COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a Council Recommendation on the Validation of non-formal and informal learning
Date: 2012-09-05
Institutions: European Commission
Subjects: access to education, apprenticeship, continuing education, cooperation in the field of education, job mobility, learning technique, professional qualifications, unemployment

EUROPEAN COMMISSION 

Brussels, 5.9.2012  
SWD(2012) 253 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Council Recommendation 

on the Validation of non-formal and informal learning 

{COM(2012) 485 final} 
{SWD(2012) 252 final} 

EN 

   EN 

 
 
 
  
 
COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Council Recommendation 

on the Validation of non-formal and informal learning 

This impact assessment accompanies the proposal for a Recommendation of the Council on 
the validation of non-formal and informal learning. 

1. 

PROBLEM DEFINITION 

Rapid  economic  and  technological  changes  with  increasing  job  transitions  are  pushing 
individuals to acquire higher qualifications and more generic skills. In this context education, 
training  and  qualifications  systems  need  to  recognise  the  full  range  of  learning  experiences 
(formal,  non-formal,  informal)  through  a  learning  outcomes  approach.  This  can  be  done 
through the validation of non-formal and informal learning. This principle was adopted by the 
Recommendation  on  the  European  Qualification  Framework  (EQF)  of  2008  to  which  this 
initiative is complementary. 

Validation of non-formal and informal learning experiences has many benefits for: 

– 

– 

– 

Individuals:  enhanced  employability,  enhanced  career  prospects,  increased  wages, 
second  chances  for  school  dropouts,  improved  access  to  formal  education  and 
training, higher motivation to learn and increased self-confidence; 

The economy: a better skilled population, a better skills match on the labour market, 
transferability  of  skills  between  companies  and  sectors  and  more  mobility  on  the 
European  labour  market,  all  of  which  contribute  to  a  more  competitive  European 
economy and higher economic growth; 

The society at large: a better qualified population and workforce, a better access to 
further learning for disadvantaged groups and a more inclusive labour market.  

The impact assessment defined two main problems to be addressed: 

(1) 

Validation opportunities are limited and underused in the majority of Member States. 
According to the 2010 update of the European Inventory on validation of non-formal 
and informal learning, Cyprus Greece and Hungary offer hardly any possibilities for 
validating  non-formal  and  informal  learning.  Bulgaria,  Latvia,  Malta  and  Poland 
recently took steps towards the setting up of systems for the validation of non-formal 
and informal learning, but the validation system itself in these countries is still in its 
initial  stage.  In  Austria,  Belgium,  the  Czech  Republic,  Estonia,  Italy,  Ireland, 
Lithuania, Slovakia and Slovenia validation systems exist in one or more sectors, and 
are  only  used  by  small  numbers  of  individuals.  Also  in  countries  with  a  more 
developed  validation  system  such  as  Denmark,  Germany,  Luxembourg,  Romania, 

EN 

2 

   EN 

 
Spain, Sweden and the United Kingdom the take up rate of validation is still rather 
limited.  

The limited and underused validation opportunities make that skills remain invisible 
and are not used to their full potential for the benefit of individuals, the economy and 
the society at large.  

Three drivers for the limited availability and use of validation systems are the lack of 
trust  in  validation  systems,  processes  and  outcomes  (confirmed  by  the  public 
consultation held for the purpose of this initiative), the low awareness of validation 
possibilities in countries where validation opportunities exist (also confirmed by the 
public  consultation)  and  cultural  and  attitudinal  barriers  towards  validation  of  non-
formal and informal learning. The first two drivers are addressed by this initiative.  

(2) 

A  lack  of  comparability  and  coherence  between  the  validation  approaches  of 
Member  States.  The  current  uneven  availability  and  disparities  between  national 
validation  policies  and  practices  reduce  the  comparability  and  transparency  of 
validation systems. They make it difficult for citizens to combine learning outcomes 
acquired  in  different  settings,  on  different  levels  and  in  different  countries.  They 
create obstacles for the transnational mobility of learners and workers at times where 
such mobility is needed for creating more economic growth. 

The  Europe  2020  Strategy  on  smart,  inclusive  and  sustainable  growth  stresses  the  need  for 
more flexible learning pathways and sees validation of non-formal and informal learning as a 
pre-requisite for these. Validation will also contribute to achieving the EU headline targets as 
defined under Europe 2020 Strategy on early school leaving, on tertiary education attainment, 
on poverty reduction and on a high employment rate.  

2. 

ANALYSIS OF SUBSIDIARITY 

Articles 165 and 166 of the Treaty on the functioning of the European Union (TFEU) foresee 
that  the  Union  will  contribute  to  the  development  of  quality  education  and  implement  a 
vocational  training  policy  by  encouraging  co-operation  between  Member  States  and,  where 
necessary, supporting and supplementing their action, while fully respecting the responsibility 
of the Member  States for the content of teaching and the organisation of education systems 
and vocational training.  

The  current  initiative  recommends  lines  of  action  to  be  implemented  by  the  Member  States 
with  some  European  support.  It  proposes  actions  that  will  need  implementation  at  Member 
State  and  at  EU  level.  Member  States  will  remain  entirely  responsible  for  the  design, 
development  and  implementation  of  their  arrangements  (laws,  regulations,  collective 
agreements)  for  the  validation  of  non-formally  and  informally  acquired  learning  outcomes. 
The  EU  level  will  provide  coordination  –  including  in  particular  coordination  with  the 
relevant  European  instruments  –  and  support  by  organising,  for  instance,  peer  learning 
activities. Action on both levels is complementary and the prerogatives of Member States are 
safeguarded. 

3. 

OBJECTIVES OF THE INITIATIVE 

The general, specific and operational objectives of this initiative are the following: 

EN 

3 

   EN 

 
General objectives: 

(1) 

(2) 

To provide citizens in all Member States with the opportunity to validate their skills 
acquired outside formal education and training systems; 

To  provide  citizens  with  the  opportunity  of using  their  validated  skills  for  working 
and learning purposes throughout Europe. 

Specific objectives: 

(1) 

(2) 

To  put  in  place  systems  for  the  validation  of  non  formal  and  informal  learning  at 
national level linked to the National Qualifications Framework;  

To  establish  an  appropriate  level  of  comparability  and  coherence  between  national 
validation systems linked to the National Qualifications Framework. 

Operational objectives: 

(1) 

(2) 

(3) 

(4) 

To  promote  national  qualification  frameworks  in  a  way  that  qualifications  can  be 
acquired through formal programmes as well as through the validation of non-formal 
and informal learning; 

To  provide  mechanisms  for  the  identification,  documentation,  and  quality  assured 
assessment  and  validation  of  skills  acquired  through  non-formal  and  informal 
learning, taking advantage of common European instruments such Europass, ECTS, 
ECVET;  

To allow individuals to have their skills and competences identified and documented 
without resulting into a formal qualification; 

To  extend  and  intensify  the  cooperation  and  exchange  of  good  practice  between 
Member States, supported by peer-learning activities and European reporting tools; 

(5) 

To raise the awareness of validation opportunities. 

4. 

POLICY OPTIONS 

Option 1 (baseline scenario):  

This option consists of the continuation of the current situation which can be summarised as 
follows:  

– 

– 

– 

Validation  of  non-formal  and  informal  learning  is  taken  into  account  in  European 
policies  concerning  education  and 
training,  employment,  youth  and  active 
citizenship; 

Existing European instruments, in particular the EQF Recommendation, call for the 
possibility  to  validate  experiences  acquired  through  non-formal  and  informal 
learning, without indicating how to do it;  

The Common European principles on validation adopted by the Council in 2004, the 
European guidelines on validation by Cedefop, as well as available funding through 

EN 

4 

   EN 

 
the Lifelong Learning Programme, the future "Erasmus for All" Programme and the 
European  Social  Fund,  as  supporting  tools  for  validation  policy  and  practice  in  the 
Member States will continue to be relevant;  

– 

– 

Validation is part of the policy agenda in most Member States, but only implemented 
in a comprehensive way in a few Member States;  

Member  States  exchange  experiences  on  validation  under  the  Open  Method  of 
Coordination (in particular in the EQF Advisory Group).  

Option 2 (Council Recommendation on the implementation of validation):  

Option  2  proposes  political  and  practical  measures  to  Member  States,  stakeholders  and  the 
Commission  in  the  form  of  a  Council  Recommendation,  as  announced  by  the  Europe  2020 
flagship initiatives "Youth on the Move" and "Agenda for New Skills and Jobs". .  

The Recommendation invites Member States to put in place mechanisms for the validation of 
non-formal  and  informal  learning  linked  to  national  qualifications  frameworks.  These 
mechanisms  should  include  quality  assurance  mechanisms,  facilitate  the  portability  of 
learning  outcomes  by  using  standardised  documentation  tools,  raise  awareness  of  validation 
opportunities,  facilitate  access  to  validation  in  particular  for  disadvantaged  groups,  ensure 
appropriate  guidance  to  individuals  and  finally  provide  the  opportunity  to  individuals  to 
undergo a skills audit within three months of an identified need.  

The Recommendation stresses the need to involve labour market stakeholders (e.g. to record 
learning  outcomes  acquired  in  the  workplace),  as  well  as  education  and  training  providers 
(e.g.  to  provide  opportunities  to  gain  access  to  formal  education  and  training)  and  the  third 
sector (e.g. NGO/volunteer organisations). 

The Recommendation will be complemented by more intensive cooperation on the validation 
of  non-formal  and  informal  learning  within  the  existing  EQF  Advisory  Group  as  Open 
Method of Coordination structure. The Recommendation invites the Commission to regularly 
update the European Inventory and the European Guidelines on the validation of non formal 
and  informal  learning  and  to  support  the  implementation  of  the  Recommendation  by 
organising effective peer learning activities. 

The Council Recommendation is expected to be approved in 2012, with an implementation of 
the  proposed  mechanisms  by  the  Member  States  and  the  European  Commission  from  2013 
onwards. 

Option  3  (A  new  Open  Method  of  Coordination  devoted  to  validation  aimed  at  the 
development of a European Quality Charter on validation): 

Under Option 3 Member States will work together, in a new Open Method of Coordination 
(OMC)  specifically  devoted  to  validation,  aiming  at  the  setting  up  of  a  European  Quality 
Charter on the validation of non-formal and informal learning.  

The European Quality Charter will be formulated around the following lines: quality ensured 
validation  procedures,  quality  standards  for  assessors,  guidance  and  counselling,  access  to 
validation,  stakeholder  involvement,  specific  target  groups  and  the  European  dimension  of 
validation.  

EN 

5 

   EN 

 
The European Quality Charter will build on both European (e.g. European guidelines and the 
common  European  principles  on  validation)  and  on  national  initiatives  (public  and  private) 
related  to  quality  assurance  in  the  area  of  validation.  A  European  Quality  Charter  will 
contribute to building trust and confidence between Member States.  

The new OMC process will consist of a new set of reporting mechanisms by Member States 
and monitoring of progress by the Commission. Dedicated OMC mechanisms are expected to 
be in place in 2012, leading to the approval of the Charter in 2014. Its implementation will 
follow from 2015 onwards.  

5. 

ASSESSMENT OF IMPACTS 

Appropriate  action  by  the  Member  States,  through  the  creation  of  more  validation 
opportunities, allowing for the use of available knowledge, skills and competences to their full 
potential,  will  have  significant  economic  and  social  impacts.  There  will  only  be  limited 
environmental impacts.  

The  social,  economic  and  other  impacts  have  been  examined  in  qualitative  terms  based  on 
likely impacts, as there are no hard data available. For each of the likely impacts a comparison 
with the baseline scenario has been made.  

The  most  important  economic  and  social  impacts  of  setting  up  comprehensive  validation 
systems are: 

– 

– 

– 

– 

– 

– 

– 

– 

A positive contribution to economic growth and employment through a better use of 
available skills in the labour market and through more skills development; 

A better access to the labour market and easier job transitions, through the inclusion 
of all available skills in recruitment decisions and for occupational changes; 

A  better  access  to  further  learning  through  a  better  recognition  of  prior  learning 
experiences by education and training institutions; 

Better  information  on  available  skills  which  become  more  visible  thanks  to  more 
validation opportunities; 

A  higher  education  level  of  workers  (both  through  the  validation  of  existing  skills 
and through a better access to further learning); 

Potentially better working conditions for individuals thanks to higher qualifications; 

Improved equality and social inclusion by creating more opportunities for validation 
of non-formal and informal learning for disadvantaged groups; 

A higher mobility of workers across Europe, beneficial for economic growth. 

The  realisation  of  the  expected  impacts  will  depend  on  a  number  of  factors  such  as  the 
concrete implementation by Member States of the recommended measures (Option 2) and the 
way  in  which  Member  States  will  effectively  work  towards  a  European  Quality  Charter  on 
validation  (Option  3).  It  has  been  assumed  that  the  set  of  recommendations  addressed  to 
Member States under Option 2 will have more immediate effects on the creation of validation 

EN 

6 

   EN 

 
opportunities  than  the  newly  created  OMC  under  Option  3  which  does  not  include  a  set  of 
recommendations to Member States.  

Ongoing developments of National Qualification Frameworks will benefit from the measures 
proposed  under  Option  2  which  will  be  able  to  deliver  concrete  outcomes  already  in  2013. 
Immediate effects are also relevant for reaching the Europe 2020 targets in time and therefore 
expected immediate impacts received higher scores than impacts expected in the longer term.  

The real costs of putting in place validation mechanisms depend on a number of factors such 
as  the  readiness  of  the  current  system  (existing  infrastructure:  institutions,  assessment  and 
certification  procedures  and  standards),  the  scale  of  validation  arrangements  (focus  on  all 
occupations  or  on  specific  occupations),  and  the  target  groups  of  validation  (all  citizens  or 
specific target groups).  

On the basis of available evidence, the full costs for a validation procedure leading to a full or 
partial qualification vary from 800 to 1,800 EUR depending on the country and the type and 
level of qualification. Investment in validation of non-formal and informal learning leads to 
cost savings on formal education and training for individuals who will obtain a qualification 
on the basis of their learning obtained through non-formal and informal learning, without the 
need for further formal education and/or training.  

The  resulting  net  costs  of  validation  have  to  be  weighted  against  the  benefits  of  validation. 
The impact assessment assumed that in all three options the aggregate benefits of validation 
altogether  outweigh  the  net  costs  of  validation  in  terms  of  e.g.  improved  employability, 
enhanced  career  prospects,  improved  skill  matching,  more  economic  growth,  better  social 
inclusion.  

6. 

COMPARISON OF OPTIONS 

Option 2, a Council Recommendation on the implementation of validation, results as the most 
effective and efficient  option. Option 2 is also the most  coherent  with EU policy objectives 
and with the largest positive economic and social impacts.  

Under  Option  1,  the  current  situation  of  validation  is  expected  to  change  only  slowly, 
implying  that  the  limited  availability  and  use  of  validation  of  non-formal  and  informal 
learning experiences, as well as the lack of a comparable and coherent approach in validation 
across Europe, will remain. 

Option 3 (a new OMC) is expected to lead to improvements compared to the baseline scenario 
regarding  impacts  effectiveness,  efficiency  and  coherence  with  wider  EU  policy  objectives. 
However  the  setting  up  a  new  OMC  creates  additional  structures  and  additional  reporting 
mechanisms, increasing the administrative burden and costs for the Member States. Moreover 
due to its exclusive reliance on the OMC method there is more uncertainty as to the concrete 
action is taken by and in the Member States as well as to the timeframe of such measures. 

Apart  from  impacts,  effectiveness,  efficiency  and  coherence  with  EU  policy  objectives,  the 
main assets of Option 2 are: 

– 

It will fill the "validation gap" which currently exists within the available European 
tools  and  instruments  such  as  the  EQF,  Europass  and  credit  systems.  It  will  in 
particular  fill  the  missing  link  in  the  European  Qualification  Framework  which 

EN 

7 

   EN 

 
provides  for  the  promotion  of  validation  of  non-formal  and  informal  learning, 
without further guidance on its implementation;  

It  proposes  concrete  practical  measures  for  implementation  of  validation  in  the 
Member States; 

A  Council  Recommendation,  as  legal  instrument,  signals  the  commitment  of 
Member  States  towards  the  measures  indicated,  most  of  which  will  require 
implementation at national level and adapted to the national context; 

involves 

It  explicitly 
stakeholders 
youth/voluntary  organisations,  education  and 
development of validation systems; 

relevant 

(labour  market 
training 

institutions) 

stakeholders, 
the 
in 

Member  States  will  continue  to  cooperate  within  existing  OMC  structures,  in 
particular  the  EQF  Advisory  group,  representing  a  more  simple  implementation 
structure than foreseen under Option 3;  

It  will  form  a  new  and  stronger  political  base  for  cooperation  in  the  field  of 
validation of non-formal and informal learning. 

– 

– 

– 

– 

– 

7. 

MONITORING AND EVALUATION 

Under the initiative monitoring will take place on the basis of the use of existing tools. This 
will limit its costs for monitoring as well as the administrative burden to the Member States. 

The  European  Inventory  on  Validation,  under  the  responsibility  of  the  Commission  and  of 
Cedefop,  will  be  further  consolidated  and  strengthened  in  view  of  the  monitoring  the 
implementation of the Council Recommendation by the Member States. 

The  annual  Cedefop  report  on  the  development  of  national  qualifications  frameworks  in 
Europe  will  be  used  for  assessing  the  progress  achieved  by  Member  States  in  creating 
validation of non-formal and informal learning as a pathway to obtain a qualification. 

Member  States  will  report  on  their  implementation  of  the  Recommendation  through  their 
national  progress  reports  already  planned  in  the  context  of  the  Education  and  Training 
Strategic Framework 2020 (next reporting year: 2014). 

Finally the initiative foresees to strengthen peer learning, involving governmental actors and 
stakeholders, focussed on the exchange of experiences and demonstrations of good practice. 
Given the close relationship between the initiative and the Recommendation on the European 
Qualifications  Framework, the EQF  Advisory  Group  is  the  most  appropriate  body  for  those 
activities  

An external evaluation of the Recommendation's implementation is planned within four years 
after its adoption. 

EN 

8 

   EN