REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional qualifications
Date: 2026-02-20
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: administrative cooperation, digitisation, free movement of workers, freedom to provide services, labour shortage, mutual recognition principle, professional qualifications, recognition of diplomas, recognition of vocational training qualifications, single market

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.2.2026  COM(2026) 86 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional qualifications  {SWD(2026) 64 final}  
 
 
TABLE OF CONTENTS 

1. 

2. 

3. 

Policy context: labour and skills mobility in a context of shortages .................................................... 4 

The Professional Qualifications Directive provides crucial support to mobility in the Single Market ............. 5 

Overall user experience ......................................................................................................... 9 

3.1. 

3.2. 

Availability and exchange of information ........................................................................... 9 

Recognition systems .................................................................................................. 10 

3.2.1. 

The general system of recognition ............................................................................. 10 

3.2.2. 

Automatic recognition based on professional experience .................................................. 11 

3.2.3.      Automatic recognition based on minimum training requirements ........................................ 12 

4.  Mutual trust and administrative cooperation are essential to the functioning of the regulatory framework . 15 

4.1. 

4.2. 

4.3. 

Notifications ............................................................................................................ 15 

The alert mechanism .................................................................................................. 16 

Updates to the automatic recognition system based on minimum training requirements .............. 17 

5. 

6. 

Digitalisation .................................................................................................................... 19 

Conclusions ...................................................................................................................... 20 

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The  effective  functioning  of  the  single  market  depends  on  the  freedom  of  qualified 
professionals across all sectors and competence levels to move and work wherever their skills 
are  needed.  European competitiveness relies on the strength and completeness of the  single market, 
which  remains  the  EU’s  core  economic  engine.  However,  a  truly  integrated  market  cannot  function 
effectively without enabling mobility of people and the free circulation of skills. This is why, in the context 
of her Political Guidelines, President von der Leyen has announced that the Commission will put forward 
a skills portability initiative to ensure that a skill acquired in one country is recognised in another. The 2025 
single market strategy also emphasises the importance of professional mobility and identifies recognition 
of professional qualifications as one of the most significant barriers to the free movement of services and 
workers across the EU.  The capacity of professionals to move and have their qualifications recognised 
across borders is essential for them to thrive, for firms to access the talent they need, for innovation to 
spread, and for productivity to increase.  

Formal recognition of qualifications by the competent authorities of a Member State is only 
needed where access to the profession is regulated1 in that country. Regulation of professions 
remains the competence of the Member States’ competence in compliance with within the limits of EU 
law, including the principles of non-discrimination and proportionality. At present, over 5 700 professions 
are regulated in the  EU  Member States2, with considerable  variations between them. According to the 
latest  available  estimates,  approximately  22%  of  those  employed  in  the  EU  work  in  a  regulated 
profession3. Justified and proportionate regulation may play an important role in protecting public policy 
objectives,  protecting  consumers  and  ensuring  the  safety  of  the  public,  and  in  protecting  consumer 
protection, public security and the protection of health and the environment. Nevertheless, diverging access 
requirements to regulated professions across the EU can limit professional mobility across borders.  

The  Professional  Qualifications  Directive4  continues  to  play  a  decisive  role  in  making  that 
mobility a reality, both for workers and the self-employed, while safeguarding general interest 
objectives such as service quality and public safety. It sets out procedural rules on the recognition 
of  professional  qualifications  across  Member  States5,  enabling  professionals  to  access  and  pursue 
regulated professions in another Member State, either on a permanent or temporary and occasional basis. 
The steady flow of recognition decisions following the rules set out in the Directive confirms its support to 
professional mobility. Many of the recognition decisions concern shortage occupations in essential sectors 
marked by high demand for skilled labour like healthcare and education. Without the Directive, general 

1 In the meaning of Article 3(1)(a) of Directive 2005/36/EC, as amended. 
2 Regulated Professions Database. 
3  See  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions on reform recommendations in professional services (COM (2016) 820 final).  
4 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional 
qualifications  (hereafter:  the  Directive)  was  adopted  to  consolidate  several  earlier  instruments  covering  the  recognition  of 
professional  qualifications  across  the  EU.  Following  its  transposition  into  national  law  by  October  2007,  the  Directive  has 
undergone several important amendments to modernise and adapt it to evolving professional and regulatory contexts. The 
most significant reform was adopted in 2013 and implemented by 2016, introducing the European Professional Card, an alert 
mechanism, a streamlined recognition procedure and the possibility of partial access for cross-border professionals. This revision 
also empowered the Commission to adopt delegated and implementing acts which adds flexibility to the system. Subsequent 
delegated and implementing acts ensured regular updates of the Directive, contributing to maintaining trust in the system and 
free movement within the EU’s single market while safeguarding service quality and public safety. 
5 The rules under Directive 2005/36/EC, as amended, with very limited adaptations, also apply to Iceland, Liechtenstein and 
Norway  through  the  Agreement  on  the  European  Economic  Area.  Certain  rules  under  Directive  2005/36/EC  also  apply  to 
Switzerland through the EU-Swiss Agreement on Free Movement of Persons. This report covers specifically the implementation 
of the Directive in the EU Member States. 

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care nurses,  medical doctors,  teachers,  architects, electricians, plumbers and many more professionals 
wanting to have their qualifications recognised in another Member State would face increased complexity 
and have to navigate different national recognition rules and procedures. By providing a legally binding, 
harmonised framework that regulates recognition processes throughout the EU, the Directive offers easier 
access  to  the  benefits  of  the  single  market  to  regulated    professions  and  vocational  trades  that  are 
essential to the EU’s competitiveness.  

However, the experience of professionals navigating the existing regulatory framework reveals 
that recognition can often remain 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. Stakeholders welcome 
the  Directive’s  achievements  but  call  for  a  renewed  focus  on  simplification,  transparency,  and  digital 
transformation to meet the needs of today’s mobile workforce. In its 2024 special report on the recognition 
of professional qualifications in the EU, the European Court of Auditors also noted that the application of 
the Directive by the Member States had shortcomings, including the lack of electronic procedures, gaps 
and  inconsistencies  in  the  information  provided  to  the  public,  costly  and  cumbersome  processes  and 
deficiencies in the use of the alert mechanism intended to help ensure patient and consumer safety.  

This report assesses the implementation of the Directive. It fulfils an obligation set in Article 60(2) 
of the Directive which requires the Commission to publish a report on the implementation of the Directive 
every five years.6 The present implementation report, which focuses on the period 2020-20247, aims to 
identify gaps, issues and challenges related to the Directive’s implementation in the current policy context. 
More specifically, the report looks at how the Directive facilitates the mobility of professionals in the single 
market (Section 2) and potential improvements to the overall user experience under the various recognition 
regimes (Section 3). It also analyses how the legal framework fosters trust and administrative cooperation 
between the relevant authorities in the Member States (Section 4) and the to what extent digital tools are 
used in support of procedural aspects of the framework (Section 5). The report draws on desk research 
and  extensive  stakeholder  consultations,  involving  members  of  the  Group  of  Coordinators  for  the 
recognition  of  professional  qualifications8  as  well  as  competent  authorities,  regulators,  professional 
associations, civil society, social partners and citizens.9  

6 Some data covers the period 2018-2023 for the following reasons. Firstly, to give a better comparison with previous years as 
there was a decrease in the number of recognition decisions in the COVID-19 period. Second, data on recognition decisions for 
the year 2024 is not yet fully available since Member States are obliged to notify such statistics to the Commission on an 
annual basis and often do so towards the second half of the following year as they first need to collect them from the competent 
authorities. 
7 The latest implementation report was published by the Commission on 11 May 2020, together with an accompanying staff 
working document. That implementation report covered a period of five years (2014-2019) and focused on the new elements  
under  Directive  2013/55/EU,  including  the  European  Professional  Card,  the  modernisation  of  the  knowledge,  skills  and 
competences for the sectoral professions, the common training principles and the special upgrading programme for Romanian 
nurses. The 2020 implementation report concluded that the legal framework under the Professional Qualifications Directive 
effectively facilitated the mobility of professionals across the Member States and that implementation had improved due to 
the enforcement actions taken by the Commission. However, the report also pointed out several areas for concern, including 
procedural requirements that imposed significant administrative and financial burden on applicants, and shortcomings in the 
operation of the national points of single contact and the alert mechanism.   
8 The Group of Coordinators for the recognition of professional qualifications (GoC) was created by the Commission Decision of 
19 March 2007 (2007/172/EC) to promote a uniform application of the Directive and to collect all the information which is 
relevant for its application. The group is comprised of national coordinators designated by the Member States.   
9 See the staff working document accompanying this report for more details about the consultation strategy and the various 
sets of questions raised with the different stakeholder groups.  

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1.  Policy context: labour and skills mobility in a context of shortages  

Following the COVID-19 pandemic, the EU labour market quickly bounced back and surpassed 
its  pre-pandemic  performance,  resulting  in  record  low  unemployment  rates.  The  gradual 
slowdown in employment growth that started in 2022 continued in the first half of 2025, but the EU 
currently  remains  on  track  to  meet  its  headline  employment  target  of  78%  by  2030.10  With  minor 
fluctuations, labour market slack of the extended workforce in the EU has been decreasing steadily from 
18.6% in 2015 to the record low level of 10.9% in Q2 2025.11  

Meanwhile, labour and skills shortages remain a significant and persistent challenge across 
the EU. Despite a decrease from their peak in 2022, they are still high by historical standards and continue 
to  undermine  the  EU’s  competitiveness  in  the  global  economy.12  Shortages  affect  small  and  medium 
enterprises  (SMEs)  in  particular.  They  are  especially  acute  in  administrative  and  support  services; 
professional, scientific and technical activities; transport; accommodation and food services; construction; 
and  information  and  communication.  As  regards  occupations,  most  countries  classify  the  following 
occupations as facing critical shortages: information and communications technology (ICT), healthcare and 
transport (e.g. professional drivers). Structural factors, such as demographic change and skills demands 
from the  digital and  green transition, as  well as poor working conditions in some sectors are likely  to 
sustain shortages in the foreseeable future. As digitalisation and the uptake of artificial intelligence (AI)  
accelerate, many jobs will require new, adapted or enhanced skill sets, which may exacerbate existing 
shortages if the supply of appropriately trained professionals  lags.  

At the same time overqualification remains a persistent structural feature of the EU labour 
market. While tertiary education levels have been steadily increasing across the EU, many professionals 
do not make the best possible use of the skills they have, in particular when moving across borders.13 
These points towards skills being underused and inefficiencies in the labour force allocation.  

Against  this  background,  the  Union  of  Skills14,  adopted  by  the  Commission  in  March  2025,  
represents  a  comprehensive  and  coordinated  strategy  to  strengthen  EU  competitiveness  by 
developing and making the best possible use of the EU’s human capital and by attracting and 
retaining talent, including from non-EU countries. The strategy aims at building skills for quality jobs 
and lives, including through a strong educational foundation which addresses labour market needs. It brings 
together  education,  training,  employment,  migration,  and  industrial  policies  to  boost  upskilling  and 
reskilling at all  levels and across  all sectors, to foster lifelong learning  and to tackle labour and skills 
shortages across Member States. In the same context, the Commission first-ever proposal for a Council 
Recommendation on human capital as part of the European Semester calls for urgent action to tackle 
human capital- related structural challenges that can damage the EU’s competitiveness. To address such 
labour and skills shortages, the Commission is also working on specific initiatives for attracting talent from 
abroad,  including  the  EU  Talent  Pool,  the  first  EU-wide  platform  aimed  at  facilitating  international 
recruitment and providing opportunities for jobseekers from third countries that are interested and have 
the skills required to work in EU-wide shortage occupations. In the context of the EU Visa Policy Strategy, 

10 Proposal for a Joint Employment Report 2026.  
11 European Economic Forecast. Autumn 2025. 
12 Proposal for a Joint Employment Report 2026. 
13 In 2024, the overqualification rate of people born in another Member State stood at 30.3% compared to 20.2% of those born 
in the country of work. Source: Eurostat, Migrant integration Statistics.  
14 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 on the Union of Skills, COM (2025) 90 final.  

4 

 
 
 
the Commission also presented a Commission Recommendation on attracting talent from abroad, focused 
on students, researchers, highly skilled workers, innovative entrepreneurs and start-up founders.  

Skills portability also plays a central role in the Union of Skills. By enabling workers’ abilities and 
qualifications to be recognised and valued across borders, sectors and learning systems, it ensures that 
individuals can move freely within the single market without  their skills losing value. This supports labour 
mobility, improves skills allocation and helps to alleviate regional and sectoral skill mismatches. 

The Directive is a crucial instrument in the EU’s policy toolbox to facilitate mobility for access 
to regulated professions within the single market. The Proportionality Test Directive (EU) 2018/958 
acts as a preventative gatekeeper, requiring Member States to carry out a proportionality test before the 
adoption of any new and before amending the existing professional regulations to ensure that they are 
non-discriminatory, necessary and proportionate to the objectives pursued.  The Professional Qualifications 
Directive, in turn, provides  a comprehensive regulatory framework governing the mutual recognition of 
professional qualifications across Member States whenever specific qualifications are required by law for 
practising  professional  activities.  More  specifically,  the  Directive  establishes  automatic  recognition  for 
certain  sectoral  professions  with  harmonised  minimum  training  requirements  and,  for  some  types  of 
economic activity in trade and commerce, based on professional experience, as well as clear rules on the 
assessment and the recognition of professional qualifications obtained in other EU countries for access to 
any  regulated  profession.  The  Directive  also  imposes  procedural  deadlines  and  promotes  cooperation 
between  national  contact  points  and  competent  authorities  in  the  Member  States.  Together,  these 
mechanisms aim at ensuring fair, consistent and timely recognition of professional qualifications across 
the EU.  

To allow workers and businesses to fully exploit the potential of professional mobility in the 
single  market,  the  Commission’s  Union  of  Skills  Communication  has  announced  a  skills 
portability initiative. This will be part of a broader fair labour mobility package to be adopted in 2026, 
which aims at facilitating the exercise of the right of free movement of workers and services. This package 
will  also  include  proposals  for  a  European  Social  Security  Pass,  a  stronger  mandate  for  the  European 
Labour  Authority  and  measures  to  address  the further  modernisation  and  simplification  and  better 
implementation  of  the  labour  mobility  rules  and  practices,  as  also  recommended  by  stakeholders 
participating in the recent Implementation Dialogue with Executive Vice-President Mînzatu on fair labour 
mobility. This report on the implementation of the Directive contributes to informing the skills portability 
initiative by assessing the overall functioning of the regulatory framework applicable to the recognition of 
professional qualifications in the context of regulated professions and by identifying key implementation 
gaps and potential areas for further improvement.  

2.  The Professional Qualifications Directive provides crucial support to mobility in the Single Market  

The Directive constitutes an essential pillar of the functioning of the single market. It provides 
professionals  who  have  acquired  their  professional  qualifications  in  a  Member  State  with  procedures 
ensuring that they may obtain recognition of their qualifications and thereby that they may access and 
pursue the same regulated profession in another Member State under the same conditions as nationals.  

Broadly  speaking,  the  Directive  provides  for  three  main  recognition  systems  In  addition  to 
automatic recognition for sectoral professions based on minimum training requirements, there is automatic 
recognition based on professional experience for certain professions in the crafts, commerce and industry 

5 

 
 
sectors and the so-called general system of recognition for all other regulated professions with limited 
exceptions. The rules and procedures applicable in each of these three systems differ. 

Evidence  shows  that  the  Directive  facilitates  the  mobility  of  professionals,  both  for  the 
establishment and for the temporary and occasional provision of services.15 Its main elements 
remain relevant in the current socio-economic environment, as confirmed by stakeholders. Between 2020 
and 2024, despite the mobility restrictions imposed by COVID-19 pandemic, around 185 000 decisions 
were  taken  by  EU  Member  States  on  recognition  of  professional  qualifications  for  the  purpose  of 
establishment.16 More than 83% of these decisions were positive,17 and more than 140 000 concerned 
professions  in  essential  sectors  such  as  education  and  health.  Over  the  same  period,  around  40  000 
professionals submitted declarations to provide services on a temporary and occasional basis in another 
EU  Member  State.  In  only  around  5%  of  these  cases  were  providers  not  allowed  to  provide  services,  
because of health and safety reasons. 

Ten most mobile professions - Establishment  (2020-2024)

Number of recognition decisions

32257

27263

22739

1358712752

9115

7209

5487

3684 2972

35000

30000

25000

20000

15000

10000

5000

0

Source: Regulated Profession Database

15  Free  movement  of  services  covers  two  fundamental  freedoms  enshrined  in  the  TFEU  provisions  (Articles  49  and  56). 
Establishment refers to a professional moving to another Member State to practice on a permanent or stable basis, which 
requires a formal recognition of their qualifications by the host country in order to practice under the host country professional 
title. In contrast, temporary service provision applies when a professional already established in his home country provides 
temporary  services  in  another  state  on  an  occasional  or  time-bound  basis  under  his  home  professional  title.   In  case  of 
temporary service provision, the professional has only to submit a yearly prior declaration and does not have to apply for a 
prior recognition of their professional qualification except for professions having public health and safety implications.  
16 The figure was 230.000 for the period 2016-2019. The Regulated Professions Database provides more detailed statistical 
breakdowns by country, period, recognition system and generic names of professions. It can be accessed via the following link.: 
Regulated Profession Database 
17 Positive decisions are calculated as a percentage of the sum of positive decisions, negative decisions, decisions imposing an 
adaptation period and decisions under appeal.  

6 

 
 
 
 
Ten most mobile professions - Temporary mobility (2020-2024)

Number of declarations

7141

3374

2862 2623

1623

1076 1072 995

936

875

8000

7000

6000

5000

4000

3000

2000

1000

0

Source: Regulated Profession Database

The professions benefitting from automatic recognition —whether based on minimum training 
requirements  or  professional  experience—  are  among  those  where  severe  shortages  are 
reported. According to the latest European Employment Services (EURES) report on labour shortages and 
surpluses18, nursing professionals, generalist and specialist medical practitioners, pharmacists and dentists 
are ranked among the most widespread shortage occupations by number of countries and prevalence of 
high  severity.  In  the  context  of  the  Directive,  general  care  nurses,  basic  medical  training  and  general 
practitioner training as well as 56 specialist doctors’ qualifications are covered by the automatic recognition 
regime  based  on  minimum  training  requirements.  The  same  applies  to  the  basic  and  specialist 
qualifications  of  dentists  and  pharmacists.  The  most  widespread  shortage  occupations  in  the  EU  also 
include many of the commercial, craft and industry professions subject to automatic recognition based on 
professional  experience  such  as  metal  workers,  construction  workers,  engineers  and  engineering 
technicians.  This  illustrates  how  the  current  rules framework  already  uses  the  possibility  of  automatic 
recognition to promote mobility precisely where it is most needed.   

Stakeholders expressed overall satisfaction with the main elements of the Directive. Generally 
speaking, mobile citizens and businesses appreciate that setting common rules reduces uncertainty for 
professionals seeking to work in another Member State and provides a structured process for recognition. 
While stakeholders raise issues that may, in certain cases, prevent the Directive’s full potential from being 
realised and underline the need for improvements, they do not question its necessity, relevance, or benefits. 
They nevertheless call for fewer barriers to mobility and simpler recognition procedures, including through 
the use of digital tools, which is fully in line with the objectives of the Directive and its implementation.19 

18 EURES Report on Labour shortages and surpluses 2024. 
19 Chapter 10 of the staff working document provides more insights in the views of the various stakeholders concerned by the 
Directive, highlighting in particular the areas in which they see further room for improvement. 

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The  Commission  continued  to  implement  and  enforce  the  Directive  in  2020-2025.  Given  the 
importance of uniform application, many Member States20 have faced new infringement procedures in this 
period because of non-compliance with various aspects of the Directive. This included a batch of 22 cases 
related  to  incorrect  implementation  of  Article  7(4)  of  Directive  2005/36/EC  with  prior  checks  of 
professional  qualifications  imposed  for  occasional  and  temporary  service  provision  for  professions  not 
falling  under  its  scope.  As  emphasised  in  the  2025  Annual  Progress  Report  on  Simplification, 
Implementation  and  Enforcement  of  Executive  Vice-President  Mînzatu,  these  enforcement  actions  are 
central to removing disproportionate administrative barriers and directly support the Commission’s broader 
objective  of  enhancing  professional  mobility  and  ensuring  coherent  implementation  of  EU  law  across 
Member States.21  

The Commission also continued its infringement actions concerning incorrect transposition of 
various aspects of the amended Directive that were started in two batches in 2018 and 2019 
respectively. The first set of infringement procedures, launched in 2018, related to incorrect transposition 
covering new  issues  crucial to the functioning of the revised Directive,  in particular the new European 
Professional Card, the alert mechanism, partial access to a professional activity, the proportionality of 
language requirements and the setting up of assistance centres. In addition, the Commission raised issues 
relating to the transparency and proportionality of regulatory obstacles in professional services following 
the  Reform  Recommendations  on  professional  services.22  The  second  set  of  infringement  procedures, 
launched in 2019, concerned compliance with the rules on freedom of establishment, freedom to provide 
services,  professions  benefiting  from  automatic  recognition  based  on  harmonised  minimum  training 
requirements, documentation and formalities, recognition of professional traineeships and administrative 
cooperation. Although this enforcement work focused on the main changes introduced by the amending 
Directive 2013/55/EU23, it also addressed overall implementation of the revised Directive in the national 
legal frameworks.   

Most non-compliance issues raised by the Commission relating to the Directive’s transposition 
in the Member States’ national legal frameworks have already been addressed.  In the period 
2020-2024, the number of unresolved infringement procedures open in 2018-2019 has decreased: three 
procedures were closed in 2020, four in 2021, nine in 2023, and two more in 2024. In 2025, eight Member 
States24 continued to face active procedures. Two of the infringement cases resulted in judgements of the 
European Union Court of Justice.25  

20  The  European  Commission  opened  30  new  infringement  procedures  in  this  period:  22  cases  on  issues  relating  to 
misapplication of Article 7(4) of Directive 2005/36/EC against AT, BE, BG, CY, CZ, DE, DK, EL, ES, FI, FR, HU, IE, IT, LU, LV, MT, NL, 
PL, RO, SE and SI; and 8 cases  covering various issues under Directive 2005/36/EC: two cases against EL and the remaining 6 
cases were open against BE, CY, DE, ES, IE and MT. 
21  2025  Annual  Progress  Report  on  Simplification,  Implementation  and  Enforcement  by  Executive  Vice-President  Mînzatu, 
September 2025. 
22 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee 
and the Committee of the Regions on reform recommendations for regulation in professional services, COM(2016) 820 final.  
23 The  amending Directive 2013/55/EU introduced  several major changes  to  the Directive, including  the introduction  of  the 
European Professional Car, the alert mechanism, the use of the Internal Market Information System (IMI) and the concept of 
partial access.  
24 Currently, from the first batch of cases the procedures are still formally opened against BE, DE, EL, HR, and SK (two of them 
are in the process of being closed) and from the second batch, against BE, CZ (court ruling), DE, ES, SK (court ruling). 
25  Details  about  the  enforcement  of  the  Directive  in  the  assessed  period  can  be  found  in  Chapter  9  of  the  staff  working 
document.  

8 

 
 
 
3.  Overall user experience  

3.1. 

Availability and exchange of information 

The functioning of the system for the recognition of professional qualifications within the EU 
relies on the accessibility of pertinent information. Information exchange between Member States 
is  essential  to  support  administrative  cooperation.  Ensuring  that  information  on  national  regulation  of 
professions, professional education and training, evidence of professional qualifications required for access 
to  the  given  profession,  contact  data  of  competent  authorities,  conduct  and  experience  is  clearly 
understood and effectively disseminated is also crucial to allow citizens to benefit from the rights conferred 
on them by the Directive and by national implementation frameworks.  

The Directive lays down several measures to ensure that stakeholders are well-informed and 
can easily access pertinent information concerning recognition of professional qualifications. 
One of the key measures is the establishment of national assistance centres26, which serve as primary 
contact points for professionals and competent authorities seeking guidance and information. They support 
applicants  by  offering  them  information  about  the  recognition  process,  helping  them  to  understand 
requirements, and advising them on rights and obligations under EU and national law. They also foster 
cooperation between competent authorities, ensuring that mutual assistance and exchange of information 
are streamlined.  

Assistance  centres  have  proven  to  be  a  valuable  source  of  information  for  the  Commission 
about problems frequently encountered by mobile professionals. One of the issues reported that 
illustrates  the  importance  of  information  and  awareness  raising  is  the  limited  understanding  of  the 
availability and purpose of the European Professional Card (EPC), which provides a simplified and faster 
electronic  recognition  for  certain  regulated  professions27.  Respondents  from  several  Member  States 
observed that professionals often do not know that the EPC exists as an available option.28 Consultation 
results showed that stakeholders expect broader communication and guidance on different possibilities for 
professional recognition, as well as capacity support and resourcing for Assistance Centres. 

In addition to assistance centres, the Directive emphasises the significance of centralised and 
accessible online information. Points of single contact (PSCs) serve as digital gateways for obtaining 
information about administrative procedures on the recognition of professional qualifications and related 
professional activities. By consolidating various procedural details into a single, user-friendly portal, PSCs 
facilitate smoother and quicker interactions for applicants and competent authorities alike. They ensure 
that mobile citizens and competent authorities can access all necessary forms, guidance, and requirements 
without having to navigate through disparate information sources, thus promoting ease and efficiency.  

Despite these various mechanisms, the information provided to the public is not always equally 
reliable and consistent. In its 2024 special report on the functioning of the Directive29, the European 
Court of Auditors observed, for example, that the lists of regulated professions in the national databases 

26 Article 57b(1) of Directive 2005/36/EC lays down that each Member State must designate an assistance centre to provide 
information and assistance to citizens and authorities concerning the recognition of professional qualifications. 
27  The  European  Professional  Card  currently  applies  to  the  professions  of  general  care  nurse,  pharmacist,  physiotherapist, 
mountain guide and real estate agent. 
28 For example, Member States report that they do not always inform applicants of the EPC possibility for various reasons 
(see section 6.1 of the staff working document). 
29 European Court of Auditors, Special Report, The recognition of professional qualifcations in the EU, 2024.  

9 

 
 
 
sometimes differ from the information notified by the Member States to the EU’s Regulated Professions 
Database, which collects information on all regulated professions along with their specific requirements 
and competent authorities, in EU and EEA countries and Switzerland. Surveys carried out for the purpose 
of this report also noted inconsistencies between the information provided by home and host countries. In 
several  instances,  respondents  seeking  information  from  both  sides  received  conflicting  or  incomplete 
guidance.30  To  remedy  the  issue,  the  European  Court  of  Auditors  recommended  that  the  Commission 
ensure reliable  and consistent information for  the public, ideally through a  single EU-level information 
source. 

For matters regulated under national law in compliance with EU law, the competent authorities 
of the host country remain the authoritative source of information. To facilitate dissemination to 
citizens, detailed information on the practical steps of the recognition procedures, document requirements, 
fees and the choice between an adaptation period and aptitude test as potential compensation measures 
should be provided at EU level. Looking ahead, AI-powered large language models (LLM) can considerably 
improve  how  people  search  for  information  and  might  gradually  replace  the  traditional  information 
architecture  of  websites  with  a  more  intuitive  and  efficient  way  for  citizens  to  access  regulatory 
information.  

3.2. 

Recognition systems  

The experiences of mobile EU citizens seeking to have their qualifications recognised in another 
Member  State  for  access  to  a  regulated  profession  depend  on  the  applicable  recognition 
system.  

3.2.1.  The general system of recognition  

Under  the  general  system  of  recognition,  an  applicant  seeking  to  establish  themselves  in 
another Member State must provide a number of documents including evidence of nationality, 
professional qualifications, and relevant experience, if applicable. The competent authority in the 
host  Member  State  then  compares  the  applicant’s  qualifications  that  give  them  access  to  a  given 
profession in the home Member State with the national requirements for access to the same profession in 
the host state, on a case-by-case basis. If they are deemed equivalent, recognition is granted, allowing the 
applicant  to  practise.  If  substantial  differences  exist  that  cannot  be  compensated  by  professional 
experience  and/or lifelong learning, the authority may require  an aptitude test or adaptation period to 
bridge the gap. Once completed successfully, the applicant obtains recognition and may legally exercise 
the profession in the host state.  

While  the  deadlines  prescribed  by  the  Directive  are  considered  realistic  and  generally 
respected, several factors can cause delays. Under Article 51(2) of the Directive, the application for 
recognition under the general system must be examined as quickly as possible and within a maximum of 
four  months  after  the  date  on  which  the  applicant’s  complete  file  was  submitted.  Based  on  a  sample 
analysis  of  four  highly  mobile  professions31,  this  deadline  is  generally  well  respected.  Nevertheless, 
incomplete applications as well as delayed expert evaluations or verifications of documents by the Member 

30 On this, see in particular section 8.2 of the staff working document.  
31 To obtain precise and comparable input from the Member State authorities, the analysis focused on radiographers, secondary 
school teachers, health care assistants and social workers. These four professions were chosen, as they belong to the most 
mobile professions falling under the general system, based on the data in the Regulated Professions Database and based on 
their mobility patterns (covering a large number of Member States rather than only a few).   

10 

 
 
 
State in which the qualifications are obtained sometimes prolong the process. Delays are also caused by 
insufficient staffing at national level to process applications and the complexity of certain applications, in 
particular in cases where compensation measures are being considered.32  

The  procedure  involves  considerable  document  requirements  and  is  not  always  facilitated 
through electronic and/or digital means. 33 Annex VII of the Directive provides an exhaustive list of 
documents  that  may  be  required  by  national  competent  authorities  for  the  purpose  of  establishment. 
Member  States  generally  require  a  core  set  of  documents  for  professional  recognition  applications: 
typically proof of nationality, qualifications, and professional experience. Requirements beyond these, such 
as  attestations  of  good  character,  health  certificates,  or  insurance  coverage,  vary  widely  between 
professions and countries. On average, applicants must provide between 5 and 10 documents, totalling 
about 10 to 20 pages, though this can be higher in some Member States. Increasingly, Member States are 
adopting digital procedures for submitting documents, but the extent of electronic processing still differs, 
with  some  countries  maintaining  partially  digital  or  paper-based  systems.34  That  being  said,  for  the 
professions  to  which  the  European  Professional  Card  applies,  digitalised  procedure  is  available  in  all 
Member States. 

The complexity of recognition procedures under the general system depends on the degree of 
similarity in the regulation of professions between Member States. It is easier when the home and 
host Member States regulate access requirements to a profession in a similar way. If the regulations differ 
significantly, or if a home Member State does not regulate the profession and the host Member State does, 
recognition  is  still  possible,  but  applicants  face  more  difficulties  collecting  evidence  to  prove  their 
professional qualifications.  

A  small  number  of  recognition  procedures  under  the  general  system  end  with  a  negative 
decision on recognition.35 These decisions do not allow the applicants to exercise the profession of their 
choice. Further analysis is needed to determine the causes underlying these decisions, especially in cases 
where the applicants fail to deliver evidence required by a recognition authority. Some negative decisions 
could possibly also stem from rigid requirements that limit flexibility in accepting documentation. In some 
cases,  applicants  may  also  decide  not  to  pursue  their  application  when  confronted  with  lengthy  or 
cumbersome procedures. In others, the decision not to provide the documents could be linked to a lack of 
required formal qualifications, experience and/or a clean criminal record by the applicant. 

32 See section 2 of the staff working document for more information about the duration of the procedure and the causes of 
possible delays.  
33 See section 2. of the staff working document for more information about the types of documents requested under the general 
system of recognition, beyond proof of nationality, proof of qualification and attestations of professional experience, as well as 
the varied degree at which completion of the recognition procedure can be done via electronic means in the Member States. 
34 With the exception of those professions to which the European Professional Card Procedure applies, the availability of fully 
electronic  procedures  (apart  from  those  to  which  the  European  Card  Procedure  applies)  varies  by  Member  State  and  by 
profession. For example, for the profession of health care assistant only four MS (DK, FI, PT and RO) offer a fully electronic 
recognition procedure whereas for social workers the full recognition procedure via electronic means is available in all but three 
Member States. The use of available electronic procedures also varies considerably. To illustrate, while for  the profession of 
radiographer mobile citizens can complete the full recognition procedure via electronic means in almost all Member States, 
applicants in different Member States opt for electronic procedure to widely varying degrees, ranging from 10% in HR to over 
95% in IE, FI, PT, FI and DK. The staff working document accompanying this report provides additional illustrative data on this.  
35 For the period 2020-2024 this share stood at 7.4%. 

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3.2.2.  Automatic recognition based on professional experience 

Recognition  based  on  professional  experience  pertains  mainly  to  craft, trade,  and  industrial 
professions  where  EU-level  minimum  harmonised  training  requirements  do  not  exist.  More 
specifically, this recognition system applies to the professional activities listed in Annex IV of the Directive 
(e.g. painters, bricklayers, carpenters, catering managers, etc.). Under this system, a professional who has 
gained sufficient and verified experience in a regulated profession in one Member State can have their 
qualifications automatically recognised in another Member State, without undergoing further assessment. 
The applicant must provide evidence - such as certificates or attestations from competent authorities - 
showing that they have lawfully and effectively pursued the profession for a prescribed period (usually 
between two and six years, depending on the profession, employment status and level of training). The 
host Member State must then recognise the applicant’s right to practise the same or comparable activity. 
This procedure simplifies mobility for experienced professionals while maintaining safeguards for service 
quality and public protection. 

Despite the advantages it offers, this second recognition system is used sparsely. Compared to 
the general system, this second recognition system is usually faster, with recognition procedures taking 
between less than one month to up to three months following completion of the application. In addition, 
this system provides the advantage of referring to verifiable professional experience rather than formal 
training and involves relatively few documents. However, use of the system remains uneven, with only a 
minority of Member States using it on a regular basis and a large group reporting no or very limited use.36 
The reason for this is not clear-cut and requires further analysis, also due to the limited number of survey 
replies on this topic. For instance, the user-friendliness and currency of the system is perceived differently 
by  different  stakeholders in the same Member State.  While  many  competent authorities  and  national 
experts view the current system as practical and find the assessment of professional experience relatively 
easy - particularly when supported by certificates from the home Member State - many others consider 
the procedure and its underlying lists of activities to be outdated.37 These national experts deem the lists 
of professions in Annex IV and the underlying nomenclature to be unclear, with overlapping or imprecise 
definitions that complicate determining which professions qualify. Moreover, bureaucratic hurdles, lack of 
digital  processes,  and  inconsistent  documentation  practices  across  Member  States  sometimes  make 
applications cumbersome.  

3.2.3.      Automatic recognition based on minimum training requirements 

Recognition of professional qualifications based on minimum training requirements is the most 
streamlined  recognition  system  because  the  competent  authority  only  needs  to  verify  the 
authenticity of the document. This system is regulated in Title III, Chapter III of the Directive and is 
usually referred to as the  'automatic' recognition system.  It applies to professions such as doctors of 
medicine,  nurses  responsible  for  general  care,  dental  practitioners,  veterinary  surgeons,  midwives, 
pharmacists, and architects (referred to as ' sectoral ' professions). 

Harmonised  minimum  training  requirements  for  sectoral  professions  ensure  a  consistent 
baseline for education and training across the EU. These requirements maintain trust among Member 

36  Between  2020  and  2024,  the  five  EU  Member  States  that  took  the  most  recognition  decisions  based  on  professional 
experience (FR, RO, PL, PT and DE) accounted for over 72% of all decisions in the context of this system. Ten Member States 
reported to have taken 20 or fewer recognition decisions based on professional experience. 
37 For example, 55% of competent authorities and 50% of national experts consider Annex IV  to be adapted to the current 
needs of professionals. More data on how stakeholders assess the functioning of Annex IV is available in section 3.1 of the 
staff working document. 

12 

 
 
 
States  and  limit  discrepancies  in  educational  standards,  guaranteeing  a  certain  verifiable  level  of 
competence  and  contributing  to  the  safety  of  patients  and  service  recipients.  The  Directive  stipulates 
specific minimum training requirements per profession, with certain requirements adaptable via delegated 
acts  to  remain  aligned  with  scientific  and  technical  progress.  It  respects  the  autonomy  of  national 
education and training systems, allowing Member States to exceed these minimum requirements according 
to their needs. 

In general, stakeholders assess the functioning of the recognition system based on minimum 
training  requirements  more  favourably  than  that  of  the  other  recognition  systems.  With 
generally  low  application  fees,  adherence  to  procedural  deadlines,  and  manageable  documentation 
requirements, this  recognition  system  facilitates professional mobility  in an  efficient and cost-effective 
manner. For these reasons, stakeholders generally agree that the ' automatic ' system of recognition based 
on  minimum  training  requirements  is  a  better  solution  than  the  general  system  of  recognition  whose 
effectiveness and efficiency depends on the level of harmonisation of the regulations in Member States. It 
is also better appreciated than recognition based on professional experience, the application of which is 
considered less straightforward by some authorities for the reasons outlined above.38  

In view of its advantages, there is a clear interest  in extending ' automatic ' recognition to 
additional professions. Extending automatic recognition to professions that are not currently covered 
would  simplify  and  speed  up  the  recognition  process,  thus  facilitating  recognition  of  professional 
qualifications  and  boosting  professional  mobility  within  the  EU.  This  can  be  done  in  different  ways.  In 
addition  to  extending  the  list  of  professions  for  which  minimum  training  requirements  have  been 
harmonised  through  legislative  amendments,  there  is  also  a  possibility  to  rely  on  common  training 
frameworks (CTFs) or common training tests (CTTs) both of which can be adopted through delegated acts.  

CTFs provide the most flexible option. They aim to enable more professionals to move across the EU 
by extending automatic recognition based on a common set of knowledge, skills and competences for the 
pursuit of a specific regulated profession. CTFs do not fully harmonise training requirements and allow 
Member  States  to  keep  both  CTF-compliant  and  other  trainings  leading  to  the  regulated  professions. 
According to the Directive, a CTF can be established for professions which have a notable level of mobility 
or possess the potential for increased cross-border movement, and for which there is sufficient alignment 
on professional regulation and education and training in a minimum number of Member States. Specifically, 
at least one-third of EU Member States must regulate the profession and at least one-third must currently 
have in place the common set of knowledge, skills and competences on which the potential CTF would be 
based. The framework must also align with existing EU and national legislation and demonstrate that it 
serves the public interest in a proportionate way. The automatic recognition and common set of training 
requirements under a given CTF would only apply to national qualifications compliant with its requirements 
and between Member States participating in such a CTF. While CTFs facilitate recognition procedures and 
have generated interest from professional organisations seeking visibility at the EU level, no CTF has been 
established to date because the considered professions did not fully meet the requirements stipulated in 
the  Directive  as  explained  above.  This  was  often  due  to  the  different  national  education  and  training 
requirements  for  access  to  the  professional  activities  in  question.  A  Common  Training  Test    has  been 
established in 2019 for the profession of ski instructor. 

38 See Chapter 4 of the staff working document for more details on the competent authorities’ experience with and assessment 
of the system of automatic recognition.  

13 

 
 
 
Efforts are underway to establish a CTF for physiotherapists. In 2022 and 2023, the Commission 
discussed CTFs  with the  group of  coordinators  for the recognition of professional qualifications, which 
identified physiotherapists and civil engineers as potential candidate professions for a CTF. In March 2024, 
the  sub-group on Common Training Frameworks  was created under the umbrella of the Commission’s 
expert group of coordinators for recognition of professional qualifications.  The sub-group currently consists 
of representatives of Member States and of physiotherapy experts nominated by Member States and its 
work has focused exclusively on the feasibility of creating a CTF for the profession of physiotherapist. In 
particular, the expert sub-group has assisted the Commission to map the education, training and regulation 
of the profession across Member States. Based on the preliminary outcomes of the sub-group's work, the 
Commission  is  finalising  the  mapping  on  which  it  intends  to  base  a  Delegated  Act  for  a  CTF  for 
physiotherapists as part of the skills portability initiative.    

Moreover,  in  cooperation  with  the  Member  States,  the  Commission  is  working  to  identify 
additional  professions  for  which  CTFs  could  be  developed  in  the  future.  At  the  same  time, 
reflections  are  on-going  on  how  to  further  streamline  and  structure  the  process  for  the  selection, 
prioritisation and assessment of suitable professions for a CTF in the medium-term. These efforts require 
close cooperation with the Member States, as well as with the professional organisations concerned and 
other stakeholders.  

In  addition  to  extending  automatic  recognition  to  more  professions,  there  is  scope  to 
streamline  the  automatic  recognition  procedure  based  on  minimum  training  requirements 
itself. In principle, the process of checking whether the evidence of professional qualifications submitted 
by  an  applicant  corresponds  to  the  admissible  evidence  listed  in  Annex  V  of  the  Directive  should  be 
straightforward and swift. In practice, however, competent authorities sometimes spend significant time 
and effort to analysing the documents submitted by applicants. Evidence shows that the time needed to 
take a decision in various Member States or even across institutions within a single Member State varies.  

The main issue seems to be verifying the authenticity of documents. This often involves contacts 
between the respective authorities. Although this process is supported by the Internal Market Information 
System (IMI)39 the availability of resources, administrative structures and procedures, and the response 
time  of  competent  authorities  all  influence  how  smoothly  and  quickly  this  verification  is  completed. 
Paradoxically, competent authorities sometimes consider technological advancements as an additional risk 
rather  than  an  opportunity  to  streamline  and  improve  the  processes  (e.g.  it  could  be  easier  to  forge 
documents by using latest technology).   

To  make  the  recognition  system  based  on  minimum  training  requirements  truly  automatic 
would  require  the  use  of  new  and  emerging  technologies  such  as  LLMs  to  minimise 
administrative tasks. Where applicable, this could free up resources for substantive tasks related to the 
recognition process. Such solutions could include digital credentials and digital procedures in line with the 
wider  digital  policy  initiatives  of  the  Commission  (see  Section  5  below).  However,  this  would  require 
issuance  of  digital  certificates  for  which  underlying  data  can  be  easily  checked  and/or  alternative 
procedural steps in which home Member States verify and confirm documents and data as an initial step 
for recognition (like in the EPC procedure). 

39 The Internal Market Information System is a secure, multilingual online database that facilitates the exchange of information 
between public authorities involved in the practical implementation of EU law. 

14 

 
 
 
While the Directive already integrates the possible use of digital tools, the current provisions 
could  be  further  adapted  to  fully  exploit  the  potential  of  digitalisation.  Following  the  2013 
amendment, the legal framework introduced a degree of flexibility by allowing for instruments such as the 
EPC and greater use of the IMI system. These provisions demonstrated that the Directive can successfully 
integrate digital tools into recognition processes. Electronic procedures and cooperation platforms have 
reduced  administrative  complexity  and  illustrate  the  added  value  of  integrating  technological 
developments in the operational mechanisms of the Directive.40 Nevertheless, the transition towards digital 
procedures is uneven across Member States. In many cases,  competent authorities  still require mobile 
workers and professionals to submit paper copies of documents, despite existing electronic submission 
options, because of signature verification or other security concerns. As digital technologies have evolved 
considerably,  there  is  a  clear  opportunity  to  make  better  use  of  fully  electronic  and  interoperable 
recognition  procedures  that  are  faster,  more  consistent,  secure  and  more  accessible  for  citizens  and 
competent authorities alike. 

4.  Mutual trust and administrative cooperation are essential to the functioning of the regulatory 

framework 

Mutual trust between the administrative authorities of the Member States is crucial to ensure 
the proper functioning of the regulatory framework established by the Directive. Maintaining a 
high level of trust requires transparent, consistent, and proportionate rules governing the regulation and 
recognition  of  professional  qualifications  in  the  Member  States.  It  also  crucially  hinges  on  timely 
notifications by the Member States to ensure transparency and facilitate oversight and enforcement of the 
rules (4.1) and on the effective use of the alert mechanism put in place to share critical information about 
professionals who may pose a risk (4.2). Finally, maintaining trust in the regulatory framework requires 
regular updates of the framework to ensure that it reflects the latest scientific and technical developments 
(4.3). 

4.1. 

Notifications 

The  Professional  Qualifications  Directive  covers  a  number  of  notification  requirements  for 
Member States to ensure transparency and effective coordination of the recognition process. 
For example, Member States must inform the Commission of all professions to which they regulate access, 
along  with  the  qualification  requirements  and  competent  authorities  responsible  for  recognition  in  the 
regulated professions database. Under the Directive, Members States must also notify the Commission of 
the laws, regulations and administrative provisions which they adopt that have an impact on the national 
evidence of qualifications that is subject to automatic recognition under the Directive, based on the EU 
harmonised minimum training requirements. As a result, the introduction of any new training leading to 
issuance of national evidence of qualifications covered by Annex V of the Directive as well as any changes 
to evidence of qualifications/underlying training/awarding bodies that are already included in Annex V to 
the  Directive  should  also  be  notified.  Such  notifications  must  be  transmitted  through  the  IMI.  The 
Commission then updates Annex V via delegated acts. Member States must also report to the Commission 
the number of individual recognition decisions taken at national level which allows for transparency on the 
professional mobility between Member States and on recognition rates per profession and per country. 
Thanks to these notification obligations, the Directive ensures transparency, oversight and cooperation, 

40 One of the clearest benefits of the EPC procedure is its short processing time. Based on a survey of competent authorities, 
more than 60% of Member States complete recognition procedures within less than one  month, while the remainder report 
timeframes of one to two months. No Member State reported durations exceeding two months. 

15 

 
 
 
which allows the information about qualifications and professional regulations to remain consistent, up to 
date, and trusted across the EU. 

While 90% of competent authorities surveyed rate the notification system under the IMI as 
efficient, some describe the process as burdensome and time-consuming. Surveys carried out for 
the purpose of this Report have shown a high level of proficiency among competent authorities concerning 
the  notification  process.41  Competent  authorities  generally  recognise  it  as  an  important  tool  for 
transparency, cooperation, and regulatory consistency across  the EU. However, several authorities also 
describe  the  process  as  administratively  burdensome  and  time-consuming,  particularly  when  frequent 
updates or complex national reforms require multiple notifications. Some express concerns about limited 
guidance  and  differing  interpretations  of  what  information  must  be  notified,  which  can  lead  to 
inconsistencies  across  countries.  Others  highlight  technical  difficulties  with  the  electronic  submission 
process and the need for better coordination between national ministries and professional bodies within 
their own Member State. 

4.2. 

The alert mechanism 

Since 2016, the Directive provides for an alert mechanism about professionals whose pursuit 
of professional activities on the territory of a Member State has been restricted or prohibited 
by  national  authorities  or  courts.  Its  main  purpose  is  to  enable  rapid  communication  between 
competent  authorities  when  a  professional’s  right  to  practise  has  been  restricted,  suspended,  or 
permanently withdrawn because of disciplinary or criminal sanctions-- especially in sectors that directly 
affect public safety, such as healthcare or education of minors. Member States are also bound to send 
alerts where professionals used falsified diplomas in the process of qualification recognition. In light of 
the division of competences between the EU and the Member States, the latter play a crucial 
role  in  implementing  and  operating  the  alert  mechanism  system  at  the  national  level.  The 
Directive requires Member States  to  exchange  information regarding any decisions taken to restrict  or 
prohibit,  even  temporarily,  the  pursuit  of  professional  activity  by  a  given  individual.  However,  Member 
States remain competent to define the reasons for doing so. As a result, the reasons may substantially 
differ across the EU in various areas. Member States thus remain responsible for implementing the alert 
mechanism at national level and for following up on the alerts received. Their competent authorities must 
identify relevant cases and are required to issue alerts through the IMI system within the specified time 
limits (typically three days). Member States  are also responsible for ensuring that alerts are accurate, 
timely, and limited to what is strictly necessary under data protection rules. When alerts are received, it is 
the duty of the authorities in the receiving Member States to review the information, assess its relevance 
to their jurisdiction, and take appropriate measures under their own national laws. While the Commission 
operates the IT tool (the IMI) it does not take on any role as sender, recipient or controller in the information 
exchanges. Its role is  to monitor the system’s overall functioning, ensure  consistent application across 
Member States and provide technical and procedural guidance through the IMI framework. 

The alert mechanism should not be viewed in isolation. It does not replace any domestic registers 
that Member States may have to keep track of professionals who are suspended, prohibited or restricted 
from  pursuing  their  professional  activities;  it  complements  other  provisions  embedded  in  the  Directive 

41 More than 90% of respondents confirm that they know how to notify via IMI, and the same percentage rate the notification 
system as efficient. More information about the views of stakeholders regarding submission and verification of notifications is 
provided in section 4.4 of the staff working document. 

16 

 
 
 
which enable national authorities to secure the interests of consumer and patients by verifying the absence 
of temporary or final suspensions from exercising the profession or the absence of criminal convictions.    

Nevertheless,  the  significant  variation  in  the  number  of  alerts  sent  among  Member  States 
requires closer attention. Naturally, the differences in the number of alerts to some extent correlate 
with the size of the Member State and the number of professionals registered. However, other factors 
seem to matter at least as much including variations in administrative practices and legal frameworks 
(e.g.  the  existence  and  application  of  suspension  measures  and  the  reasons  for  doing  so)  and  the 
availability of resources to monitor and enforce professional regulations. The trend towards an increasing 
number of alerts for administrative reasons42 highlights the need for further harmonisation across the EU 
and  further  improvements  in  the  implementation  of  the  alert  mechanism  to  ensure  consistency  and 
effectiveness across the EU. 

The Commission is taking measures to address the issues raised by Member States related to 
the alert mechanism’s  implementation. Several infringements procedures concerning the set-up of 
legal frameworks pertaining to the alert mechanism in the Member States were launched prior to 2020. 
They  resulted  in  Member  States  introducing  the  necessary  measures  to  enable  compliance  with  the 
Directive. The Commission also  introduced the possibility for sending authorities to distinguish between 
alerts triggered by “substantial reasons concerning the practice of the profession” and “other reasons”. The 
alert “for other reasons” includes, for example, cases in which a professional is suspended from exercising 
the profession for non-compliance with administrative requirements. While stakeholders appreciated this 
measure, some called for further clarification, amplified by the recommendation on this issue in the 2024 
audit  report  of  the  European  Court  of  Auditors.  In  response,  the  Commission  is  preparing  a  guidance 
document and hands-on trainings  for competent authorities to  clarify the categorisation of alerts and 
address other practical questions concerning alerts, raised by the Member States.  

4.3. 

Updates to the automatic recognition system based on minimum training requirements 

Keeping the Directive’s minimum training requirements for professions eligible for automatic 
recognition up to date is vital for maintaining a dynamic and effective professional recognition 
system within the EU. Since 2013, the Commission has had the power to update these requirements 
through delegated acts  to ensure that the qualifications benefiting from automatic recognition remain 
aligned with generally acknowledged scientific and technical developments across the EU. This process is 
crucial for maintaining mutual trust among Member States and for safeguarding public health, patient 
safety,  and  service  quality,  while  ensuring  that  automatic  recognition  continues  to  reflect  current 
professional realities rather than outdated standards. 

The process for updating minimum training requirements is  designed to  consider the way in 
which the legal frameworks and curricula across the EU incorporate  scientific and technical 
progress.  The  Directive  respects  the  autonomy  of  national  education  and  training  systems  and  the 
diversity of training approaches across the EU. It seeks to reflect and accommodate changes in Member 
State  legislation  rather  than  to  force  conformity.  It  does  this  by  setting  out  the  minimum  training 
requirements necessary for cross-border automatic recognition while allowing Member States to exceed 
or  augment  these  requirements  for  the  purpose  of  education  and  training  provided  on  their  territory 
according to their specific needs and educational contexts. The updating process involves technical and 

42 See Chapter 8.1 of the accompanying staff working document. 

17 

 
 
 
 
 
scientific assessments, often supported by studies, expert consultations, and input from stakeholders such 
as  professional  associations,  educational  institutions,  and  Member  State  experts  via  the  group  of 
coordinators on the recognition of professional qualifications. 

Discussions about updates to minimum trainings requirement are often complex and technical. 
There is a continuous balance to be found between facilitating mobility by setting the common standard 
at an achievable level and ensuring that the minimum training requirements in the Directive  reflect the 
current generally acknowledged practices and technological advances across the Member States. Scientific 
progress  also  has  to  be  balanced  with  legal  stability  avoiding  frequent  or  disruptive  changes  that 
complicate implementation.  

So  far,  delegated  acts  to  update  minimum  training  requirements  based  on  scientific  and 
technical advancements have been adopted for the professions of general care nurse, dental 
practitioner, pharmacist and veterinary surgeons. The Commission has also contracted a study on  
profession of midwives. Based on the Commission’s assessment of its conclusions, the minimum training 
requirements for midwives may also be updated.  

Furthermore, regular updates to the list of evidence of professional qualifications benefiting 
from  automatic  recognition  based  on  minimum  training  requirements  are  vital  to  preserve 
mutual trust in the system. Such updates are also done by means of delegated acts and each change 
to the list is triggered by an IMI notification from a Member State. Indeed, Member States are obliged 
under the Directive to notify  the Commission of any changes in their national legal, administrative and 
executive provisions that have an impact on the evidence of qualifications that benefit from automatic 
recognition, and their timely cooperation is crucial for the efficient functioning of the system.   

Opinions  differ  as  to  whether  the  delegated  powers  of  the  Commission  to  update  minimum 
training requirements under the Directive should be extended. According to some stakeholders, the 
existing  possibility  to  update  the  Directive  by  means  of  delegated  acts  should  be  extended  to  more 
elements of the automatic recognition system  to make it even more agile and responsive to changing 
circumstances. The staff working document accompanying this report provides more insights on this. It 
gives examples of the major elements (e.g. the duration of basic medical training) and technical elements 
(e.g.  the  generic  names  of  medical  specialties)  which  are  not  covered  by  the  Commission’s  delegated 
powers.  When  asked  about  possibly  extending  of  the  Commission’s  delegated  powers,  stakeholders 
recommend  focusing  on  technical  updates  only  through  delegated  acts  while  preserving  core  content 
stability.  A  majority  of  those  consulted  opposed  the  use  of  delegated  powers  to  amend  substantial 
elements (such as the minimum duration of basic medical training) through delegated acts.43 

A  separate  question  is  whether  the  current  process  based  on  delegated  acts  could  be 
automated. Automating part of the process of updating minimum training requirements is not without 
risk. In principle, the legal framework could be amended so that new evidence of qualifications subject to 
automatic  recognition,  names  of  the  institutions  issuing  such  evidence,  reference  dates,  etc.,  could  be 
automatically added or modified by the competent authorities in the Member States, without the need for 
processing notifications via the IMI, consultations with other Member States, and preparation of delegated 

43  Stakeholders  in  favour  of  updating  minimum  training  requirements  through  delegated  acts  put  forward  flexibility  and 
timeliness as arguments, while those who are more sceptical emphasise the need for stability of the standards and scrutiny by 
Member States. More information about the views of stakeholders on the use of delegated acts to update minimum training 
requirements is provided in section 4.3 of the staff working document.  

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Commission  decisions.  Although  such  a  hypothetical  process  would  be  faster,  the  present  system 
eliminates  a  lot  of risks  and  errors.  While  the  current way  of  updating  minimum training requirement 
involves considerable resources, the built-in checks and controls and the involvement of all Member States 
have  a  generally  positive  effect  on  mutual  trust  and  reliance  on  the  automatic  recognition  system. 
Therefore, efforts could focus on improving the efficiency of current internal processes rather than replacing 
them entirely. 

5.  Digitalisation  

The findings in this report highlight several procedural challenges that affect the efficiency and 
user-friendliness of professional recognition. These findings are echoed throughout the stakeholder 
feedback, where individuals, professionals, businesses and assistance centres consistently report complex, 
lengthy  procedures,  paper-based  requirements  in  some  Member  States  and  wide  disparities  in  online 
application processes.   

The  introduction  of  the  European  Professional  Card  (EPC)  represented  a  step  towards 
digitalisation  by  creating  an  EU-level  electronic  procedure  for  submitting applications.44  For 
applicants, the key advantage is that the procedure  offers a simplified, faster,45  and more transparent 
electronic  procedure for  having  their  professional  qualifications  recognised  in  another  EU  country. 
According to the consultations conducted in the context of this report, competent authorities appreciate 
that  the  procedure  reduces  administrative  duplication,  improves  transparency,  and  makes  the  overall 
process more user-friendly, especially for applicants moving repeatedly across borders. It also strengthens 
administrative cooperation through the IMI, fostering more efficient communication between authorities 
when verifying qualifications or professional status. 

There  are,  however,  limitations  to  the  EPC  which  could  be  overcome  through  contemporary 
digital technologies. Some competent authorities report that the EPC can be complex and burdensome 
to operate, with procedural steps that do not always save time compared to  the standard recognition 
system  based on minimum training requirements or the  general system. Technical and interoperability 
issues (linked to uneven levels of digitalisation across Member States) also hinder smooth functioning. A 
further  drawback  is  low  awareness  among  both  professionals  and  authorities,  resulting  in  limited  use 
despite its potential benefits. Since the procedure does not automate or simplify processes for confirming 
authenticity or classifying documents, this remains one of the more time-consuming tasks to be done 
manually by many competent authorities.  

The IMI, launched in 2008, plays a key role in the functioning of the Directive. It facilitates online 
exchange  of  information  and  notifications  between  competent  authorities  and  the  Commission.  As  an 
enabling platform, it does not by itself guarantee timely responses  since it still relies on administrative 
input by national competent authorities. IMI processes are streamlined and harmonised across the EU. 
While they allow for submission of digital documents, they do not yet incorporate automated verification 
processes, which  may already be available in several countries based on recent technical developments. 
While many Member States have begun to offer alternative, national digital submission channels in parallel, 

44  The  EPC  was  initially  introduced  in  2016  for  five  specific  regulated  professions  with  the  possibility  to  expand  to  more 
professions in the future. 
45 For both of the EPC professions examined in the staff working document, most Member States reported that the procedure 
is completed within less than one month (see section 6.1). 

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feedback  shows  that  processes  remain  uneven,  and  several  Member  States  continue  to  rely  on  paper 
documents and bureaucratic processes.  

Building on the experiences with the EPC and IMI, a more unified digital approach could help to 
reinforce  the  safeguards  and  mutual  trust  that  underpin  the  Directive  while  improving 
efficiency, transparency and user experience. Stakeholders stressed that the current legal framework, 
though flexible enough for incremental improvements, lacks the clarity and ambition needed to fully exploit 
the potential of digitalisation and simplification, with several contributions calling for stronger recognition 
of digital credentials, better interoperability across systems, a centralised electronic platform and faster 
processing.  From  the  applicant’s  perspective,  fully  electronic  and  interoperable  digital  recognition 
procedures  could  make  recognition  processes  simpler,  faster  and  more  predictable.  For  competent 
authorities,  digitalisation  could  increase  efficiency,  consistency  and  data  reliability.  Such  tools  would 
preserve the final decision-making responsibility of competent authorities while supporting accuracy and 
efficiency. However, effective digitalisation would depend on the availability of comprehensive, up-to-date 
information on regulated professions and competent authorities, meaning the issues related to consistency 
of information described above in 3.1 must be addressed. 

6.  Conclusions  

The legal framework governing the recognition of professional qualifications in the EU works 
generally  well.  It  provides  a  clear  legal  basis  for  mobility,  especially  in  highly  regulated  and  mobile 
sectors such as healthcare, engineering, architecture, and education. By setting common rules, the Directive 
has  reduced  uncertainty  for  professionals  seeking  to  work  in  another  Member  State  and  offered  host 
authorities  a  structured  process  for  recognition,  as  has  been  widely  acknowledged  by  stakeholders. 
Between 2020 and 2024, around 185 000 decisions were taken for the purpose of establishment. This 
volume of positive decisions, with more than 140 000 concerning essential sectors like healthcare and 
education, demonstrates the Directive's crucial support for professional mobility in the single market. 

Maintaining trust in the system is paramount. Rigorous enforcement, continuous updates to reflect 
the latest scientific and training developments, regular training, guidance, experience sharing and strong 
administrative  cooperation  are  essential  to  maintain  this  trust.  This  is  a  joint  responsibility  of  the 
Commission  and  the  competent  authorities  in  the  Member  States.  Maintaining  this  trust  also  crucially 
hinges on the effective use of the alert mechanism to share critical information about professionals who 
may pose a risk to safety of patients and minors.  

The Directive has proven flexible and responsive to new scientific and training developments in 
the Member States. The empowerments embedded in the regulatory framework allowed for updates to 
the minimum training requirements and lists of professional titles without  the need for full legislative 
revisions. Expanding their use could allow for swifter updates. Nevertheless, this would need to be balanced 
with  the push  for further  simplification,  legislative  oversight,  and  stakeholder  engagement  to preserve 
legitimacy and acceptance. 

Even with the legal framework in place, professional mobility in the single market still faces 
barriers.  Some  of  these  are  due  to  the  differences  in  national  regulatory  frameworks  and  cannot  be 
resolved  through  regulatory  action  at  EU  level  alone.  Under  certain  conditions,  however,  extending 
automatic recognition to additional professions by means of Common Training Frameworks could provide 
a viable way forward. Work in this area is currently on-going. In addition, there is still scope to improve the 
provisions  of  consistent  and  reliable  information  to  the  applicants  and  to  simplify  and  streamline 

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recognition  procedures  through  targeted  interventions.  The  experience  of  professionals  shows  that 
recognition can still be a complex and time-consuming process as a result of lengthy procedures, uneven 
digitalisation and heavy documentation requirements.  

Embracing  the  potential  of  digitalisation  could  make  recognition  processes  faster  and  less 
cumbersome. By leveraging digital tools, procedures can be streamlined, administrative burden reduced, 
and a seamless experience provided for both applicants and competent authorities. Fully electronic and 
interoperable procedures, including the use of digital credentials that are secure and machine-readable, 
could  enable  instant  verification  of  qualifications  and  significantly  reduce  processing  times  under  the 
various  recognition  systems  for  both  applicants  and  competent  authorities.  Such  modernisation, 
simplification and improved implementation would not only address current inefficiencies but also pave 
the way for a more integrated and responsive professional recognition system within the EU. This is crucial 
for mobile professionals to thrive and reap the benefits of the single markets, for firms to access the talent 
they need, for innovation to spread, and for productivity to increase.  

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