing legal channels. Nonetheless, concerns about skills drain from partner countries,

particularly in health, must be addressed in the communication and design of the action. As flagged

in the description of PO3, the rollout of automatic recognition will be attentive to these dynamics,

including through the Talent Partnerships framework, which is designed to support managed and

mutually beneficial mobility.

Competitive effects: Concerns about competitive pressure on EU citizens are addressed through

a consistent commitment to equal treatment. The procedural standards would apply uniformly and

50

do not confer any preferential status on TCN relative to EU citizens. Where administrative burden

may shift such as under PO3 (where quality assurance requirements fall partly on third-country

institutions) this is considered a proportionate consequence for third country institutions with an

interest in structured labour mobility with demonstrated willingness to engage with such

frameworks. Where review costs represent a barrier for institutions in lower-income origin

countries, the Commission could consider co-financing arrangements for priority partner countries.

7. HOW DO THE OPTIONS COMPARE?

This chapter evaluates the relative performance of each policy option against baseline across three criteria:

(i) effectiveness in achieving the specific objectives of the action; (ii) efficiency in terms of the balance

between benefits and costs, monetised and non-monetised; and (iii) coherence, including with broader EU

policy objectives and the EU policy landscape.

Options are scored relative to the baseline on a scale from '+' to '+++': a single '+' indicates a limited positive

effect; '++' a moderate positive effect; and '+++' a significant positive effect. Equal weights are applied

across criteria in the absence of a strong evidential basis for differential weighting. All three policy options

are expected to generate positive effects relative to the baseline across all three criteria.

7.1 Effectiveness

PO3 is the most effective option across all three specific objectives, with a score of +++. Under SO1, the

automatic recognition channel eliminates case-by-case assessment for the seven sectoral professions,

replacing it with a uniform outcome for all holders of qualifications from verified programmes — the most

direct structural response to fragmentation between and within MS. Under SO2, binding deadlines compress

processing time from 14.2 months to approximately 4 months for the sectoral subgroup, document limits

and multilingual document acceptance reduce per-application burden, and per-procedure savings reach

approximately EUR 510 for automatically recognised applications. Under SO3, prior verification of third-

country learning programmes against EU minimum training requirements replaces repeated case-by-case

assessments with a systematic quality assurance foundation, substantially increasing the share of CA able

to decide on the basis of a verified programme listing without requesting compensation measures. PO2

scores ++ across all objectives, delivering the same structural procedural improvements as PO3 for the

general system but without the automatic recognition channel, leaving trust-building dependent on the

authenticity service and comparability database rather than programme pre-verification. PO1 scores + across

all objectives, as voluntary measures improve information availability and encourage convergence but

cannot mandate coordination, enforce timelines or systematically address the knowledge and documentation

asymmetries that drive compensation measure use. The effectiveness assessment takes account of the

capacity, incentive and enforcement considerations analysed in Section 6.1.5, which are reflected in the

realisation factors applied to the quantified estimates under each option.

Table 7.1 — Assessment of policy options against criterion of effectiveness

Specific Objective Criteria PO1 PO2 PO3

SO1: Streamlined

recognition systems

within and between

MS

Reduction in duplication across recognition

and migration procedures and increased

alignment between national systems.

+ ++ +++

SO2: Reduced legal

and administrative

complexity for

recognition of

Reduction in processing times,

documentation burdens and applicant-side

costs.

+ ++ +++

51

Specific Objective Criteria PO1 PO2 PO3

qualifications of

TCN

SO3: Increased trust

and understanding of

qualifications

obtained in third

countries

Increases in the share of CA with sufficient

information to make timely decisions, and

reduction in recourse to compensation

measures.

+ ++ +++

7.2 Efficiency

Efficiency is assessed by two dimensions. First, the difference between expected benefits and costs under

each option (table 7.2); second, because not all benefits can be expressed in monetary terms, efficiency

assessment takes into account also non-monetised benefits (wider economic and social impacts) as presented

in sections 6.2 and 6.3.

All three options are efficient with net present value above zero and with positive wider economic and social

impacts. PO3 is considered the most efficient option, with a score of +++. This is due to its ability to deliver

high net present value. The binding coordination requirements and shared verification infrastructure (EU

comparability database and authenticity check service) address the two principal structural inefficiencies

directly and for all procedures, leading to substantial administrative cost-saving and time savings across

different stakeholders, including applicants, CAs and employers. For the sectoral subgroup, automatic

recognition brings important savings by replacing substantive per-case assessment with credential

verification. PO3 also delivers high wider economic and social impacts across all assessed areas (increased

high-quality recruitment opportunities, making the EU more attractive destination for qualified TCN,

reduction of “brain waste” and overqualification, employment opportunities and upward career mobility,

respect for fundamental rights, combat against undeclared work and improving access to essential services).

Total efficiency for PO2 is ++ and for PO1 is +, reflecting their lower net present values and wider economic

and social impacts. PO2 gains are smaller in the absence of automatic recognition, while the PO1 gains are

smaller and uneven across MS given the non-binding nature of the measures.

Table 7.2 — Summary overview of cumulative monetised benefits and costs (present value in 2026)

PO1 PO2 PO3

Benefits

Administrative cost- saving –

regulated professions

(cumulative)

EUR 35M EUR 134M EUR 212M

Administrative cost- saving –

migration related procedures

(cumulative)

EUR 5M EUR 19M EUR 19M

Monetised time savings

(cumulative) EUR 346M EUR 2824M EUR 3098M

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PO1 PO2 PO3

Cost savings for employers

(cumulative) EUR 49M EUR 161M EUR 207M

Total EUR 435M EUR 3138M EUR 3536M

Costs

EU one-off implementation

cost EUR 1–3M EUR 6-11M EUR 8-14M

MS one-off cost (27 MS) Marginal (0) approx. EUR 20-

35M approx. EUR 20-35

EU recurring costs

(cumulative) 0 EUR 15-22M EUR 17-27M

MS recurring cost

(cumulative) 0

approx. EUR 20-

34M approx. EUR 20-34M

Total EUR 1-3M EUR 61-102M EUR 64-109M

Notes: aPresent values in 2026, using 3% discount rate. b Annual benefits for PO1 start to accrue in 2028 and up to

2040. Annual benefits for PO2 and PO3 start to accrue in 2029. cOne-off EU and MS implementation costs are equally

spread between 2027 and 2028. Recurrent EU and MS costs start in 2029 and up to 2040.

7.3 Coherence

Coherence is assessed on consistency with broader EU policy objectives and policy landscape, in particular

with EU talent attraction and Single Market objectives, without undermining or duplicating other initiatives

and the EU simplification efforts .

PO3 delivers the strongest coherence with both dimensions, scoring +++. It directly aligns recognition for

the seven sectoral professions with EU-level objectives on talent attraction, healthcare workforce supply

and the Single Market, mirroring the logic already applied to EU citizens under the PQD and closing the

gap between the procedural guarantees available to EU nationals and those available to TCN. By

establishing a fully integrated recognition channel that is consistent and equivalent across all MS, PO3

provides the structural certainty that the EU's talent attraction instruments require to function as a coherent

ecosystem. It most directly operationalises the EU's competitiveness and demographic agenda. PO2 scores

++, ensuring that EU talent attraction instruments can deliver on their promise: a TCN admitted on a Blue

Card or prepared through a Talent Partnership is guaranteed a time-bound, procedurally consistent

recognition procedure. By focusing on procedural rules rather than admission criteria, PO2 preserves

national competence while creating a common operational baseline across MS. PO1 scores +,

operationalising Commission Recommendation EU 2023/2611 through voluntary tools that complement the

talent attraction ecosystem but cannot guarantee predictable procedures at national level, leaving the

fragmentation that limits the ecosystem's effectiveness structurally unchanged.

The coherence of the options has also been assessed against the wider ecosystem of instruments addressing

EU labour market needs, mapped in Annex 8. First, within the Fair Labour Mobility Package, the action is

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complementary to, and does not overlap with, the other principal strands. The modernisation of social

security coordination, including the European Social Security Pass (ESSPASS) and the strengthening of the

European Labour Authority are Single Market instruments concerned with workers who are already present

and moving within the Union. They do not address the recognition of qualifications which is the specific

gap addressed by this action. They form part of the wider set of conditions shaping a TCN's experience of

the EU labour market once admitted, particularly from a protection and enforcement perspective, rather than

instruments interacting with the recognition procedure itself.

Second, the action is complementary to the EU Talent Pool Regulation. The Talent Pool can flag the

applicable recognition procedures to registered jobseekers and employers, but it has no capacity to influence

the nature, duration, cost or outcome of recognition itself. A TCN matched through the Talent Pool with an

employer must still complete the full national recognition procedure under the same conditions that would

apply in its absence, whether for a regulated profession, as part of a migration procedure, or both. This

action addresses the procedure itself, so that the two instruments reinforce each other and will develop in

parallel.

Third, within the SPI, Action 2 and Action 3 share the underlying objective of facilitating the mobility of

regulated professionals and addressing skills shortages, but they address distinct personal scopes arising

from different Treaty legal bases. Action 2 operates under the Single Market legal bases and modernises

recognition for EU nationals exercising free movement rights, a personal scope which excludes TCN,

whereas Action 3 operates under Article 79(2) TFEU and addresses TCN, for whom no comparable

framework currently exists. By introducing a common framework that largely mirrors the PQD and

incorporates several of the improvements developed under Action 2, Action 3 fills a gap in the existing

acquis rather than duplicating Action 2, and its material scope is necessarily broader, extending to

qualification checks conducted within migration procedures, including in relation to unregulated

professions.

Fourth, as regards the EU's international obligations, coherence extends beyond the mutual recognition

agreements discussed in Chapter 5. The schedules of commitments in EU free trade agreements make certain

references to professional qualifications, particularly in services industries, and the WTO framework,

notably the GATS, imposes general non-discrimination and most-favoured-nation obligations. These

instruments establish framework-level commitments rather than operational recognition mechanisms, and

the design of the options is compatible with them, since the common procedural rules apply to qualifications

from all third countries alike and eligibility for automatic recognition under PO3 is determined by the

functional verification of a training programme against defined EU minimum training requirements, applied

on the same basis irrespective of the third country concerned, rather than by preferential treatment of specific

trading partners. PO3 attaches recognition to individually reviewed programmes rather than to a partner

country's system as a whole, keeping the level of assurance constant across countries. The common rules

and the system of automatic recognition would in fact reinforce mutual recognition agreements and

partnership arrangements, whether national or EU-level, by providing the stable and uniform framework on

which they can build.

Table 7.3 — Assessment of policy options against criterion of coherence

Criteria PO1 PO2 PO3

Consistency with EU talent attraction, Single

Market objectives and EU simplification

objectives

+ ++ +++

7.4 Comparative overview

Table 7.4 — Overall assessment of policy options against the baseline

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Criterion PO1 PO2 PO3

Effectiveness + ++ +++

Efficiency + ++ +++

Coherence + ++ +++

Overall score 3 6 9

Each policy option respects the principles of subsidiarity and proportionality. PO1 imposes no new

obligations on MS and is fully compatible as a non-binding option. PO2 addresses procedural requirements

without harmonising substantive assessment standards or affecting MS competence to take recognition

decisions or manage migration and admissions. Its implementation obligations are proportionate to the

improvements it delivers and sit within the established EU legislative tradition of minimum harmonisation

in the field of qualifications. PO3 measures are directly linked to the scale and persistence of the problems

they address and are grounded in the existing framework of minimum training requirements under the PQD.

Automatic recognition grounded in prior programme verification is a proportionate response that preserves

MS competence over qualification standards and admission decisions; participation by third-country

institutions is voluntary and the system will expand based on demonstrated interest by the institutions,

limiting the risk of unintended effects on origin country skills systems.

8. PREFERRED OPTION

8.1. Policy Option 3

PO3 is identified as the preferred option. It is the most effective, efficient and coherent of the three options

assessed, and it provides the appropriate overall policy response to the scale and persistence of the identified

problems with recognition of qualifications of third-country nationals, while keeping and respecting the

competences of MS in the areas of migration and professional regulation. The preferred option would be

implemented through a proposal for a Directive, based on Article 79(2), points (a) and (b), TFEU, as set out

in Section 5.2. Parallel amendments to Directive 2005/36/EC should be made as part of SPI Action 2 to

ensure coverage of EU citizens holding third-country qualifications, as that Directive which addresses EU

citizens is the appropriate instrument for this purpose.

PO3 meets the specific objectives of the action in the most direct and complete way. Under SO1, the binding

common procedural rules establish, for the first time, a comprehensive framework governing recognition

across all 27 Member States — eliminating the divergence that currently produces inconsistent outcomes

for the same qualification assessed in different national systems — while the automatic recognition channel

for the seven sectoral professions replaces repeated individual assessments using established EU standards.

This represents a structural shift from a system defined by national fragmentation to one grounded in shared

rules and mutual trust, with a clear dimension of EU added value that neither voluntary coordination nor

procedural reform alone could deliver. Under SO2, binding procedural deadlines, documentation limits,

transparent fee structures and a right of appeal establish a common procedural floor that applies consistently

across all Member States, compressing processing times from the 14.2-month baseline to 4 months for

automatic recognition procedures and to 5 months for the remaining ones. The per-procedure administrative

burden would be reduced by approximately EUR 208 on the central estimate for non-automatic procedures

and by EUR 510 for automatic ones. Under SO3, the system of automatic recognition, with the

interoperable databases, and EU authentication service create a new foundation to address issues of trust,

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providing a basis to increase the share of CAs able to decide on the basis of a verified programme listing

without requesting compensation measures.

The current system imposes its heaviest costs (in time, money and skills waste) on precisely the professions

where qualifications are most standardised, workforce shortages most severe, and case-by-case assessment

most disproportionate to the risk it is designed to manage. Automatic recognition for those professions is

the appropriate and proportionate response. PO3 does not remove Member State competence over

qualification standards; it first establishes a core of simplified, common procedural rules, and secondly

removes the redundant procedural burden of repeatedly re-examining applications from individual

applicants from verified programmes. It restructures recognition around a logic of uniformity, trust,

transparency and proportionality that the current system lacks and that the scale of identified labour market

needs requires.

PO3 is also the most efficient option, generating aggregate cumulative net benefits that are substantially

larger than PO2 and several times larger than PO1. Cumulative benefits over the assessment period are

estimated at approximately EUR 3,536 million against total cumulative implementation costs of EUR 64–

109 million, yielding a strongly positive net present value that is robust across all tested sensitivity

dimensions. While PO3 entails higher EU-level implementation — EU one-off costs of EUR 8–14 million

and cumulative recurring costs of EUR 17–27 million — these remain modest in relation to the scale of

expected benefits.

PO3 also delivers the strongest coherence with EU policy objectives. It directly aligns recognition for the

seven sectoral professions with EU-level objectives on talent attraction, healthcare workforce supply and

the Single Market, mirroring the logic already applied to EU citizens under the PQD and closing the gap

between the procedural guarantees available to EU nationals and those available to TCN. By establishing a

fully integrated recognition channel that is consistent and equivalent across all MS, PO3 provides the

structural certainty that the EU's talent attraction instruments — the EU Talent Pool, the Blue Card, and the

Talent Partnerships — require to function as a coherent ecosystem. It most directly operationalises the EU's

competitiveness and demographic agenda as set out in the Union of Skills communication and the European

Council conclusions of March 2026.

8.2. REFIT (simplification and improved efficiency)

The initiative tackles recognition system inefficiencies through binding common procedural rules

that are estimated to reduce certified translation needs by around one third, while a shared EU

authenticity service will reduce the burden associated with verification of documents. Mandatory

coordination between recognition and migration authorities eliminates duplicate qualification

checks across parallel procedures, reducing avoidable exchanges and rework for both applicants

and CA. For the seven sectoral professions covered by automatic recognition, processing times are

projected to fall from 14.2 months to approximately 4 months, freeing CA capacity for complex

cases. Employers stand to benefit from faster recruitment and more predictable timelines, with

administrative costs for hiring a recognised professional estimated to fall by 35–50% for sectoral

professions, generating indicative aggregate savings of EUR 14–30 million per year.

8.3. Application of the ‘one in, one out’ approach

There are no expected administrative costs for citizens and businesses arising from the initiative.

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9. HOW WILL THE ACTUAL IMPACTS BE MONITORED AND EVALUATED?

9.1. Monitoring framework

The monitoring framework for the action is based on headline indicators for each specific objective,

and identified data sources, including new streams coming from the implementation infrastructure.

The framework will comprise the elements below and will be subject to further adjustment

according to the final legal and implementation requirements and timeline.

• Annual MS reporting: From entry into force, MS will submit an annual standardised report

covering: applications received; share of complete applications at first submission; average

processing times; information exchanges per case; cases handled under the automatic

recognition channel; and authenticity checks requested. The template will be kept short to

minimise burden on national authorities.

• EU shared infrastructure data: The authenticity check service will generate operational

data automatically — queries processed, average response times — available to the

Commission and MS on a continuous basis and feeding directly into annual monitoring

cycles without additional national reporting effort.

• Stakeholder surveys: Approximately two years after entry into force, the Commission will

survey CA on early implementation experience and the functioning of new digital tools,

and TCN applicants and employers, including SMEs, on user experience, procedure

duration and administrative burden.

Monitoring is directly connected to enforcement, and the Commission will monitor compliance

both in law and in practice. A first step will be a conformity assessment of the national transposition

measures. The experience of the PQD demonstrates that a comprehensive conformity check

enables the Commission to detect and address inconsistencies in national legal frameworks,

including in areas involving a wide range of different competent authorities, and this ex ante review

will also allow the Commission to verify that MS have put in place the institutional arrangements

required for practical compliance, including structured cooperation between migration and

recognition authorities where required.

Following the initial transposition check, the annual statistics provided by MS - covering outcomes,

average processing times, information exchanges per case, authenticity checks, appeals and fees,

will provide the basis for identifying systemic patterns of non-compliance. This data will be

complemented by qualitative feedback and complaints received from TCNs, employers and other

stakeholders and by the exchanges within the dedicated expert group.

Where the evidence points to an administrative practice incompatible with the Directive, the

Commission may take enforcement action under the Treaties, while, in line with the Union's

decentralised enforcement system, individual cases remain primarily a matter for national remedies

and judicial review, supported by the right of appeal guaranteed under the common rules.

The elaborated framework is set out in Annex 14.

9.2. Evaluation

A formal evaluation will be conducted no sooner than seven years after the date of application of

the legislation. The evaluation will assess the effectiveness, efficiency, coherence and EU added

value of the measures, based on monitoring data collected throughout implementation. It will

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examine in particular whether processing times and administrative costs have fallen, uptake of the

automatic recognition channel by third-country institutions, and whether trust in TCQ among CA,

migration authorities and employers has increased.

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ANNEX 1: PROCEDURAL INFORMATION

Identification of the lead DG:

DG Employment, Social Affairs and Inclusion (DG EMPL) is the lead DG.

Organisation and timing

PLAN/2025/2650 Fair labour mobility package: Skills Portability 3: recognition of qualifications

and skills of third country nationals

Commission work programme 2026, Supporting people, strengthening our societies and our

social model - 25: Skills and fair labour mobility – Fair labour mobility package

The Call for evidence2 providing an overview of the SPI, the 3 actions and envisaged policy

options was published on 05 December 2025 and remained open for feedback until 27 February

2026 (a detailed assessment of the feedback received is provided in Annex 2).

The Impact Assessment report (IA report) is based on a number of studies and existing literature,

reports and background research. A study from an external contractor was launched in October

2025 to inform the IA report.

In addition, extensive targeted consultations were conducted on this action between October

2025 and April 2026.

Previous consultations were also taken into account in the preparation of the IA report in

particular for development of the Proposal for a Regulation of the European Parliament and the

Council establishing an EU Talent Pool.

Inter-Service Steering Group

The Inter-service Steering Group (ISG) was set up by the Secretariat-General to assist in the

preparation of the initiative as part of the wider Union of Sills. A specific sub-group (technical

steering committee to the support studies of the IA) on the Skills Portability Initiative was created.

The representatives of the following Directorates-General participated in the ISG work: BUDG,

CNECT, COMM, EAC, ECFIN, EEAS, EMPL, ENV, ESTAT, GROW, JUST, JRC, INTPA,

MOVE, NEAR, REFORM, REGIO, RTD, SANTE, TRADE, SG and the Legal Service.

The ISCG met 3 times to discuss the SPI, namely on 16 September 2025 (meeting on the overall

Union of Skills with a dedicated point on the SPI), on 26 March 2026 (to discuss preliminary

elements of the three SPI IA) and on 27 May (to discuss the three IA before their submission to the

Regulatory Scrutiny Board.  

The steering group for the external study supporting the IA on SPI Action 3 met on 13 October

2025 for the kick-off meeting, on 20 November 2025 to discuss the draft Inception report and on

19 March 2026 to discuss the draft Interim report. The draft Final report was discussed by written

procedure with a deadline for comments by 3 June 2026.

Bilateral meetings with other Commission services

Furthermore, DG EMPL has held a number of bilateral meetings with several Commission services

including DG HOME and DG RTD.

59

On 31 March 2026 and 20 April 2026 a joint meeting with HOME and LS was organised to discuss

key aspects for the design of SPI Action 3.

External meetings and consultations

SPI Action 3 touches upon different policy areas including, migration, employment and

recognition of qualifications related aspects. Therefore, extensive consultations were conducted

with a wide range of stakeholders and experts from different backgrounds.Meetings and ad-hoc

consultations with EU institutions and agencies, international organisation, MS, expert groups,

high-level groups, think tanks, and civil society were organised. A full overview of the

consultations conducted is available in Annex 2.

Consultation of the Regulatory Scrutiny Board

On 15 June 2026, DG EMPL submitted the draft IA to the Regulatory Scrutiny Board, which

examined the draft IA on 15 July 2026.

The Board issued a positive opinion with reservations on 17 Month 2026. The Board pointed to a

number of elements of the IA that should be addressed. The table below summarises the main

recommendations for improvement, and how they have been addressed in this IA report.

Main recommendations for improvement Modifications in the IA report

Better substantiate the magnitude of the

problem and isolate it from other factors

shaping TCN destination choice; draw more on

existing evaluations (Annex 8) to support the

problem definition and drivers.

Added text acknowledging destination choice

reflects many factors but showing recognition

is the one EU-regulable determinant, and that

the problem also affects TCN already resident.

Brought forward Annex 8 information (Legal

Migration Fitness Check, Single Permit and

Blue Card IAs) into Chapter 2.

Explain how a uniform approach will be

ensured given MS flexibility, and how rules on

deadlines, document lists and fee transparency

will actually be enforced.

Added text on the legal instrument (Directive,

Art. 79(2) TFEU) clarifying enforcement

mechanism (transposition/conformity check,

practice-based monitoring via annual statistics,

expert-group exchanges) in the PO2/PO3

sections and Chapter 9.

Better explain the role, selection and

governance of the envisaged EU quality

assurance agencies under PO3, and how the

EU-wide QA channel relates to existing

national approaches.

Added detail on trusted review bodies,

approval validity, renewal and withdrawal

conditions. Added text/footnote evidencing

existing MS–third country curriculum-

alignment initiatives to show the EU channel is

complementary, not competing.

Analyse whether CAs have the capacity and

incentives to meet shorter deadlines without

raising costs, what drives the assumed

Added a new section (6.1.5, methodological

uncertainty and sensitivity) covering

CA/migration-authority typologies and

incentive structures, the specific sources of

60

efficiency gains, and the range of CA types,

governance and enforcement risk.

efficiency gains (authenticity service,

interoperable databases, mandatory

coordination), and confirming enforcement

risk is captured via the realisation factors.

Provide evidence of third-country institutions'

interest in, and willingness to bear the costs of,

automatic recognition; present

benefits/monetisation more cautiously,

specifying assumptions and their sensitivity.

Added evidence on institutional uptake

drawing on existing MS-led curriculum-

alignment projects as a proxy for demand.

Added an explicit sensitivity analysis (Annex

4.5) testing realisation factors, baseline

caseload and opportunity-cost assumptions,

referenced in the main text.

Strengthen coherence analysis against the

wider ecosystem (EU Talent Pool Regulation,

other SPI actions), synergies with Action 2's

digital solution, and specify the type of legal

act proposed.

Added a four-part coherence analysis (Fair

Labour Mobility Package, EU Talent Pool

Regulation, Action 2, international trade

obligations) and specified the Directive under

Art. 79(2)(a)–(b) TFEU as the proposed

instrument, mirroring the PQD. Clarified why

use of a potential digital work flow (similar to

SPI Action 2) is not feasible in section on

discarded options.

External consultant

An external contractor (consortium led by EY Italy in collaboration with the Istituto Ricerca

Sociale (IRS)) has assisted DG EMPL by conducting a study to support the work on the IA report.

The call for tenders for the study was launched on 25 July 2025, three substantive bids were

evaluated in October 2026, leading to the award decision on 16 October 2025. The kick-off meeting

for the study took place on 24 October 2026, an inception report was delivered on 16 December

2025 and a draft interim report on 3 March 2026. The final report for the first reviews cycles was

submitted on 30 April 2026.

Evidence and Sources

This IA draws on a broad and layered evidence base assembled through desk research, a

comprehensive literature review, inter-service consultation, targeted expert consultations and focus

group discussions. Quantitative analysis is grounded in numerical estimates and calculations

derived from primary data collection complemented by triangulation with external datasets and

secondary sources. Qualitative evidence draws on expert assessments, stakeholder position papers

and the outputs of structured consultation activities.

The source base spans EU institutional documentation, UN and ILO instruments, OECD labour

market and migration analyses, peer-reviewed academic literature, and sector-specific studies on

labour and skills shortages, labour migration, and labour market inclusion. A full list of sources

consulted is provided in the Annex 15 Resources.

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ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)

1. Consultation Strategy

The objective of the consultation process for SPI Action 3 was to collect the views of MS and

relevant stakeholders on EU action to improve the recognition of qualifications and the validation

of skills of TCN. Targeted consultations provided stakeholders with an opportunity to contribute to

the development of the IA, including the identification of problems to be addressed, the assessment

of policy options, and the analysis of potential impacts. The consultations sought to gather both

objective data and evidence to inform the IA, and views, opinions and concerns about possible

policy responses and their likely impacts.

Commission services carried out an initial mapping of relevant stakeholders comprising: EU

institutions and agencies; CA in MS; EU-level networks of non-governmental organisations;

subject-matter experts; economic and social partners; trade unions; international organisations; and

employer associations.

Outcomes of bilateral meetings with MS, held in December 2025 and January 2025 as part of

the follow-up to Commission Recommendation EU 2023/2611, were also analysed for the

considered in analysis stakeholder views. A summary of these meetings is included below in part

7.

2. Overview of Consultation Activities

The consultation process drew on four main methods of engagement.

2.1 Call for Evidence

The Call for Evidence was published on 5 December 2025 on the Commission's Have Your Say

platform and remained open until 27 February 2026. A total of 235 stakeholders provided

feedback, accompanied by 125 position papers. Respondents included umbrella organisations,

economic and social partners, civil society organisations (CSO), public authorities and EU

citizens.

2.2 PC

A PC was conducted in parallel with the Call for Evidence, running from 5 December 2025 to 27

February 2026. It generated 785 responses in total, of which 486 were retained for analysis as

relevant to Action 3. Respondents included TCN (61), EU citizens with TCQ (37), public

authorities (81), academic and research institutions (44), non-governmental organisations (43),

business associations (41), companies and businesses (29), trade unions (11) and other

stakeholders (56).

2.3 Targeted Consultations Conducted by the Commission

Between October 2025 and April 2026, Commission services organised targeted consultations in

the form of bilateral meetings, thematic focus groups and written exchanges. A discussion

document and questionnaire were shared in advance of each meeting. The full list of consultation

activities is set out below.

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Consultation activity Date

Meeting with EurHeCA (European Health Professionals' CA) 2 October 2025

Meeting — Alignment on "Choose Europe" (Attracting

Researchers)

22 October 2025

Groningen Declaration Network Meeting 29–30 October 2025

EU Youth Stakeholders — Targeted Consultation 6 November 2025

European Migration Network Advisory Group 6 November 2025

Adult Learning Coordinators 14 November 2025

Regular Network Meeting — VET Providers 18 November 2025

European Federation of Nurses 18 November 2025

Pharmaceutical Group of the EU (PGEU) — General Assembly 19 November 2025

Validation and Recognition Working Group 25 November 2025

Geodesks 27 November 2025

Eurochambres Skills Committee 3 December 2025

Group of Coordinators for Professional Recognition 4 December 2025

Youth Guarantee Coordinators 5 December 2025

Annual NARIC Meeting 11 December 2025

EQF Advisory Group 16 December 2025

ENIC-NARIC Network January 2026

National Europass Centres — Dedicated Meeting 13 January 2026

63

Consultation activity Date

ESCO and National Classifications Experts — Dedicated

Meeting

14 January 2026

Talent Partnership Delegations 14 January 2026

Cross-Border Regions Stakeholders — Dedicated Meeting 16 January 2026