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| 26.8.2022 | EN | Official Journal of the European Union | C 323/62 |

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Opinion of the European Economic and Social Committee on ‘Proposal for a Council Recommendation on a European approach to micro-credentials for lifelong learning and employability’

(COM(2021) 770 final)

‘Proposal for a Council Recommendation on individual learning accounts’

(COM(2021) 773 final)

(2022/C 323/11)

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| Rapporteur: | Tatjana BABRAUSKIENĖ |
| Co-rapporteur: | Mariya MINCHEVA |

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| Referral | European Commission, 21.1.2022 |
| Legal basis | Article 304 of the Treaty on the Functioning of the European Union |
| Section responsible | Employment, Social Affairs and Citizenship |
| Adopted in section | 3.5.2022 |
| Adopted at plenary | 18.5.2022 |
| Plenary session No | 569 |
| Outcome of vote (for/against/abstentions) | 204/2/4 |

1.   Conclusions and recommendations

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| | 1.1. | The EESC calls again on the European Commission and the Member States to strengthen adult learning (AL) policies to make quality and inclusive AL for life skills a right for all adults in order to meet and exceed the target of 60 % of AL participation per year. The effective implementation of the European Pillar of Social Rights (EPSR) also requires addressing skills mismatches and improving governance and financing for AL, including employee training. It is also important that investments, necessary reforms and effective social dialogue aiming to foster skills development, in line with the first principle of the EPSR on the right to training and lifelong learning (LLL), are embedded in the context of the European Semester. |

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| | 1.2. | The EESC recalls the importance of its previous opinions on LLL and AL in relation to the initiatives on individual learning accounts (ILA) and micro-credentials (MCs). In particular, it stresses that ‘upskilling and reskilling are of the utmost importance in supporting the green and digital transitions of industries and they need to be seen as a social and economic responsibility to ensure inclusive training for quality jobs, and a just transition for all. Forward-looking industrial strategies, including effective skills policies, are needed to support upskilling and reskilling of the workforce. These can help ensure a just and socially fair transition to a climate-neutral economy through balancing the labour market that contributes to inclusive digitalisation and high-quality jobs. Companies need effective support to strengthen and finance their strategies for upskilling and reskilling their workforces to encourage innovation. At the same time, the overall economic and social interest should be respected. Collective agreements should determine access to different types of paid education leave for workers’ personal and professional needs’ [(1)](#ntr1-C_2022323EN.01006201-E0001). Where paid leave is not agreed between social partners and follows a government initiative, this should be financed by public resources. |

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| | 1.3. | The rapid invention and spread of new technologies needs to be accompanied by effective upskilling and reskilling. Investment in AL and skills development can play a crucial role in economic recovery and building social Europe. Individual learning accounts can only be one of the approaches and financial tools considered by EU Member States and social partners. The proposed measures should not replace: the existing forms of training provision put in place by employers and public and private employment services; public support for education and training institutions; or other types of support. In particular, training funds managed by social partners are an effective way to provide training in response to needs identified at national and sectoral level. |

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| | 1.4. | The supply of a sufficiently skilled workforce and improved employability is a key condition for businesses and society to prosper and grow, to employ people, and to contribute to the policy objectives set by the European Union. Already today, there are skills mismatches and labour shortages across several sectors and regions and these will continue to grow. In this regard, Member States and employers have an important role to play in financing and incentivising participation in training. Skills development must match the needs of the labour markets if Europe is to strengthen its long-term competitiveness and capacity to drive innovation, which is important for businesses and employees alike. |

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| | 1.5. | Workers face numerous obstacles in accessing training. If individuals are given more control over their own training, it is important to ensure that they receive effective guidance and support to choose and to access training courses that are relevant to their needs. This would also ensure optimal investment in training as the training would closely match the identified needs of each individual. In the case of job-oriented training, a purely individualised approach may weaken the link between the financing and content of training provision thereby potentially resulting in training being less job-oriented and thus insufficiently tailored to employers’ needs. |

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| | 1.6. | The EESC agrees with the tripartite ACVT opinion when it states that there is a need to tailor the conditions for access and entitlement to training to different situations and realities through an appropriate mix of arrangements. The EESC calls on the Commission to respect the division of competences and the principle of subsidiarity, as well as the national specificities and legal frameworks of each Member State. When adopting and implementing the proposals for ILA and MCs, these must be compatible with the existing CVET systems of the Member States, with the role of collective bargaining, the regulation of working conditions and holiday entitlements for employees. |

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| | 1.7. | The EESC calls on the Commission and the Member States to respect existing national and sectoral instruments and funding schemes, and to differentiate between ‘right/entitlement’, terms which are still not defined by law or collective agreements in some countries and sectors, and ‘training account’. The EESC asks that the proposals ensure that all adults, especially the most vulnerable, have the right to access effective, quality and inclusive employee training, paid educational leave, full qualification, validation of informal and non-formal learning, and guidance and counselling. Member States are asked to improve their AL and CVET systems where necessary, following effective social dialogue and consultation with relevant stakeholders. The EESC welcomes the fact that ILA can be used for training, validation and career guidance. |

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| | 1.8. | The EESC underlines the importance of quality standards in the training market, particularly with regard to MCs, and the possible advantages and disadvantages of different approaches to financing AL (e.g. ILA), including the cost-benefit relationship, the administrative burden and costs, achieved status change (higher formal qualification level), quality assurance, the labour market relevant outcome, the added value for career development and the participation rate of the key target group of low-qualified people. The EESC regrets that the Commission did not carry out an impact assessment on MCs as the proposal can have an impact on existing national arrangements, especially on qualifications and on collective agreements. In this regard, it is necessary to ensure effective social dialogue and effective consultation, including with organised civil society, on whether and how the European initiatives on ILAs and MCs can be of added value in improving national and sectoral training systems. |

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| | 1.9. | The EESC stresses that the VET providers’ catalogue of MCs should be established with the involvement of the social partners and education and training providers based on the quality standards of the provision. The catalogue should include the learning outcomes of the MCs and their recognition by other education and training providers and by employers. |

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| | 1.10. | The EESC recalls the importance of paid educational leave [(2)](#ntr2-C_2022323EN.01006201-E0002) also in line with ILO 140 (ratified in 11 Member States [(3)](#ntr3-C_2022323EN.01006201-E0003)), and notes that the proposal on ILA should be compatible with national systems when it asks the Member States to design ILA systems for labour market purposes only, as in several Member States paid education leave can also be used for the purposes of personal development or to complete a study programme (e.g. university degree). |

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| | 1.11. | The EESC reminds the Commission and Member States that the effective involvement of the social partners in the governance of AL, employee training and paid educational leave systems is essential, including promoting joint actions among the social partners. It also stresses the importance of consulting the relevant civil society organisations on AL. |

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| | 1.12. | The EESC calls on the Commission to support the exchange of good practices and mutual learning between Member States, with the involvement of the social partners. The focus should be on how best to ensure effective access to training and how to improve Member States’ AL systems and skills strategies in particular, as well as their financial mechanisms and types of training, including MCs. The EESC also asks for the tripartite ACVT to be involved in the follow-up to the proposals and for it to take an active role in reporting on the implementation of the initiatives and in setting up the monitoring framework in cooperation with the Employment Committee. |

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| | 1.13. | The EESC calls on the Member States to link the initiatives on ILA and MCs to the implementation of the Council Recommendation of 19 December 2016 on Upskilling Pathways: New Opportunities for Adults [(4)](#ntr4-C_2022323EN.01006201-E0004). This would ensure that all low-skilled and low-qualified adults could develop their basic skills and professional skills and that they were guided and motivated to participate in training to improve their life and employability and to ensure that 80 % of adults have basic digital skills. |

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| | 1.14. | The EESC reiterates that ILA and similar financial systems need to support access to recognised and validated training courses and to allow workers to participate in processes to have their skills and work experience validated. MCs need to be recognised by the relevant authorities with the involvement of the social partners. The EESC calls for the effective implementation of the Council Recommendation on the Validation of non-formal and informal learning [(5)](#ntr5-C_2022323EN.01006201-E0005) and for sufficient public funding to be allocated to validation systems in every EU country. By ensuring that training is recognised, employers and unions can help workers improve their qualifications and can contribute to their career development and a just transition in the labour market. |

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| | 1.15. | The EESC considers it important that the initiatives address the upskilling and reskilling needs of adults and the workforce as a whole (workers/employees/self-employed persons) as well as other target groups (e.g. the long-term unemployed, inactive individuals, and specifically persons returning to work after parental leave [(6)](#ntr6-C_2022323EN.01006201-E0006), people with disabilities, retired people, women, young people under 30 and NEETs) so that they have effective access to quality and inclusive training. The specific situation of non-standard workers and the self-employed needs to be addressed urgently and appropriately, respecting the key role of social partners in terms of employee training. The role of companies in supporting their workers’ training is essential, as is that of the Member States in providing resources to ensure access to AL. As 90 % of job-related training in the EU is funded by employers [(7)](#ntr7-C_2022323EN.01006201-E0007), their commitment to and positive role in skills development needs to be fully acknowledged and supported by the EU. |

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| | 1.16. | The EESC calls on Member States to explore possible instruments for portability of ILAs, for instance establishing bilateral agreements. The EESC requests the inclusion of a ‘governance system with the involvement of the social partners’ among the EU’s quality standards for MCs and asks for MCs to be considered alongside full qualifications and employee training. The EESC asks for training providers to publish catalogues of the MCs they offer, including the learning outcomes, and their policy on the recognition of micro-credentials by other providers and companies. Improving access to all forms of quality and inclusive education and training (including MCs) for all learners, including disadvantaged and vulnerable groups is important to ensure equal access to full study programmes and qualifications. Efficient support (financial and non-financial) must be provided to people in non-standard forms of work, to enable them to access courses, including MCs, for professional development and mobility, ensuring the accessibility and usability of training materials and tools, whether they are virtual or not according to Directive (EU) 2016/2102 of the European Parliament and of the Council [(8)](#ntr8-C_2022323EN.01006201-E0008). |

2.   General comments

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| | 2.1. | On 10 December 2021 the European Commission published the Commission proposal for a Council Recommendation on Individual Learning Accounts [(9)](#ntr9-C_2022323EN.01006201-E0009) and Commission proposal for a Council Recommendation on Micro-credentials for lifelong learning and employability [(10)](#ntr10-C_2022323EN.01006201-E0010). These initiatives aim to support the EPSR Action Plan which sets a new target whereby at least 60 % of all adults should participate in training every year by 2030. This is in order to ensure that everyone has ‘the right to quality and inclusive education, training and lifelong learning’ (principle 1), ‘regardless of the type and duration of the employment relationship’ (principle 5), including ‘the right to transfer training entitlements during professional transitions’ (principle 4). It is also important for investments, necessary reforms and effective social dialogue aiming to foster skills development, in line with the 1st principle of the European Pillar of Social Rights on the right to training and lifelong learning, to be embedded in the context of the European Semester. |

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| | 2.2. | In order to contribute to the proposal on individual learning accounts, on 16 August 2021 the tripartite Advisory Committee on Vocational Training (ACVT) of governments and social partners adopted an opinion on individual learning accounts and strengthening training provision across Europe [(11)](#ntr11-C_2022323EN.01006201-E0011). This tripartite opinion reiterates that ‘The COVID-19 pandemic, digitalisation and decarbonisation are having an enormous impact on the European economy, industries, and the European workforce who are facing a very challenging adaptation to rapidly changing work. The pandemic has accelerated structural changes in many sectors, increasing the pace of the green and digital transformations. This is allied to the ongoing challenges of demographic change, new training needs and skills mismatches’. The tripartite opinion also highlights that ‘taking into account all the realities of the labour market, [...] there is a need to tailor the conditions for access and entitlement to training to different situations and realities through an appropriate mix of arrangements’. |

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| | 2.3. | The 2021 European social partners project on skills, innovation and training also identifies among its findings that ‘Enterprises and workers play a crucial role in innovation and the development of new skills and competences provided by employee trainings, and which are crucial for adapting to a changing environment. Therefore, the provision of, and access to, employee training that responds to employers’ and workers’ needs for developing innovative technologies and business models and that enables workers to find and maintain jobs in line with their skills, expectations and competences is vital’ [(12)](#ntr12-C_2022323EN.01006201-E0012). To this end, a key challenge is to make the different tools available, including vouchers, paid educational training leave (by law or through collective agreements), personal training accounts or training funds (cross-industry or sectoral), inter-operable and aligned with the country-specific institutional framework [(13)](#ntr13-C_2022323EN.01006201-E0013). |

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| | 2.4. | National legislation and/or collective agreements ensure an individual’s right to education and training, including AL and training, and paid educational leave for work-relevant training in some Member States. Across Europe, social partners, social dialogue and collective bargaining play a key role in facilitating employees’ effective access to training in different ways in each country. They may consider existing national and/or sectoral level or other alternative approaches to an ILA model to be better suited to fostering training provision within the national context. The effective involvement of national and sectoral social partners in this regard should be respected and ensured. |

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| | 2.5. | Diverse legal and/or collective bargaining frameworks reflect the choice of each Member State to adopt and implement its own training policies and build on existing financing mechanisms. In this manner, an individual learning account can only be one of the approaches and financial tools considered by EU Member States and social partners. A one-size-fits all approach will not work and Member States’ different training systems and distinctive sectoral traits must be respected. The decision on whether or not to adopt the ILA as one of the mechanisms for providing and financing training must remain fully within the competence of the Member States in the same way the training market is regulated at national level. The EESC underlines that Member States, in consultation with social partners, also have the freedom to decide not to adopt an ILA approach and could instead adapt or further develop their existing approaches to training provision. |

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| | 2.6. | The EESC recalls that ‘The measures outlined in this Recommendation should not replace training provision by employers, by public and private employment services, public support for education and training institutions or other types of support’ [(14)](#ntr14-C_2022323EN.01006201-E0014). The EESC agrees that the Recommendation ‘should not prevent [the Member States] from maintaining or establishing more advanced provisions on adult learning/training than those recommended’ [(15)](#ntr15-C_2022323EN.01006201-E0015) in the Recommendation and that it ‘should not limit the autonomy of the social partners where they are responsible for setting up and managing training schemes’ [(16)](#ntr16-C_2022323EN.01006201-E0016). |

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| | 2.7. | The EESC refers back to its recent opinion [(17)](#ntr17-C_2022323EN.01006201-E0017) which points out that ‘the rapid invention and spread of new technologies need to be accompanied by effective upskilling and reskilling. The EESC underlines that the impact of the COVID-19 crisis on Europe’s society and economy further highlighted the importance of effective education and training policies and high-quality jobs in supporting a sustainable and just social and economic recovery and resilience, which is crucial in helping Europe overcome the consequences of the pandemic. Investment in AL and skills development can play a crucial role in economic recovery and a social Europe’. |

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| | 2.8. | The EESC recalls that the obstacles for adults and workers to access training are numerous, including lack of time, insufficient financing, motivation, quality guidance and counselling, sometimes a lack of available quality training, support from the workplace (replacement) especially in SMEs, and lack of respect of work-life balance. Placing individuals in the driving seat of their own training is important when there is an assurance of effective support for them to access and pursue labour market-relevant training. This includes supporting individuals by providing advice and guidance on suitable types of training. Workers need access to company-based training and low-skilled workers need targeted support especially in relation to online training. ‘Online training offers many opportunities to expand access to AL, but low-skill workers may lack the skills to make the most of this kind of training and may need extra support’ [(18)](#ntr18-C_2022323EN.01006201-E0018). |

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| | 2.9. | In order to tackle different obstacles to training access and increase the motivation of adults to participate in training, barriers should also be considered from the point of view of the individual’s employment and education status. The instrument should be supported with the provision of effective guidance and counselling. The outreach strategy needs to be improved. In order to reduce the existing skills mismatch, training needs must be identified in advance and training courses must be properly targeted. Comprehensive learning support systems are also necessary to ensure stronger synergies between financial incentives, guidance services, and access to validation and recognition procedures [(19)](#ntr19-C_2022323EN.01006201-E0019). |

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| | 2.10. | The EESC is concerned that a purely individualised approach may weaken the link between the financing and content of training provision thereby potentially resulting in training being less job-oriented and thus insufficiently tailored to employers’ needs. As 90 % of job-related training in the EU is funded by employers [(20)](#ntr20-C_2022323EN.01006201-E0020), their commitment and positive role for skills development needs to be fully acknowledged and supported by the EU. Social partners have a key role to play, jointly, in fostering training provision and participation. In particular, training funds managed by social partners are an effective way to provide training in response to identified needs at national and sectoral level. The financial and non-financial contributions of individuals should be recognised and supported. |

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| | 2.11. | The EESC recognises the complementary role that MCs can play in broadening access to upskilling and reskilling while taking into account evolving labour market needs. The EESC also welcomes the fact that Member States are encouraged to link MCs to their employment policies, including active labour market policies, in order to help reduce skills mismatches in sectors and regions while respecting access to full qualifications. Concerning the ‘stackability’ of MCs, the EESC underlines that MCs should not be seen as a substitute for full qualifications. Member States should therefore be encouraged to include MCs in national qualification frameworks. The social partners should be involved in designing this at national level and in thinking about how MCs can be recognised and added to partial qualifications. |

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| | 2.12. | Micro-credentials can be important in helping adults upskill and reskill or transition to new job opportunities when the quality standards of MCs are well-defined and made clear to the learners. While MCs could be a form of training that is accessed through a potential ILA, they should be viewed as separate to an ILA and as part of the toolbox of additional tools for continuous learning. The EESC also welcomes the fact that among the providers of MCs, the draft recommendation acknowledges the social partners and invites Member States to promote the development of MCs designed and approved by employers’ and workers’ representatives through social dialogue. |

3.   Specific comments

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| | 3.1. | Free movement of workers can help with addressing the challenges of skills mismatches and shortages. Regulations on qualification requirements must remain a national competence with the involvement of the social partners, for example, in the validation of skills, including MCs, and while reducing the number of regulated professions. The better matching of skilled third country nationals with unfilled job vacancies across qualification levels and years of work experience can also play a role. The Commission’s upcoming skills and talent package [(21)](#ntr21-C_2022323EN.01006201-E0021), including the possible scenarios for an EU Talent Pool can play an important role in this regard. |

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| | 3.2. | Collective agreements are an important means through which the provision of paid educational leave can foster workers’ access to labour market-relevant training. Such agreements play a particularly important role in identifying the ways of accessing paid educational leave for workers in SMEs who typically experience a greater loss of productive capacity while workers are absent due to training. It is important to stress that legislative initiatives at the EU or national level must not undermine the collective bargaining process or the autonomy of the social partners in finding solutions to issues that are important for well-functioning national labour markets, including solutions for skills development and transitions, and quality jobs for workers in the context of the just transition. |

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| | 3.3. | The EESC underlines the importance of quality standards in the training market, particularly with regard to MCs and the possible advantages and disadvantages of different approaches to financing AL, e.g. ILA, including the cost-benefit relationship, administrative burden and costs, achieved status change (higher formal qualification level), quality assurance, labour market relevant outcome, added value for career development and level of participation rate of the key target group of low qualified people. This is necessary in order to ensure effective social dialogue and effective consultation, including with organised civil society, on whether and how the European initiatives on ILAs and MCs can be of added value in improving national and sectoral training systems. The EESC stresses that the VET providers’ catalogue of MCs should be established with the involvement of the social partners and education and training providers based on quality standards of the provision. The catalogue should include the learning outcomes of the MCs and their recognition by other education and training providers and by employers. |

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| | 3.4. | The EESC considers it important that the initiatives address the upskilling and reskilling needs of adults and of the workforce as a whole (workers/employees/self-employed persons) and other target groups (e.g. the long-term unemployed, inactive individuals, people with disabilities, retired people and NEETs) so that they also have access to quality, effective and inclusive training that supports their employability. In this regard, Member State support in ensuring resources for accessing AL is essential. In parallel, the role of companies in supporting their workers’ job-relevant training remains vital. The particular situation of non-standard workers and the self-employed, which cannot be solved by ILA and MCs alone, needs to be addressed urgently and appropriately, while respecting the key role of social partners in terms of employee training. |

Brussels, 18 May 2022.

The President of the European Economic and Social Committee

Christa SCHWENG

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[(1)](#ntc1-C_2022323EN.01006201-E0001)  [OJ C 374, 16.9.2021, p. 16](http://publications.europa.eu/resource/oj/JOC_2021_374_R_TOC).

[(2)](#ntc2-C_2022323EN.01006201-E0002)  [OJ C 374, 16.9.2021, p. 16](http://publications.europa.eu/resource/oj/JOC_2021_374_R_TOC).

[(3)](#ntc3-C_2022323EN.01006201-E0003)  ILO official data available here: http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:11300:0::NO::p11300\_instrument\_id:312285

[(4)](#ntc4-C_2022323EN.01006201-E0004)  [OJ C 484, 24.12.2016, p. 1](http://publications.europa.eu/resource/oj/JOC_2016_484_R_TOC).

[(5)](#ntc5-C_2022323EN.01006201-E0005)  [OJ C 398, 22.12.2012, p. 1](http://publications.europa.eu/resource/oj/JOC_2012_398_R_TOC).

[(6)](#ntc6-C_2022323EN.01006201-E0006)  https://www.europarl.europa.eu/RegData/etudes/STUD/2020/658190/IPOL\_STU(2020)658190\_EN.pdf

[(7)](#ntc7-C_2022323EN.01006201-E0007)  Adult learning statistical synthesis report, EC, 2020/082020.

[(8)](#ntc8-C_2022323EN.01006201-E0008)  Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of the websites and mobile applications of public sector bodies ([OJ L 327, 2.12.2016, p. 1](http://publications.europa.eu/resource/oj/JOL_2016_327_R_TOC)).

[(9)](#ntc9-C_2022323EN.01006201-E0009)  COM(2021) 773 final.

[(10)](#ntc10-C_2022323EN.01006201-E0010)  COM(2021) 770 final.

[(11)](#ntc11-C_2022323EN.01006201-E0011)  https://ec.europa.eu/social/main.jsp?langId=en&catId=1223&furtherNews=yes&newsId=10081

[(12)](#ntc12-C_2022323EN.01006201-E0012)  BusinessEurope: ‘Skills, innovation and the provision of, and access to training’.

[(13)](#ntc13-C_2022323EN.01006201-E0013)  Cedefop's financing adult learning database.

[(14)](#ntc14-C_2022323EN.01006201-E0014)  COM(2021) 773 final.

[(15)](#ntc15-C_2022323EN.01006201-E0015)  COM(2021) 773 final.

[(16)](#ntc16-C_2022323EN.01006201-E0016)  COM(2021) 773 final.

[(17)](#ntc17-C_2022323EN.01006201-E0017)  [OJ C 374, 16.9.2021, p. 16](http://publications.europa.eu/resource/oj/JOC_2021_374_R_TOC).

[(18)](#ntc18-C_2022323EN.01006201-E0018)  OECD: ‘Building back better: enhancing equal access to opportunities for all’.

[(19)](#ntc19-C_2022323EN.01006201-E0019)  Cedefop (2020), Empowering people to cope with change.

[(20)](#ntc20-C_2022323EN.01006201-E0020)  Adult learning statistical synthesis report, EC, 2020/082020.

[(21)](#ntc21-C_2022323EN.01006201-E0021)  Foreseen for April 2022.

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