COMMISSION RECOMMENDATION (EU) 2022/554

of 5 April 2022

on the recognition of qualifications for people fleeing Russia’s invasion of Ukraine

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union, and in particular Article 292 thereof,

Whereas:

(1) Following the unprovoked Russian military aggression and invasion of Ukraine on 24 February 2022, which the European Union has condemned in the strongest possible terms, the European Union is facing an unprecedented inflow of people fleeing from the war and seeking protection. The number of people displaced from their homes and forced to flee Ukraine has reached some four million.

(2) In its communication ‘European solidarity with refugees and those fleeing war in Ukraine’ of 8 March 2022 (1), the Commission outlined the substantial support the EU had made available to help people fleeing Russia’s invasion of Ukraine, as well as the Member States receiving them. This includes direct humanitarian aid, emergency civil protection assistance, support at the border, as well as a clear legal status allowing those fleeing the war to receive immediate protection in the EU.

(3) In its communication ‘Welcoming those fleeing war in Ukraine: Readying Europe to meet the needs’ of 23 March 2022 (2) the Commission sets out measures to help people fleeing Russia’s invasion of Ukraine and to ensure they can effectively access their rights. The measures include not only immediate ones to provide shelter, humanitarian aid and access to healthcare, but also action to ensure that people are smoothly integrated into the host countries and have access to education, housing and jobs. Government authorities, NGOs, and volunteers in Member States, particularly in the countries of first entry (Poland, Romania, Slovakia and Hungary) but also in those of final destination, are doing their utmost to provide support and protection to people fleeing Russia’s invasion of Ukraine.

(4) Council Implementing Decision (EU) 2022/382 (3) which activated the temporary protection mechanism set out in Directive 2001/55/EC (4), provides people fleeing Russia’s invasion of Ukraine with a clear legal status as soon as they arrive in the European Union. Temporary protection will in the first instance last 1 year and could automatically be renewed twice for 6 months each time. Temporary protection includes a residence permit, welfare support and healthcare, and access to housing, education and employment.

(5) Article 12 of Directive 2001/55/EC states that Member States must authorise people enjoying temporary protection to engage in ‘employed or self-employed activities, subject to rules applicable to the profession’ as well as in activities such as educational opportunities for adults, vocational training and practical workplace experience.

(6) The right to access the labour market is a key aspect of temporary protection. Experience shows that non-EU nationals, and in particular refugees, often have to take jobs below their qualification level (5). Providing a simple and rapid recognition mechanism contributes greatly to ensuring that people enjoying temporary protection can work in jobs for which they are qualified. This facilitates their integration and leads to better use of their skills, benefiting both the individual and the host community. It also ensures people gain relevant experience and skills during their period of temporary protection, which adds value to their qualifications when returning to the home country.

(7) The Commission’s 2021-2027 action plan on integration and inclusion (6) recognises that facilitating the recognition of qualifications acquired in non-EU countries and increasing their comparability with EU qualifications is key to faster and fairer inclusion of refugees and migrants in the labour market. It also recognises that many highly educated migrants and refugees – in particular women – are over-qualified for their job, which may lead to depreciation of their skills. The action plan encourages Member States to ensure that procedures for recognising foreign qualifications are quick, fair, transparent and affordable.

(8) If a Member State has opted to regulate a specific profession (7), people enjoying temporary protection will need to obtain recognition of their professional qualifications to engage in employed or self-employed regulated activities in that profession. Depending on the specific Member State, this can include for example different groups of health, teaching, legal, social or crafts professions. The recognition of third country nationals’ professional qualifications takes place at national level, applying the law and procedures of the host Member State unless international agreements apply.

(9) For non-regulated occupations, requirements for employment are not regulated by law and can vary from very specific to very general. For these occupations there are no regulatory barriers to employing a person whose qualifications have not been recognised and there is no single process in place for the recognition of qualifications for purposes of entry into non-regulated occupations (8).

(10) Some Member States and regions encounter shortages in a number of occupations across industrial ecosystems (9), including in several regulated professions. Recognition of professional qualifications can help address some of these shortages and achieve a more balanced labour market.

(11) Recognition of professional qualifications should be complemented by a framework that allows the exercise of the professions in practice, avoids bureaucratic barriers and offers advice to those who need it.

(12) For people fleeing the war, recognition of their qualifications will not be the first thing on their minds. It is nonetheless important to provide signposting and basic information so that people have it to hand once they need it. In addition to Member States providing information, the Commission put in place the ‘EU solidarity with Ukraine’ website (10).

(13) In addition to Ukrainian nationals, Council Implementing Decision (EU) 2022/382 provides that Member States must apply either temporary protection or adequate protection under national law in respect of nationals of non-EU countries other than Ukraine who can prove they were legally residing in Ukraine before 24 February 2022 on the basis of a permanent resident permit. In addition to those enjoying temporary protection, the Commission therefore encourages Member States to, to the extent possible under national law, apply this Recommendation to people that have fled Russia’s invasion of Ukraine and are beneficiaries of adequate protection under national law, in accordance with that Decision.

(14) Directive 2005/36/EC (11) does not apply to third country nationals including those enjoying temporary protection. It contains rules for recognition of third country qualifications held by EU citizens. It imposes an obligation on Member States to not recognise any qualification held by EU or non-EU citizens relating to the professions listed in Title III, Chapter III, unless the minimum training conditions set out in that chapter are fulfilled. These professions are: doctors, certain specialised doctors, nurses responsible for general care, dental practitioners, veterinary surgeons, midwives, pharmacists and architects. Where professionals fleeing Russian aggression do not meet these minimum training requirements, it is essential to identify solutions how they can obtain the missing competences or how an appropriate and quick integration in the labour market can be achieved.

(15) The current situation is characterised by a rapid inflow of a very large number of people, many of whom may be well-qualified. The long-established recognition systems and procedures in the Member States may not be designed to process so many applications at once. In particular, competent authorities in the host Member States might not be in a position to assess each one of them on a case-by-case basis and carry out a corresponding detailed analysis.

(16) Information on Ukrainian qualifications, the Ukrainian qualifications system and the Ukrainian qualifications framework is crucial for Member States to be able to streamline processes and evaluate applications for the recognition of qualifications quickly.

(17) Ukraine is a member of the European Higher Education Area that was created under the Bologna Process. The Bologna Process brings coherence to higher education systems across the European region and encourages fair and transparent recognition of qualifications. One of its main objectives is to support staff and student mobility. Countries participating in the Bologna Process have agreed to ensure the mutual recognition of qualifications for academic purposes. Rules on recognition of higher education qualifications for both professional purposes and further learning are set by the Convention on the Recognition of Qualifications concerning Higher Education in the European Region (the Lisbon Recognition Convention) (12) to which all Member States except Greece, as well as Ukraine and other non-EU countries are parties.

(18) The ENIC-NARIC network (European Network of Information Centres in the European Region-National Academic Recognition Information Centres in the European Union) developed the Erasmus+ Q-entry project, a database that covers Member States and non-EU countries and provides information on school-leaving qualifications giving access to higher education. This database includes information on Ukrainian qualifications and can be used to support the recognition process for people enjoying temporary protection.

(19) Member States may face the challenge that applicants cannot provide evidence of formal qualifications. People fleeing Russia’s invasion of Ukraine may have been forced to leave without their original documentation of qualifications. Article VII of the Lisbon Recognition Convention obliges its parties to take all reasonable and feasible steps - within and in line with their respective legal framework - to develop alternative ways of assessment of the qualifications of refugees in situations where no documentary evidence can prove such qualification. The ‘Recommendation on the Recognition of Refugees’ Qualifications under the Lisbon Recognition Convention and Explanatory Memorandum’ (13), gives further guidance how Member States should proceed in this situation to properly implement Article VII of the convention.

(20) Ukraine is one of the European Training Foundation’s longstanding partner countries. The European Training Foundation has created a resource hub (14) to support the recognition of qualifications, skills and studies from Ukraine. The resource hub will include information and documents such as reports and assessments on Ukrainian qualifications, information on the Ukrainian qualification system and framework, and information on the Ukrainian education and training system more widely. It will also contain labour market studies and analyses, project reports, contact points, and links to related websites such as qualifications databases. It will also share resources developed under the Erasmus+ Programme by the National Academic Recognition Information Centres (NARIC) like, for example, the Scand-D project with more than 300 Ukrainian diplomas featured. The resource hub will link to relevant databases and information on the Ukrainian higher education system and its academic qualifications, available on the Your Europe’s website (15) and on ENIC-NARIC network website (16).

(21) The eTranslation tool developed by the Commission has been adapted to add Ukrainian as an available language. Translation from Russian is also possible and can be useful, given that many professionals in Ukraine obtained their diplomas in Russian. The tool allows recognition of text in pictures or scans of documents (optical character recognition, OCR). This will enable competent authorities to save time and speed up processes.

(22) There is a high and increasing demand for healthcare professionals to meet the immediate needs of people fleeing Russia’s invasion of Ukraine. Skilled professionals with various backgrounds in healthcare could contribute to meeting these needs. Special emphasis needs to be put on paediatrics and related medical specialties due to the high number of children among the people fleeing Russia’s invasion of Ukraine, and on mental health services as people fleeing from war might suffer from severe traumatic experiences. The language barrier should not be an obstacle to treating those people as soon as possible to mitigate the damage. Where direct oral communication is crucial for trust-building and successful treatment, Ukrainian-speaking professionals could provide the necessary service.

(23) The Commission published a guidance note during the COVID-19 crisis covering the recognition of health professionals with qualifications from outside the EU/EFTA (17).

(24) Given the number of children that have fled Ukraine during the war, there is high demand for Ukrainian-speaking teachers who can help those children to be included in schools and have a stable routine as soon as possible. Experts have underlined how important a school routine is for children, as it can support them emotionally during an overwhelming and frightening time (18). It is crucial to ensure that governments and other authorities have the resources and capacity to provide both the displaced and local populations with access to full, equitable and quality education. This applies at all levels – early childhood education and care, primary, secondary, vocational, and higher education. Authorities should make the best use of teachers and other education personnel among the displaced to achieve this and to raise intercultural awareness within the hosting education system (19). Distance schooling can be explored where no options for in-classroom teaching are available. The Erasmus+ School Education Gateway provides access to supportive material, guidance documents and educational resources for teachers and other staff, also in Ukrainian language.

(25) A Commission Decision of 19 March 2007 set up the group of coordinators for the recognition of professional qualifications (20) to, among other things, establish cooperation between Member States’ authorities and the Commission on questions relating to the recognition of professional qualifications. Member States may have already developed extensive systems on how to assess and recognise non-EU qualifications. This group can serve as a forum for the Commission and Member States to maintain a continuous dialogue to monitor the effective implementation of this Recommendation. Involving representatives of people fleeing Russian aggression, Ukrainian competent authorities and civil society are crucial for the effective implementation of these recommendations.

(26) The Commission can provide Member States, upon their request, with tailor made expertise to implement these recommendations under its Technical Support Instrument.

HAS ADOPTED THIS RECOMMENDATION:

ORGANISING RECOGNITION OF PROFESSIONAL QUALIFICATIONS FOR PEOPLE ENJOYING TEMPORARY PROTECTION

1. The Commission encourages Member States to ensure that professionals enjoying temporary protection under Directive 2001/55/EC can access jobs that correspond to their qualification level by relying on an efficient, rapid and well-functioning system of recognition of their professional qualifications. In this context, Member States should take measures to estimate the expected number of incoming professionals to ensure they have sufficient capacity to process applications for recognition.

2. The Commission recommends Member States to issue swiftly their recognition decisions for incoming professionals enjoying temporary protection. If there are significant differences between the training acquired in a professional’s home country and the training required for the same activity in the host Member State, Member States should take the decision to impose any compensation measure as soon as possible, and are encouraged to do so no later than a month after the applicant asks for recognition.

3. The Commission recommends Member States to reduce the formalities for recognition of professional qualifications to a minimum. To this end, Member States are encouraged: — to speed up the process by putting in place fast-track procedures for handling applications of professionals enjoying temporary protection; — to ensure that only essential documents are required; — to accept other forms of proof than original documents (e.g. digital copies); — to dispense with certain requirements, e.g. not asking for certified translations; — to reduce or eliminate costs, such as application fees, where possible. In case of doubt about the authenticity of the qualification, verification should be quick and efficient. Digital tools like the FRAUDOC - Guidelines on Diploma Mills and Document Fraud for Credential Evaluators (21) may be used to that effect.

4. The Commission encourages Member States to apply a flexible approach to treating incoming professionals enjoying temporary protection to allow a high number of cases to be processed in a short time with a positive outcome. In particular, Member States should consider checking qualifications of professionals only if it is essential, and should remove any restrictions and requirements that are not absolutely needed. The Commission reminds host Member States that they are allowed, but not obliged, to check the qualifications of professionals for whom no harmonised minimum training requirements exist.

5. The Commission encourages Member States to identify situations in which an in-depth assessment of applications for recognition is not essential, especially in cases where the Member State has previously assessed the qualification for a particular profession and there are no serious doubts as to its equivalence with the comparable qualifications in the host Member State. If the outcome of such a previous assessment was favourable, the in-depth assessment should not be necessary.

6. The Commission urges Member States to ensure a fast and efficient recognition procedure even when an in-depth assessment of qualifications is needed. In such cases, the assessment of the host Member State could follow a similar approach to that of the general system of recognition under Directive 2005/36/EC.

FACILITATING ACADEMIC RECOGNITION FOR PEOPLE ENJOYING TEMPORARY PROTECTION

7. The Commission recommends Member States to promote fast, flexible, and efficient recognition procedures for academic recognition by responsible institutions.

8. The Commission recommends Member States to automatically recognise Ukrainian higher education qualifications that fulfil all the requirements from the Bologna Process.

9. The Commission recommends Member States to provide further support to the National Academic Recognition Information Centres (NARIC) to ensure that they have the necessary resources and capacities to deal with higher numbers of recognition requests and to enable them to provide support, guidance and training for credential evaluators.

10. The Commission recommends that, as far as possible and in line with national law, a recognition decision made in one Member State should be accepted in other Member States.

INFORMATION PROVISION AND USE OF ELECTRONIC TOOLS

11. The Commission recommends Member States to provide their front-line services with appropriate and simple information in Ukrainian on recognition procedures within their territory. The information should be also available digitally and tailored to the needs and situation of people arriving from Ukraine, explaining in particular differences between Ukraine and the host country.

12. The Commission encourages Member States to use the eTranslation ( 22 ) tool as a means to speed up recognition processes. Where feasible, machine translation should suffice.

13. The Commission encourages Member States to be transparent with each other and the Commission and to share all information on Ukrainian qualifications and the Ukrainian education system they might have. The European Training Foundation has, at the request of the Commission, created a resource hub on Ukrainian qualifications where information can be shared.

DEALING WITH INCOMPLETE EVIDENCE ON QUALIFICATIONS

14. The Commission encourages Member States, where evidence of qualifications is missing, to first check whether a reliable confirmation of the qualification achieved can be obtained from the Ukrainian authorities. To facilitate this process, the Commission will work with Member States in cooperation with Ukrainian authorities and awarding bodies to have missing documentation of qualifications confirmed and will explore whether the European Digital Credentials for Learning ( 23 ) can be used to re-issue documentation of qualifications digitally for that purpose.

15. The Commission reminds Member States that, if no other solution is possible, the ‘European Qualifications Passport for Refugees’ ( 24 ) developed by the Council of Europe together with partners, provides for an assessment of post-secondary qualifications based on available documentation and a structured interview. Although this qualification passport itself does not constitute a formal recognition act, it helps to assess the qualifications a refugee is likely to have, and it may also be applied to people enjoying temporary protection. Other tools such as the qualifications passport developed by UNESCO ( 25 ) and similar systems developed under the Erasmus+ Programme (for example the REACT – Refugees and Recognition toolkit) ( 26 ) could also be explored.

SPECIFIC REQUIREMENTS FOR CERTAIN PROFESSIONS

16. The Commission encourages Member States to explore how people enjoying temporary protection can, where appropriate, be employed in healthcare services, including by: — identifying good practices where non-EU nationals can participate in fast-track programmes within the area of healthcare professions to facilitate the exercise of those professions; — assessing the feasibility of extraterritorial healthcare facilities where healthcare staff enjoying temporary protection can treat people displaced from Ukraine (e.g. Ukrainian field hospitals operated on a Member State’s soil); — assessing Ukrainian training curricula for medical professions and, where feasible, developing short-duration up-skilling programmes to meet the minimum training standards required for certain professions.

17. For professionals with qualifications not meeting the minimum training requirements set out in Directive 2005/36/EC, the Commission encourages Member States to apply the same approach as in the guidance note for the COVID-19 crisis for the recognition of health professionals with qualifications from outside the EU/EFTA. Member States may still allow people enjoying temporary protection to perform certain activities, with a different status than that of a full member of the profession. For example, a third-country qualified nurse whose training does not meet the minimum training requirements may be allowed to work as a health care assistant.

18. The Commission invites Member States to explore different ways to ensure that access to the relevant sector of activity is ensured promptly for teachers and other education professionals, e.g. by: — employing people enjoying temporary protection who have acquired the professional qualification of teacher in Ukraine in schools where children fleeing Russia’s invasion of Ukraine have been placed; — providing language training to teaching professionals; — allocating Ukrainian-speaking teachers to schools with additional capacity and shortage of teachers; — changing the contracts of teachers with a professional qualification acquired in Ukraine, who have been temporarily hired as assistant teachers in host countries, to qualified teacher contracts quickly after the professional qualification has been recognised; — supporting student teachers enjoying temporary protection to access host countries’ teacher education and training.

19. The Commission invites Member States to facilitate the recruitment of educational staff enjoying temporary protection to work in structures which provide formal early childhood education and care, such as crèches and kindergartens, and in informal structures, such as play hubs, taking into account the wide diversity of these professions across Europe.

20. The Commission stresses that measures for facilitating the recruitment of educational and teaching professionals enjoying temporary protection shall take into account national provisions for the protection of children and youth.

FACILITATING THE EXERCISE OF REGULATED PROFESSIONS

21. The Commission encourages Member States to ensure that professionals can exercise their profession in order to access the labour market after obtaining recognition of their professional qualifications, without unnecessary administrative barriers and with the support they need.

22. The Commission recommends that Member States do not introduce or maintain any requirement for companies to prove that they could not hire an EU citizen before recruiting a person enjoying temporary protection.

23. The Commission recommends that Member States ensure that all relevant professional skills and competences of people enjoying temporary protection are assessed and taken into account, regardless of whether they have been acquired through formal, informal or non-formal learning. The Commission encourages Member States to support people in recording their skills and qualifications, including by the provision of one-to-one support. To facilitate such collection and assessment of skills and competences Europass ( 27 ) and the EU Skills Profile Tool for Third Country Nationals ( 28 ) can be used.

24. The Commission recommends that Member States put in place measures to facilitate the exercise of professions for people enjoying temporary protection who have no knowledge or limited knowledge of the language of the host country, such as language courses, or arrangements to practice their profession under supervision or in a setting where the language of the host country is not needed.

FOLLOW UP OF PROPOSED MEASURES

25. The Commission invites Member States to cooperate closely with Ukrainian authorities, representatives of Ukrainian civil society, including the Ukrainian diaspora, and the Commission to support practical solutions for recognition of qualifications and the smooth integration of people enjoying temporary protection into the labour market.

26. The Commission will initiate and coordinate dedicated meetings within the group of coordinators for the recognition of professional qualifications. This group will meet regularly to discuss and exchange national practices on this topic. The Commission will invite representatives of the relevant Ukrainian authorities to these meetings. Discussion and peer learning will also be initiated in other relevant structures, like in the European Education Area framework Working Groups and the Network of Academic Recognition Information Centres (ENIC-NARIC).

27. The Commission asks Member States to share their expertise in the dedicated ad hoc meetings, with a view to speeding up the process and avoiding duplications. Cooperation, best practices, and extensive information sharing is crucial at this stage.

Done at Brussels, 5 April 2022. For the Commission Thierry BRETON Member of the Commission

(1) Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, European solidarity with refugees and those fleeing war in Ukraine, COM(2022) 107 final.

(2) Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, Welcoming those fleeing war in Ukraine: Readying Europe to meet the needs, COM(2022) 131 final.

(3) Council Implementing Decision (EU) 2022/382 of 4 March 2022 establishing the existence of a mass influx of displaced persons from Ukraine within the meaning of Article 5 of Directive 2001/55/EC, and having the effect of introducing temporary protection (OJ L 71, 4.3.2022, p. 1).

(4) Council Directive 2001/55/EC of 20 July 2001 on minimum standards for giving temporary protection in the event of a mass influx of displaced persons and on measures promoting a balance of efforts between Member States in receiving such persons and bearing the consequences thereof (OJ L 212, 7.8.2001, p. 12).

(5) OECD (2019), Ready to Help?: Improving Resilience of Integration Systems for Refugees and other Vulnerable Migrants, OECD Publishing, Paris, https://doi.org/10.1787/9789264311312-en.

(6) Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, Action plan on Integration and Inclusion 2021-2027, COM(2020) 758 final.

(7) According to Article 3.1 (a) of Directive 2005/36/EC a ‘regulated profession’ is: 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; in particular, the use of a professional title limited by legislative, regulatory or administrative provisions to holders of a given professional qualification shall constitute a mode of pursuit.

(8) https://www.enic-naric.net/non-regulated-professions.aspx

(9) Shortages have been reported e.g. for plumbers, nursing professionals, welders, civil engineers, general medical practitioners, bricklayers, electricians, accountants and roofers. See European Labour Authority (2021), Report on Labour Shortages and Surpluses, November 2021, https://www.ela.europa.eu/sites/default/files/2021-12/2021%20Labour%20shortages%20%20surpluses%20report.pdf

(10) https://ec.europa.eu/info/strategy/priorities-2019-2024/stronger-europe-world/eu-solidarity-ukraine_en

(11) 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).

(12) https://www.coe.int/en/web/higher-education-and-research/lisbon-recognition-convention

(13) https://rm.coe.int/recommendation-on-recognition-of-qualifications-held-by-refugees-displ/16807688a8

(14) https://www.etf.europa.eu/en/education-and-work-information-ukrainians-and-eu-countries/education-and-work-eu-support-ukraine

(15) https://europa.eu/youreurope/citizens/work/professional-qualifications/index_en.htm

(16) https://www.enic-naric.net/ukraine.aspx?srcval=ukraine

(17) Communication from the Commission, Guidance on free movement of health professionals and minimum harmonisation of training in relation to COVID-19 emergency measures – recommendations regarding Directive 2005/36/EC (OJ C 156, 8.5.2020, p. 1).

(18) UNHCR (2011), Refugee Education: A Global Review, https://www.unhcr.org/4fe317589.pdf

(19) Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, Lives in Dignity: from Aid-dependence to Self-reliance – Forced Displacement and Development, COM(2016) 234 final.

(20) Commission Decision of 19 March 2007 setting up the group of coordinators for the recognition of professional qualifications (OJ L 79, 20.3.2007, p. 38).

(21) http://www.cimea.it/it/progetti-in-evidenza/fraudoc/fraudoc-project.aspx

(22) https://ec.europa.eu/info/resources-partners/machine-translation-public-administrations-etranslation_en

(23) https://europa.eu/europass/en/europass-digital-credentials. European Digital Credentials are carrying an electronic seal and thus fall under Article 35 of Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, p. 73). Thus, they should be accepted as evidence of qualification.

(24) https://www.coe.int/en/web/education/recognition-of-refugees-qualifications

(25) https://en.unesco.org/themes/education-emergencies/qualifications-passport

(26) https://www.nokut.no/globalassets/nokut/artikkelbibliotek/utenlandsk_utdanning/veiledere/toolkit_for_recognition_of_refugees_qualifications.pdf. See also the REACT project (REACT – Refugees and Recognition | Nokut).

(27) https://europa.eu/europass

(28) https://ec.europa.eu/migrantskills/